As one of the siren voices involved in the consultation who effectively fell out with PFC and argued that the Gerbil was flawed in several ways, and then ironically was subsequently given a late diagnosis of a previously well hidden intersex condition myself, I would have to agree with every one of this articles observations.
It's one of those acts which, though well intentioned, demonstrates in so many ways the law of unintended consequences. It already badly needs amending both in view of the ludicrous problems that it causes to non-domicile people born in Britain who have been treated in other countries, and indeed in terms of the way that it discriminates against IS people. Add to that the way in which scientific understanding of the condition is evolving and I can see the current act becoming unworkable within a very few years.
Sadly though, knowing Britain, and based on the amount of time it took us to get the damaging Ormrod legal precedent overturned by the so called gerbil, it will take another quarter century or more before the legislative powers actually DO something!