I ma genuinely baffled at how you can write:
The regulation is from 2012. It sounds like no non-8.33 radios are allowed at all.
three lines below:
5. Radios intended to operate exclusively in one or more frequency assignments that will remain in 25 kHz channel spacing shall not be required to have the 8,33 kHz channel spacing capability.
but I’ve added the bold anyway.
If you have a radio installed and you intend to use it only on 25 kHz frequencies, you can keep it.
Yes, you have made that very clear indeed. But I understand there is a requirement to carry two radios anyway, in certain circumstances (IFR notably); I cannot imagine anyone is going to have three installed. The mandatory two needing to be 8,33 to count.
No. Part-NCO does not call for two radios for IFR.
If countries request two radios for IFR in their airspace, or two radios in for IFR aircraft on their register, then that is in breach (i.e. on top of) Part-NCO.
I can’t imagine an airspace requirement for two radios. Does part NCO say anything about two radios?
Ah, ok, my mistake. Why then do ALL planes in FlightSim have two radios? 
Usually, two NAV/Coms, actually.
I ma genuinely baffled at how you can write:
Because I am not as clever as you, bookworm, which is why your presence here on EuroGA is so appreciated 
This bit
Radios intended to operate exclusively in one or more frequency assignments that will remain in 25 kHz channel spacing shall not be required to have the 8,33 kHz channel spacing capability.
is ambiguous on the word “intended”. Intended by who?
I could just decide my #2 radio is intended only for 25kHz frequencies and that’s it; no need to make it 8.33.
The regulation is thus meaningless. It’s a great result for GA but who would draft such a regulation?
Peter wrote:
Because I am not as clever as you, bookworm, which is why your presence here on EuroGA is so appreciated
I meant no offence Peter, I’m just puzzled that we can read the same words and come to such radically different conclusions.
Peter wrote:
is ambiguous on the word “intended”. Intended by who?
By the operator. Who else could it be? The manufacturer? Even if you do interpret it as the manufacturer, there’re still an obligation on the operator to ensure “the aircraft radio equipment has the 8,33 kHz channel spacing capability”.
boscomantico wrote:
If countries request two radios for IFR in their airspace, or two radios in for IFR aircraft on their register, then that is in breach (i.e. on top of) Part-NCO.
LeSving wrote:
I can’t imagine an airspace requirement for two radios.
I can imagine a state claiming that it is an “airspace requirement”. We may still have to have that fight.
Peter wrote:
is ambiguous on the word “intended”. Intended by who?
That would be the operator who in turn should ensure all pilots know it’s for nothing else (e.g. by a placard). To me it means the equipment can be capable of transmitting on other frequencies (i.e. it’s not necessary to “cripple it” and prevent transmissions on other frequencies).
Peter wrote:
So this reg allows us to keep the 2nd (25kHz) radio for 25kHz frequencies. These will always be the vast majority of GA-relevant frequencies, …
I don’t agree. Try reading it again. It clearly mentions frequency assignments that will remain in 25 kHz spacing, which to me means that the neighboring frequencies won’t be available for assignment. After 31.12.2018, there should be only a handful left. It doesn’t matter whether the frequency is the same, what matters is the spacing used (and switching to 8.33 will change the designator). That is how I read it. So no, this reg doesn’t allow you to use your “25 kHz radio” for a “vast majority of GA-related frequencies”. In the end, 121.5 might be the only one relevant to light GA.
Martin wrote:
In the end, 121.5 might be the only one relevant to light GA.
I’d be surprised if the Climax (offset carrier) frequencies like London Info move to 8.33 by 2017, but I may be wrong.
