You are correct, but it's an opinion that bridges the gap editorially between those knowledgable about ATC but not data, and those knowledgable about data but not ATC. This is a valuable service to provide, as both fields are rather complex.
Thanks. I didn't have the patience to read it all. I initially hoped that the author was a field expert or even someone with inside knowledge, but he is apparently from a completely different domain and not in the UK, and there were assumptions about things the report was rather specific about (as specific as such reports usually are). It would be more useful if people would take a closer look at the report and draw the right conclusions about organizational failures and how to avoid them. All the great software technologies to achieve memory safety, etc. are of little use if the analyses and specifications are flawed or the assumptions of the various parties in a system of systems do not match. But people seem to prefer to speculate and argue about secondary issues.