Yep, can be ...
For Belgium ...
Also 3 frequencies, TWR, DEP and AREA ... but of course all on one dime...
Also other procedures.
Just a question, when you depart or arrive from JFK, is it possible that you'll level off for more than one minute? I mean, in initial Climb (lets say below FL100) or arriving?
I think it's a tradeoff between continuous descend/climb and long(er) leveloffs... If you create Procedures who are clear of each other for DEP's and ARRIVALS (on a procedural level and not a radar level) then, you can remain on less freq's... but you might level off at 4000 ft or FL70 for more than 10 NM...
That and the availability of surrounding airspace (MILITARY vs CIVIL)
If you look at Belgium,(not that big!) has 50/50 CIVIL and MILITARY...
Let me know!
Greetings
BM