From my understanding (from an NSAA affiliated individual)
D1 is the largest 32 eligible + all ineligible
all other 8 man teams will be split in half.
If it’s an odd number, the extra will be in D3.
It's not as simple as what you're making it sound. What you said is correct, but you've got to look at the process of classifications for all sports/activities to understand the depth of how this happens.
All teams will be lined up for football in enrollment number order, starting with the biggest schools. Those schools who are 55 & below (along with the two who will be in their exemption cycle) will be "eligible" teams for the playoffs. They will select the biggest 32 of those schools for D1, and then split D2 and D3 in half.
THEN, they will take the teams who are too large for 8-man (over 55 enrollment and not in an exemption cycle) and put them in their appropriate places. In this case, that means adding 2 eligible schools to D1 for CEC waivers, 1 to D2 for a CEC waiver, and 2 to D3 for CEC waivers. That's how you get to 34 eligible in D1.
FINALLY, all the INELIGIBLE schools will be dumped into D1 because that's where they land. D1 will be 40 teams.
I initially took the stance that the CEC teams would be included in the "eligible" list, but I don't believe that's how it will work. No other activity/sport moves a team up or down a division based on who opts up or down a class. So the first thing that needs to happen is for the schools to be placed where they SHOULD BE, and from there, the adjustments get made.
We'll see how things look when the final classifications come out, but I'm confident in the way they are split above.