N Reg; A Flag of Convenience?
Thread Starter
N Reg; A Flag of Convenience?
I have started this new thread to pick up where the recent Alderney accident left off.
In my opinion there are many ‘grey charter’ and other ad hoc operators who must be looking at their methods of operations following the Sala accident.
It was unusual to see a UK owner flying a US registered aircraft when I started flying in 1981.
Over the intervening years N reg aircraft have popped up everywhere in Europe and it now appears to be a semi global flag of convenience. This is a term from shipping companies who chose nations such as Liberia and Monrovia to register their fleet to avoid regulators.
The owners of these aircraft are hidden behind trusts such as Southern Air Consultancy at Bungay in East Anglia which is little more than a brass plate office. By chance they operated out of a house just a few miles from my UK home until a couple of years ago. It now appears they have many N aircraft registered in the UK to this small Suffolk office.
Here in Asia it is forbidden to base a non local registered aircraft in the various countries for longer than a few months.
Recent events have focused on this use of N reg in Europe.
The argument is that the US register is much easier to operate an aircraft than the more stringent European equivalent.
Clearly the news in recent days suggests that maybe the operators of US registered aircraft need to address how they comply with the FAA regulations.
Will we start to see the CAA prosecutors addressing this grey area that undermines genuine AOC operators?
In my opinion there are many ‘grey charter’ and other ad hoc operators who must be looking at their methods of operations following the Sala accident.
It was unusual to see a UK owner flying a US registered aircraft when I started flying in 1981.
Over the intervening years N reg aircraft have popped up everywhere in Europe and it now appears to be a semi global flag of convenience. This is a term from shipping companies who chose nations such as Liberia and Monrovia to register their fleet to avoid regulators.
The owners of these aircraft are hidden behind trusts such as Southern Air Consultancy at Bungay in East Anglia which is little more than a brass plate office. By chance they operated out of a house just a few miles from my UK home until a couple of years ago. It now appears they have many N aircraft registered in the UK to this small Suffolk office.
Here in Asia it is forbidden to base a non local registered aircraft in the various countries for longer than a few months.
Recent events have focused on this use of N reg in Europe.
The argument is that the US register is much easier to operate an aircraft than the more stringent European equivalent.
Clearly the news in recent days suggests that maybe the operators of US registered aircraft need to address how they comply with the FAA regulations.
Will we start to see the CAA prosecutors addressing this grey area that undermines genuine AOC operators?
Last edited by Mike Flynn; 20th Mar 2019 at 22:50.
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The rules were made to make flying an elite activity.
The US on the other hand hzve rules that open up flying to the masses - I sm one of them - bought a plane in the US and operste it on the US register as I do not want to go to the time and expense of putting it on the local register.
Indeed the US reg makes it easy to operate.
There are two locally registered airplanes down here which were being switched back to the US register when the A&P IA died in odd circumstances, they went out of local annual and have to be re regustered locally for the switch to occur. A very expensive proposition due to the hangar in which they are located "does not meet standards for work to be carried out to local standards" - so spend a quarter of a million dollars on the hangar (which is a true hangar unlike the one here!) and you can then put the airplanes back to local annual and then switch them to US. Not a realistic proposition for airplanes once on US and in annual have a value at the upper end of a total of $75,000.
To this day over five years since they went out of local annual they sit in the hangar on a nearby island untouched.
That would not be the case had they remained on the US register.
The US has a very safe regulatory regime - the Sala incident would have been less dodgy with an EASA state registered airplane in the same circumstances, after all Wingy type arrangements are legitimate in EASAland (hands up all those who think the pilot of the Sala flight was going to be paying 50% of the cost if the flight!)
Foying US registered airplanes makes flying accessible, it is not a washed up third world convenience to cut corners, as possibly implied by the tennor of the original post. The reason why some locations say based here must be registered here has nothing to do with safety and everything to do with the taxes, levies, duties and annual imposts which can be collected on locally registered airplanes once they have breached the bond status of the airport.
The US on the other hand hzve rules that open up flying to the masses - I sm one of them - bought a plane in the US and operste it on the US register as I do not want to go to the time and expense of putting it on the local register.
Indeed the US reg makes it easy to operate.
There are two locally registered airplanes down here which were being switched back to the US register when the A&P IA died in odd circumstances, they went out of local annual and have to be re regustered locally for the switch to occur. A very expensive proposition due to the hangar in which they are located "does not meet standards for work to be carried out to local standards" - so spend a quarter of a million dollars on the hangar (which is a true hangar unlike the one here!) and you can then put the airplanes back to local annual and then switch them to US. Not a realistic proposition for airplanes once on US and in annual have a value at the upper end of a total of $75,000.
To this day over five years since they went out of local annual they sit in the hangar on a nearby island untouched.
That would not be the case had they remained on the US register.
The US has a very safe regulatory regime - the Sala incident would have been less dodgy with an EASA state registered airplane in the same circumstances, after all Wingy type arrangements are legitimate in EASAland (hands up all those who think the pilot of the Sala flight was going to be paying 50% of the cost if the flight!)
Foying US registered airplanes makes flying accessible, it is not a washed up third world convenience to cut corners, as possibly implied by the tennor of the original post. The reason why some locations say based here must be registered here has nothing to do with safety and everything to do with the taxes, levies, duties and annual imposts which can be collected on locally registered airplanes once they have breached the bond status of the airport.
Thread Starter
You make some valid points Ebbie but of course you are very close to the US mainland.
You also have the option of the Cayman Island register.
Fine if you have a corporate jet moving across continents.
Not so easy with a locally based 182 or Saratoga.
The point I am making is that Europe is a long way from the USA in terms of regulation.
We already have a lot of old former military helicopters and fixed wing ex Eastern European airframes exploiting the regulations.
You also have the option of the Cayman Island register.
Fine if you have a corporate jet moving across continents.
Not so easy with a locally based 182 or Saratoga.
The point I am making is that Europe is a long way from the USA in terms of regulation.
We already have a lot of old former military helicopters and fixed wing ex Eastern European airframes exploiting the regulations.
One of my planes is on the N register, mainly because it is more easily modified (changing windows, adding equipment etc.). Particularly the whole field approval procedure which has no easy equivalent in Europe.
I also 'use' my FAA certificate (commercially) much more than my EASA CPL - thus having that aligned is simpler.
I'm not sure that the FAA is less stringent on fundamental safety, if an owner wants to 'skip' bits of legislation he can do that under any registration.
Are you sure that the camera ship operation is illegal? Don't forget that aerial photography has some exemptions from the full 'commercial' requirements. I don't know what they are though - not something we do.
I object to being lumped in with the Sala crash - rather in the same way that the Airbnb murderer who has just been sentenced is always described as the 'Airbnb murderer'. Not sure Airbnb have done anything to deserve the link!
There was nothing more stopping Mr.Ibbotson (UK PPL) doing exactly the same flight in a G reg Malibu...The relevance of the aircraft registration is...?
And the guy who crashed with the twitchers was using a G reg...
I also 'use' my FAA certificate (commercially) much more than my EASA CPL - thus having that aligned is simpler.
I'm not sure that the FAA is less stringent on fundamental safety, if an owner wants to 'skip' bits of legislation he can do that under any registration.
Are you sure that the camera ship operation is illegal? Don't forget that aerial photography has some exemptions from the full 'commercial' requirements. I don't know what they are though - not something we do.
I object to being lumped in with the Sala crash - rather in the same way that the Airbnb murderer who has just been sentenced is always described as the 'Airbnb murderer'. Not sure Airbnb have done anything to deserve the link!
There was nothing more stopping Mr.Ibbotson (UK PPL) doing exactly the same flight in a G reg Malibu...The relevance of the aircraft registration is...?
And the guy who crashed with the twitchers was using a G reg...
Thread Starter
I think the big difference is using an N reg for commercial use instead of private ops Sam.
Clearly if someone owns and operates an aircraft on the US register for private use that is far removed from leasing it for commercial third party operations.
I would suggest that aerial work and filming comes under the umbrella of commercial operation.
We both know someone who used a US registered aircraft for sponsored and commercial air to air filming.
Clearly if someone owns and operates an aircraft on the US register for private use that is far removed from leasing it for commercial third party operations.
I would suggest that aerial work and filming comes under the umbrella of commercial operation.
We both know someone who used a US registered aircraft for sponsored and commercial air to air filming.
The CAA does not appear very proactive in checking what goes on in the field.
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ive never been ramp checked in a g reg but twice in a n reg at racecourses
Thread Starter
The BBC Wales investigation makes interesting reading.
It appears there are a lot of very charitable people flying their aircraft on a non commercial basis?
Here again is the list of flights in question.(No doubt just the tip of a very large iceberg.)
Looking at Malibu N14EF and flown by Lord George Porchester ‘Oggers’ posted this on the Sala thread.
Lord Porchester stressed to the BBC he was just doing a favour to McKay.
BBC Wales understands that the two jets used to fly various parties including Sala, his agent Meissa N'Diaye, Cardiff City manager Neil Warnock and club player liaison Callum Davies, Willie McKay and his son Mark on seven separate occasions in January did not fall under the AOC at the time.
Both planes were registered in America, which means they cannot be flown commercially in Europe without the express permission of US regulator, the Federal Aviation Authority, and the CAA.
The flights were listed on flight plans, as non-commercial.
Both planes were registered in America, which means they cannot be flown commercially in Europe without the express permission of US regulator, the Federal Aviation Authority, and the CAA.
The flights were listed on flight plans, as non-commercial.
Here again is the list of flights in question.(No doubt just the tip of a very large iceberg.)
The flights:
- 5 December 2018 - Flight from Stapleford in Essex to Nantes - carrying Cardiff City manager Neil Warnock, assistant manager Kevin Blackwell, Willie McKay and Mark McKay to see Emiliano Sala play against Marseilles
- 6 December - party returns from Nantes to Cardiff. Both flights made on G-KARE, operated by Surrey-based Flexifly Aircraft Hire Ltd
- 8 January 2019 - Flight from Cardiff to Nantes - carrying Neil Warnock, Cardiff City player liaison Callum Davies, Willie and Mark McKay to meet Sala and his agent. They're flown back to Cardiff the same day. On N531EA, owned by Guernsey-based Channel Jets
- 14 January - Sala's agent, Meissa N'Diaye, flown from Paris to Nantes. N'Diaye and Sala are flown from Nantes to Cardiff to have a look around the Cardiff City Stadium, returning to Nantes the same day. Mr N'Diaye is then flown back to Paris. All flights made on N843TE - owned by Channel Jets
- 18 January - Sala flies from Nantes to Cardiff for a medical and to sign his contract with Cardiff City. Via Channel Jets in N531EA. Sala's agent Mr N'Diaye - who has travelled to Cardiff for the signing via a commercial flight - flown back to Paris by Lord George Porchester in his own aircraft, N14EF
- 19 January - Sala flown back to Nantes by David Ibbotson on N264DB to bid farewell to his Nantes team-mates and make personal arrangements. Mr Ibbotson books into a hotel to await the return leg of the journey - on 21 January - to deliver Sala back to Cardiff for his first training session
- 21 January - The flight leaves Nantes at 19:15 and disappears from radar around an hour into the journey.
Dave Edwards, chief executive of Baca, said: "We did our research into these flights, we've identified which aircraft they were and the routes they flew, and that gave us rise for significant concern.
"There's enough for us to feel that the authorities need to be looking very closely at this to make sure everyone is keeping the interests of the travelling public at the forefront of their minds."
Mr Edwards said Baca had been voicing concerns about "grey" and illegal charters to the CAA and the European Union Aviation Safety Agency (Easa) for several years.
"There's enough for us to feel that the authorities need to be looking very closely at this to make sure everyone is keeping the interests of the travelling public at the forefront of their minds."
Mr Edwards said Baca had been voicing concerns about "grey" and illegal charters to the CAA and the European Union Aviation Safety Agency (Easa) for several years.
I can find nothing for this George Herbert (Lord Porchester fellow DOB 13 Oct 92) on the FAA database. It seems likely we have another illegal flight as he would require an FAA licence to fly his N reg outside the UK. There is a George E Herbert but wrong DOB.
As the plane is registered in the US, it cannot be flown commercially in Europe and Lord Porchester can only fly passengers in the EU on a cost-sharing basis, not for reward.
Lord Porchester has told BBC Wales he flew Mr N'Diaye as a "favour" for Willie McKay and did not receive any payment for the flight.
"I've got my own aircraft and I flew that flight," he said. "There was no financial arrangement at all with anyone, it was a private flight."
He added: "I've been pulled into this because I've done someone a favour."
Lord Porchester has told BBC Wales he flew Mr N'Diaye as a "favour" for Willie McKay and did not receive any payment for the flight.
"I've got my own aircraft and I flew that flight," he said. "There was no financial arrangement at all with anyone, it was a private flight."
He added: "I've been pulled into this because I've done someone a favour."
Last edited by Mike Flynn; 22nd Mar 2019 at 03:49.
After the Malibu accident, it won't surprise me in the least if new restrictions are applied to 3rd country aircraft based in the UK.
For example, a time limit before they have to be transferred to the UK register. Also, once the BASA is in place, converting FAA licences to EASA licences should become rather simpler.
For example, a time limit before they have to be transferred to the UK register. Also, once the BASA is in place, converting FAA licences to EASA licences should become rather simpler.
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Any one who thinks the “N” plate is a flag of convenience is sadly mistaken, some parts of the American system are more flexible in terms of implementation but the emphasis is on those within the industry to comply rather than having the state regulator policing the rules closely ( and usualy inefficiently ).
Get caught breaching the FAA regulations and the American leagal system will show no mercy for those who think that just because the regulator is on the other side of the Atlantic they don’t care what you do .
Get caught breaching the FAA regulations and the American leagal system will show no mercy for those who think that just because the regulator is on the other side of the Atlantic they don’t care what you do .
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The owners of these aircraft are hidden behind trusts such as Southern Air Consultancy at Bungay in East Anglia which is little more than a brass plate office.
Picking up on A and C,s point of the FAA’s willingness to apply the heavy hand of the law for those that flout their rules, IIRC their was a recent case of several ex US servicemen who had seen combat and were now civilian PPL holders, on their Airmen’s medical application they said they had no outstanding issues and at the same time ware applying for or receiving Federal benefits for claimed PTSD from the Veterans administration. They were indicted for BOTH making false benefit claims and also lying on their PPL medical application and are looking at serious jail time. The bottom line? the FAA have rules, flout then at your peril, they are no soft touch or laxed outfit regardless of where you are located.
Thread Starter
After the Malibu accident, it won't surprise me in the least if new restrictions are applied to 3rd country aircraft based in the UK.
For example, a time limit before they have to be transferred to the UK register. Also, once the BASA is in place, converting FAA licences to EASA licences should become rather simpler.
For example, a time limit before they have to be transferred to the UK register. Also, once the BASA is in place, converting FAA licences to EASA licences should become rather simpler.
Clearly there are benefits from operating on the N register but these should be incorporated in to UK certification.(assuming we leave Europe)
UK GA tends to be over regulated in some areas but under regulated elsewhere.
We have this strange scenario where a foreign registered ex military aircraft or helicopter can be legally flown in the UK outside of CAA regulation.
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Mike flynn
you wrote
We have this strange scenario where a foreign registered ex military aircraft or helicopter can be legally flown in the UK outside of CAA regulation.
can you elaborate which ex military helicopters are you referring too ?
you wrote
We have this strange scenario where a foreign registered ex military aircraft or helicopter can be legally flown in the UK outside of CAA regulation.
can you elaborate which ex military helicopters are you referring too ?
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Clearly there are benefits from operating on the N register but these should be incorporated in to UK certification.(assuming we leave Europe)
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Convenient? Very! Avoiding the ridiculous contortions and stupidities foisted on the aviation community by the ever-changing European regulatory systems must be a huge convenience. The changes from national regulators to JAA and then EASA have confused many and cost plenty for no good reason that I can see. The one great thing about dealing with the FAA is the certainty - they write everything down, there is rarely an "interpretation" and they are generally practical and pragmatic about the things they subject their "customers" to. Upgrades and improvements are cheaper to install and more plentiful, training concentrates on the useful stuff and maintaining one's licence is far simpler. The only actual cost savings are on pointless paperwork and involvement of people who do not need to be in the chain. "Hiding" behind trusts is not actually happening - the FAA know who is behind each one. The same sort of rules appear in most countries registration processes and companies or trusts are used to make things legal. try to register something in the UK if your are not an EU entity or passport holder....
Aerial work by N registered aircraft is allowed with permission from the CAA. Illegal flights are illegal flights, whatever the letters/numbers painted on the side and the Sala flight was a sad, preventable incident. More involvement by regulators, rather than pronouncements from on high, might help the community be safer all round. The confrontational stance does not help.
Aerial work by N registered aircraft is allowed with permission from the CAA. Illegal flights are illegal flights, whatever the letters/numbers painted on the side and the Sala flight was a sad, preventable incident. More involvement by regulators, rather than pronouncements from on high, might help the community be safer all round. The confrontational stance does not help.