From an INTAREA perspective, this document has no concerns.

However, viewed from a transport perspective, the document has one key concern - the use of two TCP code points. Information expressed in TCP options should occur inside the option payload, not be encoded indirectly in code points. The variants desired in Table 5 can easily be differentiated using a single bit of the first counter indicated. There's no good reason to consume two TCP code points for this optimization. 

Additionally and somewhat less significantly, it is nonsensical to assign non-adjacent code points, again as this unnecessarily breaks up the TCP code point space for use by other future assignments (e.g., were there to be a legitimate need for a range of code points). Frankly, see no good reason why this mechanism should not use code points in order of availability, e.g., 80 (and, with GREAT hesitation, 81 if warranted).