Ummm, it is an Opinion from the head Prosecutor of the State of MD, and as such will be used by all other lower prosecutors in the state of MD.
So call it an opinion, but the only way that opinion gets reversed/overturned/nullified is for someone to violate the "opinion" and have a defense attorney challenge it in court, and then have a judge rule against the AG.
Are you volunteering to challenge the "opinion?"
It will be challenged when someone waiting for 100 days to be ND gets the call on October 1 to pick up and doesn't have a HQL.