The Civil Aviation Safety Authority on Monday published the latest feedback to the Multicom Notice of Proposed Rule Making (NPRM) as presented to the aviation industry in late April.
The proposal simplified the ongoing debate over which frequency to use at uncharted airports to using 126.7, instead of the area VHF as was stated in an AIP amendment in 2013.
Feedback on the issue still appears mixed, with many of the submissions finding little fault with the new proposal, balanced out by those who object on a variety of grounds.
"I think it can only be safer, and formalise a practice currently used by many pilots," said Michael Smith. "I always feel bad making calls for an unchartered aerodrome when the area frequency may be busy with IFR and RPT activities, yet I know I am nowhere near those aircraft. With most modern radios allowing dual monitoring, 126.7 becomes a great second station for cross country flights."
The strength of support for the new proposal was not unanimous, with some respondents still concerned that using 126.7 and not the area VHF could pose safety risks.
"This proposal will completely clog the radio and make the 126.7 frequency unusable," says pilot Tony Taggart. "Private airstrips don't need a radio frequency because they are private. Local use airstrips can often use a locally devised frequency for their users and are not a burden or hindrance to anybody else.
"As it is I don't need to know what is happening at an airstrip 10, 20 or 30 miles from the one that is my target. As it is there are frequencies that clog each other"
There was a stream of feedback that urged further safety by making sure more airports are placed on charts, particularly World Aeronautical Charts (WACs). CASA alluded to this requirement in the NPRM.
Several suggested the definition of "vicinity" for 126.7 should be pushed out from 3 nm to 5 nm, and that a comprehensive education campaign would be needed to make sure the changes got through to the aviation community.
Greg Ackman: "I believe that the use of 126.7 MHz should as a minimum distance be out to a radius of 5 nm from the aerodrome not 3 nm as envisaged. This is the minimum normal distance that an inbound call would be made by an approaching aircraft. Ideally as 10 nm calls are normal, a 10 nm distance would be the most desirable.
"At 120 knots the 3 nm distance is equal to only 1.5 minutes of flying time and only 45 seconds separation for two aircraft on reciprocal tracks, which is in my opinion insufficient separation to establish collision avoidance."
Dougal McQuie from Goldfields Air Services told CASA that the new proposal would serve to formalise current practice.
"My own inquiries regarding the conduct of operations by private operations and sports aircraft owners leads me to believe that the current ruling is largely misunderstood and that this is how most people operate at uncharted aerodromes and airstrips anyway."
The saga of the Multicom frequency is five years old now and has been the subject of constant debate within the industry. Pilot David Brown summed up the feelings of many within the aviation community.
"Constant changing of things that work creates change fatigue," he said. "Pilots now have no idea on when and where to use what frequency, when and where to do a departure report, the list goes on.
"Get it right and stop mucking with it."
A list of feedback agreed to be published is on the CASA website.