The widespread condoning of vectoring below MSA is a pretty good start.
The whole document is contradictory, full of holes, dangerous in parts and a pointless exercise best left until the future classification of airspace, and service provision within that, is agreed with the same implementation date.
Stating that there's no reason why an ATCO has no good reason why they
can't provide a surveillance service to aircraft outside CAS (it's not my primary task - I will prioritise accordingly and if I can't provide it due to workload then tough) shows it was written by a buffoon who has no grip on the reality of providing such services.