Capot,
Don't think they are too interested in the opinion of pilots, given that the opening paragraph of the document is
" The Department for Transport has actively considered the needs of blind and partially sighted people in accessing this document. The text will be made available in full on the Department’s website. The text may be freely downloaded and translated by individuals or organisations for conversion into other accessible formats. If you have other needs in this regard please contact the Department."
Doubt that covers too many pilots.
I think a healthy suspicion of "too long too quiet" is as good a defence against this as anything, but, even in Europe there are lengthy silences in certain sectors at certain times. Totally agree Re SELCAL /CPDLC etc, Ryanair can probably be crossed off the list, but would imagine a BA777 has a few options ATC could have used to try & establish contact. If nothing else why don't they simply ask a proximate aircraft to call on it's 2nd box on the last frequency it was known to be monitoring ? air to air is assumedly going to "outrange" calls from the ground.