The following is quoted from the RAAus December Newsletter......
CASA survey action required by 12 January 2018 - MULTICOM
Members are advised CASA have issued a Notice of Proposed Rule Making (NPRM) MULTICOM frequency use after the recent consultation process in which the majority of respondents indicated the MULTICOM frequency was their preferred option below 5000’ Above Mean Sea Level (AMSL). We are requesting all members complete the survey and provide a response to CASA on this important topic.
The NPRM is worded poorly, making two recommendations in one response. As one of these recommendations was not part of the original consultation process we advise members that RAAus fully supports only one part of this proposal.
CASA have proposed MULTICOM frequency 126.7 is monitored and used in uncontrolled airspace below 5000’ Above Mean Sea Level (AMSL) where there is no discrete frequency or broadcast area. Above 5000’ AMSL the area frequency would be monitored. This proposal is completely acceptable to RAAus.
The other proposal is to increase the size of a CTAF from the current recommended 10 nm to 20 nm. This is unacceptable to RAAus and its members for a variety of reasons, including the quadrupling of area requiring the CTAF frequency to be used, significantly increasing the risk of radio frequency congestion, the unavoidable inclusion of private airstrips or fields which were previously outside the CTAF, which would require aircraft to now carry radio. Further the CAAP recommends inbound traffic make relevant situationally required radio calls relative to the speed and type of operation of the aircraft. Inbound Regular Passenger Transport (RPT) aircraft routinely make calls 30-40 nm outside the CTAF, which should be continued. Accordingly, RAAus strongly objects to the portion of the NPRM to increase the size of CTAFs.
RAAus members are strongly encouraged to complete this survey, however members need to consider the difficulty presented by the NPRM combining these two questions into one response. This requires the respondent to answer no to the MULTICOM part of the proposal to avoid the increase in CTAF component. RAAus therefore recommends the following course of action by all RAAus members.
1. Follow this link CASA MULTICOM NPRM
2. Answer the identification questions as you believe appropriate
3. For the next question you will be asked if you prefer the MULTICOM and CTAF increase. Your initial answer should be “Proposal is NOT acceptable” and in the additional information box below, you should add words to the effect “I only accept the MULTICOM Proposal below 5000 feet AMSL”
4. You will be prompted during the next question to provide your answer as to why the CTAF size increase is not acceptable. RAAus recommend you provide words to the effect “There has been no safety case or risk assessment regarding the proposal to expand a CTAF size to 20 nm. This was not part of the original MULTICOM consultation process. CAAP 166 provides guidance for pilots to make appropriate calls relevant to the aircraft type and speed of operation. Expanding CTAFs to 20 nm will enlarge the potential area requiring calls by a factor of 4, potentially leading to additional congestion in CTAFs.”
5. Complete the remainder of the questions as relevant to your aircraft type and submit
RAAus has raised our concerns about the combination of the two distinct and separate questions with CASA and will continue to inform members about further progress related to MULTICOM changes in the New Year.