Could you point me at the last mid-air collision in the UK that occurred in cloud please?
I'm not approaching this solely from a 'risk' angle. While I believe it would reduce risk, I think it's also important to consider SERA and the alignment of UK procedures with other nations.
Our good IMC mid-air safety record is largely based on the application of airmanship and UK-only ATSOCAS; it's the pilot's choice whether to get a radar service for IFR in class G and thankfully it seems to have worked over the years. I don't think my suggestion would have a significant effect on the usability of any airspace - all that Class E does is
force pilots to get a radar service to go IFR; if they were sensible they would have done it anyway. However it would take safety slightly away from the realms of airmanship and spare ATC capacity (which I think are inherently a bit difficult to pin down in a safety case) and into the realm of regulation.
No matter how good the safety record in Class G IFR, the fact is that the UK's approach to it is practically unique and non-compliant with ICAO and SERA. But the modification I suggested would at least preserve our current level of safety, with little or no loss of airspace flexibility, and would bring matters into line with ICAO - which may be of little concern to controllers working their 'patch' but it is certainly important for pilots who would rather not have to learn and apply dozens of differing national procedures. The 2 F-15s that crashed into Ben Macdui in 2001 did so, at least partially, because their American pilots did not understand the nuances of terrain avoidance responsibility under UK ATSOCAS at the time. You can argue that they
should have understood but neverthless regulatory alignment is a desirable objective in an environment which has no physical boundaries. SERA is
a good thing from this perspective and if we can align to it (and ICAO wherever possible) without losing anything then I think we should.
I take on board all the comments about cost. The trouble is, in good old British fashion, we simply make do with what we have; provision of ATSOCAS is one of the first things to go when ATC capacity becomes stretched and this is far from ideal for a service which underpins the safety of our current operations. With a Class E layer there would be a defined requirement for ATS, and if this was not adequately funded, the beancounters could be held accountable. Accountability has a funny habit of freeing up resource.