No offence meant GW. The point you make about commercial flying outside CAS is a fair one but is it relevant? The issue of risk assessing commercial operations is a separate issue from a major change to ATSOCAS. Commercial operators should do it anyway and the CAA should insist on it. It is relatively easy for an operator to do that and then insist that appropriate operating procedures are adopted. That they do not is a disgrace. That failure, however, is not the reason for changing ATSOCAS (unless you know something we don’t). The reason for changing ATSOCAS is to remove confusion and errors of application.
My point is that the vast majority of ATSOCAS provided by civil controllers is down in the boondocks to thousands of light aircraft daily. Those pilots will not do risk assessments and will not change the way they operate. They will be even more confused than now. What is needed is education, the correct application of the present rules and the sort of clarification of responsibilities contained in CAP774. What we will get is a huge shuffling of deckchairs and even more confusion. If people are confused now, after 20 years, do we really believe this will change anything?