...20 near misses with aircraft above 3000 ft.
I'm gonna claim shenanigans. That is simply their excuse for Bypassing the "Good Cause" regulation that allowed them to bypass Public Comment.
I don't really want to call pilots liars, but flying at 3000ft and hundreds of miles an hour, I do not believe you can accurately identify something that small let alone see it. Have you ever had trouble trying to figure out which direction your model airplane is headed when it gets more that a few hundred feet away? A pilot hopefully paying attention to other things as well as the view, traveling fast, would have to have the eyes of an eagle to accurately identify a basically stationary drone. I'd love to see the near-miss report details - time of day, weather, speed, etc. Equip planes with DashCams and show me the video.
Catch some of these idiots. If you can't catch them you can't pass new regulations. Catch a few and punish them, then I'll listen.
Best regards,
PCH