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Latest on 8.33 requirements (merged)

Here are some new 8.33 Garmin radios.

No idea if they are plug-in replacements for anything previous.

Administrator
Shoreham EGKA, United Kingdom

I always thought the touch screen of Garmin's GTN series a bit odd, when one follows the turbulence argument to turn knobs. Besides having fingerprints and grease all over the screen. Not my favourite.

mh
Aufwind GmbH
EKPB, Germany

The GTNs work very well. You have knobs when you want those and touch screen for other things. Haven't found greasy fingerprint to be a problem at all to be honest.

EGTK Oxford

The ones I have flown with did now show any adverse effects from touching, but presumably they must eventually.

The funny thing is that reports from the USA indicate a significant level of LCD failures in older units, in the form of "spots", where people try to poke a finger into the screen thinking it is a touch screen

Administrator
Shoreham EGKA, United Kingdom

Honestly, I almost did this recently. I am now so used to tomtoms, garmin aeras, iphones and ipads, so I did reach for the screen of my Avidyne PFD, but refrained in the last second...:-) felt really stupid, though...

Mainz (EDFZ) & Egelsbach (EDFE), Germany

Speaking of keypads in turbulence, if you have one central keypad for everything, the keys can be made large enough and surrounded by small "handrails". Alternatively, one can use a palm-sized keypad with a mobile phone-like design, which can be pulled out of the panel on a retractable cable.

LKBU (near Prague), Czech Republic

I have just come back to this issue, speaking to another TB20GT owner with two KX155A radios (a lot of them around).

Referring to that Article 5 text, it says

"unless the aircraft radio equipment has the 8,33 kHz channel spacing capability"

It does not say

"unless ALL the aircraft radio equipment has the 8,33 kHz channel spacing capability"

Where does it say that ALL your radios need to be 8.33?

I may be going over old ground (it happens as you get old ) but I can't see what right any individual EU airspace owner has to gold plate the above EASA reg.

The "problem" is that one can plug-swap the lower KX155A (NAV2, driving a KI204) with a 165A, and it just works. But one can't do that with the upper 155A (NAV1, driving the KI525 HSI). The radio works but the HSI doesn't work laterally. I suspect that the 165A needs some config (the 155A has no config for anything of significance). I didn't spend any time on it; I just put the 165A in the COM2/NAV2 position. But people who want to be totally compliant with everything imaginable will need to do the upper one also.

Administrator
Shoreham EGKA, United Kingdom

"unless the aircraft radio equipment has the 8,33 kHz channel spacing capability"

It does not say

"unless ALL the aircraft radio equipment has the 8,33 kHz channel spacing capability"

Check the dictionary for the definition of "equipment". That's what a judge would do and he would come to the conclusion that all devices have to be 8.33kHz capable. Otherwise the text would say "the primary VHF" or "at least one VHF". In the UK you should be fine with one 8.33kHz and one INOP radio. Just don't overfly or land in Germany

If we had a lobby organization, it would be working very hard to get the directive changed to read "at least one VHF radio". Garmin & Co. do have a lobby organization and they all agree that 8.33kHz is a very good idea.

To me, the English phrase

"unless the aircraft radio equipment has the 8,33 kHz channel spacing capability"

means "some equipment" not "all possible equipment".

The word "equipment" is non-specific as to singular or plural.

If you have one 8.33 radio then there is absolutely no question you have "8.33 equipment" - in English. The German translation of Article 5 may be different.

Moreover, the "equipment" needs to be working only before departure. I heard one argument from a German which was that you need two 8.33 radios in case one fails during the flight, but the regulation doesn't say that, and you would also need 2 engines because your aircraft is totally unairworthy and thus illegal to fly once an engine fails.

I think laws must be read as they are written. I have been told that regarding FAA regs too; that they are written by lawyers and if the lawyers want something in there they will put it there.

Administrator
Shoreham EGKA, United Kingdom

I heard one argument from a German which was that you need two 8.33 radios in case one fails during the flight, but the regulation doesn't say that,

The law requires 2 COMs and the reason behind the law doesn't really matter. I wouldn't think it's for redundancy but to be able to tune to more than one station at the same time. In Germany we have tax subsidies for porn magazines and dog food but we don't remember how we got them.

I think laws must be read as they are written.

Yes, that's the job of judges. My interpretation of "unless the aircraft radio equipment has the 8,33 kHz channel spacing capability" is that all VHFs need to have 8.33kHz capability because they all are part of the "aircraft radio equipment" and the 8.33kHz capability is generally mandated by the above article. Again, our opinions don't count, it's a case for a court ruling or even better a clarification by the law maker. Unfortunately, it takes very long to correct mistakes in EU directives and there is no legal way around them. Part FCL has such cases where the CAAs have to be very creative until the directive gets a bugfix.

The German translation of Article 5 may be different.

Don't know but that's actually an interesting thing. In Euro land, only the translation is an authoritative law source for the country so if the German translation (legally, there are no "translations", only "originals") contains some translation error, this error becomes valid law in Germany. Such things have happened in the past, I remember some provision in an EASA directive that required 1000 hours of experience which was translated to German as 1000 hours of instruction

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