Dan
Much good logical analysis of the shortcomings of current BH theory, which I hoped for and expected from you. Very well done for that. But I ended up disappointed by the limited argument and falsification of your extension of the flat space time basis into your alternative model.
As an astronomer whose studied real, not just theoretical, BH's and SMBH's, I was left feeling that the theoretical gap with the reality of observation was left as wide as at present. Shame you didn't use the extra words available to present any more recent verification, logic or novel predictions. There's now a mass of observational data which doesn't seem to fit your postulated model much better, or in some cases any better than the current paradigm.
You may recall my approach is directly to underlying physical reality. Testing pattern matches to only then rebuild more consistent theory. In Astronomy SMBH's are now studied to death in every way, as active galactic nuclii (AGN's). They ARE often quite visible (as are their effects), except for the jet matter receding at high speeds shifting the light beyond the visible to the infra red (We then observe it at IR frequencies, by Chandra etc.) i.e. an 'event horizon'.
There is no 'singularity' as all the (accretion disc) matter gets re-ionized by the violent helical (toroid) em field and recycled (ejected) in the quasar jets. All this is well evidenced and understood, but theoretical physicist's often don't bother to read up to date. We have our own nearby at Sagittarius A, but we can see others better.
A clock accreted from the disc will be moving away from a stationary' observer so quickly we will observe it's sequential emissions as a slowing of it's 'ticking'. Nothing more than Doppler 'time dilation'. Any physical effect on it's mechanism does NOT "slow down time"!! Only this physical basis is 100% consistent with observations and logical monotonicity. So now, when considering the other observations we group under 'relativity' in the light of these real mechanisms, they emerge in simple mechanistic form as kinetic effects without recourse to metaphysics. Some are analogous to your suggested view but it seems many also not.
Th basics are initially a little complex to grasp as they require abandoning of more than half the 19th century assumption in town, and most from the 20th century, but the consistent evidence logic is irrefutable. I've been unable to falsify the ontology so I'd be really grateful if you'd read my essay to see if you can assimilate the mechanisms and effects, and find any errors.
Hopefully you'll also find yet more analogies with your own work, or perhaps just more of the 'reinterpretations' at it's heart. I have to admit there seems to be no closer basis than yours and very few others.
Many thanks, and very best wishes in the contest.
Peter