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This raises what appear to be important points. Has it been formally submitted to Unicode in some way?

Yeah, there's a long discussion about this on the official Unicode mailing list recently. You can read it at http://unicode.org/pipermail/unicode/

Link to the thread: http://unicode.org/pipermail/unicode/2017-May/thread.html#53...

Discussion on the mailing list does not constitute official feedback to the UTC; ultimately, it's nothing more than a discussion forum, and does not mean the issue will necessarily come back to the committee.

The contact form for more formal feedback is at http://www.unicode.org/reporting.html

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