I worry that everyone will have an incentive to "cheat" at congestion control, leading to a tragedy-of-the-commons situation of ever-more-aggressive flows, followed by eventual congestion collapse.
This effect didn't happen with in the TCP world, since most applications don't run with enough privileges to speak TCP without the kernel's involvement. But now that we're moving to a model in which applications do their own congestion control, an arms race seems inevitable.