Perhaps it would have been a good idea to consult with industry. Some of the things brought up here are clear to those of us who work in the GAAP environment every day but seem to have been overlooked.
Agreed that it is the approach points outside the CTR that are the most hazardous areas. Particularly when you have people who either don't know the rights of way or are apparently flying with their eyes shut. Overtaking on the left is one of my pet hates, people reporting at a point when they are in fact a couple of miles away from it is another. And orbiting at a GAAP approach point
I think we might see more of that with these proposed changes!
These proposed changes won't make any difference to safety for as long as the people who do the above and the orgnaisations they come from see no consequences for their actions. Perhaps if people thought that CASA might actually invite them over for tea and biccies to explain themselves we might see better airmanship. Until then there will always be those who behave this way, and the students will think that it's OK, and as CASA left Jandakot years ago to look after the fare paying pax at Perth there's no enforcement.