That's a pretty solid response. However, I'm confused about the idea of including chicks in the total # of chickens. Most people raise chicks in a brooder, which is usually entirely separate from the coop/run structure, if not inside their house. Perhaps language should be suggested that has a separate mimimum for chicks up to 16 weeks (processing age for heritage breeds) as long as their brooder is housed separately. Typically these aren't structures in and of themselves, but something akin to specialized furniture. If necessary, the coop/run limitations could be gotten around by including something about chicken tractors for birds that will be held on the property for less than 6 months (this also would give people a way to have a hospital coop without breaking any rules).
I think this is especially important for those who want to raise them for meat, as you would need more birds for meat, temporarily, than for egg laying.
Any concerns about early crowers could be addressed with animal nuisance laws already in place, more than likely.