The APPG-GA response is pretty good.
http://www.generalaviationappg.uk/wp...Response-1.pdf.
One point they didn’t pick up on though is that the CAA doc says SVFR clearances are only permitted in CTRs but not CTAs (is that true? I’ve never had the need to request one), if that’s the case I can imagine the impact for pilots based at airfields nearby CTAs who currently routinely transit them being even more impactful, and the CAA seem to have excluded that factor from their analysis.