Don't overlook the fact that agencies like the USCO are at the bottom of the totem pole in terms of determining stuff like this. They move first because they're on the front lines, as it were, but they can be overruled by the courts and the courts can be overruled by congress.
100% this will be litigated and likely altered in the coming months/years.
100% this will be litigated and likely altered in the coming months/years.