8.33 is an airspace reg but I think the number of 8.33 radios is different. Not sure however…
De facto the number of radios is trivially enforceable on D-regs (via the IFR certificate system) and virtually unenforceable on anything else.
You would need to train a whole new class of ramp inspectors for that. It is in the same category as the EASA FCL attack on N-regs, based on the residence of the operator 
You would need to train a whole new class of ramp inspectors for that. It is in the same category as the EASA FCL attack on N-regs, based on the residence of the operator
But then again you have the Flight Plan 2012 equip list….I wonder if this could be a means for accepting or not the Fl Plan..?
8.33 (“Y”) is already used as an acceptance criterion by Eurocontrol – has been since ~ Dec 2012 I think.
However, as the regs are currently written, it is up to each country to decide how many 8.33 radios are required, and there isn’t any present Eurocontrol coding for that (e.g. Y1 or Y2) which could be used to throw the FP out if crossing Germany with Y1.
Also it would affect light GA only as all the heavy stuff will be at least 2 × 8.33 (I guess?) so I wonder if Eurocontrol would go to the huge trouble of implementing say Y1/Y2, forcing all the airlines etc to file Y2, just to force compliance on behalf of the small number (one?) of airspace owners who demand two. There is almost no light GA flying Eurocontrol IFR in Europe, as a % of traffic.
The FP 2012 PBN stuff comes from ICAO so Eurocontrol had to do something with it… Even America had to implement it, though as usual I doubt they force it on domestic GA.
Practically speaking, nothing would prevent you filing Y2 if you had only one radio. Same as nothing prevents you filing PBN/D2 (PRNAV) if you are non-PRNAV – there is no central database of PRNAV approved airframes especially one which ATC would have real time access to, and to do the job properly they would also need to have a database of PRNAV approved pilots, and then what would you do on a multi pilot aircraft when the flight plan format supports just one pilot name? Or an airline could have two pilots both called Smith, one having attended the PRNAV course and the other not. This stuff is too bizzare to even think about
Just as a side note a few days ago I actually got assigned two 8.33 frequencies in different sectors of Munich radar. I did fly about the same route a few weeks before and they must have changed their frequencies in between.
How high were you?
I want to know too..
We cruised at FL200. So theoretically above FL195 where 8.33 is already required for quite some time. But until that day I never got assigned a 8.33 frequency cruisng all over Europe, so Munich radar must have reorganized their sector frequencies. On the flight southbound EDAZ to LSZS we got in one sector 122.680 and on the return flight Munich radar used in another sector 131.055
Germany, Ireland, France, Italy, Luxembourg, Hungary, Nethelrand, Austria and the United Kingdom, all have to change 25% of their frequencies to 8,33 kHz before the end of this year.
I get them all the time in the 20s and I think you should assume they will be used more and more at lower altitudes now you are required to have one. Not saying I agree with it but it will happen.
Me too. I usually cruise at FL200.
