We can respectfully agree to disagree. A large portion of (in fact nearly the entirety of) the intent of this is to significantly change behavior. So I don't think that an assessment prior to behavioral changes is a solid starting point in the sense of being a good estimate of the outcomes. It literally can be a 'starting point' in the sense that one can start there and then make large adjustments to get from there to a good estimate, which is what I am pointing out.
It is also quite possible IMO that EIP is a complete failure in the sense that there aren't major behavioral changes, but that's somewhat of a different claim to make.