At first glance it's better than the CAA's original "fit mode S to every flying object everywhere" proposal.
If you want to fly in controlled airspace I guess there's a fair argument for transponders so them down there can see you.
But the sections on "Transponder Mandatory Zones" and their possible application anywhere, and at short notice sounds a bit like "we'll squeeze you into smaller and smaller bits of open airspace until you surrender and fit a transponder" to me.
And the new cost estimates for installing and operating Mode S look a lot more realistic - but would double the value of many microlights and gliders!
