I am finding the document a fascinating read, full with hopes and expectations, just like all government IT briefs.
It is clear the CAA are concerned that the 'cheap-skates' will find it hard to afford this additional cost and looking for the magical piece of kit that can be brought down in price by generous manufacturers
I love the bit (6.2), where they give an example of a flying school with 8 aircraft required to find £24k to equip their fleet, probably resulting in the sale of one aircraft. They then state that they expect businesses to get a 15% discount (built into the figures) when bulk-purchasing the kit, but in 5.2.4, this is an anticipated discount for purchases of 10 units - not a lot of good for the 8 aircraft club, then.
This doesn't even get close to the situation of the user groups with one or two aircraft that need to be re-equipped. They can't even set the cost off against tax - as mentioned in 4.3 and 4.4, where it is acknowledged that the main burden will be picked up by private aircraft operators - not business.
Add to that the massive hike in the numbers of annual checks (up to 13,200) new aircraft requiring licencing and annual checks), and we start to see the scale of the issue.