It under costs the CEV.

There is to little over lap with the end of STS and the first use of CEV and non with CEV to the Moon or Mars.

There is no HLV designed into the mix. Thus costs of the Moonbase and Mars exploration are vastly underestimated with multilaunches, the dangers single point failure there in and the assemble in space.

The CEV system is not being designed to use at Mars in actual fact it doesn't seem to be being built for Moonbase use either.

There is nothing stopping the termination of this Initiative after the current Administration ends next year or (God forbid!) 4 years later.

There is nothing stopping termination before returning to the Moon or just after the first few missions.

The Initiative relies on Moon ISRU use to fuel spacecraft for beyond the Moon without evidence that ISRU at the Moon will be cost effective at all. Instead of relying on lowering launch costs from Earth as a simpler and more obvious solution.