FAQ – frequently asked questions

8.33 kHz – “Samionics” told me that my old radio will most likely work just fine on most channels, so why replace the COM at all?

Your old radio will work just fine or at least seem to work just fine,  but there is a major difference.

  1. Frequency accuracy, older radios had a tolerance of +/- 0.003% which means +/- 4.11kHz, new radios have a tolerance of 0.0005 % equivalent of +/- 0.68 kHz.
  2. Bandwidth, AM (amplitude modulation) – there should be no change in bandwidth. True BUT,  newer radios limit the audio frequeny bandwidth. So even if you are “female” your voice will sound darker.
  3. The receiver of your old radio is designed for 25kHz channel separation, ie the filters inside the radio are not good enough.  

8.33 kHz requirement for all IFR flights 2018
“1st of January 2018 (04/01/2018 AIRAC date), the Network Manager Integrated Flight Planning System (IFPS) will reject automatically all the flight plans for non 8.33 kHz radio equipped flights operated as General Air Traffic (GAT) under Instrumental Flight Rules (IFR)”
For more information see AIC A 10/17

The requirement for 8.33kHz starts 1 Jan 2018 but please note that the implementation will be spread over the whole year of 2018.
Many channels are transferred from the old 25kHz channel spacing system to the new 8.33kHz system in such way that the actual operation frequency remains the same.

Preliminary frequency allocation table may be found in AIC A 01-18

For example, Eskilstuna ESSU airport has today 126.850 MHz (25kHz) and on the 1st february 2018 the frequency will be changed to 126.855 MHz (8.33kHz). In this case the actual transmitting and receiving frequency will be exactly the same,  basically you could talk to ATC using your old COM set on 126.850 MHz and not notice any difference.  Please understand that an old COM like KX170B/175B Series has a very wide receiver covering several 8.33kHz channels! Have your radio replaced asap, meanwhile – this could be an emergency solution however not encouraged by us.

Example 8.33kHz / 25kHz frequency allocation table provided by Eurocontrol 

Suomi / Finland – 10 Year extension of 8.33kHz channel spacing requirement!?
Good news? Perhaps? But after an additional 10 years some avionics will be 50 years old, is this ok?

EASA CS-STAN procedures now also acceptable for Swedish Annex II aircraft!
Swedish registered Annex II aircraft will in many cases no longer need a national minor change approval. Instead CAA Sweden will accept EASA CS-STAN procedures. Futher details, validity and possible limitations – refer to CAA Sweden MFL AIR 2017-3. Link

Do I have to remove my old 25kHz COM from the aircraft?

No you dont – the unit and the installation will remain approved, however you may not use the old COM radio after 31 December 2017 on other than 25kHz channels such as the emergency frequency 121.50MHz or other 25kHz channels that remain in use such as Swedish air club channels, see AIC B 103-17

Do I need two (2 ea) 8.33kHz capable COM’s for IFR?

NCO.IDE.A.190 Radio communication equipment.
(c) When more than one communication equipment unit is required, each shall be independent of the other or others to the extent that a failure in any one will not result in failure of any other.

The regulation does not say how many COM units you need and may vary between countries.

Do I always need a 8.33kHz capable COM radio in Sweden?
It depends on what and were you fly. Certain club frequencies are exempt from the 8.33kHz mandate.

Refer to Swedish AIC B 103-17 Link

Do I need a TSO/ETSO COM radio or is it ok with a cheaper non-TSO like the Icom IC-220A

For all EASA aircraft you will need equippment that is approved and found to be in compliance with the appropriate Technical Standard Order (TSO/ETSO)

Annex II aircraft will also required TSO/ETSO. Refer to Swedish TSFS 2012:89

Experimental aircraft – there is no TSO/ETSO requirement but Swedish requlation TSFS 2012:89  Chapter 3 – Installation in aicraft, “all COM equippment used inside the allocated frequency space intended for aircraft operations must be approved by EASA Part-21”, ie TSO/ETSO. This might seem unclear due to the fact that many already have non-TSO equippment installed. Before EASA, non-TSO COM radio may have been approved by the national CAA. For a list of all approved equippment refer to CAA Sweden publication “TU – Typgodkänd utrustning”. Link

What (navigation) equipment do I need for IFR?

Aeroplanes shall have sufficient navigation equipment to ensure that, in the event of the failure of one item of equipment at any stage of the flight, the remaining equipment shall allow safe navigation in accordance with the ATS flight plan and/or the applicable airspace requirements, or an appropriate contingency action, to be completed safely.

Swedish AIP GEN 1.5 revised 17 August 2017

For Swedish requirements refer to AIP GEN 1.5 Aircraft instruments, equipment and flight documents.
This means that its up to the pilot to determine if the aircraft has the necessary equipment for the intended flight.

FM Immunity requirement for NAV VOR/LOC receivers

The requirement for FM immunity compliant VOR/LOC receivers dates back to the mid 90’s. Some older VOR/LOC receivers may not be used for IFR navigation and should be labeled accordingly. For example, Bendix/King KX155 Series with mod status 16 implemented are FM immunity approved hence fully IFR compliant. KX155 units lacking mod 16 are “VFR only”. See also LFS 2007:27 (ICAO Annex 10) Link

Do I need a Mode-S transponder?

The Mode-S mandate IFR was initially 7 December 2017 but has been delayed to 7 June 2020 for GA IFR.
However, some countries already require that a Mode-S transponder is installed.
Regulation (EU) No 1207/2011 ammended 2017/386 Link

Do I need an ELT, and if YES is a PLB enough?

Firstly – an ELT and PLB is two different things although they essentially “do the same”. If we look at private non commersial Part-NCO.IDE.170 – we could easily get confused with dates and terms like “any type”,  “ELT” and “PLB” so here is the straight and simple answer. Yes all aircraft will need an emergency locator transmitter of either the type ELT or PLB (personal location beacon). “Please explain NCO.IDE.A.170 par 1, 2 and 3.”
Par 1. If the certificate of airworthiness is issued before 1st July 2008 the airplane may be equipped with an ELT capable of transmitting on 121.5/406MHz either automatic/manual activation.
Par 2. Same as par 1 but it must have automatic activation “G”-switch.
Par 3. In Uk there was no need for ELT or PLB  – so we belive someone came up with the great idea, ok a PLB is good enough for aircraft with a passenger seating of 6 or less. Note! 6 passengers and 1 pilot total 7 seats.

In Sweden all ELT requirements were stated in LFS 2007:30 and later on cancelled for EASA aircraft by TSFS 2016:67.

You can no longer install a  121.5MHz ELT it must be 121.5/406MHz, this particular requirement was introduced by:

ICAO Annex 10, Volume V, Chapter 2, Frequencies for emergency locator transmitters (ELTs) for search and rescue
2.1.2 All emergency locator transmitters installed on or after 1 January 2002 and carried in compliance with Standards of Annex 6, Parts I, II and III shall operate on both 406 MHz and 121.5 MHz
2.1.3 From 1 January 2005, emergency locator transmitters carried in compliance with Standards of Annex 6, Parts I, II and III shall operate on both 406 MHz and 121.5 MHz

ELT plastic fantastic, arent they supposed to be made out of steel?

Kannad is a great ELT and recommended by us, but their welcro stap locking mechanism is not UV resistant (if mounted in such way that it is exposed to sun light – replace the velcro each 2-3 years) and the DIN connector at the ELT is a nice idea but can not take thicker than awg 24 wire.

Artex had earlier also a velcro strap but is now replaced for a steel snap lock mechanism! Still the Artex requires that the remote switch has a wire to the hot bus (wire to the aircraft battery) that can sometimes make the installation more complicated.

Ameri King has lost their approval. ACK E-04 Avionics, we tried to install 2 ea different ACK ELT’s in 2 ea different aircraft without success. We did a bench test and found that ACK did not meet TSO requirements and we have submitted an occurence report to both EASA and FAA. Note: 2 ea units tested with close serial numbers – may be a batch fault.

ELT – Antenna separation / Distance between ELT and COM antennas

Clip from EASA Certification memoriandum (EASA CM No.: CM-AS-008 Issue 01)
“Ideally, for the 121.5 MHz ELT antenna, 2.5 meters is a sufficient separation from VHF communications and navigation receiving antennas to minimize unwanted interference.”
This means that ELT installations in many GA aircraft will be impossible… (Artex and Kannad ELT’s seem work with shorter antenna separation.) Note – that antenna separation is nothing new, the distance between COM antennas in Cessna and Piper aircraft are worst case 2ft and have worked just fine.  And the answer – someone made a misstake when developing RTCA DO-204 and the fix is not to change the certification requirement but “to clarify” antenna separation. Else most if not all GA aircraft would be un-airworthy. Those aircraft with Kannad or Artex ELT’s will do just fine while other low cost brands simply wont work.