For now, I've implemented the upper registers as documented. But the lower registers has 1 BAR implemented (for the BIOS specifying a memory area to use with the address registers, with a size of 16MB).
I've also made the command register bits 0-2 writable, so that the BIOS can detect and enable the software's use of the BAR for detecting if it's actually filled.
Software that needs a memory area to use for (in this case a Tseng VGA card using 16MB ISA space mapped anywhere in memory) mapping the 16MB memory hole into a different memory location can simply use that field to fill the actual memory BARs at location 70h-7Fh if it wants to remap it to a safe memory address location without conflicts.
In the case of the i440fx BIOS I'm using (with 128MB of RAM) the BIOS sets up the location to E7000000, so that's a safe place to place things like the Tseng framebuffer using the remapping functionality of the card (using registers 3CD for read/write location on AX (1MB location, so that's specifying bits 20-23), register 30h bits 0-1 on W32i (4MB location, so that's specifying address bits 22-23 in that case)).
Although the register 3CD mapping for the ET4000AX isn't documented by the chipset itself, but it must be, due to it being the only 'unused' register in linear mode.