My submission to airservices
This proposal will not increase safety, likely to decrease safety, several issues that come to mind,
1) aircraft are not fitted with AGL meters, 500' agl is easy enough to questimate, but 1500' agl is a very vague figure, especially when operating around hilly terrain, just from where or how are pilots to ascertain where the limits are?
2) training schools are required to carry out stall training, according to the syllabus, stalls must be recovered by 3000' agl, in order to comply they will all have to be fitted with a transponder at a not insignificant cost (approx $5-7,000. Not to mention the on going rad47 costs every 2 years) A lot of training takes place in RAAus registered aircraft, most of which are not fitted with a transponder.
3) forcing all non transponder equipped aircraft below 1500' is a recipe for disaster, imagine flying near mountainous terrain and being caught in rotor, or the increased turbulence adding to pilots work load, and also extra airframe loading. With a higher concentration of aircraft below 1500' without hemispherical levels will increase chance of a midair.
3) circuit height for high performance aircraft is 1500'agl any aircraft overflying would also be forced to fly through the circuit area or detour around. Most midairs occur in the vicinity of aerodromes, this proposal increases this risk.
4) there are a lot of recreational aircraft not fitted with transponders, the owners would incur significant costs if forced to fit transponders.
5) Airservices has not presented a safety reason for implementing such a radical change in airspace.