The draft charity Sorp is sure to be a long document, but charities must review it thoroughly. The final product will be much better if there are lots of responses to the consultation.
Charities preparing Sorp-based accounts should have the skills and competence to understand the accounting framework. So one key question is whether the Sorp needs to be so long - is it explaining the obvious?
The consultation process is not a popularity contest - any approach must fit within the official accounting framework established by FRS 102 or other standards. Your arguments must be technically acceptable.
Watch out for back-door regulation, especially in the annual report. Does the Sorp require something generated by FRS 102, or is it just something the regulators would like?
Your response will normally be made public, so you might want to make clear whether or not it's a personal one. If it's from the charity, it should probably be seen by some trustees first.
You can always contribute to the debate through other bodies or representatives.