I skimmed the paper; it has a lot of issues. First it doesn't attempt to frame the theory in our current best understanding of the problem of consciousness. It doesn't say up front if its attempting to explain qualia or just give a new understanding of the functional aspects of consciousness.

The next issue is that it doesn't do much explaining. If it is attempting to explain qualia, it needs to explain how the functional descriptions on offer help in explaining why there is a qualitative feel associated with conscious states. If it's not attempting to explain qualia, then it needs to clearly identify the functional problem it is proposing to solve, then explain how the theory solves it. Many homegrown theories mistake description for explanation. Just giving existing functions a new name in the guise of a new framework doesn't explain anything. A reframing can be useful, but it should be made explicit that the theory is a reframing rather than an explanation, and what benefits this framing gives to solving various problems related to consciousness.

Another issue is that it spends too much time talking about implications and not enough time just communicating the core ideas. Each major section has like a paragraph or two. This isn't enough for a proper introduction to the section, let alone a sufficient description of the theory.