Interesting. I see what you mean about the 3nm guideline. However two sentences on in the same guidance it says:
Controllers shall aim to pass information on relevant traffic before the conflicting aircraft is within 5 NM, in order to give the pilot sufficient time to meet his collision avoidance responsibilities and to allow for an update in traffic information if considered necessary.
So that would tend to limit the difference between RIS and TS, would it not?
I also think one of the main aims of the new ATSOCAS - to reduce the instances of controllers providing radar-based traffic info to aircraft on a FIS - hasn't happened. I still get lots of radar-based traffic info on a BS. I'm not complaining though - it's all useful and appreciated and I never EXPECT it.
As a little postscript, I was offered a "Flight Information Service" by a radar controller a couple of weeks ago. Felt like a time-warp.
NS