- An "overarching use of average rather than extreme current speeds to estimate operational limits in the design process"
- No real solutions for how biofouling – the growth of marine life on the boom assembly – would affect its durability and functions. "As currently designed, the moored array is under-engineered and likely to fail."
- Inadequate sampling of plastic pollution at depth
- No substantial plans on how to address environmental issues, snaring unwanted critters, or "high seas law"