The only way to save the new rite of episcopal consecration is if the entire preface is considered the form, in that case it does appear to meet the requirements that Pope Pius XII laid down in Sacramentum Ordinis, because the entire preface does mention the power of the high priesthood and the Holy Ghost. If i recall correctly, the rite of episcopal consecration in the eastern rites has the entire preface as the form, and not just a few words like in the roman rite.The only problem with this theory is that Paul VI said that the few words which includes the phrase "governing spirit" is to be considered the form.