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N register - CAA Rumour

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Old 22nd Mar 2004, 09:00
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N register - CAA Rumour

A little birdy tells me that so concerned are the CAA about the increasing prevalence of N registered GA aircraft that are domiciled in the UK, that they are seriously considering the position regarding aeroplanes operating under flags of convenience.

The little birdy also tells me that they are in the throes of drafting legislation that may affect the operators of said aircraft. As I understand it, it is long the lines of, "those aircraft can be based here BUT must return to the country where they are registered to have their annual inspection done".

To reiterate this is just a rumour from a very well informed source, however were it to be true, I guess that it would affect quite a few Ppruners. I do not know how it would be policed or enforced - maybe ramp checks a la FAA?

Both of mine are G registered but I often borrow an N reg bipe - so I do have a limited but vested interest


Stik
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Old 22nd Mar 2004, 09:57
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Unless somebody goes on the record with this, it is just another such rumour.

I am quite certain that some people spread them deliberately, either out of a feeling of personal importance, or because they work for the CAA and they don't like the fact that the CAA isn't getting the CofA and license fees.

Which isn't to say that something isn't in the pipeline. Forcing N-reg to do their annuals in the mainland USA would be a particularly vindictive way to go about forcing GA to G-reg, while not affecting large cargo operations.
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Old 22nd Mar 2004, 10:37
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Another birdie told me recently that somebody has discovered an N-reg aircraft that had been brought over here having been de-registered, left with the N on the tail and flown in the UK for 5 years without any supervised maintenance or CofA renewal being done.

Given that the birdie who told me was a CAA maintenance standards surveyor, it wouldn't surprise me if moves were afoot !

G
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Old 22nd Mar 2004, 10:37
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Well done IO540! That killed the thread dead without any proper debate or consideration about what COULD be a very serious issue for many GA operators in this country. While you may well be correct in your assessment, I do think a thread discussing why a regulator may or may not be considering taking such draconian action and why so many people are deciding to go along the N registration path in the first place would be very worthwhile and does not warrant such aggressive sarcasm.
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Old 22nd Mar 2004, 10:52
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Maybe stik would like to indicate (no names required) where his source got the info, or to qualify the rumour in some other way. We have heard many such rumours over the years.

GG
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Old 22nd Mar 2004, 10:54
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The DGAC recently investigated the possibilities to do this and were not supported by their own aviation industry (TBMs not certified other than in France and US)

That is the word on the street.

These 'rumours' come up with a monotonous regularity.

It would be churlish to deny that in the aviation land as a whole there would not be pressures to 'rectify' the situation.

Unfortunately it may be easier and more 'convenient' to tighten
up regulations than take a good look why there are people choosing to operate under a 'foreign flag' and be proactive about these matters.

A lot of people are happy to blame the authorities for regulating things but at the end of the day that is their raison d'etre and they are trying to do the best they can within the parameters set by us as a society.

Not sure whether the tale of the inproperly registered machine is contributory to the debate as that was obviously someone who was not playing by the rules. I would certainly be unhappy if it was infered that this means that people flying N registered aircraft were somehow cowboys breaking the rules or looking for an easy way out.

For starters people flying on non G aircraft have not only to oblige with the CAA rules when operating but also the FARs.

FD
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Old 22nd Mar 2004, 11:45
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Stik

Did your little birdy tell you exactly why the CAA are 'so concerned'? If they consider this a safety issue, I would be interested to know the thinking behind it, as surely all N reg planes will be affected. If it's not safety, then what? Surely not something as trivial as loss of revenue?
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Old 22nd Mar 2004, 12:39
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My little birdy

My little birdy works within the administration of airworthiness approval.

Little birdy cheeped that the reason for doing this was because of the recent saga/fiasco with Yak maintenance and that there was also some concern that certain private operators were using the N reg whilst not always adhering to FARs.

Like I said in my initial post, it is unsubstantiated but it is the first time that I have heard anything of the like and alas I have been around GA a long time!

Stik
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Old 22nd Mar 2004, 12:41
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I don't see how they could enforce an N reg a/c being returned to the USA for the annual. The FARs require the annual to be carried out by an FAA licenced engineer, and the FARs don't specify where this maintenance must be carried out. So long as the aircraft is inspected and maintained according to the FAA regulations, then nothing else matters as far as I can see....

EA
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Old 22nd Mar 2004, 12:41
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Presumably the cost implications of closing this "loop-hole" would be enormous to owners and syndicates with N-reg planes, not to mention FAA IR ratings being difficult to use if you can't get access to an N-reg!

I've not yet got my PPL but was certainly considering going the N-reg route when qualified - hope it isn't closed off.

Would there be concerted opposition and lobbying if the CAA moved on this, or would it have to be grudging acceptance, like when the Inland Revenue closes down tax-avoidance schemes?

- Michael

Last edited by MichaelJP59; 22nd Mar 2004 at 14:45.
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Old 22nd Mar 2004, 14:41
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Based onwhat has been said, this would also put many FAA licenced engineers out of business too.

I cant see how it could be enforced without the cooperation of the FAA, and I cant also see those good folks buying into that concept either.

GG
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Old 22nd Mar 2004, 15:51
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It may be slightly different, I don't know, but last year there was a kerfuffle when Swazi-registered Gazelle helicopters were effectively grounded by the CAA. G-reg ex-mil Gazelles (not the pukka civil ones) are restricted to Permits, and this was a way round this.

Is there a parallel, and if so once a precedent's been set, may it be done again ?

I think it would be heavy handed, but then again . . .
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Old 22nd Mar 2004, 15:54
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TC_LTN

As you can see it hasn't killed the thread, and there is no need for such comments. The problem is that these "I have heard from a well placed source that..." rumours have been doing the rounds all the time I have been looking at this (3 years), here on pprune and elsewhere, and reportedly for much longer before that, while nobody whatsoever has ever backed them up. When these people are questioned further, they often vanish without elaborating - easy in an anonymous forum.

It is funny to observe that when discussing this face to face with people in the business, as I have done at every opportunity, I have never heard any such rumour.

Genghis the Engineer

Anybody (who tells everybody at his base that he gets his plane serviced somewhere far away) can fly with no CofA, no servicing, no logbooks, no pilot's license (or a forged PPL). Fine if there is no incident. Just like you can drive a car with no road tax and no insurance and no license and no MOT; if you only ever park it in a garage, there is almost zero chance of getting caught. Similarly with importing a plane without paying import VAT. This example therefore doesn't prove anything, and certainly would not be a reason to ban N-reg because one can pull the same stunt with a G-reg. The biggest risk in this activity has to be insurance (lack of), and I know for a fact that the assessor checks the lot: logbooks, licenses, any currency / type rating requirements. But insurance isn't mandatory...

stiknruda

The YAK business, as I understand it, was caused by suspect paperwork being issued by the Russian authorities to unsuspecting owners. A re-occurence of this would not be prevented by banning foreign-reg aircraft resident here, because a plane in any condition whatsoever (safe or unsafe) can fly over to the UK from anywhere and hang about here as long as it wants, especially on a farm strip where nobody might care.

Banning N-reg would be a disaster for the mostly-serious PPLs who have invested lots of time and money into the FAA PPL/IR route. These are generally skilled pilots with lots of currency and I would bet the planes, being mostly privately/business-owned, are well above the UK average GA aircraft condition. Therefore there cannot be a safety case for doing such a thing.

It could be a revenue raising measure, of course, but the motivation for raising more money has always been there.

I am sure the CAA read everything here and always have done. They know exactly why most people go N-reg:

- the FAA IR

- planes which cannot be G-reg e.g. the Cirrus and the new TBM700 variant

- planes which have non-CAA-approved addons fitted (e.g. aftermarket turbos, different types of wingtip lights, but I can't think of any example which has a safety issue)

- planes flown by people who already have FAA licenses and don't see why they should waste money getting CAA licenses

- the FAA PPL / Class 3 medical will enable some people to fly when they can't get the CAA Class 2 medical, but evidence from the USA shows there is no detectable safety issue with that

Are there other reasons? There is an easier maintenance regime but it's comparable to the G-reg Private CofA.

The CAA must have always known all this. Why act now?

Perhaps it is time for somebody in the "trade" to confront them directly and get a statement out of them. There would be nothing to lose.
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Old 22nd Mar 2004, 16:03
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Are there other reasons? .........

Why act now?
"National Security" issues? Seems to be the Guv'mints reason to interfere with other liberties we think we have. Maybe they don't like all these planes flying around which they cannot force Mode-S into? Maybe TSA want to regulate overseas N-regs a bit and the CAA are being poodles. Or something similar.... Bl00dy hell, sound like some mad conspiracy theorist...
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Old 22nd Mar 2004, 16:21
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planes which have non-CAA-approved addons fitted (e.g. aftermarket turbos, different types of wingtip lights, but I can't think of any example which has a safety issue)
Or a negative safety issue...what about ballistic parachute systems, which were freely available on certain FAA types, saved lives, yet were not allowed in the UK....how mad is that? I dunno if its changed at all now....

The problem with GA in Europe, is that its treated in a special way ("ooh no sir, you can't possibly change that light bulb, without filling in forms 1020,1030,1050, in triplicate, then applying to the CAA, waiting 10 monthsm, then paying a large fee, then get a CAA approved engineer to charge you £10,000 for it"), when all it really is is a form of transport to many. Would be great if I could commute to work by plane, but unfortunately unless I get that £500,000 / week job as an F1 driver, its not going to happen. Whereas, if I lived in America, there is a real possibility that I could commute to work by aeroplane, indeed many *normal* (ie. other than the very wealthy) people do (live in Santa Maria, work in Santa Barbara, and its a quick 15 minute hope over the mountains....beats driving). And as stated, there is not a difference in pilot skill / aircraft airworthness between this side of the pond and the other.

Maybe if Private GA wasn't so costly due to regulations, then maybe people could afford the Mode S transponder

Right off my soap box....

EA
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Old 22nd Mar 2004, 17:14
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Snoop

The same discussions come up in Germany regularly. I did read somewhere that it's the FAA that requires N registered aircraft to spend a certain number of months in the USA, not the European governments!! I don't have the details, but it would be interesting to know what the FAA thinks about aircraft stationed overseas.......

Westy
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Old 22nd Mar 2004, 17:58
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I have also heard a whisper about this, but from the Department for Transport.......Maybe it is down to national security issues?? Something about an aircraft 'registered' in the USA, painted as such and operating over here, but not actually registered anymore with the FAA! Who's to know if it's actually registered apart from the FAA, who tend not to be looking much in the UK.

Lots of whispers together normally make a loud noise at some stage.
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Old 22nd Mar 2004, 18:35
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It has been noted that rumours have been doing the rounds at least 3 years and that nobody has backed them up. This may well be because people in the CAA and DfT are asking questions and thinking about the issue but have not yet formulated a firm view. My experience from contact with the CAA and DfT is that they can take time to address some issues. Take alcohol limits and police testing powers. These were first recommended by the AAIB in about 1991. The DfT issued a consultation paper on proposals in 1996 and legislation was made in 2003. That legislation will not come into effect until later this year.

Questions are also raised as to motive. I think the answer that is clear if you think about it. The Government is responsible the safety of aviation in the UK. Through Parliament it has established a regulatory regime and given the CAA the function of regulation aviation safety standards. By keeping and operating a foreign registered aircraft in the UK the provisions established by Parliament for the good of the population of the UK as a whole are being bypassed and responsibility is in effect being delegated to the authorities of another country. While the difficulties this could cause may be ignored if the number of aircraft involved is limited, it becomes more difficult for them to ignore if the scale of foreign aircraft operation rises. I have heard suggestions that getting on for 10% of privately operated aircraft based in the UK are on foreign registers, mainly the US, Bermuda and Cayman. The percentage appears to be a lot higher in respect of twin turbine powered aircraft.

If the CAA or DfT were to decide to do something about this, I am told the most obvious solution would be to follow the Canadian requirements which automatically grounds foreign registered privately operated aircraft if they have been Canada for more than 90 days in the preceding 12 months.

It is my understanding that the FAA, at a technical level at least, would be fully supportive of such action.
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Old 22nd Mar 2004, 18:47
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How could the CAA force you to have your N reg serviced in the USA? They MAY be able to stop you having it serviced in the UK (I don't know for sure, but suspect they could), but how could they stop you having it serviced in another country?

If you F reg has to be serviced in accordance with FAA regs to stay legal on the F reg, and it's not illegal under local laws to have it serviced in a particular country, then how could they stop you?

I mean could you not fly over to Ireland, and have it serviced here by an FAA approved outfit. CAA can't tell you what you can or can't do in Ireland on an F reg aircraft, flown on a FAA PPL.

Then when you are returning to the UK, you are flying in a N reg, with all its maitenance uptodate, and with an FAA licence. ie...you are ICAO compliant.

Am I missing something?

dp
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Old 22nd Mar 2004, 18:53
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Nr F
The Swazi-registered Gazelle helicopters were grounded by the CAA.
The Swazi authority took a sensible approach and issued ex-mil Gazelles with C of A's but the CAA refused to recognise them and not only grounded the helicopters but threatened to prosecute the pilots who'd flown them on flight tests here. I assume someone with more grey cells and not as petty must have intervened because nothing came of the stupid prosecution prosecuting idea, but the Gazelles were grounded until they were put on the G register and issued with permits.

"I think it would be heavy handed, but then again . . ."

it wouldn't be the first time!
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