Exactly 
I sought more clarification from UK CAA on the need to upgrade all radios in a Part NCO aircraft. As a consequence the CAA webpage has been updated:
https://www.caa.co.uk/General-aviation/Aircraft-ownership-and-maintenance/8-33-kHz-radios/
So for a Part NCO aircraft even if operating in IFR, it’s clear that only ONE radio needs to be 8.33 compliant.
Here’s the essential paragraph:
Upgrading to 8.33 kHz-compatible equipment and installation options
There are a number of options for purchasing and installing equipment in time for the 8.33 kHz changeover deadline, including a number of ways the installation design approval can be simplified. The Implementing Rule (IR) 1079/2012 says that radio equipment put into service after November 2013 should be 8.33 kHz voice communications system (VCS) capable and manufacturers must ensure radios placed on the market from this date meet this requirement.
Dual radios and existing 25 kHz systems
Aircraft will need to be equipped with the number of 8.33 kHz capable radios required by operational rules. So if where the carriage of two radios is required, both radios must be 8.33kHz VCS capable.
Non-commercial operations fall under Part NCO which does not include a requirement for aircraft to carry dual radios. But owners are advised to check the relevant regulation to their own operations in order to establish what is required.
Existing 25kHz radios can be left installed provided that they are only used for exempted frequencies, such as the emergency frequency.
Many thanks wigglyamp for this very good post!
Oddly enough I spoke to one shop yesterday and he is booked up solidly for the foreseeable future doing 8.33 work. He intensely dislikes the KX165A route (even to replace a KX155A radio which is a slide-in replacement) and he seems to be installing GNS/GTN/IFD boxes to achieve this. Obviously this is a very pricey route unless you want the extra features.
Yet, I know that the supply of KX165A radios practically dried up in the USA, both new and overhauled, as a result of this European stuff. This is despite the EASA complication of apparently not accepting an 8130-3 form with used or overhauled equipment.
What is the typical profile of the equipment people are installing to get 8.33 today?
Has anyone managed to file a claim for the subsidy from the U.K. CAA, a pirep on this would be helpful. Is there a form?
Peter wrote:
Oddly enough I spoke to one shop yesterday and he is booked up solidly for the foreseeable future doing 8.33 work. He intensely dislikes the KX165A route (even to replace a KX155A radio which is a slide-in replacement) and he seems to be installing GNS/GTN/IFD boxes to achieve this. Obviously this is a very pricey route unless you want the extra features.
I can understand this. The KX-165A has insane pricing. Unless you have a complete King stack with KX-155A now, then it makes some sense. It is not better or worse then an Garmin GNC-255A, though the pricing on the GNC-255A is so much lower, that even an GNC-255A with labour for installation will give a lower price then an KX-165A.
If one wants to upgrade to a GPS, then the others boxes are the only way forward.
though the pricing on the GNC-255A is so much lower, that even an GNC-255A with labour for installation will give a lower price then an KX-165A.
GNC255A – From $3865.00 to $5685.95
KX165A – $5095.00 (28 volt only)
And if you have a KX155A then a used KX165A, with a KX155A trade-in (or US Ebay sale) is way cheaper than the above and, subject to your “personal regulatory climate”, you can slide it in yourself. Subject to this which may mean it goes in the COM2 position.
KX-165A is 28 Volt only, so the number of aircraft are limited. List price is just over 6000 USD. GNC-255A is 4495 USD. The others you compare are the high power 16 Watt version (not fare, as the KX-165A is 10 Watt). Apart from that, if you don’t need 16 Watt for regulations, I would suggest 10 Watt version. As you will notice the difference (in dB) is very small. The other one you compare with is one with night vision, which isn’t fair either.
So basically you have 6000 USD vs 4495 USD list, you can easily see that even with labour a GNC-255A will be lower then a KX-165A.
I always suggest my customers to sell their equipment themselfs for best pricing, ideally to an end customer. With transponders I did trade in transponders and sold them to USA. Even though they were tested before removal, often 8 out of 10 where considered out of tolerance, we pay 150 USD for parts, or ship them back on your expense, which isn’t fair either. Selling from end user to end user will remove this hassle, and a shop can do the testing if needed.
I saw this in one UK GA mag
Interesting that the UK CAA was one of those who sabotaged central frequency allocation and thus forced 8.33 on us.
Peter wrote:
What is the typical profile of the equipment people are installing to get 8.33 today?
Peter wrote:
Interesting that the UK CAA was one of those who sabotaged central frequency allocation and thus forced 8.33 on us.
I’m not sure it was the CAA — “national sovereignty” doesn’t sound like their thing. The MoD would also have a stake in aeronautical frequency allocation, would it not?
