Those who’ve been around a while will probably remember the debate that raged about the frequency to be used in the vicinity of uncharted aerodromes. For a time there was a correct regulatory answer: The Area frequency.
But as usual the initial implementation of the decision was half-baked, there was insufficient education and, in this particular instance, air traffic controllers among some others didn’t like the answer. This led to ATSB responding to reports like “
contradictory information contained in AIP concerning the frequency to be used at non-controlled airports”, lack of education about “
the use of Multicom (126.7) versus Area Frequency” and “
Air traffic controllers not understanding the requirement for aircraft to broadcast on the area frequency when operating to or from aerodromes which are not marked on a map”.
In response to the first of those, CASA told ATSB that, among other things:
CASA will use both industry education and changes to AIP to ensure a consistent and safe approach.
In response to the second of those, CASA told ATSB that, among other things:
CASA has taken a number of steps to ensure the aviation community is aware of its policy for radio broadcasts at non-controlled aerodromes as follows:
- Amended relevant sections of the AIP;
- Revised CAAPs 166-1 and 166-2 to reflect the policy;
- Updated the relevant pages and products on its website and deleted outdated material;
- Run a campaign through nationwide seminars by CASA Aviation Safety Advisers;
- Placed articles in recent CASA Briefings – August 2014 ‘Get on the right frequency at unmarked aerodromes’ and September 2014 ‘No reports of area frequency congestion’; and
- Issued a NOTAM to raise awareness of the changes prior to their incorporation while changes have been made.
In response to the third, CASA noted that Airservices had promulgated further educational material to ensure that controllers were aware of their requirements in relation to VFR aircraft broadcasting on Area frequency. The Airservices controller educational material said, among other things:
Why is that VFR aircraft broadcasting on Area VHF?
..
If, however, an aircraft is beginning a flight, approaching or flying in the vicinity of an aerodrome not depicted on aeronautical charts, the pilot must make their required broadcasts on the Area VHF frequency.
Next time you hear a broadcast on the Area VHF frequency, consider whether the aerodrome in question is depicted on aeronautical charts (WAC, VNC, VTC, ERC, TAC). The aircraft may be complying with AIP requirements.
So, after the usual confusion and mess, we finally got there: A clear rule understood by just about everyone. And clear rules understood by just about everyone are better than the alternative. But…
The clear rule was evidently not
accepted by everyone. Obviously somebody whinged loud and long enough to somebody in CASA because there is now no rule. It’s been replaced by a meaningless motherhood statement that can be interpreted any way anyone likes. AIP ENR 1.1 para 9.1.7 now says:
In the vicinity of uncharted aerodromes, pilots have discretion to use the most appropriate frequency that ensures safe operation. This may be 126.7. However, pilots should be aware that transiting aircraft will be monitoring Area VHF. To ensure mutual traffic awareness, it is recommended that pilots using an alternative frequency also monitor Area VHF.
How on Earth could that result in a “consistent and safe approach”?
The ”most appropriate frequency” in the vicinity of an uncharted aerodrome is actually the one that everyone else will assume is being used in the vicinity of that aerodrome. Remember: It’s about communicating with other people.
CASA could have backflipped and specified 126.7 instead of Area. But no: It’s now: Take your pick and just hope that everyone else has ESP. What could possibly go wrong? (I am waiting for the equivalent change to the road rules: Drivers on country roads have discretion to drive on whichever side of the road that ensures safety. That may be the right side of the road but you should be aware that oncoming drivers may have exercised their discretion the other way.)
Naturally, there is inconsistency with the text of AC 91-10v1.1. It says, with my bolding:
There are additional risks associated with operations at aerodromes or ALAs that are not published on an aeronautical chart. Under limited circumstances, such as multiple aircraft using the same uncharted ALA outside a CTAF or Mandatory Broadcast Area, it may be appropriate for the pilots involved to monitor and broadcast on a frequency other than Area VHF (such as the CTAF or 126.7 MHz). However, pilots undertaking these operations should be aware that overflying traffic will be on Area VHF and are likely to be unaware of the uncharted aerodrome / ALA. Hence, the safety benefits of 'alerted' 'see-and-avoid' may not be achieved. It is recommended that pilots at uncharted aerodromes using a frequency other than Area VHF also monitor Area VHF.
The clear effect of the bolded text is that the Area frequency should be used in the vicinity of uncharted aerodromes
except in “limited circumstances” like the example given. That’s not the clear effect of the words in ENR 1.1 para 9.1.7.
Note 1 under the quoted text says:
The intent is to ensure broadcasts are made on a frequency that other aircraft in the vicinity will be monitoring.
No kidding.