I'm trans and the GNU Communication Guidelines feel way more empathetic to me than CoC-like documents.
> gives cover for transphobes to intentionally misgender trans people
It also gives cover to people who prefer to always use gender neutral pronouns. If a transphobe is acting on their views on gender to bully people, I'd rather deal with them on a case-by-base basis, while being empathetic to everyone else who might have meant to harm.
BTW, I've met RMS in person a few years ago, and exchange emails with him every once in a while. I've found him to be very fun, and not hard to deal with if you're used to hanging out with neurodivergent people.