Slim_slag
A fine response.
At a recent meeting BGA representatives highlighted the lack of any mention in the Partial RIA to H & S risk from a Mode S transponder in a rag and tube aircraft or when held on the person.
It now seems that the CAA are producing a separate analysis of the radiological issues, but this will be published in late Sept or Oct ie after the consultation has closed and therefore we will be unable to comment on the analysis
As you rightly mention the paper is shot full of holes, and has been cobbled together using questionable statistics. Even the response form is loaded so that the 'tick boxes' will support the CAA view
Note that if you tick the 'Do Nothing' option on Response 5, this does not mean that you support the idea of 'Do nothing' but that you support the view of the CAA in that 'Do Nothing' is unworkable.
They obviously know little about low-end aviation, and care less. Here is a classic quote from the RIA Section 5.2.5.1:
"For example, only those private pilots that use ATC would have their recreational flying directly helped by any economic benefits from more efficient ATS. However, they would benefit from ATC efficiency as members of the public when undertaking flights with commercial operators for business or pleasure."
In other words, for the financial outlay, we won't see any benefit unless we fly Chavair to Ibiza - nice one!!!