First, Steve, thanks for an excellent review.
You detected some really important fixes we need to make!
Hi. I'll respond in more detail later. I generally agree with Joe's
comments.
I want to respond to the IANA issues so Joe doesn't have to dig around.
Early allocation is a well-defined concept; I forgot to reference the
appropriate RFC, but IANA does (and according to their last call
comments did in this case) understand it.
IANA also correctly assumed the codes registry is a sub-registry not a
new top-level registry.
I don't mind fixing, but I'll point out that IANA was not actually
confused nor did they request clarification.