The changes in ENR 1.1 44.1.1 (May 1013) that moved broadcasts from non-charted aerodromes on to the area frequency has caused a lot of concern amongst the RAPACs. Nobody can tell us what perceived problem was being addressed by moving broadcasts from non-charted aerodromes from the Multicom to the area VHF frequency. We can not find any evidence of consultation with any stake holders either.
At the July Vic. RAPAC meeting CASA and the Office of Airspace Regulation (OAR) refuse to allow it on their agenda for discussion on the basis that it is an "Operational issue" whatever that means.
Having identified four serious issues as a result of the change the RAPAC convenors then tried to have the matter added to the agenda for the Airspace and Aerodrome Consultative Forum (AACF) scheduled for Friday 05 Sept.
Again all discussion was blocked by the remarkable response that in spite of being an Airspace and Aerodrome consultative Forum the RAPAC concerns could not be listed on the agenda because it was an operational issue.
What therefore is the purpose of the OAR and the AACF if they cannot discuss all matters relevant to aerodromes and aerospace and why would anybody bother attending such lame events? Nobody has an answer to this as yet.
The RAPACs want all aerodromes without a separate CTAF to broadcast on the Multicom (126.7). Whether they are on charts or otherwise is irrelevant.
The four concerns we have are:
(1) The potential frequency congestion and unintentional jamming on the area VHF because the ATS transmissions do not have coverage down to the lower levels in many places. This is largely because the area VHF boundaries are related to the TAATS overlays not the transmitter sites. In fact some transmitters are actually located outside the actual sector. Nobody knows jut how many non-charted aerodromes there are within VHF coverage of traffic at flight levels but every ag strip would have to be included.
(2) Previously, aerodrome broadcasts were either on a published CTAF or on the Multicom so monitoring the latter made sense in many situations. Now the traffic information from non-charted aerodromes has been lost.
(3) There is now a conflict between the frequency requirements of CAR 166C and the AIP at non-charted aerodromes that are in the vicinity of charted aerodromes.
(4) Where an un-charted aerodrome is situated near the boundary of two area VHF frequencies, two broadcast frequencies for that aerodrome have been unwittingly created.
The whole issue has every sign of a change made without a proper understanding of the consequences followed by an orchestrated refusal to consult with the airspace users.