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funfly
23rd Jul 2014, 11:24
When I had my aircraft about 7 years ago there was a lot of talk about us having to install Mode S and, as I remember, it had to be done then and there on all aircraft including gliders and microlights.

I don't fly now so it's only of academic interest, but would someone be so kind as to update me about what has happened to the Mode S requirement, is it now mandatory?

ChickenHouse
23rd Jul 2014, 12:14
That is quite easy to answer.

for us private flyers there is no requirement to be equipped with a XPDR
if you fly only in airspaces with no XPDR mandatory label, everything is fine and if you switch on your venerable Mode A/C, everybody is happy
if you fly into airspaces with mandatory XPDR, such as class C, D or the more and more upcoming TMZ, then the requirement "mandatory transponder" now equals "mandatory Mode-S transponder". If you go there without Mode-S, you need to get a special clearance to enter airspace without transponder
the last date for Mode A/C was in Spring 2008 and thereafter "to be a transponder" under EU regulations, it has to be Mode-S

robin
24th Jul 2014, 14:35
That's my understanding. Any new fit or replacement will mean a Mode S

What I am still unclear about is that there was an exemption for TMZs if you had a Mode C. Sounds like the CAA either let it lapse or forgot to continue the exemption

Pirke
24th Jul 2014, 15:00
From memory: in The Netherlands above 1200 feet: Mode-S required.

Rod1
24th Jul 2014, 15:54
No manaton to fit mode s in UK for vfr. No mandation to fit a transponder in New aircraft but if you do it has to be mode s.


Rod1

Fitter2
24th Jul 2014, 17:17
From memory: in The Netherlands above 1200 feet: Mode-S required.


True. And if you are a glider you have to switch it off.

UV
27th Jul 2014, 01:38
What I am still unclear about is that there was an exemption for TMZs if you had a Mode C. Sounds like the CAA either let it lapse or forgot to continue the exemption
That exemption ran out in, I think, 2012, so there was no need for the CAA to renew it. They didnt forget anything!

ChickenHouse
28th Jul 2014, 13:54
Any new fit or replacement will mean a Mode S

Correct, and strongly to remember for everybody in the EU: the possibility for 1:1 replacement of old and/or defective avionics expired last year in November.

So, if something breaks, such as an old Mode-C/A XPDR, you are no longer allowed to stick in another old Mode-C/A, you have to comply with new rules = if your Mode-C breaks, you have to put in Mode-S, same is true for COM: if your venerable COM breaks, you have to put in 833 COM. Many are not aware of that.

Rod1
28th Jul 2014, 15:34
"with new rules = if your Mode-C breaks, you have to put in Mode-S,"

Not quite true - many are, unfortunately, fitting a blanking plate to replace faulty a/c transponders.

Rod1

A and C
28th Jul 2014, 19:45
You can fit a radio or transponder of the same part number if one becomes unserviceable.

You can't fit another type of mode A / C or 760 radio.

ChickenHouse
29th Jul 2014, 15:17
You can fit a radio or transponder of the same part number if one becomes unserviceable.

You can't fit another type of mode A / C or 760 radio.

No longer true, this possibility was discussed quite lengthy when EU-1079/2012 got valid and denied by the authorities. Starting November 17th 2013 every radio to come into service has to be 833 and every XPDR put in service has to be Mode-S. There are some windy avionics shops telling you another, but we had already two plane immediately grounded at ramp check due to that.

A and C
29th Jul 2014, 17:56
This is an interpretation of the new regulations that is quite frankly stupid and overly restrictive............. What you are telling me is that if an aircraft with a 760 channel radio has a problem with that radio away from base it can't be fitted with another 760 radio of the same part number to let it fly back to base....... In effect grounding the aircraft.

I can only think the people pushing this interpretation of the new regulations have lost all reason or are in the business of selling 8.33 & mode S equipment.

This is not the interpretation the UK CAA put on the regulations, in the UK replacement of one radio with another of the same part number is not considered a change of equipment......... Just a unit change.

With this sort of nonsense from Europe you can see why the Brits want out of the EU.

ChickenHouse
29th Jul 2014, 19:12
I am all with you - it is stupid, but what do you expect from administration people without any knowledge of aviation? Maybe CAA is still more friendly to owners, but they have no chance to stay that way. We already have airspaces now, where you cannot fly without Mode-S and/or 833 - special clearance is not always granted and even these occasions will fade away.

stevelup
29th Jul 2014, 19:36
No longer true, this possibility was discussed quite lengthy when EU-1079/2012 got valid and denied by the authorities. Starting November 17th 2013 every radio to come into service has to be 833 and every XPDR put in service has to be Mode-S. There are some windy avionics shops telling you another, but we had already two plane immediately grounded at ramp check due to that.

Who ramp checked you and where?

Exactly which legislation did they use to ground your aircraft?

A and C
29th Jul 2014, 20:31
My guess is that this is all a result of those doing the ramp checks not understanding the true meaning of the EASA English and implementing the rules in a draconian way due to their misunderstanding.

This is part of the reason that large numbers of German Cessna's are being re-registered in the UK.

A and C
31st Jul 2014, 06:44
This whole issue revolves around the issue of what bringing into service actually means.

To most of the world bringing a radio system into service means fitting a new system, so that means a new rack, radio and all the things you require to make a radio system work.

Just taking a radio box out of an aircraft and refitting another box of the same part number IS NOT bringing a new radio system into service, it is carrying out maintenance on the radio system fitted to the aircraft and I see nothing to stop this practice under EU regulation until 2018 when the change over period has ended.

ChickenHouse
31st Jul 2014, 06:59
Many true things. Not very surprisingly, the most problems arise at countries not native english speaking. Just have a look at the Cessna SID discussion: FAA and CAA have a natural understanding what Cessna did: they wrote up a workshop manual with what-to-do for what-if you find hints for corrosion. Some countries authorities, such as the most stupid one - the German LBA - interpret the what-to-do without the what-if. Cessna made it wrong for them not to tell explicitly WHEN you have to do the things. What if you treat the workshop manual of a car like this? You would rip apart axles and engine every 50.000 miles to have a look at it?

"Bring into service" IS different in different countries. Some countries have separate radio certificates for the plane and they do list the serial number of the device - for them a change to a similar box with another S/N requires you to get a new radio certificate from the authorities, while other countries only list the radio on type. Some even don't have separate radio certificates. (Or look at radio operators licenses - converting US PPL IR as a German citizen to part-FCL you get an AZF radio operators certificates for free, because German authorities require you to have one - but FAA don't issue any).

Just yesterday an outrages friend called me - he was ramp checked and the radio certificate showed the wrong serial number of his KT76A. He got fined for it and now he has to document when and who fitted the replacement into the machine. Unfortunately this is not in the papers, so he has given a hard time and most probably now has to switch to a new Mode-S.

So far for the Brave New EASA world.

A and C
31st Jul 2014, 09:26
It is common to have spare parts on the shelf and to remove an unserviceable radio and replace it with a serviceable item takes 10 min, you do the tech log entry and that is the end of it, the change is then put into the aircraft technical records ( airframe log book) ....... That is the end of it.

The airline world would grind to a halt if the authorities had to produce a new radio certificate for each box change.

Any how I hope the inspector removing the box for inspection of the S/N had a B2 licence to re fit the item and the appropriate test equipment.

I the face of this utter stupidity it would seem the answer is to move the aircraft to the UK register...........

What EASA state are we talking about ?

ChickenHouse
31st Jul 2014, 12:57
To have serviceable parts on the shelf is a must for some parts, especially since ROHS is in place and some spare parts are no longer allowed to cross EU borders ... Radio certificates on the basis of S/N are i.e. common in Germany and Czech.

A and C
31st Jul 2014, 18:27
If it is the case that radio certificates are S/N specific how do airlines is Germany change radio system LRU's ?

I can't see Lufthansa having an A320 sitting about on the ground at an airport at the other end of Europe while the German aviation authority's send a new radio certificate by UPS or FEdex !

From what I can see these "radio certificates " are not an EASA requirement and the guy who is having trouble with the German Authority's should file a non compliance report to EASA.

ChickenHouse
3rd Aug 2014, 09:34
The airliners have a central digital storage system for their certificates and yes, if they replace a radio, they are off for about 20 hours. Luckily they have a department special only for the issuance of the licences - and they are fast ... GA is facing one single person, sending a notification of receipt after 6 weeks with no estimated start date for working on whatever you submitted. File letters of complaint are useless, nobody will read it.

Capt Kremmen
3rd Aug 2014, 10:09
Another example of the Law of Unforeseen Consequences ?

A and C
4th Aug 2014, 11:26
What an utterly stupid situation......to ground an airliner for 20 hours or so just for a radio LRU change....... The lunatics are clearly in charge of tha asylum !

Just for clarity in the UK the paperwork requires for a radio LRU change is just the tech log entry ( the paperwork system will route the record of the change into the log books or the equivalent record system).

So in Germany a light aircraft can be grounded for six weeks ( 20 hours for an airliner) but in the UK the same radio LRU change would result in the aircraft released for service as soon has the B2 engineer as compleated the tech log entry ( about ten min at the most).

It would seem to me that removing the D from the side of your aircraft and replacing it with a G would be something that would save you a lot of time trouble and money.

ChickenHouse
4th Aug 2014, 12:02
It would seem to me that removing the D from the side of your aircraft and replacing it with a G would be something that would save you a lot of time trouble and money.

Yes, the street rumor tells about cutting 2/3 off annual costs ... the only advantage with a D-tail is on condition flying, where CAA is more restrictive.