Balanced view? Have you actually read that risk assessment?
They give an example of non radio aircraft, with the option of other pilots using the multicom or using the area frequency. They use the same risk mitigation for both options.
How is it possible that their risk assessment can result in two completely different safety outcomes? According to the risk assessment, if using the area frequency the risk is reduced to level 5 through "education" and "targeted advice to flying schools re procedures/collision avoidance", but using the multicom and using the same risk mitigation strategies of "education" and "targeted advice" it is level 7.
Why is the risk level different?