The idea expressed in the CAA paper that it is unsafe to depend on it is extreme.
And that, dear Nick, neatly sums up CAA thinking and is the ethos that leads to the ridiculously restrictive regulations under which we have to operate.
Don't knock it too much. We're grateful for small mercies here. At least they let us fly, with strong misgivings that they shouldn't really allow such a dangerous activity to take place at all.