Exact(1)
The subject of a substantial change cannot be a substance; if it were, the result would be a modification of that substance, that is, an incidental change.
Similar(7)
The subject of a surface or incidental change is a substance.
So the point to notice about this analysis is that substantial change is spoken of on an analogy with incidental change.
TGE-MPS identified an incidental heterozygous change in GJB2 (c.101 T > C p.M34T) and a heterozygous two-exon deletion (exons 14 and 15) of TMC1.
We see that matter and form apply in an analogous way to the various kinds of incidental change and then to substantial change.
The analysis of incidental change is presupposed and regulative.
Moreover, the language used to speak of the elements of incidental change are extended to substantial change and altered in meaning so as to avoid equivocation.
As the analysis of incidental change makes clear, the substance previously existed without the form it acquires in the change and it could lose it and still be itself.
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Since I tried Ludwig back in 2017, I have been constantly using it in both editing and translation. Ever since, I suggest it to my translators at ProSciEditing.

Justyna Jupowicz-Kozak
CEO of Professional Science Editing for Scientists @ prosciediting.com