Thanks Vag. I see from the “Summary of Consultation” that the “Future direction” foreshadowed what’s now happened: “The AIP will be simplified and less prescriptive about the frequency to use at those aerodromes that are uncharted.” The perfect bureaucratic answer to competing opinions, which answer is given the Orwellian description ‘simplification’ and results in an increased risk to aviation safety compared with the pre-existing rule.
I’d be interested in who constitutes “the industry”, Capn Bloggs, as my observation is that different parts of it often disagree as to what the rules should be. (Not that I’m pressing you for a definition.)
In any event, it’s just bizarre to me that these kinds of decisions seem to be a popularity contest rather the result of cold, hard logic. It’s like consulting on the speed limit to be set on a particular stretch of road.
CASA’s original decision to mandate Area as the frequency to be used in the vicinity of uncharted aerodromes was based on cold, hard logic (just as your view and mine - and others’ - are based on cold, hard logic). Given that the ultimate aim is to “ensure broadcasts are made on a frequency that other aircraft in the vicinity will be monitoring” - because that is the only way in which the broadcasts will serve their safety purpose - there was (and I and it seems you say remains) only one answer to the question as to which frequency to use to achieve that aim and serve the safety purpose in the vicinity of uncharted aerodromes.
Presumably, that is why CASA settled on the pre-existing rules to which you referred and vigorously defended them (as can be seen in the ATSB investigations, links to some of which I posted earlier). And it appears that the drafters of the AC provision I quoted earlier continue to take the same view, because the language in the AC is to the effect that Area should be used except in some “limited” circumstances.
So let’s test whether the “simplified” rule achieves the aim of “ensur[ing] broadcasts are made on a frequency that other aircraft in the vicinity will be monitoring”.
Question: When you exercise your discretion as to the frequency to use for broadcasts in the vicinity of an uncharted aerodrome, how do you know that all other pilots will be exercising their discretion in the same way in the vicinity of that aerodrome?
Answer: You don’t know.
QED.