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In Europe, FM immunity is applicable also to VHF communications.
EU-OPS 1.865(f): "An operator shall ensure that VHF communication equipment, ILS Localiser and VOR receivers installed on aeroplanes to be operated in IFR are of a type that has been approved as complying with the FM immunity performance standards."
And for further info refer to former JAA ACJ OPS 1.865(e):
"FM Immunity Equipment Standards
See JAR-OPS 1.865(e)
1 FM immunity performance Standards for ILS Localiser, VOR receivers and VHF communication receivers have been incorporated in ICAO Annex 10, Volume I - Radio Navigation Aids Fifth Edition dated July 1996, Chapter 3, Paragraphs 3.1.4, 3.3.8 and Volume III, Part II - Voice Communications Systems, Paragraph 2.3.3.
2 Acceptable equipment standards, consistent with ICAO Annex 10, are contained in EUROCAE Minimum Operational Performance Specifications, documents ED-22B for VOR receivers, ED-23B for VHF communication receivers and ED-46B for LOC receivers and the corresponding RTCA documents DO-186, DO-195 and DO-196."
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