This outside my area of expertise, and I'm on the side of the Atlantic which is not affected, but...
I am aware that Canadian aviation regulation or fee change proposals, include an element of the effect on aviation safety, which could result form the change being implemented. Looks to me that making the use of radio for air traffic awareness and separation less viable, creates a definate safety shortcoming, compared to the present situation. Wave that flag at the money grubbers...
What is the cost of an accident (mid air) comapred to not taking that money in fees, which created a disincentive to use the radio?
Just a thought...
Pilot DAR