EASA proposal to stop N-reg

[IO540]

This is the NPA

http://www.easa.europa.eu/ws_prod/r/doc/NPA/NPA%202008-17b.pdf

and if you go to page 159 of the PDF you find stuff on "3rd country" licenses.

This time, there isn't the old style parking ban on N-reg planes. They are now attacking pilot licenses, apparently on the basis of citizenship.

There is a specific attack on ICAO (non JAA) PPL/IR holders who will have to sit some of the JAA ATPL exams. It is not clear how ICAO (non JAA) CPL/IR holders are affected if merely exercising private privileges.

This appears to be a cleverly conceived and hard hitting measure which will be just as "popular" as the previous ones which were based on say 90 days' parking.

Whatever law results from this, it is AFAIK due to be in place in 2012.

[Keygrip]

I wouldn't have thought that EASA had any say what-so-ever in who flies, or in what conditions, on an FAA licence at the controls of an N registered aircraft.

They may be able to get involved in the *residency* of an N registered aircraft - but licensing has (surely) got @#$% all to do with them.

[n5296s]

I must be missing something... where is the reference to citizenship?

It isn't clear, to me anyway, what all the stuff about "complete the skill test" and so on means... does it mean in the third country or does it mean in the "Member Country"? Presumably the former since otherwise it would mean that when a N-tail plane belonging to am American airline is flown into an EASA country, the pilot wuold have to stop off and do a skills test...? In which case surely it is just reflecting ICAO policy?

I don't understand item 5: "the period of acceptance of a licence shall not exceed one year". What does that mean?

n5296s

[Whopity]

Lets get this in context, it is related to non JAA licence holders flying aircraft that come under EASA jurisdiction i.e. EASA reg aircraft. Nothing to do with N reg!

Para 1 says that ICAO PPLs may be acceptable to the authority; exactly the same as it is at the moment.

Para 2 relates to commercial licences and the process of validating them to conduct commercial activity in EASA Reg aircraft. Again exactly the same procedure as the UK currently adopts.

[IO540]

where is the reference to citizenship?There isn't, but this is a proposal, not the final law. The real thing would have to define the requirements somehow - because they cannot stop a 'genuine foreigner' flying into Europe on his ICAO PPL/IR.

Typically, this kind of thing would be hung on citizenship, or taxpayer status.

The French already determine the eligibility of foreign license validation (for use in an F-reg) on this kind of stuff (I have some examples).

I don't understand item 5: "the period of acceptance of a licence shall not exceed one year". What does that mean?It probably means you have to do the checkride every year.

Lets get this in context, it is related to non JAA licence holders flying aircraft that come under EASA jurisdiction i.e. EASA reg aircraft. Nothing to do with N reg!Whopity, we would hope you are right but it doesn't actually say that. The only clue to "commercial activity" is the word "operator" and that one can be interpreted both ways.

If you have some other document which contains explanatory notes, or any other support for what you say, please post it here. I would be delighted if you were right, of course.

[S-Works]

Hmmmm. I did tell you this was coming last year and you told me I was wrong IO.

My understanding of where the proposal is heading is for N Reg ops to continue but if the pilot is based in Europe over a certain period along with the aircraft the pilot will have to be dual licensed. How this is achieved is going to be an interesting question. Simple validation the same as the US and a foreign instrument test for IR pilots is possible but I suspect unlikely so more likely to be a subset of exams and a flight test. I don't believe there will be any difference between CPL or PPL holders.

This basically means that visiting airline aircraft and crews will be unchanged but those based in Europe under a flag of convenience will have to be dual qualified giving EASA 'oversight'. I think there will be something similar come out of the woodwork on maintenance as well.

[mm_flynn]

The NPA does specifically comment on requirements to allow an EASA area resident Operator to exercise the IR privileges of a 3rd country PPL in an aircraft registered in the 3rd country. I.e. it is specifically framed at PPLs not at all licence holders. There is a lack of clarity of what happens to a CPL/ATPL holder who does not or can not validate there licence for commercial privileges in the EASA area.


In the non-AOC context, the word Operator is commonly used and would normally mean the pilot (as compared to the owner).

Keygrip,

EASA has no say on who can fly an ICAO compliant aircraft, registered in an ICAO country, on a licence issued by or validated by that country. However, EASA can definitely dictate what you as a European Citizen can and can not do. It is slightly more ambiguous what they can and can not do with regard to a resident alien exercising ICAO privileges conferred by a country outside the EASA region.

[S-Works]

EASA can also dictate what happens in European airspace. If you are based in Europe and want to fly through it you will need to meet whatever rules they set......

[mm_flynn]

Although they can only do this in an ICAO compliant way, which on this particular issue will not be achieved by rules around EASA's airspace. But can be achieved by rules imposed on people already signed up to European Rules being imposed on them ;) .

[S-Works]

I guess that will be the key way of doing it. But it is my understanding that they can also file airspace differences as well.

So visiting crews are exempt as they are only visiting and are ICAO compliant. For based crews they naturally want oversight.

[youngskywalker]

Fortunatly Europe is a tiny and pretty insignificant player in Aviation (despite what some on here believe), the Feds are the big players and ultimately it is them who set the rules and procedures worldwide, eventually everyone else follows. I suspect thats lots of changes are iminent but then it has always been this way, I started flying in 1992 and there were always dark clouds on the horizon. Nobody really knows what will happen and like IO540 says we have until 2012, 4 years is a long time in aviation!

[S-Works]

Fortunately Europe is a tiny and pretty insignificant player in Aviation (despite what some on here believe), the Feds are the big players and ultimately it is them who set the rules and procedures worldwide, eventually everyone else follows. I suspect thats lots of changes are iminent but then it has always been this way, I started flying in 1992 and there were always dark clouds on the horizon. Nobody really knows what will happen and like IO540 says we have until 2012, 4 years is a long time in aviation!

Please don't take this the wrong way but I think you (and others) are burying your head(s) in the sand. Your very comment about the FAA setting the rules is the sort of thing that causes the EASA rule makers to flex their muscles. EASA are determined to be the major player just as the European politicians are intent on building the stupid 'country' of Europe USE. They want oversight of everything that goes on in Europe (it keeps them in jobs) and they will keep on maneuvering until they get what they want.

European airspace my be a tiny bit of the world, but if you want to fly through it you have to follow the rules they set. If you are an N Reg operator based in Europe you have to fly through the airspace!

This is the way politics works. Take a look at the Irish referendum, rather than listening to the very people they represent they are looking at ways of voiding the vote.....

[youngskywalker]

Trouble is where do you draw the line? For years they have been changing rules and moving the goal posts. If EASA say we must all be graduates of the Empire Test Pilots School does that mean we should all just accept it, bend over and let them give us one? I'm not burying my head in the sand, I accept things will change, but in 4 years my bet is that somebody else will put the rules into a box, shake them up and come up with something else, just like it has always been...

Besides it's quite useful for people to bury heads in the sand, it gives me somewhere to park my bicycle.

[mm_flynn]

The key things to take away from this thread are


EASA have launched the next stage of the 'extend the European State' agenda.
People who read this particular forum are overwhelmingly EASA area residents so EASA's actions are directly relevant
European institutions have an established track record of creating their own special version (usually gilded) of things that work perfectly well elsewhere, even if this hurts European citizens and interests
It is clearly EASA's intent to bring private N-reg operation under their remit
Allowing 'the Feds to save us' won't happen. They don't care and even if they did, a lot of European officials would like to work one up the Feds.
NOW is the time to act - through comment and effectively organised engagement.

There has already been lobying to create this, but it is still only part way through the process. So, choose an organisation, get involved, make sure your voice is heard now when there is an opportunity to influence. In a few years the train will have left and we will get what we are going to get in 2012.

[IO540]

Couldn't agree more with mm-flynn.

As a general comment on bose-x's posts, unfortunately warnings about impending doom (in aviation) are two a penny. So nobody is entitled to claim credit for drawing attention to some hypothetical measure. In this game, there is always somebody trying to get you - pop along to the next NATS or Eurocontrol presentation and listen to the garbage about GPS not being acceptable for navigation. That boat left the port years ago but they still bang on about it. If they could, some of them would ban all GA (i.e. pilots with gold plated JAA IRs flying Cirrus SR22s) from Eurocontrol airspace. Of course they cannot (ICAO).

This EASA proposal is just another proposal. OK, it is nearer to reality than previous ones, but I am sure you all remember the bizzare UK DfT one, kicking out N-reg after 90 days' parking. That one had everybody's knickers in the twist, with some N-reg owners going back to G-reg purely because they were scared! How daft, when they had nothing to lose by waiting, and taking action only when mandated.

This is a cleverly worked out proposal, which takes advantage of a country's right under ICAO to shaft its own citizens in its own airspace in any way it wishes, and which is going to affect the usual players in the same way as booting out N-reg airframes from Europe would have done. So, expect much mobilisation of lobbying power - just as previously.

We must do our bit in the response to the NPA, of course.

IMHO, the final set of rules will be very different from this proposal - not least because this is very vague.

4 years is an awful long time in politics.

Some things could be harder than having to sit 4 JAA exams. Imagine a hypothetical mandating of Enhanced Mode S for PRNAV airspace. Imagine the massive avionics refit you would need to do to collect all the data in a form suitable for squirting into your GTX330 so it can be radiated on 1090ES. Easily well into 5 digits.

Finally, what we see here is the STICK. There is likely to be a CARROT. Certainly so, if they want to avoid a war from the bigger operators (turboprops and corporate jets). The carrot (e.g. FAA to EASA conversion rights on both certification and FCL) has not yet been published, and won't be for a long time, because in EU politics you have to keep the best meat in the bag, for the biggest dogs.

[S-Works]

Don't be such an ass IO, you just hate it when I am right.
;)

[Julian]

I havent read the document yet but going on IOs comments about having to sit the ATPLs to use your ICAO licence in certain circumstances, what happens 36mths after you have passed them?

Presumably if you have not then obtained the JAA/EASA CPL & IR you will lose them and have to do the whole thing again!!! So you sit the ATPL to use your ICAO licence and then get forced down the Euro route anyway....

I will have to sit down this weekend and read it but inclined to agree with IO, its probably more scare tactics to try and frighten N Reg owners and reascert their authourity upon us.

J.

[IO540]

I think Julian you may be trying to read specifics into this rather non-specific and very poorly phrased proposal, and it is years too early to do that.

A lot of people far more clever than me have been reading those 3 pages, over and over, and they cannot work out what it means.

[S-Works]

No Julian, the proposal is that you sit the exams and a flight test you get an EASA licence. you then keep the FAA licence current and the EASA licence.

If you have an ATPL (no the legendary fATPL) then you sit the exams and get a licence. It is how it happens now for conversion, it is just the current proposal is to force the conversion on us.

[flaxman]

Don't be such an ass IO, you just hate it when I am right.

Are you ever anything else?

[Fuji Abound]

Don't be such an ass IO, you just hate it when I am right.

In the nicest way - your track record aint great as a predictor of imminent doom.

:)

[IO540]

Bose x is always right on this one, for the same reason he would be 'always right' if he said it will rain sometime in 2008.

Yet another (yawn......) proposal to shaft foreign license holders in Europe is a sure bet, every year or two.

[S-Works]

Stick your heads in the sand guys.......

I do like it when I tell you what is coming, you spend pages telling me why I am wrong and then when it does come along tell me that it was inevitable all the time.....
;)

[Fuji Abound]

;)

I would be cautiously optimistic that something may happen in the next 6 months to implement some of these recommendaitons

Making the exams available "on-demand"

3rd party testing centres

IMC holders get credit towards the 10hr Basic module

Making the flight training more "competency-based" rather than requiring 50hrs for all candidates.

Do you remember those predictions?

Not having a go, but it seems to me any predictions in this game is a dangerous business. Perhaps it is best to keep the predictions for the pier and deal with the reality. :bored:

[youngskywalker]

I'm curious to know why you seem to care so much about this issue anyway bose? I know that the Malibu you have a share in is on the N reg (not sure which reg your shared 172 rocket is on) but as you say on your profile you have loads of licences, tens of thousands of hours and any more licence conversions are unlikely to bother you finacially as you told us all recently you wouldnt get out of bed for less than 170k a year! :E

Interestingly I popped your name into google, seems your quite well in with the diving! Sadly my name produces nothing in google :(

[S-Works]

Making the exams available "on-demand"

Proposal pending acceptance from EASA

3rd party testing centres

Not 3rd party testing centers, greater accessibility of testing centers other than Gatwick. Exams are taken at 3 other places currently and the intention was to get the availabilty widened. Stalled due to EASA take over.

IMC holders get credit towards the 10hr Basic module

Other way around and already in force.

Making the flight training more "competency-based" rather than requiring 50hrs for all candidates.

Proposal with EASA.

Youngskywalker, flattered that you have the time to troll the web looking for me!! Happy to send a photograph....... ;) You are right it does not effect me as I already have the bases covered including FAA and JAA Class 1 medical's. My Cessna is G-Reg.

But where would the fun be if we could not have some debate! Shame it always sinks to personal attacks. Give it 3 more posts and fuji will make it all AOPA's fault......... :p

[youngskywalker]

I like to do my research! :E

Mind you, I've finally got a JAA class one (as I figured that was a subtle dig at me!) after all these years so I suppose I ought to just get stuck into the conversion.

Interestingly I heard through the grapevine that the intention is to make the ATPL exams available via computer style testing (similar to the FAA style of computer testing) at the actual training schools, allowing students to sit them as soon as the training provider deems them ready. That would certainly make life a little easier if it happens.

Not everything changes for the worse, it just seems that way at times.

[S-Works]

Interestingly I heard through the grapevine that the intention is to make the ATPL exams available via computer style testing (similar to the FAA style of computer testing) at the actual training schools, allowing students to sit them as soon as the training provider deems them ready. That would certainly make life a little easier if it happens.

Yep, see my comment above in answer to my predictions about the future dig from Fuji. We have worked on no end if this stuff for a quite some time. Try pushing a square block uphill and you will understand what we face.

All of the stuff that fuji chose to dig about is in the pipeline but slowed by the takeover by EASA.

Glad you got the Class 1 now though, even though I was not actually digging at you. Far to polite to do that........ :p

[MIKECR]

As a slight aside, but still on the same subject of N reg etc. Is it possible for a UK JAA licence holder(with JAA IR) to use an N reg SEP(IFR certified) for a private trip within UK and Europe?? Most of it would be VFR but certain sections may be airways.

[S-Works]

Yes. According to the letter I have from the FAA.

You may fly an N reg aircraft outside of the USA on a foreign licence, exercising the full privileges of that licence including IFR.

[IO540]

The non-FAA license has to be issued by the country in whose airspace you are flying. Reference FAR 61.3

[IO540]

or the state in whose airspace you are flying accepts you flying an N reg aircraft in their airspace on a UK issued licence.Well, that is not what 61.3 says.

I don't see how a local airspace rule can override an FAA requirement. The FAA holds the jurisdiction over an N-reg and what licenses are required to fly it.

I suppose this one could be argued both ways though.

However, there are not many countries which specifically allow you to fly an N-reg on a UK license. Can you name any?

[Fuji Abound]

But where would the fun be if we could not have some debate! Shame it always sinks to personal attacks. Give it 3 more posts and fuji will make it all AOPA's fault.........

Ah yes, AOPA, now there is a subject for many hours of entertaining debate .. .. ..

To be fair you have done well with some of your IR proposals Bose, it is just shame that EASA has got in the way I suspect.

Personally, I always like your posts for the entertainment value! :ok:

[MIKECR]

Im just curious as to the legalities of it. Myself and friends are planning a week or two's touring next month or possibly Sept and are looking for a half reasonable machine to do the trip. We are all JAA licence holders and have JAA IR's. We're hoping to fly something a bit different than the average G reg club aircraft, hence I ask about N reg. I may be able to access an N reg Cirrus.

[Fuji Abound]

MikeCR

I believe

1. UK JAA PPL/IR,

2. No FAA,

then N reg in the UK VFR only with no European priviliges,

1. UK JAA PPL/IR,

2. FAA without IR

then N reg UK and Europe VFR priviliges,

1. UK JAA PPL/IR,

2. FAA with foreign pilot IR

then N reg UK and Europe VFR and IFR.

In short no European travel without a piggy back FAA or stand alone FAA and no IFR UK or Europe without a FAA piggy back or stand alone and FAA foreign pilot IR conversion.

I think there is some doubt whether a JAA IR would give IMCr priviliges in the UK outside class A in an N reg with or without an FAA but definitely no airways. There may also be some doubt whether IFR in VMC would be legal in the UK with a JAA license but no FAA license in an N reg.

You may well get individual permission from the relevant European authority on written application to operate an N reg in their airspace on your JAA license if you are also a foreign national but whether the FAA would strictly be happy is yet another issue.

[Flyin'Dutch']

I am no legal eagle and certainly don't know anything about the legal aspects of what EASA can and can not do but I hazard a guess that they will struggle to forbid someone to fly in their airspace holding an ICAO compliant license [sic] flying an ICAO compliant aeroplane with an ICAO compliant medical.

The way I read that document is that it accommodates for the situation whereby someone with an ICAO but not EASA/JAR licence wants to fly something registered in another (not same regulator as licence issuer) or EASA/JAR registered aeroplane.

Maybe someone who knows more about European and International law can clarify the situation beyond doubt.

[IO540]

This one goes round and round.

Can a JAA license meet the requirements of FAR 61.3 for flying an N-reg around Europe, despite 61.3 using the word issued (but JAA works on validation) ?

I have seen (and have copies of) two replies from the FAA which directly contradict each other.

This is set to remain one of the common sleeping dogs. The other one being whether one needs an IR to fly an N-reg in UK night which (SVFR excepted) is IFR.

More practically, there are two issues here: legality from the licensing POV, and insurance validity.

You are unlikely to get ramp checked - except in France where they reportedly do it to N-reg pilots. Rumour has it that the Frogs have special briefing packs which show them what an FAA license looks like and what wording should be on it, to fly an N-reg on an IFR flight.

But if there was an incident, the insurance will not pay out if the paperwork is deemed to be duff i.e. the flight itself was illegal. I would love to find out why Graham Hill's estate didn't get the payout; it has been claimed his CofA was invalid but why? Had to be some obscure technicality to catch him out.

[172driver]

MIKECR, from my understanding Fuji (post 36) is correct. In addition, as IO points out, insurance companies just love grey areas - gives 'em wiggle room :E

[IO540]

I agree with Fuji's post #36 too.

However, re this case:

UK issued PPL/IR
N-reg
UK airspace

should be good for full IFR (airways) in UK airspace because the UK PPL/IR clearly meets 61.3.

But take this:

German issued JAA PPL/IR
UK issued PPL
N-reg

which would meet FAR 61.3 for VFR only in the UK, and would meet 61.3 for all rights in German airspace.

I don't think the above would be good for all IFR in UK airspace but this is a grey area, which depends on the interpretation of the word "license" in 61.3.

OTOH I would argue that a license includes any ratings on it and thus the IR can be any ICAO IR which is valid on that license.

It's all a bit of a mess when you get into these obscure cases.

[IO540]

I am afraid very little is ever "achieved" on this front. These issues just go round and round.

I am sure some aviation lawyers have formed a view on it but they sure as hell are not posting it on here.

Until something gets clarified, my view is that the applicability of regs like 61.3 to scenarios outside the USA has to be read literally as it is written.

So, for an N-reg, you need a license issued by the owner of each airspace in which you fly, unless you have an FAA license in which case you can go anywhere.

On a slight digression, I have done an awful lot of digging and there really isn't much point in being on the N-reg unless one is using the FAA IR. Maintenance wise, the only significant advantage is the absence of the UK 150hr check but that doesn't affect many private owners! The other big advantage is a better system for modifications but again not many people do that many mods. There are some medical concessions but they go away if you can "somehow" get through the JAA Initial medical because you are allowed Demonstrated Ability after that. EASA is highly likely to do away with this Initial/Renewal difference anyway, since it serves no aviation safety purpose.

A state has jurisdiction over its own airspaceOf course, but this normally works in the "prohibition" direction (the example you gave) and would not normally permissively override a restriction imposed by the state of registry. I suppose it's possible (and I know others have argued so) but I have never ever seen the slightest example of such a situation.

[Fuji Abound]

Didn't someone post once that the FAA treat Europe as one airspace.

Yes, I think that was IO. I think he is correct, after all they now think Europe is like America except it is governed from Brussels instead of Washington - and they are probably right. They cant imagine how Scotland for example can have any degree of sovreignty - after all they have towns bigger than Scotland.

When we are all licensed by EASA they might even be closer to the truth.

Dont forget that a FAA license doesn't need an expensive renewal every few years.

Except my CAA license was issued for life, until of course the politicians forgot what the word meant - what a bunch of half wits. How simple would it have been to make it a condition of signing up to EASA that existing life licenses would be validated by EASA as such. In the fullnes of time they would work their way out of the system.

[S-Works]

Myself and another forumite wrote to all of the European Aviation agencies and asked if a pilot with a JAA Licence and a JAA IR could fly in their airspace in an N reg aircraft.

The answer from everyone was yes. So a pilot with a UK JAA licence with a JAA IR may fly an N Reg aicraft airways on the JAA licence anywhere in Europe. The FAR's permit a pilot to fly an N Reg aircraft OUTSIDE of the USA on a foreign licence.

The FAA do consider European airspace as a single sky because we are all under JAA/EASA.

[Fuji Abound]

Myself and another forumite wrote to all of the European Aviation agencies and asked if a pilot with a JAA Licence and a JAA IR could fly in their airspace in an N reg aircraft.

What, all of them, all 24, and got a reply from everyone, or are you only referring to the ones that replied? By European Agencies do you mean those signed up to EASA SRO?

Never the less a good effort on your part.

Would you like to share with us the letter you wrote and the reply received?

Mind you as worth while as your quest clearly was for someone flying only N reg it would seem far less time consuming to simply do the foreigh pilot conversion - after all out goes the annual renewal to be replaced with rolling currency, out goes the annual fees and out goes any doubt that might arise from any EASA member that forgot they wrote to you saying it was OK.

Never the less a good job for anyone flying both N and G reg.

[IO540]

Didn't someone post once that the FAA treat Europe as one airspace.

Yes, I think that was IO.

I am not sure it was me. I am sure it would be more accurate to say that most Americans, even those working in FAA offices, don't know much about Europe, about the JAA mutual-validation system, etc. and that is why one gets different replies from different bits.

Similar with JAA regulators - few of them will know anything about FAA regs.

I know a man who bought an N-reg TB-something; the CAA told him he cannot fly it in the UK on a UK PPL, so (on the basis of that crap piece of advice) he sold it :ugh:

I must emphasise that on the subject of whether a JAA license meets FAR 61.3 (which uses the word "issued" which a JAA license certainly is not, except in the one country which issued it) there are conflicting replies from the FAA. If anybody wants some examples, email me.

Whether a particular FAA reply is good for insurance purposes, well a lawyer could answer that.

I do know that, in UK law, an incorrect reply from an apparently authoritative source in an organisation does not modify the law, but the recipient has a reasonable expectation of receiving the correct information from an organisation (unless the reply from from somebody signing as the lavatory cleaner, and obviously subject to a full disclosure of relevant facts, etc) and can thus rely on that reply. This principle makes a criminal prosecution virtually impossible, if the recipient relied on a reply which turned out to be incorrect. This principle has led to the CAA losing some well publicised court cases - the defendant had a letter from them which they "never knew" they had written.

Whether this is good enough for insurance purposes (a civil action, not a criminal action), I don't know but I would hope it would be.

[Fuji Abound]

IO - I think the insurance issue is a bit of a red herring - the safe option is to copy the correspondence on which you rely to the insurance company and ask them if they are satisfied that the practise you propose will not invalidate your policy - if they agree it will not (in writing) all will be well.

For example while off airport landings are not illegal as such there are clearly a raft of considerations so I wrote and asked if off airport landings would be covered and whether any specific restrictions would apply.

[IO540]

the safe option is to copy the correspondence on which you rely to the insurance company and ask them if they are satisfied that the practise you propose will not invalidate your policy - if they agree it will not (in writing) all will be well.

I agree, but I have found - on these standard aviation law sleeping dogs - that the insurance co. simply says "you must comply with the legal requirements" and that's it.

This way, they reserve the right to pay out or not according to their lawyers' advice when you actually crash. They don't want to spend money on lawyers answering your questions before you crash :)

But I tend to agree that simply making a full disclosure puts the ball substantially in their court.

[AC-DC]

No one will be effected as fuel prices will kill GA well before 2012.:E

[Fuji Abound]

Electric powered gliders in the lower airways - now there is a thought.

[MIKECR]

Thanks for the replies gents. Seem's like the answer to my question is very much open to debate. I was aware we could do VFR in UK on the N reg but wasnt sure if we could stretch it to IFR in Europe. I think the best bet is an email to the FAA.

Failing that, we can go by arrow or seneca(both G Reg). The seneca is unfortunately pricey, for obvious reasons!!