Sorry. I have not yet read the exposure draft, so I thought you were just asking a PAREA question. I did not realize it was also a question about the ED.
You may be right about your claim about everyone getting a CG. I had the choice and opted not to go that route. I had all the classes and experience, but I also knew that I didn't like that work nearly as much. So, I chose CR instead.
I don't think "everyone" will be able to pass the courses required for CG. In the classes I took, some really struggled with the math.