How can I simplify my design for a Surge Protection Device (SPD)?
Generally surges couple well with capacitive transformers so that you don’t use resistor power dividers. This improves the protection after the 1st surge when the fuse blows for the MOV drawing excessive current.  (Research Offline Power Supplies)
There are many solutions but the best design has all the specs tolerances on input voltage Power lightning transient test levels and output V,I,P, then current limiting without fused MOV’s may be avoided.
The ideal is to divide the voltage with film caps then raise the impedance (and attenuate HF surge impulses ) into a ferrite L to rectify with a full wave diode bridge to get 2f instead of 1/2 wave f flicker then into a cap shunt to reduce the ripple. This way fuses are optional using a series R as a fuse if you expect 50% overvoltage in your region but even this can be protected.
See examples of this here.
E.g. 330nF film to 100uF e-cap is a 3300:1 voltage divider for AC It is not quite linear with the diode bridge effects, so simulate the link above and optimize your inputs and outputs with extra LEDs up to whatever Vdc you like.
Your 30kohm 5W +5W to LED of 15 Ohms is 2000:1 voltage divider.
One can optimize the design for 20Vdc out with a string of LEDs at 20mA by changing component values in Falstad with 350Vp 50Hz or whatever you like. This way you can avoid two 5W resistors.
I chose to offer a better design instead critiquing a worse design. If you understand something good. if you want more info ask for what you need.