Radios aren't mandatory for CTAF users.
Well that depends on what CTAF and the circumstances. CASA does permit aerodrome operators of non Reg/Cert airfields (ALA's) to insert a VHF requirement in their ERSA entry.
Going back to having the 'jam tins' is really not a workable option, regardless of the size.
It will be interested to see their risk analysis on this proposal and what other options were considered.
All things considered it might have been easier and safer to just remove the poorly thought out requirement to use the Area Frequency at 'unmarked' airfields, making the MULTICOM the default low level frequency outside of BA's and CTAFs with a different freq - with no dimensions, just recommended practices...
