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Yeah, that was my thinking too. Plus a lot of MTB chain devices are mounted like that on modern MTBs with external bearing cups, so it can't be a totally ridiculous design. One concerns is that the area of the bracket that will be clamped is not totally flat, but has several, regularly-spaced raised areas, presumably to allow them to be slightly compressed and add grip. I wonder if that could result in everything not tightening up straight.
There's actually already 2 spacers between the frame and drive-side BB cup. The design allows for them apparently, so I wouldn't lose any clamping area.
I ran my last daily bike with a chain guard (SKS Chainboard), which attaches via a bracket that's clamped between the drive side BB cup and the frame. That bike had a square taper BB and that never caused any issues (after I had tightened it up properly). My new daily bike has external BB cups (Hollowtech 2) and I've been advised that it's a bad idea having that type of fixing because there is a risk that the BB cups (and therefore bearings) will end up not being coaxial, which would lead to greater bearing wear and possibly early failure.
Is that true?