Since posting this few days ago my attention were brought to a Comment that was posted on facebook. Since I have deactivated my account, the editor of the website copied and sent me the Comment. The Comment is by Abadir Ibrahim who wrote:
This is an interesting but incomplete work. The author does not try that hard to find counterarguments. Simple examples of counterarguments could be –
1. such practice increases the risks of authoritarianism by giving an already powerful executive more powers & risks pulling down democratic progress of the country;
2. the HPR cannot delegate the power to make proclamations since what is being suggested here is in effect giving the COM the power to make proclamations (you can’t escape by calling ‘regulation’ what is in reality a proclamation);
3. the regulation power of the COM cannot affect rights and duties of citizens and groups (for ex the regulation cannot increase the age requirement) because only parliament can pass laws that limit rights;