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Annex 2 planes, G-registered, non UK-based

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Old 1st May 2017, 17:25
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Annex 2 planes, G-registered, non UK-based

I remember reports about a tendency for the LAA to not accept members/aeroplanes based outside the UK. This brought issues to the many owners of non-UK based permit planes, who found it ever harder to get their annual done.

Now I hear about a radical change: at Antwerp Airport EBAW there was the founding meeting of a Belgian LAA strut. It is not clear to me, though, what the precise practical implications will include. But there was no lack of interest, not at all.
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Old 2nd May 2017, 07:46
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Hi Jan,
I don't think the LAA has a problem with aircraft being based abroad, as long as they comply with local regulations. How will the Belgian strut aircraft comply with the 'Temporary permission to fly over Belgian territory', which is only valid for 30 days in a year, requires a FPL for each flight (including those within Belgium) and an email giving details of each flight to the Belgian CAA?

I know there are many French and German registered ULM permanently based in Belgium.
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Old 2nd May 2017, 16:27
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Are we talking about Annex 2 or LAA permit here? Because they are not the same thing. I keep an Annex 2 aircraft in France, no problem.
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Old 2nd May 2017, 16:37
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Since the OP mentions an LAA Belgian strut, I understood it involved (UK) LAA permit aircraft. Probably got hold of the wrong end of the stick.
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Old 2nd May 2017, 17:27
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As I understood things - but I am only looking on from a distance - the audience consisted mostly of people either operating a G-reg "permit" plane based outside the UK, or intending/planning/hoping to do so.

But if I opened the thread, it was in the hope of better understanding what and why. @Piper.Classique, on what registry is your Annex 2 plane?

@patowalker: there are indeed many French registered ultralights based in BE - estimates seem to be 30-50% of the total fleet - but very few D-Mxxx ; in fact I've only once come across one, and that was kept on an extremely low profile - for reasons I will of course respect. In fact the whole concept of the Belgian "overflight tax", which makes this country undeservedly impopular with foreign sub-ICAO operators, seems to be the desire to at least get SOME money from the many F-registered ultralights. I have yet to hear of any genuine foreigner to suffer from this ruling.
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Old 2nd May 2017, 18:49
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You need to go to Bullingen to see resident D reg. I know the Belgian permit was aimed at resident French registered aircraft, but it has the effect of drastically reducing visits by foreign permit aircraft, because it is expensive and bureaucratic. A visit without a permit would be illegal and invalidate insurance, which is a risk not many would take. A great shame, because Belgium offers some very good destinations, many of which I enjoyed flying into when I had a G reg permit aircraft based in Luxembourg.

BTW, the UK is the only other country that charges for visits by permit aircraft, although homebuilts and those registered in France are exempted.
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Old 3rd May 2017, 05:38
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Hm, Patowalker's:

which is only valid for 30 days in a year, requires a FPL for each flight (including those within Belgium) and an email giving details of each flight to the Belgian CAA?

Is not my understanding.

I thought (but could be wrong):

which is only valid for 30 days in a year - correct, but actually do you fly more than 30 days per year (it's days, not number of flights - 5 flights in one day counts as 1 day).

requires a FPL for each flight (including those within Belgium) - not heard this before.

and an email giving details of each flight to the Belgian CAA? - one email, at the end of each 12 month period summarising all the flights (hopefully showing 30 days or less!)

I'm sure Jan can clarify this... :-)
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Old 3rd May 2017, 05:46
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Jan, the cub is on UK register, on a NARC. ANNEX 2 not a microlight, not LAA.
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Old 3rd May 2017, 06:02
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No, Sam, I hadn't heard of such requirements either. But then I am not on that regime so I might ignore some points.
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Old 3rd May 2017, 07:44
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You wouldn't hear of it, unless you get a permit.

I tried to get the OTT requirements dropped:

From: Maarten Hoet
To: Donald Walker
Sent: Wednesday, 10 April 2013, 9:08
Subject: Betr: Re: Temporary permission to fly over Belgian territory

Dear Mr Walker,

The question raised in your below e-mail has been discussed in our department.
Given all existing and widely available means of communication (phone, mobile phone, internet, e-mail,...), it seems to us that the requirement to submit a flight plan and e-mail notification prior to a flight can be easily complied with. The risk of invalidating the insurance cover on an aircraft due to the lack of a flight plan or e-mail, is therefore very low.
Therefore, a change in the wording of the requirement of a flight plan is not considered at this moment.

Kind regards,

Maarten Hoet - Attaché
FPS Mobility & Transport - BCAA
LA/C-EXP (Commercial Air Transport Department)
CCN - Vooruitgangstraat 80 bus 5
B-1030 Brussels
Tel. +32 (0)2 277 44 04


Van: Donald Walker
Datum: 10/04/2013 09:07
Onderwerp: Re: Temporary permission to fly over Belgian territory

Dear Mr Hoet,

With reference to the email below and our subsequent telephone conversation, I write to enquire if your internal discussions have indicated there is a possibility of modifying the wording of the permit.

While the present wording may be perfectly adequate for visiting pilots who might use a single Belgian airport for arrival and departure, it is not ideal for someone like myself, who prefers to visit various small airfields.

I understand that the requirement for FPLs and email notification was introduced for safety and inspection reasons, but I believe it was never the intention of the BCAA to require foreign pilots flying non-CofA aircraft to file FPLs that are not deemed necessary for their Belgian counterparts. Compliance with ENR 1.10 and email notification in advance should ensure the appropriate level of safety and highlight opportunities for inspection.

My request is aimed purely at eliminating the risk of a technicality, such as the lack of a FPL or email, rendering a flight illegal and therefore invalidating the insurance cover on the aircraft, its occupants and third parties. This year my premium was GBP ......

By separate email I am applying for a permit.

Kind regards

Donald Walker


--- On Tue, 26/3/13, Donald Walkerwrote:


From: Donald Walker
Subject: Temporary permission to fly over Belgian territory
To: "Maarten Hoet"
Date: Tuesday, 26 March, 2013, 21:02

Dear Mr Hoet, I have enjoyed many flights in Belgium over the years and wish to visit again soon, but I am concerned about the unintended consequences that could arise from the present wording of the temporary permission to fly over Belgian territory.
The requirement for a flight plan and an email for every flight is a condition that can be difficult to comply with when flights originate at small airfields lacking the necessary communication facilities.
Also, many flights by visiting pilots are local sightseeing flights, returning to the point of departure, undertaken at short notice, without a pre-determined route or duration and which do not necessarily overfly geographical features that could meaningfully be identified in a flight plan.
The problem, of course, is that the lack of a flight plan and email would put the pilot in breach of the terms of the permission and this could invalidate his insurance. In the worst case scenario, an accident during such a flight could conceivably result in an injured third party on the ground being unable to claim against that pilot’s insurance policy.
The requirement that “The Belgian flying rules have to be respected”, covers ENR 1.10, which determines when flight plans are required or recommended, so I wonder if it might be possible to alter the wording of the permission to read something like:
"Flights subject to flight plans filed in accordance with AIP Belgium ENR 1.10 should be notified in advance to the email address [email protected], detailing date, route, type of flight, and the registration marks."
All flights would still be included in the list required at the end of the period in accordance with “The operator shall inform the Belgian CAA of the operated flights in Belgium by transmitting a list indicating the overflights dates, at the latest on ... ”
This would make it easier for visiting pilots to comply with the terms of the permission and therefore ensure that the validity of the insurance policy required by EC Regulation 785/2004 is not compromised in any way.
I look forward to hearing from you in due course.
Kind regards
Donald Walker

Last edited by patowalker; 6th May 2017 at 07:09.
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Old 3rd May 2017, 08:12
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Okay, just called them (!). No flight plan needed, but you do need to inform them (by email or online form) before every flight. So, not as onerous as a flight plan, but more tedious than just going flying!

Thank you for this, noted for the future...
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Old 3rd May 2017, 10:14
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I hope the wording of recent permits reflects what they told you on the phone. If they have dropped the requirement for a fpl, all well and good, they now need to get rid of the email nonsense.


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Old 3rd May 2017, 14:04
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They'd better get rid of all of this nonsense! There's no reason for BE to play cavalier seul on the continent. Especially as we are in all other respects attractive to transiting small aircraft.
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