This is mostly true, but the range check is done in a relatively short distance as compared to the overall range capabilities of a properly oriented antenna. If you take a walk about 200 yards and try this (this is 600 feet.. not being a wiseguy, but 200 yards is a pretty good distance) you will find that it will be marginal even for a properly oriented antenna and probably not functional if pointing towards the plane. Keep in mind that the DX7, for instance, uses the range check button, which reduces the output power when pressed. 72 MHz is done with the antenna collapsed.

Most of the energy is radiated out vertically as shown in the example above. The strength of the signal (field strength as measured in micro-volts per meter) is inversely proportional to the square of the distance.... or some such thing..