G-registered aircraft, operated in Germany with a FAA-license. Maintenance?

[German guy]

Hi everybody,

I strongly consider to purchase an aircraft (Piper PA28) in the UK.
I am German and also live in Germany, but would like to leave it registered in the UK,
what is possible, according to the CAA's website. The reason for this is, that I don't
want to have all the trouble of re-registering it in Germany. The other reason is, that
I hold a FAA private pilot's license and that the CAA (other than the German LBA) would
allow me to fly G-registered aircraft VFR without the need to convert the license.

Long story short - this sounds quite hassle-free and convenient.

I think that I got the registration stuff figured out, but still don't understand the
CAA-requirements regarding maintenance. I know that there is the thing called CAMO,
I know that every pilot Germany is complaining about it, but this is pretty much where
my knowledge ends.

I am now mainly wondering about two things: could I bring the aircraft to a German
CAMO-certified company to get the annual inspections done or would I need to bring it
to the UK? Is there somewhere an (easy to understand) overview of what the CAA's requirements
for the maintenance of a GA aircraft are and what maintenance the owner is allowed to do?
For example the German LBA requires an annual check of the avionics, I heard that
this is however not the case in all EASA-countries!?

Any other thoughts about permanently operating a G-registered aircraft with a FAA-license in Germany?

Cheers,

Oliver

[IO540]

the CAA (other than the German LBA) would
allow me to fly G-registered aircraft VFR without the need to convert the license.

That's true presently but may stop once EASA FCL gets going.

could I bring the aircraft to a German
CAMO-certified company to get the annual inspections done or would I need to bring it to the UK?

You can use a German EASA CAMO but they may not "fully understand" some UK CAA concessions e.g. an engine past 12 years. I know somebody who is doing this sort of thing and his locals are causing him all kinds of trouble because they refuse to believe (refuse to read) UK CAA regs on maintenance and licenses.

Otherwise, lots of people are doing this. It should not be a problem.

[AN2 Driver]

I wonder about the implications of this. Are you really allowed to fly with an FAA license on a non-FAA airplane that easily? I think that it actually would be easier (for now) to acquire an N-Registrated plane under these circumstances.

[camlobe]

Hi Oliver,

One of the few things EASA has brought us is easy to comprehend regulations. OK, maybe not, but some of the EASA regulations work well for some of us. In your case, it could work very well.

First of all, you need to understand the difference between CAMO and Maintenance.

EASA says that your aircraft must be managed i.e. a responsible person or organisation must manage the maintenance (including mandatory requirements e.g. AD's). You can do this if you are the sole owner, or you can contract this responsibility out to an approved CAMO (EASA Part M Subpart G).

EASA also says that your aircraft must be maintained.

These are two seperate issues.

If you purchase your 'G' registered PA 28, then enter into a contract with a UK based CAMO for the management of your maintenance, you can then have the maintenance carried out by an EASA licenced engineer or EASA approved maintenance organisation of your choosing (if you are operating the aircraft for private use).

The CAMO will create an approved maintenance programme for your aircraft, based on manufacturers information and regulatory requirements OF THE COUNTRY OF MANUFACTURE AND THE COUNTRY OF REGISTRATION. The CAMO will advise the maintenance organisation of what is required and raise all required scheduled maintenance. The engineer or maintenance organisation will carry out the engineering, and then return all paperwork to the CAMO. The CAMO will maintain records and if they are also EASA Part M Subpart I approved, issue your ARC (providing the engineer / maintenance organisation doesn't condem your aircraft).

Hope this helps. If you would like to know more, please feel free to PM me.

camlobe

[AN2 Driver]

Some very significant issues with CAMO.

First of all, it costs a LOT of money to have a CAMO. Count £2000 and more per year, at least here. They ask a basic fee for just having you, then a fee for every work order, then other stuff on top. I have decided for myself that if I am ever forced to enter a CAMO agreement that would be it for me as it will up the price per flying hour dramatically.

Secondly, you loose the right of say what to do and what not. You loose the "on condition" variant for engine and prop, as no CAMO will take responsibility for running an engine or prop over TBO.

Thirdly, the moment you have a technical problem outside your homebase, your CAMO has to take care of everything. You don't even have the right anymore to find a local mechanic to do simple work, EVERYTHING has to go through the CAMO, who in turn must open a work order (£££), if need be fly down a mechanic (even more £££££) and it is him who will decide as he is responsible.

[Whopity]

In the case of the UK CAA, they offer such a validation to allow a G reg to be flown worldwide VFR on an ICAO license.

Unfortunately that will cease with EASA Part FCL in April 2012

[German guy]

Hi everybody

and thanks for your answers, especially for your explanations, camlobe.
I additionally did some research over the last days about how this CAMO and maintenance stuff works and believe that I have it generally understood.
It will be my first certified aircraft as I have only owned microlights so far. I have to admit, that all this EASA-stuff doesn't make me too happy...

It would be OK with me to convert my FAA license, but then again, why should I if I don't have to? I am not specifically looking for a G-registered aircraft, the PA28 however seems to be nice and the CAA's regulations would be a nice add-on.

Purchasing an N-registered aircraft to completely avoid all the EASA regulations could be another tempting options - at least as long as the EASA doesn't ban them from the European airspace. The availability of N-registered aircraft on the European market is also very limited and ferrying one from the US to Europe will probably not be worth it. At least not for an airplane in my price region, which is around 30.000 €.

Cheers,

Oliver

[Ultranomad]

The availability of N-registered aircraft on the European market is also very limited and ferrying one from the US to Europe will probably not be worth it. At least not for an airplane in my price region, which is around 30.000 €.

For some types (e.g. Mooney) it's just the opposite - the vast majority of inexpensive Mooneys on the European market are N-reg, which makes them a big hassle to register under EASA.

[IO540]

Current EASA proposals are to leave N-reg airframes alone, so long as they meet the EASA definition of 'non complex' (under 5700kg, under 19 seats, piston, or SE TP).

Foreign reg planes may require an EASA (not just ICAO) Type Certificate. Nearly all have that anyway but a few don't. However there is a typo in the OPS proposal around this area.

The current proposal however is to require the pilot to have EASA license/rating to fly it in EU airspace, if the 'operator' (term not defined) is 'resident' (term not defined) in the EU.

[German guy]

So, what are you guys proposing?

As mentioned, I would be willing to get my FAA-license converted, but would of course also be happy if I wouldn't have to. Especially, as I want to keep flying in the US, which would mean that I need two medicals and flight reviews for two licenses.
Not a too big deal, but then again if I don't have to....

I am absolutely uncertain of what I should do and the ongoing discussions regarding the operation of N-registered aircraft in Europe, flying with foreign licenses and all the other 'improvements' which are currently discussed don't make it easier.

CAMO and avionics inspections also kind of spook me off. I think I start to loose the motivation for owning an aircraft. If only the useful load of microlights wouldn't be that bad, I would simply stick with them....

Cheers,

Oliver

[IO540]

Nobody is certain of anything.

I am on N-reg and will stay on N-reg, for the reasons I posted above.

If a microlight meets your mission requirements then stay with microlights

[AN2 Driver]

I am absolutely uncertain of what I should do and the ongoing discussions regarding the operation of N-registered aircraft in Europe, flying with foreign licenses and all the other 'improvements' which are currently discussed don't make it easier.

CAMO and avionics inspections also kind of spook me off. I think I start to loose the motivation for owning an aircraft. If only the useful load of microlights wouldn't be that bad, I would simply stick with them....

That is exactly how a huge part of us feel. I am in the "comfortable" situation of owning an airplane which is of the same register as the country it's operated in and the license I hold (all Swiss). Yet I am constantly discovering new threats to GA from all over the place. Yet, if we all just fold and hand over and trash our dreams into the bureaucrat's dustbin, what good will that do?

Practically, with your FAA license it would be the easiest and most economical way to go for a N-reg, were it not for the loom and gloom of EASA's guilloutine threat on that. Other than that, it is in my opinion the best way to go. Lots of choice and all those STC's available give you a much better bang for buck than European. Other than that, I can see some interesting looking PA28's on German register around as well.

Friend of mine runs a G-reg Mooney M20E in Slovenia, maybe you'd like to ask him how he cares for this. His blog is here :

http://jsenegacnik.********.com

He also used to run a D-Reg Piper there. He'll probably be able to give you some insights on how to operate a G-Reg outside Brittain.

[IO540]

I know Jose

I also think that there is a whole load of absolute shysters hanging around the Part M CAMO scene, who shaft aircraft owners who are less than on the ball on the procedures (which is the great majority). I say this because a lot of owners don't have the problems which the pilot forums are full of. Or, putting it another way, they seem to find CAMOs which apply a bit of "French pragmatism/imagination" to the paperwork issue.

Re doom and gloom, there is always doom and gloom. GA runs on 3 things: avgas, doom, and gloom. In the meantime, everybody is getting older and if they just got on with it, they would get years of flying in before anything "might" actually happen. Even the EASA FCL proposal (which is so aggressive few people believe it will happen as proposed) is not due till 2015 or so.

When I was doing the FAA IR, 2006, there was as much doom and gloom. The UK was going to kick out N-regs after 90 days' parking anywhere in the UK (even parking inside a maintenance hangar, waiting for parts). So what happened? Zilch, and I've had 5 years of fantastic IFR flying around Europe.

[AN2 Driver]

You are very right. However, the damage the incertainty does to the industry is tremendous. Lots of investments are in question these days because nobody wants to comit large sums of money into something which is unsure if it will still be around. I've been wondering if to go N-Reg or to do a trip to the US to get the IR there rather than reviving my JAR one would be the way to go. My aircraft is fully IFR according to US standards but some 10s of k's away in EASA land. I won't do that howerver before EASA FCL is fact and we know what the story is.

I reckon VFR and "basic" aircraft under owner/pilot usage will not be too much trouble. Go IFR, try to rent it out to someone to share costs, and things go pear-shaped a lot and fast. CAMO can mean an increase of cost per hour of up to £100 (based on 100 hours yearly useage and the fact that under CAMO no "on condition" is possible e.t.c.). For what? Do I increase ANY safety? Nope.

That is why I have a bit of reservations about operating an EASA registered plane with a FAA license in an EASA country which is not it's registrar state. Therefore better ask someone who's done it...

You know all the right folks We should get together some time, would be the best anti gloom treatment in a while

Best regards
AN2

[IO540]

the damage the incertainty does to the industry is tremendous

Very true, but this is 100% intentional.

If I was in the EU job protection / gravy train racket, I would be doing the same. Fear, uncertainty and doubt are very cheap to spread, and are effective in keeping a lid on foreign reg operations. Throw in some of the real hassles (like getting FAA checkrides in Europe, the need for a trust, certification hassles on mods) and the job is done

In fact you don't need to spread FUD yourself. Just let pilots do it for you. There is always some pilot forum personality who says your days are numbered. Flying school employees spread this stuff all the time - on forums and to everybody who walks through the door. Most of these people haven't got a clue about the actual regs, actual or proposed.

VFR will always be easy in regulatory terms because ATC retain the "nuclear button" ("remain outside controlled airspace, goodbye"). This takes out all the regulatory emotion out of VFR. It doesn't matter how far you propose to deregulate VFR, professional pilot and ATC representatives will not be bothered, because all this dross can be kept OCAS.

The moment the I-word is used, however, everybody crawls out of the woodwork and requires an I-word-capable pilot to pass the same exams, have the same medical, etc, as the commercial traffic. Superficially one can understand this, but there are many reasons why it is wrong. IFR GA flies in a mostly different airspace, and causes no problems to ATC. Most of the commercial ground school is not relevant to private ops (or to anything else actually but you can't say that ).

I have a bit of reservations about operating an EASA registered plane with a FAA license in an EASA country which is not it's registrar state

The only European country I know of where you can do that is the UK. The UK automatically validates any ICAO PPL for a G-reg, VFR. The others will mostly do validations, but with various daft conditions e.g. you must not be an EU citizen, etc. But this is likely to stop post-2012.

I don't see a huge use for this type of validation however because a Euro PPL is easy to get, especially if you already have an FAA one and loads of hours. The medical is the only possible big issue, but there are not many health issues where the FAA will give it to you but JAA won't - especially if you can get in under Demonstrated Ability.

I'll pop over to Zurich fairly soon

[German guy]

I think I will reconsider the idea of getting a N-registered aircraft. Having a N-registered aircraft to hand would also allow me to make use of my FAA-instrument rating here in Europe, on which I'm currently working.