Originally Posted by
Lead Balloon
The procedures effectively abdicate separation responsibility to a single point of failure, where failure is not unlikely and, as a consequence of the airspace design, failure results in high probabilities of collision.
The difficulties of identifying a specific aircraft, at night, in a background of stationary and moving lights, when moving objects on a collision course will always appear stationary to each other, are well known, as are the probabilities of mis-identification. The airspace design 'squeezes' inbound aircraft and transiting helicopters to practicality the same altitude, when instrument and other tolerances are taken into consideration.
Absolutely, and it will be very interesting to see what the NTSB has to say about the "rules" and if the FAA does anything to change those rules. Pilot-applied visual separation is common at airports all over the US, day and night. Frankly, it was only a matter of time before a tragedy occurred, for the reasons you mentioned.