Threat to N Reg Operations

[andrewlt]

The Dft website now contains a warning that N reg operations in the UK may be stopped. Go to Aviation on the Dft site and then go to International Services and then Using a Foreign egistered Aircraft for Training in the UK. It says ...


It should be noted that the Department is currently reviewing the legislation affecting the use of foreign registered aircraft in the UK. It is possible that the legislation may be amended to prevent foreign registered aircraft which are not involved in commercial air transportation from being permanently based in the UK.

This was posted on Mar 14. There is now an application form for getting Sec State's permission to train on an N reg aircraft in the UK.

Anyone have any further info?

[UV]

Whats the url/link??
UV

[Chilli Monster]

Try HERE (http://www.dft.gov.uk/stellent/groups/dft_aviation/documents/page/dft_aviation_035972.hcsp)

[UV]

Thanks CM for the simple link!

This looks more serious than any of the "rumours" we have seen in the past.

So, the Dft are prepared to allow someone to train on their own N reg aircraft but not allow them to continue to keep them in the UK and fly them privately afterwards??

UV

[stuartforrest]

I wish they would make their bloody mind up quickly then because I spent £7k putting my Bonanza on the N so I could do an FAA IR and it looks from that that it may have been a waste of time and money. I have also just been to the states for my FAA PPL.

If I knew what they were going to do I could decide whether to put it back on the G. I wonder how long this review will take?? Anyone have any idea.

[Flyin'Dutch']

And the news is?

[stuartforrest]

Flyin Dutch

What is that meant to mean. Is this not news. I have heard plenty of worrying rumours before but this seems pretty subsantantial. I didnt understand your comment. Are you saying this isnt a problem?

[DFC]

What is even more interesting is item 7 of the application form;

Confirmation that, to the best of the applicant's knowledge, the person(s) to be trained meets the medical standards for pilots established in Annex 1 to the Chicago Convention.

The FAA medical standards are in some cases lower than ICAO and that is one of the reasons why people go down that route. Thus unless the application was done on the basis of crew holding ICAO or JAA medicals then one could not confirm item 7!!!!!.

Regards,

DFC

[GRP]

I honestly can't say I am surprised. The N reg route to an IR has received a considerable amount of coverage in the aviation magazines in recent months and I would imagine that the number of G reg aircraft moving to the N reg and staying here in the UK has been steadily rising in that time. Recent events have probably also resulted in a noticeable increase in applications for permission to do training at the DfT.

We can only hope that somewhere in the midst of this review somebody will stumble upon the simple reason that this is happening and that common sense will prevail. All they need to do is to make the IR something that is as attainable (or nearly so) as the FAA version and the flow will stop and even probably reverse overnight IMHO. The specific problem that they need to address is that of requiring people to sit the full suite of 'professional' exams and to attend the ground school. The standard of theoretical knowledge required for the FAA exam is good enough for the nation with the most instrument rated private pilots so it ought to be good enough here.

Speaking for myself (N reg aircraft and planning on getting an FAA IR when time permits) if they were to find a way to solve the IR problem then my aircraft would be back on the G reg as soon as I could get it done!

[Final 3 Greens]

Sadly our nation's outlook on life tends to be "bottle half empty", rather than "bottle half full."

Thus, if public transport doesn't work too well and is very expensive, then lets punish car drivers through congestion charges.

So, regretfully, I believe that the N reg loophole may be closed and no easily accessible IR made available - I base this judgement purely on the observable decisions elsewhere.

[stuartforrest]

I have to agree. I put my plane on the "N" just so I could do the FAA IR and have spent a lot of money and effort when I would much rather have kept it on the "G" and it beggars belief that somebody involved in UK aviation cannot see the problem and put a fix together. I dont want to be a pilot of any commercial plane. I just want an IR to make my journeys safer and more achievable.

Our country is full of civil servants who have no idea they are here to "serve" the public. They believe they are here to legislate and harrass honest (and dishonest) people. They make no effort to make life easy and enjoyable for the citizens the pretend to work for.

Clearly my opinion does not include every civil servant but I suspect from the ones I have had dealings with that it is a majority. Perhaps I am just bitter after paying £50 to a dog warden who picked up my dog outside my house today (he had a tag with my address on) and took him away to a dog pound 9 miles away. (sorry I know my dog has got nothing to do with aviation)

If I was Prime Minister.................

[stuartforrest]

The low down and straight from the horses mouth.

I have just come off the phone to a Duncan Nichols who is the man at the DfT who is reponsible for conducting a review into "N" reg operations in the UK.

He was extremely helpful and pleasant and he was happy to talk about the process they are going through.

He told me that he has been tasked for about 2 years with doing this review but that it has not been a priority but that events earlier this year have now made it their and his priority. He said that they have held meetings and there was much disquiet about the UK GA fleet shifting to the "N" and it was felt it should be stopped.

I had a very good conversation where I explained the private pilots perspective but he pointed out that the problems with obtaining licences was nothing to do with the DfT and was the CAA's responsibility and they had to operate in line with other european states.

I have to say that despite me spending many thousands of pounds on putting my Bonanza on the "N" last year I am now convinced that this will become outlawed pretty soon. He said that they expect to have some preliminary findings in the next few months and he will make a report to the minister who makes a decision and it will be up to him but I can tell you from the conversation that it sounds a fait acompli.

He also said "when" they make the decision they will give a time period for people to convert back. I have decided that I will have to put the FAA IR on hold for now and I will convert my Bonanza back at its annual in July unless they have said otherwise.

If anyone wants any more info from this conversation I will be happy to chat about it. Just personal message me and I will give you my phone number.

[skydriller]

This does not affect me directly, however.....

he pointed out that the problems with obtaining licences was nothing to do with the DfT and was the CAA's responsibility and they had to operate in line with other european states.

Says the guy tasked with reviewing the situation... So will his report to ministers not state WHY so many are opting to go 'N' Registered I wonder? Or was his remit to find a way to stop owners going the 'N' route?

Just interested.....

Regards, SD..

[Genghis the Engineer]

This is the point where in my office it is traditional to ask CAA

"What's the safety argument?"

Since in theory that is the ONLY basis on which they can make a change in policy.

G

[stuartforrest]

I agree and I pointed out to the man at the DfT strongly why pilots choose this route but he said that licensing was the CAA and the DfT was merely involved in this N reg bit.

Believe me I had my say after having spent many thousands of pounds putting my plane on the N Reg.

He said that he was responsible for the safe operation of planes in the UK and if they were on a different register and maintained to different rules they could not manage that.

I have to say that I agree with the logic but it doesnt half p**s me off that I have wasted money going on the N to get round ridiculous licensing laws when in reality our own CAA should look at why people are choosing to do it and fix the problem. I suppose that common sense approach is too much to ask for though??

[PhilD]

He said that they have held meetings and there was much disquiet about the UK GA fleet shifting to the "N" and it was felt it should be stopped

Did he explain why the DfT think this is a problem that needed to be stopped?

[stuartforrest]

Yes he said that it was felt that all these planes operating outside of the control of the UK authority wasnt right. (not that he felt that personally but that this was an opinion that had been widely expressed at his meetings).

I can see their point. If loads of foreign cars were driving around the UK not taxed and insured here, we as citizens may complain. When you tie it in with the reasons why pilots choose this option then it seems unfair but seperately it seems quite sensible not to allow this operation. (not that I want them to stop it of course)

[nouseforaname]

I've just been reading all of this forum so far. I've got an FAA IR and fly an 'N' airplane.

Stuart, do you know if they will put a stop to all N reg operations that aren't commercial within the UK all together or just stop 'n' reg airplanes being based here?

what i'm trying to say is if I had my plane based in France for example would I still be able to do 'N' reg. private operations in England??

TD

[stuartforrest]

Oh I dont know about that. I think you would be able to operate here as I cant see how they could stop that but they (it seems) would look to stop people basing N reg planes here. For what its worth and I have no factual basis for this I have heard in this past that France has been clamping down on N Reg for a good while.

I am pretty cheesed off because I have only just (last July) gone onto the N but it sounded pretty convincing to me that they intend to put a stop to this apart from the commercial operations.

[Cessna 210 Heavy]

This is the way I see it, not that I am any authority on the subject.

The DofT have said that the instructor must have written permission to operate a training flight within UK airspace in a non G reg. Aircraft. They have also stated that you must be a named owner of the aircraft in question to receive that training.

I see the reasoning behind this to stop FTO’s in the UK teaching non JAR qualifications. This is why you have to be a named owner in order to receive training, and the owner limit being set at 4. From what I gather this does not stop people flying N reg. Aircraft within the UK or indeed any other country. What can they do, stop all non UK Aircraft flying in UK Airspace? I don’t think that’s going to happern.

Its all in ANO 115

[stuartforrest]

Hmm I would like to agree with you but that is not how it sounded to me. Call him yourself on 0207 944 6377 (Thats his direct number)

If anyone calls him please be sensitive to quote what I have said that he said and not chinese whispers but I dont suppose there is any problem with questioning him as I did as to his feelings on what will happen etc.

He said they were particularly concerned with UK based planes being kept on forgeign registrations.

I can definately see the point on training and why they are getting so angry now but it sounmds like it may affect us all.

[skydriller]

I can see their point. If loads of foreign cars were driving around the UK not taxed and insured here, we as citizens may complain.

I have to tell you that this is actually happening now that Europe is opened up. Mrs SD works for an Export company that exports goods to Europe. The transport company used has all its lorries registered in France because it is cheaper.....

Out of interest did you get any feedback as to how they intend to stop people having a foriegn reg on their aeroplane?

Regards, SD..

[stuartforrest]

No sorry I didnt. He just said that they were doing the consultation and they would then decide if it was to be made illegal. He indicated that without pre-empting the consultation that there was a lot of feeling that this should happen.

I suppose they would have people doing ramp checks on N reg planes and seeing where they are registered or who flies them or something but then I have no idea really :)

[Cessna 210 Heavy]

I think ramp checks will be on the increase.

As for calling the guy........well I dont fly on what a guy says at the DofT. I wait until its in black and white in the ANO, thats the letter of the law.

[stuartforrest]

Ok I was only trying to help by telling you what the man said who was conducting the review. I had gone to the trouble because it worried me as an N reg owner. Unlike many postings on here this is not speculation as I telephoned the man in charge myself and I even posted his number seeing as you seem to doubt the validity.

Having said that I dont suppose there is a lot to do until we get his official findings and the official word on any changes but this info is useful for anyone who is about to put their plane on the N reg or is about to undertake the FAA IR like I was!

I will certainly be holding fire on that one for a while. Seemingly it would make sense for anyone else who has not committed a great deal of financial resources to an N reg project (either plane registration or doing a qualification) to hang fire a bit and see what happens. If you already have the N reg and the licence then there isnt much you need to do until they make their mind up but I certainly wouldnt want to start my training with this hanging over it.

[drauk]

I certainly wouldnt want to start my training with this hanging over it

If you already have an IMC rating and perhaps some instrument time in your log book then getting the FAA IR can be the cheapest route to getting a CAA IR. This is because your existing instrument time (including the IMC rating) can count towards your FAA IR, but not a CAA one. However, once you have your FAA IR you can convert to the CAA one with only 15 more hours.

Unfortunately it makes no difference to the need for the ground school requirements.

[porridge]

I have been doing FAA IR training here in the UK for a while now and have been in contact with both the DfT and the CAA. I have found them most helpfull in making sure both my clients and myself stay within the law. I think the DfT are looking more at the operations of N-reg jets etc who are running charter operations than the GA owner/operator. I think the issue is more about persons contravening Articles 29 and 115 than closing down people who want to get a FAA IR and keep their aircaft on the N-reg. This would apply also to people who are unable to get a class 2 JAA medical, but can make the FAA class 3.
As I've said, I've made sure I've complied with both the DfT requirements and also operate in strict accordance with the CAA regulations under the priveleges of my CAA ATPL and Instructors ratings and if I am in doubt I contact the CAA/DfT for clarification. I feel quite confident and comfortable with the way I operate and so do my clients who know I make sure we are both operating within the law. If someone feels inclined to prosecute me they will be hard pushed to suceed with the evidence of previous consultation I have had with the relevant departments.:ok:

[IO540]

DFC

You are back again!!!

The FAA medical standards are in some cases lower than ICAO

Reference, please.

[Cathar]

The FAA themselves admit that their medical standards for private pilots are in some cases lower than those set by ICAO and have filed the following difference with ICAO:

Private pilots shall meet the requirements of an FAA Third Class Medical Certificate, which does not fully comply with the ICAO Class 2 Medical Certificate.

[flyingfemme]

If loads of foreign cars were driving around the UK not taxed and insured here, we as citizens may complain.

Like people have been complaining about foreign cars/drivers getting away with speeding penalties...........that's actually breaking the law, as opposed to merely operating here.

Most N reg aircraft over here are also insured here - it's tough to get a US insurance company to cover aircraft not resident in the good ole US of A. Lloyds rules.

And what about French or German registered aircraft? Does it make it OK if the letter on the side is a D or and F? We can legally own them - being all good Euro-citizens now.

[IO540]

cathar

Thank you for the ref. How current is this? Someone I know checked it very recently (a few months ago) and it wasn't the case.

However, the FAA Class 2 is attainable by very nearly every N reg pilot anyway. People go for the Class 3 because it lasts longest and is the cheapest.

flyingfemme

It's easy enough to drive foreign cars in the UK permanently if for some bizzare reason one really wanted to - all you need to do is keep changing them after the prescribed interval :O

[Cathar]

The quote comes from the most recent supplement to Annex 1 published by ICAO which dates back to 2000. However, I have spoken to an FAA approved medical examiner with the last month who confirmed that differences still existed and that in one or two cases the differences were quite significant.

[Heliport]

porridge

"I think the DfT are looking more at the operations of N-reg jets etc who are running charter operations than the GA owner/operator."
That may be true of the DfT (I don't know), but I'm told reliably that the CAA are certainly looking unfavourably at N-reg in GA generally.

I suspect we'll see a change in the rules in the not too distant future, making it more difficult to operate N-reg aircraft in the UK (other than visiting aircraft), and that the CAA will influence the DfT to change its rules as necessary to achieve that goal.
eg It would be very easy to make life difficult for UK N-reg owners by requiring foreign registered aircraft resident here for more than say 12 months to be put on the G-register.
Popping out of the country for a long weekend wouldn't get around such a rule - the insurance policy would show where the aircraft is kept.

It will probably be dressed up as a 'safety' issue, of course. :rolleyes:

[Ajay @ Anglo]

Hi folks (and thanks to Bill P for introducing me to PPrune!)

Well I didn't expect my first post on this forum to be in response to such a serious issue!

As you may gather from my nick N-registration for non-US owners is part of our daily business activities and we have been in discussion with the DfT for some time on this issue. The only things I can say with any certainty are:

1. This issue has been exacerbated by the recent prosecutions and investigations into N-reg training operations, from my understanding of the reports of the recent cases it would seem these have been predicated as a means of settling a personal score rather than out of genuine concern for aviation safety.

2. EASA has not published any framework or consultative documents on some form of pan-European register.

3. As yet the ANO does not contain any provision which prohibits the basing of non-G reg aircraft in the UK.

4. Any such initiative would have to organised in conjunction with the CAA, Dft, EASA and require European and Domestic legislation to be amended/enacted - in short this will not be happening in the next few weeks!

5. Now is a time to watch and wait, I am happy to provide feedback as this issue develops. In short:

�don�t panic Mr Mainwaring!�

or maybe:

�Don�t tell him your name Pike!�

6. We will be actively involved in the consultation and lobbying process via our membership of BBGA, the NBAA and in partnership with our UK corporate clients, and our own legal team will also be making representations on behalf of our UK and European clients.

From this it may be reasonable to suppose that:

1. The transitional arrangements are going to be "interesting"�

2. The certification process is going to be complicated and confusing.

3. Are EASA/CAA/Dft going to pay spotters to log all aircraft movements to determine what constitutes "based in the UK?" - maybe that 60% or more flight time in UK airspace?

4. If at the end of this process we end up with a more accessible training regime and more practical route to instrument flying then the aviation community in the UK (and Europe) will certainly benefit. There are two prime motives for our clients moving the N-register � 1. There are more aircraft available some types are not yet certified by the CAA 2. The advanced flying qualifications are more pilot friendly. In my own experience our clients have not moved to the N-reg because of supposed easier maintenance or less stringent medical regime (NPPL anyone?)

5. I wonder what the FAA and the major aircraft manufacturers in the US think of this?

Right that�s enough for now I�m off to read the Montreal Convention and CAP 393... yawn�.

PS

Everyone should note that we are not seeking to represent all N-reg aviators in Europe or usurp the activities of AOPA, PFA, BBGA, EBAA, NBAA etc etc, we hope to be one voice amongst many although I acknowledge that we do have a vested interest due to the number of N-reg aircraft that we register and/or insure.

These posts are made primarily as a response to questions from our clients and in response to email enquiries from members of this and other forums and order to try and minimise "Chinese whispers".

I hope that together, pilots, the various flying organisations trade bodies and the General Aviation Industry in the UK/Europe in consultation with the CAA, DfT and EASA can find a sensible solution to this matter even if that means the establishment of a new UK/European licensing and training system.

[IO540]

cathar

Do you have a reference one can actually look up?

What is being suggested here, indirectly, is that the FAA Class 3 is non-ICAO but the FAA Class 2 is ICAO.

I do know that the FAA Class 3 can be non-ICAO if it has certain restrictions on it. This doesn't mean anything, because the CAA or any other national authority can do the same. Such a concession makes the license valid only in the country of license issue, and in countries which have accepted the concession. It is up to the holder of such a medical to know his rights, as usual.

I have no axe to grind since my medical isn't Class 3.

[Flyin'Dutch']

What does AOPA have to say about this all?

[n5296s]

I'm following this with great interest as a US-based pilot, with FAA IR (and N-reg plane too) who will probably one day move back to Europe.

Couple of comments for what they're worth...

1. Class 2 FAA mdical is essentially identical to Class 3. My last one I asked at the last minute "what would it take to get a Class 2?", since I was thinking of doing my CPL (still am) and didn't want to waste the time if I couldn't get the medical. "Oh," said my AME, "I just tick this box instead of this one". And I had a Class 2. There are a couple of very minor things, but I think the main difference has to do with how they deal with exceptions. Even for Class 1 the only difference was that I'd have had to do an ECG.

2. Seems to me that an FAA IR is worthwhile anyway just because from a flying pov an IR is an IR and it's not a bad thing to get the training done. The CAA IR is obviously ridiculous in its non-flying requirements but who knows whether anything will ever be done about it - it seems to me that the US is the only country where private flying is officially viewed as anything but a serious nuisance.

3. On car registration: I very happily operated a French reg car in London for several years, occasionally popping back to France for convenience and legality. They got me in the end by changing the rules for residents parking permits. However if you live outside a major town then that doesn't apply.

n5296s

[Aussie Andy]

it seems to me that the US is the only country where private flying is officially viewed as anything but a serious nuisance. In Australia they have a Private-IR, which is a sort of modular IR designed for private pilots and broken into bite-size chunks, so you get your basic then add modules per approach type you want to fly. It would be interesting to hear from some pilots based in Aus how well this works in practice? I suspect that the US model would be preferable from our (pilot's)point of view, but perhaps this Australian P-IR model would be more palatable to our new Euro-regulators?

Andy

[englishal]

The FAA medical standards are in some cases lower than ICAO
Shouldn't that read "The JAA Class 2 medical EXCEEDS ICAO standards".....by the CAA's own admission.

AFAIK if below 40, there is no requirement for an ECG in the FAA Class 2 medical which is ICAO compliant. So why do we need an ECG for a JAA Class 2 initial if below 40? And I wonder how many people are now not flying because of this.......

[flyingfemme]

AFAIK if below 40, there is no requirement for an ECG in the FAA Class 2 medical

I think it kicks in at 50 actually.

[IO540]

I had to have an ECG for my FAA C2 and I am definitely not 50 yet :O The figure is 40 or 45, I think.

I doubt the UN-qualified FAA Class 3 is non-ICAO but since so many people seem to think it is (yet nobody has yet provided a reference to this very simple and specific question) it's probably a good policy for a pilot flying an N reg'd aircraft to get the C2 medical if possible. It costs hardly more than the C3 and is likely to be half the price of the CAA equivalent for which I usually pay about £150.

[Flyin'Dutch']

IO and FF

It is for Class 1's only.

FD

[flyingfemme]

It is for Class 1's only.

Thanks FD - had me worried for a moment there. I have never had an ECG!