Oct 8 interim final rule-Is this effective for H1B amendments immediately?

My 140 is accepted for the role of software applications, but I am now a manager and I need to file a h1 amendment so that I can go back to the role of software developer and apply for EAD (route of downgrade from eb2 to eb3). However, will this new law have an effect on me when I file the H1B amendment? This is instantly effective for the H1B or Dec 07 2020 amendments. Is there any other way I can apply for EAD without amending H1B because the phase of EAD / GC is for future employment?