Dear government Please remind us, just how many MAC's DO NOT happen. GA has just spent a vast sum re-equipping with 8.33 radios, a totally pointless exercise as our friends across the Atlantic would happily advise you.
Instead of unravelling yet another roll of red tape, how about directing your surplus resources on eliminating the excesses of controlled-airspace ,particularly in the southern half of the country, Reducing choke-points and allowing Aviators to spread out more, would reduce the risks of a MAC far more cheaply and effectively.
The vagueness if the proposed "civil sanctions" disturbs me. The CAA appears to be a law unto itself, is understaffed as far as knowledge and understanding go, (misleading and totally wrong information is almost routine as is the total lack of accurate information concerning licence conversions, renewals and validations. Many pilots have been told that "the" route involves a full training-course for a conversion, costing several thousand pounds. The truth is a very simple route that costs at most a few hundred. When confronted with their misleading" guidance " there is no apology, just a glib "well, yes, you could do it that way"
Should I remind you of the extortionate "blackmail" charges from a monopoly who refuses to answer it's "customers" on the telephone and demands a ridiculous fee to make a personal visit.
Many GA pilots have voluntarily adopted EC , both regulated and unregulated.
I suggest you sort-out an efficient, practical and cost-effective Administration FIRST before you add yet another nail in the coffin of UK GA.