The CAA proposal includes a suggestion that 121.5 should be monitored at all times.
Most of the aircraft I fly are only fitted with two VHF boxes, so how are the crew supposed to get ATIS/VOLMET or talk to handling agents etc? Are owners going to have to fork out for a third unit?
Also, I note that they have magnanimously allowed that the pilot may not be prosecuted if the loss of comms was the fault of ATC. No mention of prosecuting the controller then?