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Probably the UK’s biggest avionics shop is telling people two 8.33 radios are mandatory which is simply wrong but with this sort of thing happening there is very little chance anybody is going to look at the actual EASA rules too closely…

Administrator
Shoreham EGKA, United Kingdom

Peter wrote:

Probably the UK’s biggest avionics shop is telling people two 8.33 radios are mandatory which is simply wrong but with this sort of thing happening there is very little chance anybody is going to look at the actual EASA rules too closely…

I don’t think this is the main issue, the main issue, is can you have a mix of one 8,33 kHz radio and one 25 kHz. When you have for example a dual KX-155 installation, and go for one GNC-255A, you could according Dutch CAA either remove the second radio, and thus also loose your second NAV, or install a second GNC-255A for example. It just doesn’t make sense.

So you have basically 3,5 choices:

- Remove COM/NAV2 where second radio is 25 kHz
- Replace COM/NAV2 by 8,33 kHz COM or COM/NAV
- Don’t change anything and risk it, and see what happens when you get a ramp check, with the possibility to fight there finding for court.
- Remove PTT wire from COM/NAV2, such that COM2 would become RX only. A gray area, though at least you would be able to keep a well function NAV2.

JP-Avionics
EHMZ

Jesse wrote:

So you have basically 3,5 choices:

- Remove COM/NAV2 where second radio is 25 kHz
- Replace COM/NAV2 by 8,33 kHz COM or COM/NAV
- Don’t change anything and risk it, and see what happens when you get a ramp check, with the possibility to fight there finding for court.
- Remove PTT wire from COM/NAV2, such that COM2 would become RX only. A gray area, though at least you would be able to keep a well function NAV2.

I would be inclined to run with this option. If they aren’t mandating two radios then why should they care what the second one has.

EGTK Oxford

JasonC wrote:

I would be inclined to run with this option. If they aren’t mandating two radios then why should they care what the second one has.

They argue you may cause interference using this radio using incorrect frequency / channel. I think this doesn’t make sense, as you would need to do this deliberately by tuning using 118.00 instead of 118.005 for example. As the 8,33 kHz is required to do both 25 and 8,33 kHz you can set both 118.000 and 118.005, so if you use this setting you might cause interfence by deliberately or accidentely tune in the wrong frequency.

For aircraft with one 8,33 kHz I don’t see why one should tune the wrong frequency / channel deliberately – I do know this happens on aircraft without 8,33 kHz radio, where for example 118.00 is tuned instead of the 118.005 as 8,33 kHz is unavailble.

Then you can make a mistake by accident, however I don’t see how this would be different between and 8,33/25 kHz radio and 25 kHz radio.

JP-Avionics
EHMZ

Jesse wrote:

Unfortunatly, yes this is their position, either one 8,33 kHz or two 8,33 kHz, no 8,33 kHz and 25 kHz mix.

I wonder what they would do if I (hypothetically) showed a letter from the state of registry saying that carrying the additional 25 kHz radio is acceptable?

ESKC (Uppsala/Sundbro), Sweden

Jesse wrote:

I still can not get my head around this

Well, I have trouble getting my head around them trying to pull this nonsense on a foreign registered aircraft. It’s one thing trying to do it to their own but this is a whole new level. At least to me. And I agree with what you wrote.

In my aircraft you could remove/replace the 25 khz com 2 box whilst in flight by leaving the Allen Key permanently installed and unlocking it as required. You would have to enter a fairly steep right bank whilst sliding the radio out to clear the control column. Would this practice be acceptable to the Dutch, say on the turn to final if right hand circuit? Or would the discarded radio, lobbed over one’s shoulder onto the back seat, still count as ‘carriage of 25 khz radio’ for their ramp check purposes?

EGBW / KPRC, United Kingdom

Airborne_Again wrote:

I wonder what they would do if I (hypothetically) showed a letter from the state of registry saying that carrying the additional 25 kHz radio is acceptable?

I once had this issue, when an GTN minor change approval was refused as the second radio was KX-155. I asked the state of registery, who did reply with the question “What are these guys smoking?” Approval was issued afterwards.

Aveling wrote:

In my aircraft you could remove/replace the 25 khz com 2 box whilst in flight by leaving the Allen Key permanently installed and unlocking it as required.

I wouldn’t leave the allen key inserted all the time, it makes operation more difficult, can fall out, and with some radio’s there is a risk of shorting. When you have such key I would leavy it in the aircraft. If they are difficult on ramp check you could always remove it.

From the logic point of view, I would try to convince them why you don’t remove it:

  • It removes the second NAV, so you no longer have a redundant NAV system, which decreases safety level.
  • It removes your second COM, which you can always use on 121.500 MHz (remember, this frequency will always stay in 25 kHz) Removing communication equipment decreases safety level.
  • The error for selecting the wrong frequency is also applicable to 8,33 kHz radio’s, as they are mandatory to have 8,33 kHz AND 25 kHz modes. This argument is nonsense.
  • Your first radio is 8,33 kHz so you meet the mandate to be able to operate on 8,33 kHz radio. There is no generic requirement for dual radio’s.

For this last point, it is important to note that some approvals require two radio’s for IFR use.

JP-Avionics
EHMZ

On a ramp check I would tell them it is a GPS. Very few ramp checks actually check the operating mode of specific avionics.

EGTK Oxford

Could you carry an “inoperative” sticker and place it on it when landing I the Netherlands?

EIWT Weston, Ireland
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