I've been traveling and only now have had time to weigh in.
But send the draft out, yes. We should have our statement be part of the record. (And not be late!)
One suggestion for future drafts/statements:
Reading it carefully I am struck with the word "customers"
Separability increases the leverage of the customers of IANA over performance,.....
Should registries, as the primary customers of the IANA functions, have more of a say as to which transition proposal is acceptable?
Isn't the function an "assignment" not a purchase?
Neither ICANN nor IANA should be known as a "market" with "customers" no matter what the monetary transactions are.
DeeDee