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Latest on 8.33 requirements (merged)

Peter wrote:

Another thing is that, legally, you cannot avoid the radio for crossing borders. How can one cross a border non-radio?

You do? I didn’t know there was any requirement other than having a flight plan.

ESKC (Uppsala/Sundbro), Sweden

Timothy wrote:

Doesn’t that mean that, for the UK part of the trip at least, Callum only needs to check that the actual frequencies he needs to use have not changed yet?

The exemption article of the relevant EU regulation (1079/2012) states:

Article 14
Exemptions
1. In the framework of the first paragraph of Article 4 of Commission Regulation (EC) No 730/2006 (1), Member States may issue temporary derogations from airborne carriage obligations laid down in Article 5(1) of this Regulation for flights operated under visual flight rules.
2. Member States may take local measures granting exemptions from the compliance with Articles 4(5), 5(4) and 6(10) for cases having limited impact on the network.
3. Member States taking the local measures referred to in paragraph 2, shall provide the Commission with detailed information justifying the need for exemptions at the latest: one year before the dates identified in Articles 4(5), 5(4) and 6(10).
4. Within six months from receipt of detailed information from the Member States pursuant to paragraph 3 and after consultation with the Network Manager, the Commission may review any exemption granted pursuant to paragraph 2 if the impact on the network is not limited

Article 5(4) is the one with the requirement for carrying 8.33 radios from January 1, 2018.

So you’re right that a state may take “local measures granting exemptions”. To me, that doesn’t sound you could give a blanket exemption for VFR, but maybe I’m overinterpreting.

ESKC (Uppsala/Sundbro), Sweden

In my last post I may not have been totally accurate bit it is the information that is sort of feeding down to the average club piloot. But following the posts here I thought I should do some further research.
UE no 1079/20121 basically says that all aircraft should be equipped 8.33 by 31st December 2017.
It allowed for national derogations. In France 8.33 had been mandatory for all flights in airspace above Fl 245 since 1999.
As for the remaining airspace,according to information set out to RSA members "to take account of constraints in conforming with the new rules France has sought a derogation. This derogation delays the need for aircraft flying vfr in class C and D airspace to carry 8.33 radios for 8 months ie until September 1st 2018. In class E and G the delay will be until 1st January 2021. The number of radios depends on operational rules. Many pilots of aircraft with old or no radios are equipping with hand held radios, 8.33 capable.
The information goes on to say that frequencies, notably around aerodromes in A, C, D airspace and above Fl 115 will be progressively converted between 1st September 2018 and 30th June 2019.
The frequencies in classes E and G airspace will be converted progressively between 1st January 2021 and 31st December 2021.

NOW FOR THE GREAT GALLIC FUDGE
The CNFAS (The National Council of aeronautique and sporting federations) has also been challenging the 8,33 timetable based on the fact that the EU was supposed to come up with subsidies to help aircraft owners with the cost of converting. In the event only UK owners have received the subsidy and it is unlikely
that others will. They are in discussions with the DGAC/DSNA and whilst the RSA information is indeed accurate the DGAC are going to maintain controlled aerodromes and SIV (flight information services) in 25khz for state aircraft until 2021.
The CNFAS has pointed out that ot is difficult to conceive, therefore, that civil aircraft not yet equipped with 8.33 could possibly be penalised as a matter of security.
Whilst discussions continue the DGAC state that all changes will be notified by AIP, AIC or NOTAM.
Apologies for the verbosity

France

Peter wrote:

How can one cross a border non-radio?

Um…“Power, Attitude Trim”, or “Aviate, Navigate, Communicate”?

I have been doing it my whole flying career with no pushback.

EGKB Biggin Hill

Sure one can “do it”.

And, as the old saying goes, much depends on whether you have to land there I know of flights which were done wholly “under the radar” (in practice prob99 not under any radar but, in peacetime, in mainland Europe, nobody cares most of the time about some non-TXP contact especially if you don’t bust anything) right across France, Spain, and further, etc…

But the legal situation is not all that clear. While it appears clear that the universally taught (in the UK at least) procedure of calling up FIS (London Info) when crossing the border is not a requirement, in most cases you are supposed to make a radio contact.

I reckon this flight is possible if you check out some enroute and aerodrome frequencies, but it would still be a good idea to not p1ss off somebody important The aeroclub traffic within Spain and France can do it but they are flying locally, probably often non-radio, or I reckon they have 8.33.

Administrator
Shoreham EGKA, United Kingdom

Thank you all for the useful information. The Aircraft may be refitted with 8.33 before the trip but it is unlikely. I’m going to make sure all of the aerodromes I will use are going to be contactable and i’ll do the same with the Radar or FIS that I will use.

None the less it should be good fun.

Callum

Last Edited by Callum at 13 Aug 14:02
London Area

My most recent flight over the water was last weekend from Deauville.

The conversation went:
Deauville: Call me leaving the TMA
Wilco
Leaving the TMA
Deauville: Paris Info is available on…
Roger

Biggin Approach, this is….

This is the norm.

EGKB Biggin Hill

I do the same (EGKA <- → LFAT) but we both happen to meet the regs by doing that. The regs don’t stipulate the maximum time between coming off one frequency and coming onto the next, when crossing the border

Would you do it between a French farm strip and a UK farm strip, all non-radio?

Administrator
Shoreham EGKA, United Kingdom
Would you do it between a French farm strip and a UK farm strip, all non-radio?

Yes.

EGKB Biggin Hill

flyerted wrote:

The transmission is ok but the reception is poor.

On the off-chance that you mean volume and not reception are you aware of this Service Bulletin [ local copy ]

Nympsfield, United Kingdom
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