But you will not mention the obvious. If we had C airspace provided with the proper tools and staffing, it would indeed be safer. However, we use large amounts of C airspace controlled by a single Controller in the D airspace below. This is the reason other countries have E above D. They wish to allocate their safety resources effectively, and don’t want the concentration of a Controller in D airspace close to the runway to be affected by having to provide a Class C service at the same time when the risk of collision is far less.
Are you saying that the service currently being provided in C/D Airspace is not safe?
Would you prefer that current Ds become C?