There would still have been a bulge in complaints, given all the uncertainty around refunds when COVID first came and, more recently, around baggage loss and other delays this summer.
However, the model I'm referring to is largely done in telecommunications, where a consumer makes a complaint directly to the CCTS. The agent can take the consumer complaint, contact the telecom and get an answer back. It has to be done within a month, so the timeline is short and the resolution is informal. If the telco wants to make the offer and the customer is happy with it, it's done, and there's no need for a formal decision of any kind. The trouble with the CTA is that they still have their tribunal hat on and that's unnecessary for most of these claims—the amounts are too small.