2 REG

[beerdrinker]

From "Flyer" news:

Guernsey and Jersey are to introduce a joint aircraft registry under the name �2 REG�.
According to Fergus Woods, Director of Civil Aviation Guernsey, this registry will be open to owners of private aircraft of any size, stationed anywhere in the world. The launch for the Registry is planned to be the third quarter of 2013.
The Registry will be administered under a private-public-partnership with Guernsey and Jersey by SGI Aviation, a company based in the Netherlands.


Great news for owners of N registered aircraft who are not confident of EASA's plans for them. Note (unlike IoM registry) this is for any private aircraft - not just bizjets

[Silvaire1]

That's really great :ok:

EASA is going to learn about competition from a second source closer to home it seems. You cannot indefinitely legislate away the marketplace of ideas.

[S-Works]

There is no 'competition' from a new registry. EASA control European airspace full stop. To operate in that airspace you will have to be compliant with the rules they set. I also don't believe the CI will start their own FCL division as its currently done by the UK CAA on their behalf.

What it might mean is that they will adopt a lighter touch to maintenance and the associated regulatory fees. But the big incentive I see for people going onto the new reg is the more friendly tax schema.

[Silvaire1]

So what about CI Register maintenance then? That is (potentially) the closer to home competition EASA regulations will face, just as they face it now from N-register and always will. To me as a non-IFR pilot, EU pilot licensing, medicals etc would be a hassle but not to the same extent as Part M.

I think for almost any aircraft owner the biggest thing would be any possibility to escape the EASA Part M nonsense. If you can't do that, then I agree that N-register would continue to make a lot more sense.

My own plan is never again to have European registered residence.

[maxred]

What it might mean is that they will adopt a lighter touch to maintenance and the associated regulatory fees. But the big incentive I see for people going onto the new reg is the more friendly tax schema.

Well it cannot be any lighter than the utter shambles of EASA Part M, and the cowboys who partake.......

My own plan is never again to have European registered residence.

Ditto.........:ok:

[Bob Upanddown]

Before we all start think about putting our PA-28's and Cessna 150's on the 2-Reg, look at the potential cost....

From either N-reg or G-reg, the aircraft will almost certainly need an export C of A. Now, if you have ever had the CAA anywhere near your aircraft recently, you will know this is not an enjoyable experience and could be expensive (what is this tiny switch? do you have an STC for it?? where is the Form 1???).

Unless you are resident in the CI, you will still need an EASA Part FCL licence.

The IOM allow FAA or EASA maintenance but then send a surveyor to issue the C of A every year - that's not cheap, I bet.

The CI based companies that offer N-reg trusts are the most expensive for this service so I doubt the CI trust, if that's how it will be run, won't be cheap.

[A and C]

The CI will not let a bunch of old undermaintaned aircraft into the register, if you think you are getting out of Cessnas SID's checks forget it!

Maxred..........not all in the maintenance business are cowboys !

[Silvaire1]

Presumably, they're creating this register for a reason and that reason will undoubtedly be to make money. With volume in mind they are making their register available to small aircraft... so they will need to make it advantageous for the owners of those aircraft if they are are to attract them in volume.

Otherwise just stay or move onto N-register and operate in the logical world, with rational maintenance, by that existing method.

[Bob Upanddown]

To move from the world of "cowboy" Part M maintenance with a small old under-maintained aircraft is surely going to cost a large chunk of the aircraft's value. The only way that could happen is if the CI register issues a C of A without requiring an Export C of A from the UK.
Who, with a £40k PA-28 (yes, I know even that is ridiculous value), is going to cough up maybe £5k to £10k to get an export C of A (A&C, you must know the risks of inviting the CAA to look at an aircraft, gawd know what they might find, especially on a Cessna 172 with all the new SIDs) followed by another chunk to satisfy whatever requirement the CI register imposes to issue a CI C of A.
The CI Governments might not intend to charge much but I bet the company running the system from Holland will include enough paperwork to ensure they earn a good screw.

[S-Works]

However its all a moot point. The register is not being aimed at spam cans, it will be for CI residents and the big players as a CI equivalent of the Manx reg.

[Silvaire1]

Why does it matter what the aircraft is worth, unless you're going to sell it?

What's being described above is a death spiral: the reason the aircraft value is low is EU over regulation of certified aircraft, very much including Part M maintenance. If you're not planning on selling the aircraft, its beneficial to cut costs looking forward, and break the decreasing radius spiral.

Otherwise you sell the aircraft and switch to non-certified... Which is probably EASA's world view for 'hobby pilots'. The utility and freedom of private transportation aircraft moving around Europe is obviously not their 2020 vision!

[m.Berger]

Put me down for 2GOOD, 2RICH and 2SEXY.

[peterh337]

To move from the world of "cowboy" Part M maintenance with a small old under-maintained aircraft is surely going to cost a large chunk of the aircraft's value. The only way that could happen is if the CI register issues a C of A without requiring an Export C of A from the UK.
Who, with a £40k PA-28 (yes, I know even that is ridiculous value), is going to cough up maybe £5k to £10k to get an export C of A (A&C, you must know the risks of inviting the CAA to look at an aircraft, gawd know what they might find, especially on a Cessna 172 with all the new SIDs) followed by another chunk to satisfy whatever requirement the CI register imposes to issue a CI C of A.

I think that is a very correct analysis.

And if something goes wrong with the venture then you have to go back again... to face either the UK CAA inspector, or the £1500/day FAA DAR.

[Silvaire1]

My DAR buddy would charge $500 for a conformity inspection. Maybe he needs to buys some airline tickets :)

[sooty3694]

The CI register is going to have to go a long way to catch up with the lead that the IOM register has already established, which in just five years is now the second most popular aircraft registration domain in the WORLD. That is quite an achievement, and one which is raising eyebrows among those who are closely aligned with, or working within the bureaucratic nightmare that is EASA.

Quite why the IOM have been so successful is due to several reasons, most notably of which is the quality of service that they offer to their target audience of biz jet owners and operators. Their service is OUTSTANDING, and unlike most authorities they offer direct contact to decision makers, and generally speaking the decision makers make an effort to help their clients rather than hinder them with obstacles. The UK CAA has a LOT to learn from the very well qualified and customer orientated staff of the IOM, and so too do many European authorities. The guys working in the IOM under the charge of Hartley Elder are top notch, and they really do know their stuff!

The bureaucrats in EASA may have good reason to be a little "miffed" by the success of the IOM register. Private operators who choose to reside outside of the EU and register with the IOM will escape much of the new Basic Regulation, which when analyzed has little or nothing to do with safety regulation, but instead is an attempt to regulate for the sake of creating yet another empire filled with trough swigging eurocrats.

Regrettably though, for the owners of small light singles, I doubt if the CI reg will be of help. As previously mentioned the costs associated with export CofA's may be prohibitive, and most importantly the "operator" will have to a resident outside of the EU in order to completely escape the clutches of EASA. Most light singles are not "operated" by anyone other than the owner/pilot, and the residency of the operator is what the new Basic Regulation hinges on.

[Sir George Cayley]

Fergus Woods - CI -ex CAA

Brian Johnson - IOM - ex CAA - Re'td

Hartley Elder -IOM - ex CAA

Gatwick boys done good :ok:


SGC

[Bob Upanddown]

As a further input into the view that this is not going to be the escape from EASA that light GA is looking for, I have it on good authority that the CI maintenance regime will be based on a validation of 145 approval.
As I expect most light GA on the N is being signed off by an A&P and an IA (a situation that is unlikely to change with the current TSA block on new FAR 145 approvals) and on the G is being signed off by an engineer under Part M, your CI reg might need a higher "standard" of maintenance approval that now required if the CI look for validating organisations rather than engineers.

Looking more and more like a clone of the IOM idea.

[peterh337]

a situation that is unlikely to improve with the current TSA block on new FAR 145 approvals

I have direct experience of two FAA 145 repair stations here in the UK, and both did really crap work. The second one left a couple of life threatening bodges, which I did a video of (e.g. a control linkage cutting into a cable harness) but they weren't really interested... both are EASA 145 of course too.

FAA 145 isn't actually blocked if you have the right contacts. One firm I was at on Monday is getting its 145 finalised in 2 weeks' time. It's just that the normal Tom Dick or Harry can't get one just by applying for it.

So actually I am very happy with my very good A&P/IA. In fact I have now gone totally away from "companies" and rent a hangar for the Annual, where the IA and I do it in a few days, working solidly. The best possible job done and half the price of a "company".

Does the IOM accept planes without an Export CofA? What exactly do they do?

[Bob Upanddown]

So actually I am very happy with my very good A&P/IA. In fact I have now gone totally away from "companies" and rent a hangar for the Annual, where the IA and I do it in a few days, working solidly. The best possible job done and half the price of a "company".

Totally agree. 145 means you pay more for paperwork and bull:mad:.
You maintain your aircraft the way it should be maintained to your satisfaction as it is your neck on the line.
If CI are looking for 145 approved maintenance, then it will not be the register for light aircraft. Better be a Channel Island resident and have your light aircraft on the N.

[peterh337]

But you can have your plane on N anyway.

EASA has not imposed long term parking limits on foreign reg planes.

So... the difference is exactly what?

Saving the FAA trust cost, and eliminating the risk of the FAA trustee dying and then somebody undesirable grabbing the trust and preventing you from selling the plane.

The latter is routinely solved with the 25%/75% Delaware trust company; it just costs more money. Bizjets use that.

[G-OE]

2 regs open so many good opportunities such as '2good'. The only good g reg I've ever heard of is g-spot.

[strasser]

Information Bulletin on the proposed CI Aircraft Registry.

Prepared for AOPA CI Region by Charles Strasser, Vice President AOPA UK
from email information provided by Fons Schaefer, CIAR Project Manager, SGI Aviation Services BV
and vetted by Fergus Woods, Director of Civil Aviation, Guernsey and Jersey.

There have been a number of Aviation Forums in which various contributors have speculated on what would be in the Channel Islands Aircraft Registry Regulations (the 2-reg) and what would be the advantages and disadvantages of applying for registration. Inevitably this has resulted in misinformation and the verbatim Questions and Answers below should help to correct that position.

First email

1./ It is stated that any size aircraft from any country will be accepted.

Put simply we will register all sizes except EASA Annex II aircraft based in the Channel Islands. For non-CI based aircraft we will be targeting aircraft as defined in our Air Navigation Law as Complex Non-Commercial but to include everything from Single-Engine Turbo-props and above.

Presumably this will be by transfer of the existing registration, with export C of A, from another jurisdiction.

Correct. Export CoA or equivalent.

Will it have to be to a CI company or can it be in the name of an individual with a foreign address?.

This is still under discussion. At the very least we will require non-resident ownership to be through a Guernsey or Jersey administered company, meaning that ownership could be through a foreign company or trust but via a locally licensed Corporate Service Provider. However, the whole issue of eligibility is yet to be finalised.

Will those on the N register be able to dispense with their trusts?

This is partly dependent on the eligibility question above. However, anyone who wants to will be able dispense with their USA Trust arrangement if they wish.

2./ Will the Licences and ratings of any ICAO country be recognised, validated or converted into a CI one?.

Pilot licences and ratings will be based on validations of ICAO licences from Contracting States "acceptable" to the DCA. But generally European and American licences (the majority) will be accepted with minimal formality.

3./ Will the maintenance requirements of any ICAO country be acceptable? For example will one be able to select the CAA, EASA or FAA regulations on maintenance schedules, mods and STC's etc.?

We will in principle only accept maintenance data approved by US, Europe (EASA) or Canada.

4./ Will the proposed EASA regulations for FRA apply?

Currently the EASA focus is on commercial transport operators, but in time their rules will impact on private operations. At that time there will be clear advantages for local resident owner operators to be on the 2-reg.

5./ What will be the advantage, if any, of the thousands of European N registered aircraft changing to the CI register?

Only larger N-reg aircraft or those that are CI based will be allowed on to the 2-reg. So we are not anticipating taking on the many thousands of European based N-reg aircraft

6./ Since neither of the Channel Islands are contracted member States of ICAO will the CI register come under the supervision of the CAA and if so with what powers?

Strictly speaking they will have no jurisdiction. However, as part of our demonstration of compliance with all relevant ICAO SARPS, we will be subject to an initial audit (and subsequent regular oversight) by the CAA on behalf of the UK DfT.

Second email

1./ Am I correct in presuming that an "aircraft based in the Channel Islands" is one owned by a resident individual, resident company or resident trust?

Yes, correct.

2./ Re EASA Annex II, why will for example, a locally based US made Piper Cub, Tripacer or Apache or UK made Auster, Chipmunk or Bulldog be barred from registration?.

In line with the standards that other overseas territories apply (ref. OTARs), we will accept type certificates from the following three jurisdictions: Europe (EASA), USA and Canada. We are still considering whether we could extend the scope to other aircraft, e.g. non-Annex II aircraft having a British Type Certificate or equivalent, but in any case we will not accept permit aircraft, i.e. aircraft holding a national CoA rather than a full ICAO CoA.

3./ Am I correct in presuming that, you accept the standard definition that, a "complex aircraft" means an airplane with retractable landing gear, a controllable speed propeller, and flaps. If so why, for non locally based aircraft, is the starting point a single engine Turbo prop?

No, the reference in the proposed ANL to ‘complex non-commercial’ applies to the following aircraft:
(a) any aeroplane having a maximum total weight authorised exceeding 5,700kg,

(b) any aeroplane equipped with one or more turbojet engines

(c) any aeroplane having a maximum approved passenger seating configuration of more than 9,

(d) any helicopter having a maximum total weight authorised exceeding 3,175kg,

(e) any helicopter having a maximum approved passenger seating configuration of more than 5,

(f) any aircraft operation involving the use of aircraft that are operated by pilots employed by the operator for the purpose of flying the aircraft, or

(g) any other general aviation operation as the Director of Civil Aviation shall in the public interest specify

The basis for this is ICAO Annex 6, Part II, Section 3 and refers to those operations where prior operating approval is required.

We will however accept other aircraft that are not locally based, but essentially this will be from single engine turboprop and up. The rationale for this is that the CIAR is both a registry for local residents and an off-shore, commercial registry.

4./ Since neither Jersey nor Guernsey are ICAO "Contracting States", it is interesting to note that you insist on that status to recognise Licences and Ratings issued only by them. Presumably based on that you would not recognise licences and ratings for pilots holding licences, for example, from the Netherland Antilles (Aruba) or Bermuda?

Although indeed both Jersey and Guernsey are not contracting states by themselves, they do have a legal commitment to be ICAO compliant in all aspects of aviation. It is the basis on which the contracting State, the UK, has granted us independence in managing our own aviation affairs. It is also the only basis on which we could anticipate success as an off-shore registry provider. Our clients need to know that they are dealing with a fully compliant jurisdiction to ensure their freedom of movement through and into international airspace. Hence, our policy to validate licences from ICAO compliant jurisdictions acceptable to the DCA. The same applies to the other territories you mention. We do not preclude at this stage to accept licences from those territories.

5./ What is the definition of "larger N registered " aircraft, as mentioned in your answer to paragraph 5./?

See the answer to point 3.

6./ Is the fee for the CAA initial audit and subsequent oversight included in your fee or is it an additional overhead and if so has a price for this been fixed?

It is an overhead cost for us and will be included in our fees. Regular audits by the CAA on behalf of the UK DfT is part and parcel of our commitment to ICAO compliance generally, in terms of our self-management of our aviation affairs. Even without an aircraft registry we can expect regular audit activity to demonstrate our compliance with ICAO SARPs on aerodromes and air traffic service provision.

Third email

1./ It would be appreciated if you could email me a copy of the application form(s) for putting an aircraft on the CI register, or draft thereof.

We are currently developing our procedures and forms, but they are not yet at a stage that I could share them with you.


Further information will be published as and when it becomes available in the public domain.

[Cathar]

4./ Since neither Jersey nor Guernsey are ICAO "Contracting States", it is interesting to note that you insist on that status to recognise Licences and Ratings issued only by them. Presumably based on that you would not recognise licences and ratings for pilots holding licences, for example, from the Netherland Antilles (Aruba) or Bermuda?


Strange question. Licences not issued by a contracting state would not benefit the rights granted under the Chicago Convention and would be virtually useless for international operations. In any case all but six or so states are signatories to the Chicago Convention so this is hardly going to be an issue.

While neither Jersey nor Guernsey are contracting states (nor are they entitled to become contracting states as they are not states ) they are, like Bermuda, covered by the UK's ratification of the Chicago Convention. Aircraft registers in the UK Crown Dependencies and Overseas Territories operate as sub-sets of the UK register and benefit from the rights that the UK has under the Convention. They also have to comply with the obligations that the Convention places on the UK. A similar situation exists with Aruba which is part of the Kingdom of the Netherlands and is covered by its ratification of the Convention.

I don't know about Aruba but Bermuda does not issue licences, rather it validates licences issued by other contracting states.