boscomantico wrote:
The regs, as usual, are poorly worded and don’t clarify how to deal with legacy 25KHz radios.
Which to me means they are immaterial. It’s still approved equipment, its usefulness will just diminish over time. But you have to spell everything out because it seems there will always be an NAA that doesn’t know what to do with its resources and conjures up mind boggling interpretations.
Howard wrote:
It’s a pity that the regulations are not clear about whether I need to have two 8.33Khz radios or whether I need to remove an old 25Khz one.
I think a consensus is that if you’re required to carry two radios (which Part-NCO operators aren’t), then they both need to be 8.33 kHz (i.e. a radio with 25 kHz spacing can’t be used to satisfy this requirement). There indeed is a thread about this where it was discussed in some detail. But some genius thought up that people can’t be trusted with legacy 25 kHz radios and they have to be removed. I don’t know what they’re smoking. That’s like demanding removal of legacy navigation equipment that can’t meet B-RNAV. On the other hand, I certainly wouldn’t mind getting rid of ADFs (mainly because some other geniuses think they’re a great choice for missed approach segments of GNSS IAPs).
You can always ask the authority of the state of registration. And do what they tell you if you don’t want to risk running into trouble/ arguing.
By the way, I don’t think 8.33 has anything to do with EASA. You won’t find it on their website and it’s not really something they’re responsible for.
Airborne_Again wrote:
There is no requirement in part-NCO for two radios.
There is indeed no reference. A big however, some STC which might require a second COM or COM/NAV. The Garmin GTN is a good example of this. When installed in accordance with the Garmin STC, for IFR flights you need to have a second navigation / communication source. So in these cases you can not simply remove the second radio, as you change the certification basis.
Airborne_Again wrote:
Also, where is the requirement for actually removing 25 kHz radios?
This is the difference in interpretation of the regulations. Part NCO refers for communication to Single European Sky regulations. EU 1079/2012 says on has to have 8,33 kHz capability. Which is according Dutch CAA / Ramp inspectors, that all radios must have this capability, and thus a mix is not allowed. IMHO, this wouldn’t be an issue till at least the end of 2017, and IMHO a mixed radio setup gives more redunancy then no 2nd radio at all. So removing equipment, without replacing just doesn’t make sense. Some even loose COM/NAV capability.
Sure enough, if budget is available, two 8,33 kHz will always be more suiteable then an 25 kHz and 8,33 kHz combo. I always recommend people to read the relevalent regulations and decide for themselfs.
Thanks everyone.
@Jesse do the Dutch-interpretted version of the regulations only apply to Dutch-registered planes or do the Dutch inspectors have some authority over foreign (e.g. G-reg) planes that fly into and land at Dutch airfields? (I presume they only have authority over Dutch-registered planes, but please confirm.)
Thanks to others here too. Like them I do find it immensely depressing that the regulations are opaque and poorly publicised in fine detail.
I think I’ll probably have another 8.33 radio installed before December 2017. My 25Khz-spaced radio is very old (26 years?) and the LEDs are fading. It’s probably not got many years left and so I might as well replace it now and be done with it. It’s a pity that the new Garmin units are a few millimetres taller than the old Bendix-King kit. Otherwise the kit looks good. I might go for a new slim Trig device instead.
Jesse wrote:
Which is according Dutch CAA / Ramp inspectors, that all radios must have this capability, and thus a mix is not allowed.
Well, the regulation clearly states that any radio intended to be used exclusively on channels with 25 kHz spacing doesn’t need 8.33 kHz spacing capability. 121.5 MHz is listed among the channels that will stay in 25 kHz spacing but that channel in fact uses 100 kHz spacing (I take it that it doesn’t matter and 121.5 is a good enough reason to keep a radio without 8.33 kHz spacing capability). And the regulation doesn’t affect 25 kHz spaced channels employing CLIMAX.
So it seems clear to me that a mix is possible. I’m curious, does their definition of all include radios used for ACARS/ VDL?
Howard wrote:
do the Dutch-interpretted version of the regulations only apply to Dutch-registered planes or do the Dutch inspectors have some authority over foreign (e.g. G-reg) planes that fly into and land at Dutch airfields? (I presume they only have authority over Dutch-registered planes, but please confirm.)
No basically they co do ramp checks on all aircraft, also from foreign registers, which they also do. In the past I have seen issues where foreign registered aircraft where in need of an ELT due to ramp inspection.
It is basically that different authorities read the same EU 1079/2012 regulation on a different way. There shouldn’t be any difference between countries while it clearly is.
The Dutch are not the only authorities who read it like that, though.
Martin wrote:
Well, the regulation clearly states that any radio intended to be used exclusively on channels with 25 kHz spacing doesn’t need 8.33 kHz spacing capability. 121.5 MHz is listed among the channels that will stay in 25 kHz spacing
Correct, and this is also the point I mentioned earlier. Used exclusively is the main culprit here. From discussions with some CAA’s it seems that the ones who are against a 8,33 kHz / 25 kHz combo, tend to say that these radio’s are developed as 720 of 760 channel radio, and thus are not designed to be used on 121.5 MHz exclusively. Sure enough, that is true. The real discussions is, is exclusively used, being design for exclusive use, or you as user using it exclusively for that purpose. Again IMHO one 8,33 kHz and a second on 121.500 MHz is a prefered over one 8,33 kHz only.
Other complaints I have heard are that one could select the wrong frequency / channel. I think this is a false argument. You can tune the wrong frequency / channel in two ways, either accidental or on purpose. The chance on accidental doesn’t change between 25 kHz / 8,33 kHz.
Selecting the wrong frequency on purpose, should be considered as bad practice or worse.
Jesse wrote:
Other complaints I have heard are that one could select the wrong frequency / channel. I think this is a false argument. You can tune the wrong frequency / channel in two ways, either accidental or on purpose. The change on accidental doesn’t change between 25 kHz / 8,33 kHz.
Yes, exactly! You can’t really tune a 25 kHz radio to the frequency of a 8.33 kHz channel by mistake — only on purpose.
Jesse wrote:
No basically they co do ramp checks on all aircraft, also from foreign registers, which they also do. In the past I have seen issues where foreign registered aircraft where in need of an ELT due to ramp inspection.
Who is “they” ?
I have discussed this [ramp checks] in depth with the French Police d’Air et Frontiéres ( PAF ), THE police authority when it comes to law enforcement on Airports and aviation in general, and they told me they have NO COMPETENCE to perform technical ramp checks on foreign registered aircraft.
The Dutch aviation police do not let little things like the state of registry get in their way.
Michael wrote:
Who is “they” ?
The Dutch inspectors from Howards question.
Michael wrote:
NO COMPETENCE
No competence, doesn’t mean no go, for some… This is yet another EASA task, so should be very similair between countries, for both EASA and non EASA aircraft. Apart from from 8,33 kHz and ELT issues I haven’t heard any complains. From what I have heard Italy and French can be a pain. I think these inspections are not performed by the police, but CAA.
You can find more here on EASA ramp check programme
Jesse wrote:
The real discussions is, is exclusively used, being design for exclusive use, or you as user using it exclusively for that purpose.
Exactly. I understand it from the point of the user. Since it’s a fairly new development, it’s not likely you’ll find an older radio that was designed to tune only the channels that will remain (there might be 121.5 only radios, but that’s about it I imagine; PS: putting aside ACARS/ VDL). And the channels using CLIMAX are hard to judge. UK has literally hundreds of them, those are outside the regulation and don’t have to switch, but some of them might. Frankly, even requiring a placard is in my view over the top. If a channel is using 8.33 spacing, you can’t select it on a radio with 25 kHz spacing. It’s obvious that you’re using a radio with 25 kHz spacing.
Jesse wrote:
Selecting the wrong frequency on purpose, should be considered as bad practice or worse.
If you actually cause interference, the worse should apply. As for bad practice, why exactly would people do it if they got to have a radio with 8.33 kHz spacing? Perhaps to listen to ATIS, no harm done, if you can tune it.
Again, I think they’re trying to twist the words to suit them so they can do what they want to do. If EU wanted the radios removed, the regulation would have said so. Action with such impact shouldn’t be implied or require reading between the lines.
