Not at all trying to be disingenuous, but if you rewrite your arguments, you are expressing it as "the risks for not using a module". At first I was kidding, then when I got done, I realized I was serious. Here's a quick inversion of some of your points, just to give some flavor:

• positional params are inflexible and therefore hard to maintain
• positional params are error-prone because they are order-dependent
• positional params make it difficult from the caller's perspective because they have to remember the exact order of the arguments
• arbitrary and/or short param names inhibit memory and clarity
• positional params require manual validation (required/optional/string/integer/etc)
• hand-rolled command lines options make using flags and named params simultaneously difficult

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