Dear Mr Carmody
In relation to the “Frequency use at low level in Class G airspace” discussion, I’m not sure if you understand a very important fact.
When the mandate was originally implemented for VFR aircraft in Class G airspace to monitor and announce if in potential conflict, it was also mandatory for IFR aircraft to give full position reports – even in surveillance coverage.
This was because there was a demarcation issue between flight service officers and air traffic controllers. Pilots flying in uncontrolled airspace were forced to monitor and announce on a flight service frequency, however the flight service officers were in a different room to the air traffic controllers and did not have a radar/surveillance screen.
If we move forward to the present time, in virtually all of the airspace with high traffic density in the J-curve, IFR aircraft are not required to give position reports as they are under surveillance coverage (either radar or ADS-B) and are therefore “identified”. Position reports are not required and in practice they are not given.
Note that AIP ENR 1.1 states:
“10.5.1 Pilots of radio-equipped VFR aircraft must listen out on the appropriate VHF frequency and announce if in potential conflict. Pilots intercepting broadcasts from aircraft in their vicinity which are considered to be in potential conflict with their own aircraft must acknowledge by transmitting own callsign and, as appropriate, aircraft type, position, actual level and intentions.
10.5.1.1 The appropriate VHF frequency stated in para 10.5.1 is:
a. In the vicinity of an aerodrome depicted on aeronautical charts, with a discrete frequency, the discrete CTAF shown (including Broadcast Area CTAF), or otherwise;
b. In the vicinity of an aerodrome depicted on aeronautical charts, with no discrete frequency shown, the MULTICOM 126.7; or
c. In all other cases, Area VHF".
Civil Aviation Regulation (CAR) 243 also states:
“Listening watch (1) When an aircraft is equipped with radio apparatus for use during flight, the pilot in command must maintain a listening watch, or must ensure that a listening watch is maintained, at all times commencing immediately prior to the time at which the aircraft commences to move on the manoeuvring area prior to flight and lasting until the aircraft is brought to a stop at the apron or other point of termination of the flight.
Penalty: 25 penalty units” (Currently $5,240)
We now have a situation where it is mandated for a VFR pilot to monitor and announce if they are traffic for an IFR aircraft, whereas the IFR aircraft is not giving a position report in the first place, meaning their location is not known to VFR pilots.
Do you see the anomaly?
I am sure you also understand that there is no mandate for a transponder for VFR aircraft in Class G uncontrolled airspace, so in many cases the VFR aircraft will be completely transparent to the system.
To put it simply, it is ridiculous to legally require pilots of VFR aircraft to monitor and announce when in potential conflict when the location of IFR aircraft is not known because their pilots do not provide position reports. It is clear that it is impossible to operate a “half wound-back” system effectively.
Yours faithfully
Dick Smith