N-reg situation update
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421c I agree with everything you have said.
I might add also the N reg fleet and its acceptance in central europe dates back to the after WWII and the amount of none european long term residents which were there for the cold war.
The biz jet side of things has other things and lobbying going on in the back ground which I don't really understand or for that matter care about. There is a heap of rivalary between AOC operators and various other interested parties.
I think there is a large group that think if the N reg biz jets dissappear then life will be come easier and more prosporus. In reality I think there are just as many grey charters in european regs as there is in 3rd country regs. I am sure the boys will return that this is just rubbish pointing the finger at N reg and they are more than likely correct its a global problem.
But it comes down to this resident thing and who controls what.
And I don't think people put enough weight on the fact that the authorities have been publically slagged off for years on forums and in the press about there system and how N reg is better. There have been numerous articles etc about how to opt out of the local NAA's control usually using a N reg.
As you say they were looking at not having a GA fleet or any GA pilots. But the number of movements remaining the same or even increasing.
I think they are actually excedingly clever Peter, you don't know which direction they are going to hit you from next. The NAA's won't publically come out and show face with what there intentions are.
This will have been all worked out in an office by a load of civil servants aka "yes prime minster" then fed in a certain way to the politicians to fire them up. Your up against oxford/cam eductated guys that have been playing the goverment game for 40 plus years.
I might add also the N reg fleet and its acceptance in central europe dates back to the after WWII and the amount of none european long term residents which were there for the cold war.
The biz jet side of things has other things and lobbying going on in the back ground which I don't really understand or for that matter care about. There is a heap of rivalary between AOC operators and various other interested parties.
I think there is a large group that think if the N reg biz jets dissappear then life will be come easier and more prosporus. In reality I think there are just as many grey charters in european regs as there is in 3rd country regs. I am sure the boys will return that this is just rubbish pointing the finger at N reg and they are more than likely correct its a global problem.
But it comes down to this resident thing and who controls what.
And I don't think people put enough weight on the fact that the authorities have been publically slagged off for years on forums and in the press about there system and how N reg is better. There have been numerous articles etc about how to opt out of the local NAA's control usually using a N reg.
As you say they were looking at not having a GA fleet or any GA pilots. But the number of movements remaining the same or even increasing.
I think they are actually excedingly clever Peter, you don't know which direction they are going to hit you from next. The NAA's won't publically come out and show face with what there intentions are.
This will have been all worked out in an office by a load of civil servants aka "yes prime minster" then fed in a certain way to the politicians to fire them up. Your up against oxford/cam eductated guys that have been playing the goverment game for 40 plus years.
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writing to one's MP just produces a pre-prepared standard response
letter.
The best thing is creating awareness, and like it or not pilot forums are effective in that
letter.
The best thing is creating awareness, and like it or not pilot forums are effective in that
Peter- gets angry, mentions "gravy trains"
421- pontificates in long boring posts
Bose - needles Peter
Pace - angry too but convinced about what his lawyer friend told him
Fuji - always convinced he was right all along, about what we are not sure
MJ - lives up to the first part of his user name in many posts, with occasional outbreaks of sense
(the intention of the above was to make fun of all of us, myself included, to the same extent!)
Of course, new participants join in, but they fit a small number of categories :
"Captain Oblivious": "I haven't looked at a GA website or magazine since the 90s. I fly an N-reg Thruster 180XL, how will this "EUASA" thing affect me?"
"Colonel Mustard": "British pilots should damn well get British papers and damn this johnny-foreigner FAA - next we'll be allowing human sacrifce and polygamy if we just let people pick and choose regulations from around the world"
etc etc
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There have been numerous articles etc about how to opt out of the local NAA's control usually using a N reg.
There have been NO such articles (that I have seen).
There have been plenty of articles explaining how N-reg operation delivers a more streamlined and safer operating regime.
I have never met a pilot who was particularly out to get out of his CAA's "control". AFAICT most N-reg owners also have local CAA PPLs and medicals (possibly lapsed, like mine were at one point) so the local CAA knows all about them anyway.
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There have been NO such articles (that I have seen).
Peter's Website
Moving to N-reg
There have been plenty of articles explaining how N-reg operation delivers a more streamlined and safer operating regime.
Last edited by S-Works; 26th Apr 2012 at 11:37.
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Gosh I am getting lots of free publicity.
Tell ya what "Mr TRTO Examiner". If I got 10% every time somebody bought a TB20 after reading my writeups, I would be flying a brand new shiny TBM850
Tell ya what "Mr TRTO Examiner". If I got 10% every time somebody bought a TB20 after reading my writeups, I would be flying a brand new shiny TBM850
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Oh, you don't need me to help you promote yourself Peter, you do an exemplary job of it on your own......
And if you are going to use titles it is Head of Training and Examiner at UK FTO/TRTO.....
I did find this article written by some guy called Peter who tells us all the reasons for moving to the N Reg that seem quite clearly to make Mad Jocks point. What do you reckon to it as you did make an assertion that no such articles existed.
Email:
[email protected]
And if you are going to use titles it is Head of Training and Examiner at UK FTO/TRTO.....
I did find this article written by some guy called Peter who tells us all the reasons for moving to the N Reg that seem quite clearly to make Mad Jocks point. What do you reckon to it as you did make an assertion that no such articles existed.
Email:
[email protected]
Benefits:
a) A pilot with the FAA IR gets worldwide FAA IR privileges. This is the #1 reason private pilots do it, in most cases.
b) No Insurance Premium Tax (saves 5% on the premium)
c) Easier installation of modifications. The approval route (337, DER, etc) may not be cheap (especially via a UK avionics shop) but the process is usually straightforward. In theory one can obtain UK CAA/EASA approval for anything on a G-reg but the process can be very expensive for even small mods and is completely uneconomical in many cases.
d) Can fit STCd aftermarket accessories which are already approved in the USA but aren't not CAA approved e.g. much better landing lights. Can also fit PMAd parts.
e) Pilot maintenance is permitted, to an extent which is currently superior to the UK Private CofA regime. This is a bit of a complicated subject; the two regimes were very similar until EASA came along, but now EASA is treating as "mandatory" a lot of things which previously were not mandatory. One example is the 12 year engine life limit which prevents the issue of an initial G-reg CofA, for no apparent reason given that the rest of the world isn't worried about it.
e2) For EASA-reg aircraft, there is currently a CAA/EASA requirement to comply with all ADs that apply to the aircraft regardless of the country of the AD issue. So if you have a G-reg it has to comply with ADs from the FAA that affect it or any components on it, whereas an N-reg aircraft (Part 91) needs to comply only with FAA ADs even if it contains parts that are subject to an EASA AD. The degree to which this saves costs is probably questionable in most cases, but it is a good thing given the past tendency of for example the UK CAA to generate large numbers of ADs which every other country thinks are pointless. There are few if any important EASA ADs which are not also FAA ADs. The reference for this requirement is currently in CAA CAP411 5.1 All applicable Airworthiness Directives issued by EASA, the CAA and any applicable Third Country Airworthiness Authority which is responsible for the state of design must be complied with.
f) In some situations, reclaim of duty on parts is possible with an End User Certificate. This is however possible to achieve anyway using a Form C100 - more details here (local copy).
g) The CAA Notice 75 propeller inspection, generally regarded as causing more problems than it prevents, is not required. Update 10/2007: Notice 75 has been replaced by CAP747 Generic Requirement 17. Mostly the 3 year/6 year cycle has been replaced by overhaul in accordance with manufacturers recomendations, normally 6 years or 2000hrs.
h) Can freely buy parts (new and overhauled) from the USA. This can be a major cost benefit of N-reg. An 8130-3 form is desirable but not mandatory; the regulations are in FAA Order 8130.21. Some notes on required documentation are here. An 8130-3 is OK for a G-reg aircraft but only if the part is new. Overhauled or used parts with an 8130-3 cannot be fitted to a G-reg; they need an EASA Form 1 which can be generated only by an EASA 145 company and this usually increases the cost substantially. 4/2011: it is widely claimed that EASA regs mandate an EASA-1 form for absolutely everything, which would be a ludicrous cost inflater.
i) If an SB (Service Bulletin) becomes an AD (Airworthiness Directive) then it becomes mandatory and must be implemented. The majority of ADs track between CAA/EASA and the FAA but there are still CAA ADs which the FAA has not mandated. Given that around 75% of the world's General Aviation is in the USA, this appears pointless regulation. However, the FAA is gradually implementing a process whereby mandatory SBs on European-manufactured aircraft are automatically converted into FAA ADs and thus the work must be done on such an aircraft even if it is N-reg - additional info here. This applies to future EASA MSBs only; it is not retrospective.
j) The USA has filed some differences to ICAO on the medical front and has not imposed the audiogram requirement (reference here) which is required for a JAA CPL/ATPL or a JAA PPL/IR (it is not required for a plain JAA PPL). This unreasonable requirement means that a pilot with one perfect ear and one ear which doesn't meet the specification (a common enough condition especially among older people) cannot ever get a JAA IR - even though the headsets are monaural so one bad ear doesn't matter. JAA permits "demonstrated ability" but only on a renewal medical - this is ironic since all airline pilots who are actually working are flying on renewal medicals!. 12/2010: there is some hope here that this may change.
k) In some situations where an aircraft is technically "rented" but not in the normal sense of the word (e.g. an individual owns a business which owns the aircraft, and the aircraft is rented back to the individual; this is a common procedure done under the UK Inland Revenue Benefit in Kind rules) an N-reg aircraft is legal if maintained under Part 91 rules, whereas a G-reg aircraft thus operated would arguably need to be maintained to a Transport CofA regime, and that is significantly more expensive (50hr checks, 150hr checks, all done by a JAR145 company, plus a lot of pointless maintenance) and is pointless given that the actual operation is identical to a fully privately operated aircraft flown by the very same pilot.
l) It's easier to find good freelance maintenance engineers to work on N-reg aircraft than on G-reg. This means you can assemble a group of very good people who you can trust. For the Annual you may still have to go to a large-ish firm (because of the amount of work involved, not many freelance engineers can do Annuals) but for everything else you can make sure that the job is done properly, preferably with you present and helping out. With a G-reg, and particularly if on a Transport CofA, you may have to use a certain kind of company and the problem with using a company is that it is harder to attribute bad workmanship to a particular individual. This makes it easier to avoid the numerous crooked maintenance companies; a common EASA Part M scam is to pretend that the initial Annual needs a "back to birth" inspection of everything...
l2) When on a long trip away from Europe, it is much easier to get maintenance on an N-reg aircraft than on any EU-reg aircraft. There was a case where the Annual on a G-reg expired while passing through Australia. The UK CAA refused to accept Australian maintenance and insisted on a CAA inspector to fly out there (first class) to do it. It was cheaper to transfer the aircraft to N-reg and fly it back that way, which is what was done...
m) There is no 150-hour service. For G-reg pilots who do more than 150 hours per year, this is a major added cost as the 150 hour check costs almost as much as the full Annual.
n) There is a relatively straightforward regime for owner produced parts. This is particularly relevant for aircraft types where the original manufacturer is no longer producing the parts. In short, he owner can make the part, for his own aircraft only. However, this is not a free-for-all for making one's own bits; the part's manufacture and installation still requires to be documented and is likely to be queried by a subsequent buyer. URL local copy
o) The US aircraft market is much bigger than the European one, especially for more advanced types which are much more ubiquitious out there due to the much more accessible IR. This makes an aircraft import from the USA attractive, but transferring the N-reg aircraft to a European reg can be problematic.
a) A pilot with the FAA IR gets worldwide FAA IR privileges. This is the #1 reason private pilots do it, in most cases.
b) No Insurance Premium Tax (saves 5% on the premium)
c) Easier installation of modifications. The approval route (337, DER, etc) may not be cheap (especially via a UK avionics shop) but the process is usually straightforward. In theory one can obtain UK CAA/EASA approval for anything on a G-reg but the process can be very expensive for even small mods and is completely uneconomical in many cases.
d) Can fit STCd aftermarket accessories which are already approved in the USA but aren't not CAA approved e.g. much better landing lights. Can also fit PMAd parts.
e) Pilot maintenance is permitted, to an extent which is currently superior to the UK Private CofA regime. This is a bit of a complicated subject; the two regimes were very similar until EASA came along, but now EASA is treating as "mandatory" a lot of things which previously were not mandatory. One example is the 12 year engine life limit which prevents the issue of an initial G-reg CofA, for no apparent reason given that the rest of the world isn't worried about it.
e2) For EASA-reg aircraft, there is currently a CAA/EASA requirement to comply with all ADs that apply to the aircraft regardless of the country of the AD issue. So if you have a G-reg it has to comply with ADs from the FAA that affect it or any components on it, whereas an N-reg aircraft (Part 91) needs to comply only with FAA ADs even if it contains parts that are subject to an EASA AD. The degree to which this saves costs is probably questionable in most cases, but it is a good thing given the past tendency of for example the UK CAA to generate large numbers of ADs which every other country thinks are pointless. There are few if any important EASA ADs which are not also FAA ADs. The reference for this requirement is currently in CAA CAP411 5.1 All applicable Airworthiness Directives issued by EASA, the CAA and any applicable Third Country Airworthiness Authority which is responsible for the state of design must be complied with.
f) In some situations, reclaim of duty on parts is possible with an End User Certificate. This is however possible to achieve anyway using a Form C100 - more details here (local copy).
g) The CAA Notice 75 propeller inspection, generally regarded as causing more problems than it prevents, is not required. Update 10/2007: Notice 75 has been replaced by CAP747 Generic Requirement 17. Mostly the 3 year/6 year cycle has been replaced by overhaul in accordance with manufacturers recomendations, normally 6 years or 2000hrs.
h) Can freely buy parts (new and overhauled) from the USA. This can be a major cost benefit of N-reg. An 8130-3 form is desirable but not mandatory; the regulations are in FAA Order 8130.21. Some notes on required documentation are here. An 8130-3 is OK for a G-reg aircraft but only if the part is new. Overhauled or used parts with an 8130-3 cannot be fitted to a G-reg; they need an EASA Form 1 which can be generated only by an EASA 145 company and this usually increases the cost substantially. 4/2011: it is widely claimed that EASA regs mandate an EASA-1 form for absolutely everything, which would be a ludicrous cost inflater.
i) If an SB (Service Bulletin) becomes an AD (Airworthiness Directive) then it becomes mandatory and must be implemented. The majority of ADs track between CAA/EASA and the FAA but there are still CAA ADs which the FAA has not mandated. Given that around 75% of the world's General Aviation is in the USA, this appears pointless regulation. However, the FAA is gradually implementing a process whereby mandatory SBs on European-manufactured aircraft are automatically converted into FAA ADs and thus the work must be done on such an aircraft even if it is N-reg - additional info here. This applies to future EASA MSBs only; it is not retrospective.
j) The USA has filed some differences to ICAO on the medical front and has not imposed the audiogram requirement (reference here) which is required for a JAA CPL/ATPL or a JAA PPL/IR (it is not required for a plain JAA PPL). This unreasonable requirement means that a pilot with one perfect ear and one ear which doesn't meet the specification (a common enough condition especially among older people) cannot ever get a JAA IR - even though the headsets are monaural so one bad ear doesn't matter. JAA permits "demonstrated ability" but only on a renewal medical - this is ironic since all airline pilots who are actually working are flying on renewal medicals!. 12/2010: there is some hope here that this may change.
k) In some situations where an aircraft is technically "rented" but not in the normal sense of the word (e.g. an individual owns a business which owns the aircraft, and the aircraft is rented back to the individual; this is a common procedure done under the UK Inland Revenue Benefit in Kind rules) an N-reg aircraft is legal if maintained under Part 91 rules, whereas a G-reg aircraft thus operated would arguably need to be maintained to a Transport CofA regime, and that is significantly more expensive (50hr checks, 150hr checks, all done by a JAR145 company, plus a lot of pointless maintenance) and is pointless given that the actual operation is identical to a fully privately operated aircraft flown by the very same pilot.
l) It's easier to find good freelance maintenance engineers to work on N-reg aircraft than on G-reg. This means you can assemble a group of very good people who you can trust. For the Annual you may still have to go to a large-ish firm (because of the amount of work involved, not many freelance engineers can do Annuals) but for everything else you can make sure that the job is done properly, preferably with you present and helping out. With a G-reg, and particularly if on a Transport CofA, you may have to use a certain kind of company and the problem with using a company is that it is harder to attribute bad workmanship to a particular individual. This makes it easier to avoid the numerous crooked maintenance companies; a common EASA Part M scam is to pretend that the initial Annual needs a "back to birth" inspection of everything...
l2) When on a long trip away from Europe, it is much easier to get maintenance on an N-reg aircraft than on any EU-reg aircraft. There was a case where the Annual on a G-reg expired while passing through Australia. The UK CAA refused to accept Australian maintenance and insisted on a CAA inspector to fly out there (first class) to do it. It was cheaper to transfer the aircraft to N-reg and fly it back that way, which is what was done...
m) There is no 150-hour service. For G-reg pilots who do more than 150 hours per year, this is a major added cost as the 150 hour check costs almost as much as the full Annual.
n) There is a relatively straightforward regime for owner produced parts. This is particularly relevant for aircraft types where the original manufacturer is no longer producing the parts. In short, he owner can make the part, for his own aircraft only. However, this is not a free-for-all for making one's own bits; the part's manufacture and installation still requires to be documented and is likely to be queried by a subsequent buyer. URL local copy
o) The US aircraft market is much bigger than the European one, especially for more advanced types which are much more ubiquitious out there due to the much more accessible IR. This makes an aircraft import from the USA attractive, but transferring the N-reg aircraft to a European reg can be problematic.
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And the other half?
Come on, prove that you really know how to cut and paste in an Ipad. I can't.
But as I am in a good mood I will save you the work:
Drawbacks:
a) For full worldwide privileges, the pilot needs an FAA License. One can fly an N-reg on a UK/JAA license but only within the UK (not the Channel Islands). In fact any ICAO license is OK but FAR 61.3 limits its use to the airspace of the country that issued it. Whether the UK NPPL is OK is a good question; similarly there has been some doubt over whether the UK IMC Rating is valid or whether a UK/JAA PPL with a night qualification can be used to fly an N-reg at night in the UK; more info here.
a1) While FAR 61.3 allows an N-reg to be flown outside the USA on any foreign license provided that license has been issued by the owner of the airspace concerned, the airspace owner is able to disallow this. I have a confirmation (1/2008) that Belgium does this, and requires any N-reg flown in its airspace to be flown under either an FAA license, or a FAA validation of a Belgian license (no indication this is enforced). There may be other instances of this. However, 61.3 is not a useful concession since most pilots only have one license and thus the aircraft cannot leave the one country...
b) There was a question mark over the ability to rent out an N-reg aircraft, and common rumour has been that a Dry Lease is required if one does so. The legislation (FAA and UK) is silent on this subject, and extensive enquiries have not found anything supporting the Dry Lease requirement. On 1st March 2005, Roger Kinsey at the DfT confirmed to me that renting is OK provided the renters don't do any aerial work in it. The DfT will not (officially) give permission to anyone who has rented an N-reg aircraft, even for any form of training and that includes a BFR (unless the instructor does it for free - see the link in g) below) but in practice they are quite helpful, so it's always a good idea to ask them. So anyone renting an N-reg aircraft (UK airspace) needs to already be legal to be PIC in the type. More details here.
c) Cannot do PPL Cost Sharing. Even though the FAA does have such a scheme, it cannot be operated in UK airspace on a foreign registered aircraft as this would breach 2005 ANO Article 140. Passengers are not permitted to make any contribution to costs in UK airspace. There is also the theoretical possibility that a payment from a passenger on a flight which took place wholly within a country where the aircraft is not registered could be regarded as cabotage. I carry a letter from a senior French Customs official assuring that cabotage will not be applied to private flights, but there is the possibility that they might not regard such as a "private" flight to start with. The safest thing is for the pilot to not accept any money from passengers, in an N-reg flying in Europe, and make this very clear before the flight (before witnesses, if the passengers are not known to the pilot
).
d) Document checks: U.S. registered aeroplanes are provocative to people who do not like U.S. foreign policy and while the European aviation world is nearly universally professional there are sporadic exceptions where Customs/Police officials do targeted document checks, so documents must be carried on board and be in order. In particular, they look for a document showing EU VAT has been paid on the aircraft, and for the pilot's IR if he arrived via an IFR flight plan / instrument approach. Under an EU VAT treaty, a country has the right to query the VAT status of any aircraft which is registered within that same country, or outside the EU. These checks have been reported in France and Germany in particular. It would probably be unwise to take a flying holiday around Iran, of course... Also, each pilot flying under the privileges of an FAA license, outside U.S. airspace, needs to have his own radio license; details in the Documents link above.
e) While most European maintenance shops do maintenance on N-reg aircraft, few of them have actual FAA approvals for anything. They can do the work by getting an FAA IA to come in and sign it off, but for many items (e.g. pitot-static system test) they have to get someone to come in who charges substantial hourly and travelling fees. This can increase costs.
e2) For Major Alterations, the common US system for field approvals, whereby a 337 is filled in by an IA and sent off to the local FSDO for approval, is not available to European N-reg owners. The only FSDO available for Europe is the NY IFO and they have stopped doing this work several years ago. The only remaining "official" option is to get a DER to generate an 8110-3 form which is then sent with a 337 to the FAA in Oklahoma for filing (they cannot, in general, refuse it) and this route (popular with European avionics shops) can add quite a bit of money and effort. However, a lot of installations can be done as Minor Alterations, using e.g. the Installation Manual as the Approved Data - it is up to the IA to determine if there is enough Approved Data. It is however also possible to process a 337 + Approved Data conventionally via a normal US FSDO, if you can find a co-operative one, as described here.
f) Prices charged to N-reg owners are more likely to get inflated than to G-reg owners. This is probably because N-reg planes tend to be owned by the pilot and so they get looked after better than the average G-reg self fly hire machine. A quick look around any European GA airfield shows the generally higher standard of N-reg aircraft over locally registered aircraft. It pays to get educated on how much something should cost before getting work done.
g) Any aerial work (which includes instruction or BFRs, if the instructor is being paid for it) requires permission from the DfT. More details here.
h) The trust requires you to sign the aircraft over to somebody that you have to trust and in theory they could just run off with it. I am not a lawyer but apparently this is very difficult for them to do (because the trust document obliges the legal owner to allow the beneficial owner to do more or less whatever he likes) and some also have insurance to cover various things. I have checked with one of the UK's largest aviation insurance firms and it is not possible for the beneficial owner to insure against a breach of the trust. They were unconcerned about it however, stating that one can get more problems if the US citizen that runs the trust dies. It's worth checking with him what provisions have been made for such cases. Update 2010: this has actually happened; the owner of Southern Aircraft Consultancy, Warren Chmura, did die in a motoring accident, but his brother (also a US citizen) took over immediately - just as he said would happen when I put the question to him years earlier.
i) If flying under a standalone FAA license, the pilot needs the FAA Class 3 medical as a minimum. The FAA Class 3 has stirred up some controversy, perhaps because it doesn't include an ECG. However The FAA Class 2 doesn't have an ECG either, below a certain age. ICAO does permit a national authority to impose its own medical requirements on resident pilots; this is rarely invoked but in 2004 the Irish CAA has reportedly taken advantage of this and refused to accept the FAA Class 3 for Ireland-based N-reg pilots. For some reason a FAA Class 2 is a lot cheaper than the CAA Class 2. For me, £60-80 against £150 for the CAA Class 2, both being very similar and done within 2 weeks of each other, and the FAA one was slightly more stringent (for me) on the eyesight. The FAA Class 3 is valid for an extra year but I reckon that one may as well go for the FAA Class 2, to avoid any potential for future trouble. Personally I hold an FAA Class 1 medical, which still costs only about £80, for both initial and renewals, while the CAA Class 1 initial is over £300.
j) An ELT is mandatory. It is probable that around 2009 the FAA will mandate it to be one which works on 121.50+406MHz, rather than the more common and cheaper 121.50-only or 121.50+243MHz types. The installation can be suprisingly expensive especiall if extra metalwork is required. Update 5/2010: it appears that the FAA has abandoned plans to make 406MHz ELTs mandatory (thus, a simple 121.5MHz ELT fulfills the legal requirement) but many/most European CAAs have mandated 406MHz and this applies to all aircraft flying in their airspace regardless of registration.
k) The FAA will not accept some modifications that the CAA (now EASA) will accept (and vice versa). The FAA is fussy in some departments; for example a TB20 aircraft with full TKS is certified for flight in icing on a G-reg but not on the N-reg - this is because the FAA requires two alternators and other items.
l) There are sporadic instances of non-EU aircraft requiring longer PPR notifications e.g. 24hrs instead of 3hrs. This has been noticed in Greece but there are likely many others. Entry into Turkey needs 24hr prior notice from the Turkish CAA (confirmed 2007). It is always worth faxing the destination airport regarding PPR requirements, giving the N- tail number so they can see in advance it is US registered, in case they are different to the published ones. I reckon that some of the issues I have come across with PPR might well be the result of prejudice against U.S. aircraft and this has been cited as a prime reason why owners of business jets are looking at the Isle of Man (M-reg) register.
m) The recent American TSA regulations have caused havoc with FAA training. A useful summary is here and here and it's worth noting that the TSA applies even to certain classes of FAA instruction (mainly PPL and IR) outside the USA! The Visa situation is more of a grey area but it is most likely needed for a PPL or an IR. Getting FAA training in the UK is not much of a problem but getting checkrides organised in the UK is difficult. More details are in this article.
n) In the USA, FAR 91.175 prohibits an instrument approach other than using an official instrument approach procedure (IAP), and this possibly applies to N-reg aircraft worldwide. More details here.
o) Going back to G-reg can be problematic. Think about this carefully! There are cases where an aircraft with certain certification issues can exist on a G-reg, but it could not be placed on G-reg today. Of course they have to get a CofA every so often (or the EASA equivalent these days) but that is not the same as an initial CofA, which involves an inspector crawling all over the aircraft and checking that every non-original item (well, every item he can spot) has acceptable documentation. If you go to N-reg and then want to go back, you might get caught by this - even if you have not done any mods. The EASA 12-year engine life issue is one recent issue. However, the whole EASA business (Part M specifically) is in a state of flux and nobody knows what will happen. There is also the more general problem (see h) under Benefits above) that a part can be fitted to an N-reg purely on the basis of an STC or PMA approval, signed off by an IA, but such an aircraft cannot go back on G-reg unless the part came with additional documentation; more details here.
p) While a US based owner can choose which U.S. mainland FSDO he uses to approve a modification, non-US owners have to go via the NY IFU, but the NY IFU stopped processing avionics 337s around 2010. There are ways around this, by using a DER to generate approved data which is then submitted via a different process, but this is a lot more expensive. Some details are here.
q) Denmark has some curious regs banning the basing of foreign reg planes there, particularly by Danish residents URL local copy Google translation. There are reports of fines being imposed (around £300) but it does not appear the legality of this policy has been tested properly. It is obviously very difficult to frame legislation which imposes a long term parking time limit, so any practical implementaton is bound to be ad hoc.
r) In 2012, the EU has finally passed into law some ludicrously vague proposals requiring all pilots to have EASA licenses/ratings regardless of aircraft registration, if the "operator" is EU based. More links are at the end of this article. Some countries have opted for a 2 year delay (to April 2014) but, for IFR, this will eventually cause a significant increase in the effort to reach IFR capability and will reduce the incentive to own an N-reg aircraft to cases where the more reasonable certification regime (unusual equipment, mods, etc) is sufficiently relevant.
Benefits and Drawbacks Summary
For most private pilots and given an aircraft that can be registered under G or is already, there is no significant benefit in the N registration, particularly given the cost of the transfer (see more details below). The most pressing reason is likely to be the FAA IR. Other reasons might be the wish to fit certain items (typically avionics) for which obtaining EASA approval is unrealistic, or the wish to purchase an aircraft (from e.g. the USA) with such items already fitted. In a few cases it can be medical issues related to the JAA IR which is probably the JAA audiogram requirement.
I also think that there is very little difference in the cost of scheduled maintenance - if you do the stuff that is actually important for safety and long airframe life. The major cost savings come from the ready use of FAA STCs, and - given the EASA Part M regime now running in Europe - from the ability to use freelance FAA A&P/IA engineers.
Come on, prove that you really know how to cut and paste in an Ipad. I can't.
But as I am in a good mood I will save you the work:
Drawbacks:
a) For full worldwide privileges, the pilot needs an FAA License. One can fly an N-reg on a UK/JAA license but only within the UK (not the Channel Islands). In fact any ICAO license is OK but FAR 61.3 limits its use to the airspace of the country that issued it. Whether the UK NPPL is OK is a good question; similarly there has been some doubt over whether the UK IMC Rating is valid or whether a UK/JAA PPL with a night qualification can be used to fly an N-reg at night in the UK; more info here.
a1) While FAR 61.3 allows an N-reg to be flown outside the USA on any foreign license provided that license has been issued by the owner of the airspace concerned, the airspace owner is able to disallow this. I have a confirmation (1/2008) that Belgium does this, and requires any N-reg flown in its airspace to be flown under either an FAA license, or a FAA validation of a Belgian license (no indication this is enforced). There may be other instances of this. However, 61.3 is not a useful concession since most pilots only have one license and thus the aircraft cannot leave the one country...
b) There was a question mark over the ability to rent out an N-reg aircraft, and common rumour has been that a Dry Lease is required if one does so. The legislation (FAA and UK) is silent on this subject, and extensive enquiries have not found anything supporting the Dry Lease requirement. On 1st March 2005, Roger Kinsey at the DfT confirmed to me that renting is OK provided the renters don't do any aerial work in it. The DfT will not (officially) give permission to anyone who has rented an N-reg aircraft, even for any form of training and that includes a BFR (unless the instructor does it for free - see the link in g) below) but in practice they are quite helpful, so it's always a good idea to ask them. So anyone renting an N-reg aircraft (UK airspace) needs to already be legal to be PIC in the type. More details here.
c) Cannot do PPL Cost Sharing. Even though the FAA does have such a scheme, it cannot be operated in UK airspace on a foreign registered aircraft as this would breach 2005 ANO Article 140. Passengers are not permitted to make any contribution to costs in UK airspace. There is also the theoretical possibility that a payment from a passenger on a flight which took place wholly within a country where the aircraft is not registered could be regarded as cabotage. I carry a letter from a senior French Customs official assuring that cabotage will not be applied to private flights, but there is the possibility that they might not regard such as a "private" flight to start with. The safest thing is for the pilot to not accept any money from passengers, in an N-reg flying in Europe, and make this very clear before the flight (before witnesses, if the passengers are not known to the pilot
).d) Document checks: U.S. registered aeroplanes are provocative to people who do not like U.S. foreign policy and while the European aviation world is nearly universally professional there are sporadic exceptions where Customs/Police officials do targeted document checks, so documents must be carried on board and be in order. In particular, they look for a document showing EU VAT has been paid on the aircraft, and for the pilot's IR if he arrived via an IFR flight plan / instrument approach. Under an EU VAT treaty, a country has the right to query the VAT status of any aircraft which is registered within that same country, or outside the EU. These checks have been reported in France and Germany in particular. It would probably be unwise to take a flying holiday around Iran, of course... Also, each pilot flying under the privileges of an FAA license, outside U.S. airspace, needs to have his own radio license; details in the Documents link above.
e) While most European maintenance shops do maintenance on N-reg aircraft, few of them have actual FAA approvals for anything. They can do the work by getting an FAA IA to come in and sign it off, but for many items (e.g. pitot-static system test) they have to get someone to come in who charges substantial hourly and travelling fees. This can increase costs.
e2) For Major Alterations, the common US system for field approvals, whereby a 337 is filled in by an IA and sent off to the local FSDO for approval, is not available to European N-reg owners. The only FSDO available for Europe is the NY IFO and they have stopped doing this work several years ago. The only remaining "official" option is to get a DER to generate an 8110-3 form which is then sent with a 337 to the FAA in Oklahoma for filing (they cannot, in general, refuse it) and this route (popular with European avionics shops) can add quite a bit of money and effort. However, a lot of installations can be done as Minor Alterations, using e.g. the Installation Manual as the Approved Data - it is up to the IA to determine if there is enough Approved Data. It is however also possible to process a 337 + Approved Data conventionally via a normal US FSDO, if you can find a co-operative one, as described here.
f) Prices charged to N-reg owners are more likely to get inflated than to G-reg owners. This is probably because N-reg planes tend to be owned by the pilot and so they get looked after better than the average G-reg self fly hire machine. A quick look around any European GA airfield shows the generally higher standard of N-reg aircraft over locally registered aircraft. It pays to get educated on how much something should cost before getting work done.
g) Any aerial work (which includes instruction or BFRs, if the instructor is being paid for it) requires permission from the DfT. More details here.
h) The trust requires you to sign the aircraft over to somebody that you have to trust and in theory they could just run off with it. I am not a lawyer but apparently this is very difficult for them to do (because the trust document obliges the legal owner to allow the beneficial owner to do more or less whatever he likes) and some also have insurance to cover various things. I have checked with one of the UK's largest aviation insurance firms and it is not possible for the beneficial owner to insure against a breach of the trust. They were unconcerned about it however, stating that one can get more problems if the US citizen that runs the trust dies. It's worth checking with him what provisions have been made for such cases. Update 2010: this has actually happened; the owner of Southern Aircraft Consultancy, Warren Chmura, did die in a motoring accident, but his brother (also a US citizen) took over immediately - just as he said would happen when I put the question to him years earlier.
i) If flying under a standalone FAA license, the pilot needs the FAA Class 3 medical as a minimum. The FAA Class 3 has stirred up some controversy, perhaps because it doesn't include an ECG. However The FAA Class 2 doesn't have an ECG either, below a certain age. ICAO does permit a national authority to impose its own medical requirements on resident pilots; this is rarely invoked but in 2004 the Irish CAA has reportedly taken advantage of this and refused to accept the FAA Class 3 for Ireland-based N-reg pilots. For some reason a FAA Class 2 is a lot cheaper than the CAA Class 2. For me, £60-80 against £150 for the CAA Class 2, both being very similar and done within 2 weeks of each other, and the FAA one was slightly more stringent (for me) on the eyesight. The FAA Class 3 is valid for an extra year but I reckon that one may as well go for the FAA Class 2, to avoid any potential for future trouble. Personally I hold an FAA Class 1 medical, which still costs only about £80, for both initial and renewals, while the CAA Class 1 initial is over £300.
j) An ELT is mandatory. It is probable that around 2009 the FAA will mandate it to be one which works on 121.50+406MHz, rather than the more common and cheaper 121.50-only or 121.50+243MHz types. The installation can be suprisingly expensive especiall if extra metalwork is required. Update 5/2010: it appears that the FAA has abandoned plans to make 406MHz ELTs mandatory (thus, a simple 121.5MHz ELT fulfills the legal requirement) but many/most European CAAs have mandated 406MHz and this applies to all aircraft flying in their airspace regardless of registration.
k) The FAA will not accept some modifications that the CAA (now EASA) will accept (and vice versa). The FAA is fussy in some departments; for example a TB20 aircraft with full TKS is certified for flight in icing on a G-reg but not on the N-reg - this is because the FAA requires two alternators and other items.
l) There are sporadic instances of non-EU aircraft requiring longer PPR notifications e.g. 24hrs instead of 3hrs. This has been noticed in Greece but there are likely many others. Entry into Turkey needs 24hr prior notice from the Turkish CAA (confirmed 2007). It is always worth faxing the destination airport regarding PPR requirements, giving the N- tail number so they can see in advance it is US registered, in case they are different to the published ones. I reckon that some of the issues I have come across with PPR might well be the result of prejudice against U.S. aircraft and this has been cited as a prime reason why owners of business jets are looking at the Isle of Man (M-reg) register.
m) The recent American TSA regulations have caused havoc with FAA training. A useful summary is here and here and it's worth noting that the TSA applies even to certain classes of FAA instruction (mainly PPL and IR) outside the USA! The Visa situation is more of a grey area but it is most likely needed for a PPL or an IR. Getting FAA training in the UK is not much of a problem but getting checkrides organised in the UK is difficult. More details are in this article.
n) In the USA, FAR 91.175 prohibits an instrument approach other than using an official instrument approach procedure (IAP), and this possibly applies to N-reg aircraft worldwide. More details here.
o) Going back to G-reg can be problematic. Think about this carefully! There are cases where an aircraft with certain certification issues can exist on a G-reg, but it could not be placed on G-reg today. Of course they have to get a CofA every so often (or the EASA equivalent these days) but that is not the same as an initial CofA, which involves an inspector crawling all over the aircraft and checking that every non-original item (well, every item he can spot) has acceptable documentation. If you go to N-reg and then want to go back, you might get caught by this - even if you have not done any mods. The EASA 12-year engine life issue is one recent issue. However, the whole EASA business (Part M specifically) is in a state of flux and nobody knows what will happen. There is also the more general problem (see h) under Benefits above) that a part can be fitted to an N-reg purely on the basis of an STC or PMA approval, signed off by an IA, but such an aircraft cannot go back on G-reg unless the part came with additional documentation; more details here.
p) While a US based owner can choose which U.S. mainland FSDO he uses to approve a modification, non-US owners have to go via the NY IFU, but the NY IFU stopped processing avionics 337s around 2010. There are ways around this, by using a DER to generate approved data which is then submitted via a different process, but this is a lot more expensive. Some details are here.
q) Denmark has some curious regs banning the basing of foreign reg planes there, particularly by Danish residents URL local copy Google translation. There are reports of fines being imposed (around £300) but it does not appear the legality of this policy has been tested properly. It is obviously very difficult to frame legislation which imposes a long term parking time limit, so any practical implementaton is bound to be ad hoc.
r) In 2012, the EU has finally passed into law some ludicrously vague proposals requiring all pilots to have EASA licenses/ratings regardless of aircraft registration, if the "operator" is EU based. More links are at the end of this article. Some countries have opted for a 2 year delay (to April 2014) but, for IFR, this will eventually cause a significant increase in the effort to reach IFR capability and will reduce the incentive to own an N-reg aircraft to cases where the more reasonable certification regime (unusual equipment, mods, etc) is sufficiently relevant.
Benefits and Drawbacks Summary
For most private pilots and given an aircraft that can be registered under G or is already, there is no significant benefit in the N registration, particularly given the cost of the transfer (see more details below). The most pressing reason is likely to be the FAA IR. Other reasons might be the wish to fit certain items (typically avionics) for which obtaining EASA approval is unrealistic, or the wish to purchase an aircraft (from e.g. the USA) with such items already fitted. In a few cases it can be medical issues related to the JAA IR which is probably the JAA audiogram requirement.
I also think that there is very little difference in the cost of scheduled maintenance - if you do the stuff that is actually important for safety and long airframe life. The major cost savings come from the ready use of FAA STCs, and - given the EASA Part M regime now running in Europe - from the ability to use freelance FAA A&P/IA engineers.
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To a degree it depends on how much you have in the way of "lifed" parts, which in turn depends on the manufacturer's maintenance manual.
Obviously most planes are American, and obviously most currently flying are very old and probably no longer made, and their MMs were written decades ago when the regulatory climate was that the MM was a guide to stuff that needed to be done and the A&P knew how to really do it.
In the new European climate, the maintainer is deemed to be incompetent so the regs are much more prescriptive. This is also reflected in the Major and Minor alteration process which in Europe is very prescriptive and leaves virtually no discretion to anybody in the field.
Of course nothing actually changes; the incompetent maintainers still do half the job they are supposed to do but they have a lot more boxes to tick, and a lot of the less visible mods are simply done off the books. It's like ISO9000; the companies which made crap before make crap after, but this time the crap is shipped with a nice Certificate of Conformity. We do CofCs at work too; it's just another template in the accounts software
But the piece I really love is the utterly and completely bogus Arab Certificate of Origin which we buy for £30 from the local "Chamber of Commerce" and charge to the customer at £100 Which reminds me... at £25 we charge too little for an EUR1
ps Most IAs in Europe are freelance too. I think some are employed by FAR 145 repair stations... but even the employed ones tend to freelance. The way maintenance works is the work is actually done by a normal EASA company and they charge you their standard Part M fee (say £2500+V for a TB20) but instead of you getting a release to service at that point, they (or you) being in the IA, he checks everything, and he types up the RTS, and you pay him personally. So it costs you more than if you were G-reg
Obviously most planes are American, and obviously most currently flying are very old and probably no longer made, and their MMs were written decades ago when the regulatory climate was that the MM was a guide to stuff that needed to be done and the A&P knew how to really do it.
In the new European climate, the maintainer is deemed to be incompetent so the regs are much more prescriptive. This is also reflected in the Major and Minor alteration process which in Europe is very prescriptive and leaves virtually no discretion to anybody in the field.
Of course nothing actually changes; the incompetent maintainers still do half the job they are supposed to do but they have a lot more boxes to tick, and a lot of the less visible mods are simply done off the books. It's like ISO9000; the companies which made crap before make crap after, but this time the crap is shipped with a nice Certificate of Conformity. We do CofCs at work too; it's just another template in the accounts software
But the piece I really love is the utterly and completely bogus Arab Certificate of Origin which we buy for £30 from the local "Chamber of Commerce" and charge to the customer at £100 Which reminds me... at £25 we charge too little for an EUR1 ps Most IAs in Europe are freelance too. I think some are employed by FAR 145 repair stations... but even the employed ones tend to freelance. The way maintenance works is the work is actually done by a normal EASA company and they charge you their standard Part M fee (say £2500+V for a TB20) but instead of you getting a release to service at that point, they (or you) being in the IA, he checks everything, and he types up the RTS, and you pay him personally. So it costs you more than if you were G-reg
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No I won't, I can't be bothered copying and pasting proudpilots posts to show the other side of the coin.
Its still not going to change the fact that they have set things up for you to be shafted.
Its still not going to change the fact that they have set things up for you to be shafted.
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To get an IA, an A&P mechanic takes a short writtten test and thereafter does enough inspection related work to maintain it. It isn't rocket science.
Same with AMEs - it's very much dead man's shoes now.
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Its still not going to change the fact that they have set things up for you to be shafted.
You would withouit doubt love us N reg guys to be shafted as you put it!
Dont deny that because you would!
You may or may not be right as anyone posting here as none of us know.
All I can say is I took the problem to a Negotiator with the Bi lateral agreement and suggested I started the process of converting my licences.
Financially the ground exams are not a major expense item so it would have been an easy option to tell me to get on and do the exams.
Far from that his advice was to do NOTHING!
I presume you know more than those involved in EASA and those involved with the Bi Lateral agreement?
You may infact be correct but I would rather go with the advice I am given from someone better informed than you or I!
That in a few months may change! I may be back here saying that MJ was correct! but we are all pissing in the wind.
We either accept that EASA are total liars decievers and make people like Mr Weavers of this world look like the Pope or we believe there is an ounce of genuine intent in their published actions and intentions.
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Wow..... I had no idea the UK GA licensing and certification system was so corrupt. have you thought about sharing your evidence with the UK CAA Peter?
Bose I did and the CAA did the square root of zero. Full evidence I might add. I would name and shame the CAA individuals but the Mods might run.
Totally happy and SAFE on N reg thank you
*
Bose I did and the CAA did the square root of zero. Full evidence I might add. I would name and shame the CAA individuals but the Mods might run.
Totally happy and SAFE on N reg thank you
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I wouldn't actually on a personal level.
But I do agree that residents should be subject to the local regulation.
I have sat on the side lines of other processes with feelings of unease and then bitten the bullet and covered my arse to be proved correct or at least partially correct, enough so that my investment was good.
In fact I made the call on this issue in 2001 when training it was obvious to me then with JAR that the noose was tightening and they were moving towards ending it. Its taken longer than I thought more than likely due to GWII and Afganistan and the bank crisis.
Why should EASA be any different to any other political body?
Getting angry with folk that don't tell you that its all going to be fine isn't going to help your plight.
But I do agree that residents should be subject to the local regulation.
I have sat on the side lines of other processes with feelings of unease and then bitten the bullet and covered my arse to be proved correct or at least partially correct, enough so that my investment was good.
In fact I made the call on this issue in 2001 when training it was obvious to me then with JAR that the noose was tightening and they were moving towards ending it. Its taken longer than I thought more than likely due to GWII and Afganistan and the bank crisis.
Why should EASA be any different to any other political body?
Getting angry with folk that don't tell you that its all going to be fine isn't going to help your plight.
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When EASA is basically rewriting the FAR's then I think it's everyone's problem. As a previous post stated the FAA don't have a problem with foreign reg aircraft based on their soil.
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They are just the same as the FAA is political as well.
There is no way that the ATC in the US could be shafted as it has been without it being a political call.
As for the power thing yep they can dictate to EASA the way they want it to go. As per every other body be it finacial or any other type of body.
And to answer the worries of people about me line training.
We had a good week.
25 approaches 18 of which were RVR's and sub 500ft cloud base. 18 NPA in class G so full procedure. 20 hours block time.
The FO did pretty well, only had to take it 5 times with him having 165 hours TT not suprising. He attempted 20 approaches.
He is now in his bed (9pm local) and I am having a beer. A knackaring week but as usuall a very rewarding week for myself.
There is no way that the ATC in the US could be shafted as it has been without it being a political call.
As for the power thing yep they can dictate to EASA the way they want it to go. As per every other body be it finacial or any other type of body.
And to answer the worries of people about me line training.
We had a good week.
25 approaches 18 of which were RVR's and sub 500ft cloud base. 18 NPA in class G so full procedure. 20 hours block time.
The FO did pretty well, only had to take it 5 times with him having 165 hours TT not suprising. He attempted 20 approaches.
He is now in his bed (9pm local) and I am having a beer. A knackaring week but as usuall a very rewarding week for myself.
Last edited by mad_jock; 27th Apr 2012 at 18:37.
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Does anyone know AOPA's stance on the latest developments ?
Firstly on the basis that there appears to be genuine intent to get such an agreement from both sides.
The stupidity of all this is at some time in the future worldwide licence standardisation and acceptance has to come.
It is the only practical solution for an industry which knows no boundaries.
With the emergence of China the industry is becoming more and more global and the need for ease of movement of pilots essential.
EASA had the opportunity of modelling part of the FAA system which like it or not is a system which is well tried and tested and works.
In that case a Bi Lateral would be relatively easy!
I see EASA as a missed opportunity based on regulatory self interest and protectionism and little more.
Maybe we are about to be shafted by EASA who as some suggest are only going through the motions to get a Bi lateral as a smokescreen for their real agenda.
If that is the case shame on them and who will celebrate that victory as we will all be losers JAA or FAA.
Especially with Europe again on a downward slide. Spain with massive unemployment levels, Italy crumbling EASA should have looked at easing pressure on the industry and hence costs not creating a burocratic minefield.
Pace
Last edited by Pace; 28th Apr 2012 at 07:31.