On one level, it's a matter of national shame that our Department of Transport is proposing to bypass British courts of law in this 800th year of Magna Carta.
Absent from the consultation document is the fact that half of the CAA prosecutions tried last year resulted in acquittals. That dismal record, and the refusal of courts to award even a tenth of their eye-watering costs, are the "problems" which this obscene proposal is intended to address.
It is inconceivable that the CAA's Board of Directors is unaware of this, and yet, mired as they seem to be in institutional mendacity, they have published a document which does its best to conceal and mislead.
It's not too late for Andrew Haines to get a grip - to withdraw this flawed consultation, to dismiss whichever members of his Board are responsible for it, and to apologise.