Only one 8.33 required?
I just screened this thread to see if there appears to be a definite answer to the one-or-two-8.33’s question. It seems there isn’t.
Recently I stumbled across a paper from Eurocontrol called “Avionics requirements for Civil Aircraft”. (I printed it and lost the url, but it is likely googlable)
It reads: Equipment requirement: VHF COM 8.33. The probability of the loss of voice communication is better than or equal to remote. – Depending of the size of the aircraft and the kind of operation, this could mean that only one set of 8.33 kHz COM is required.
There is no mention of airspace or altitude. If the requirement only depends on a/c size and type of operation, then it is hard to imagine an interpretation requiring more than one set for small (how small? less than 5.700 kg perhaps?) aircraft flying private or corporate operations.
I just screened this thread to see if there appears to a definite answer to the one or two 8.33’s question. It seems there isn’t?
I think you have that exactly right 
Last I heard, it was down to the aircraft reg authority to decide whether one or two were required. Plus “creative interpretations” by some avionics shops, with a well known German one wanting two, at some stage, to issue the IFR certificate.
But then what do you do about N-regs? The FAA doesn’t require 8.33 at all. Maybe then it is down to the residence of the pilot (whatever that means). I know precisely only one person who knows the latest on this and he posts here very very rarely.
In practice you do need 8.33 now if flying IFR in CAS in Europe – I know because I got one in NL earlier this year, FL150 or so. For VFR OCAS it may be years before you get caught out by ATC issuing you one, but it’s going to be like Mode S in that you “can” go without but in practice you can’t really go anywhere properly.
The EASA PDF you refer to is here – found by a google for a fairly unusual word sequence between quotation marks – always a great technique for finding sources to documents when somebody posts the text but not the reference
But then what do you do about N-regs? The FAA doesn’t require 8.33 at all.
European 8.33kHz is an airspace requirement in certain countries so it applies to N-reg as much as to any other reg. As to whether you need one or two can be a registration country requirement. There was a phase of uncertainty in Germany (which requires 2 COMs for IFR) but it was resolved by the regulator saying that one is enough (for now).
I appreciate the discussion about 1 vs 2 devices, but think that we as pilots have a tendency to search for situations where we might be “busted” for not being in line with regulations, unlikely as they might be.
In the case of 8.33, the most important thing is the ability to select any frequency that we are given. As long as we can do that, the chances of being ramp-checked and cited for non-compliance of the 8.33 reg is very very small. ATC won’t know or care. We all sometimes need to weigh the benefit vs the risk, knowing that some poor guy, one of us, might fall into that 0.01% that get cited. Even then, we will have the opportunity to fight it and bring the wrath of the GA community against the relevant authority. This latter has also worked on occasion in Germany.
I think this is an easy one compared to the language proficiency entry on licences and aerodrome language classification and requirements from country to country.
Well the paper I quoted from (#81) is rather new, from February 2015, and from Eurocontrol, not EASA. It is of course not authoritative, having many cover-my-ass wordings on its front page, but it is still the only official paper I have seen that specifically gives some weight to the view that only one 8.33-thing is necessary for little GA-planes generally. That, and because it is new, made it somewhat interesting in my eyes.
Apologies for being too clumsy/lazy to supply a Link in the first place.
Interpretation by the Dutch authorities is that if your aircraft or type of operation (IFR!) requires two radios, and you operate in airspace that requires 8.33, both radios need to be 8.33.
Conversely, if you do not operate in a way that legally requires you to have two radios (VFR), but you happen to have two for convenience, to operate in 8.33 only requires one 8.33 radio.
Makes sense, really, AFAIC.
Oh, and by the way, there’s a story on the Dutch VFR Pilots Facebook page that a pilot was fined 1750 euros (yes, you read that correctly) for forgetting to include the “Y” in his equipment list on a flight from EHEH. His aircraft was based there, had all the required 8.33 kit and he used the proper frequencies and all that. All he forgot was to include that single letter in his FPL. It’s going to be interesting to see how this plays out, but for now, make sure your flightplans include the proper equipment list. S/S does not imply 8.33 capability!
Makes sense, really, AFAIC.
Sure, but isn’t it amazing how after the “Mode S wars” (which were worth at most 3k to any aircraft owner i.e. prob90 less than the excess billing on his next Annual 
) “we” are so apparently accepting of this purely politically motivated and not technologically necessary mandate (yes, I know you could say the same for Mode S, for all lower airspace traffic) which will skim the said owner of 3k per radio… Maybe GA just got tired out on the Mode S stuff and the people who were determined to argue it have left GA? 8.33 is a very expensive mod for many people. It cost me about €3k to change just one KX155A for a KX165A.
there’s a story on the Dutch VFR Pilots Facebook page that a pilot was fined 1750 euros (yes, you read that correctly) for forgetting to include the “Y” in his equipment list on a flight from EHEH. His aircraft was based there, had all the required 8.33 kit and he used the proper frequencies and all that. All he forgot was to include that single letter in his FPL. It’s going to be interesting to see how this plays out, but for now, make sure your flightplans include the proper equipment list. S/S does not imply 8.33 capability!
I think we should each contribute €10 to his defence fund. Which law did he break?
Where you directly involved? If so please contact me using PM, as this information is not consistant.
@Jesse: No. But my club initially only changed one of the two radios for an 8.33 one, on all our IFR-capable aircraft. They later had to go back and change the other one as well. I can only assume that this was not done on a whim, but some very knowledgeable people looked at that very carefully, and talked to all the right people at the authorities.
The information given to the club members was exactly as I said: It was necessary to comply with the Dutch’ authorities interpretation of the rules regarding IFR and 8.33.
If this was me, then before spending a few k I would demand it in writing from the CAA and with references to the current regulation.
One problem in GA is that half the people gold plate stuff, and a lot of them are pilots i.e. people who don’t profit from somebody else having to fit extra avionics.
