Not quite the same problem if the opening of that breaker on the service input side of the ATS triggers the generator to start and pick up the load through the ATS.
You would need two points of failure to create the same outage as the single point downstream of the ATS.
True, but if the EPSS is already running the show and whatever caused the normal side to go has not been cured we still have a single point of failure that is the concern.
The point is, if there is a problem with the loads or a fault from the Critical Panelboard opening the feeder OCPD, it is going to happen on both devices assuming they are the same values.
Roger