Dick, I'll post additonal comments relating to 2c on here when I have more time. I've just downloaded the NPRM and am frankly quite disturbed by what I've seen on a brief read through.
I've just got a couple of quick questions at this stage.
That's why you have to be very astute and allocate the finite resources so they save the most lives.
At this stage, what cost saving is there to the tax payer in amending MBZ/CTAF procedures to this extent? Surely it doesn't cost the taxpayer a cent to leave these procedures as they are. No resources will be saved, in fact taxpayer dollars will be wasted as a result of these unnecessary changes. Scarce dollars that could be better spent, perhaps, in educating pilots better on our current procedures?
the reason that unalerted see and avoid incidents will be reduced in MBZ airports is because VFR aircraft flying enroute will no longer be monitoring hundreds of calls which are irrelevant
Any aircraft flying in an MBZ should only be hearing the calls that are made from within that MBZ and as such are directly relevant to the operation. This point simply doesn't hold water!!
where the collision risk is higher - that is closer to the airport
You accept this fact - in essence it is the raison d'etre for ALL NAS amendments. However, 2c seems to directly contradict this through the removal of MBZs. If this NPRM is accepted you will have High Capacity RPT aircraft that will be sharing airspace with aircraft that may or may not have radios. This can only lead to an increase in
serious unalerted see and avoid incidents.
The new recommended procedures, and a requirement for pilots to
take all reasonable steps to ensure that his/her aircraft does not cause a danger to other aircraft
are too general and, at the end of the day, are only recommended procedures.
I can assure you that I'll be responding to this NPRM through the appropriate channels also and resisting these changes.
As I said, I'll add some further comments later but I would urge you to reconsider this.