PPRuNe Forums

Information Bulletin on the proposed CI Aircraft Registry.

Prepared for AOPA CI Region by Charles Strasser, Vice President AOPA UK
from email information provided by Fons Schaefer, CIAR Project Manager, SGI Aviation Services BV
and vetted by Fergus Woods, Director of Civil Aviation, Guernsey and Jersey.

There have been a number of Aviation Forums in which various contributors have speculated on what would be in the Channel Islands Aircraft Registry Regulations (the 2-reg) and what would be the advantages and disadvantages of applying for registration. Inevitably this has resulted in misinformation and the verbatim Questions and Answers below should help to correct that position.

First email

1./ It is stated that any size aircraft from any country will be accepted.

Put simply we will register all sizes except EASA Annex II aircraft based in the Channel Islands. For non-CI based aircraft we will be targeting aircraft as defined in our Air Navigation Law as Complex Non-Commercial but to include everything from Single-Engine Turbo-props and above.

Presumably this will be by transfer of the existing registration, with export C of A, from another jurisdiction.

Correct. Export CoA or equivalent.

Will it have to be to a CI company or can it be in the name of an individual with a foreign address?.

This is still under discussion. At the very least we will require non-resident ownership to be through a Guernsey or Jersey administered company, meaning that ownership could be through a foreign company or trust but via a locally licensed Corporate Service Provider. However, the whole issue of eligibility is yet to be finalised.

Will those on the N register be able to dispense with their trusts?

This is partly dependent on the eligibility question above. However, anyone who wants to will be able dispense with their USA Trust arrangement if they wish.

2./ Will the Licences and ratings of any ICAO country be recognised, validated or converted into a CI one?.

Pilot licences and ratings will be based on validations of ICAO licences from Contracting States "acceptable" to the DCA. But generally European and American licences (the majority) will be accepted with minimal formality.

3./ Will the maintenance requirements of any ICAO country be acceptable? For example will one be able to select the CAA, EASA or FAA regulations on maintenance schedules, mods and STC's etc.?

We will in principle only accept maintenance data approved by US, Europe (EASA) or Canada.

4./ Will the proposed EASA regulations for FRA apply?

Currently the EASA focus is on commercial transport operators, but in time their rules will impact on private operations. At that time there will be clear advantages for local resident owner operators to be on the 2-reg.

5./ What will be the advantage, if any, of the thousands of European N registered aircraft changing to the CI register?

Only larger N-reg aircraft or those that are CI based will be allowed on to the 2-reg. So we are not anticipating taking on the many thousands of European based N-reg aircraft

6./ Since neither of the Channel Islands are contracted member States of ICAO will the CI register come under the supervision of the CAA and if so with what powers?

Strictly speaking they will have no jurisdiction. However, as part of our demonstration of compliance with all relevant ICAO SARPS, we will be subject to an initial audit (and subsequent regular oversight) by the CAA on behalf of the UK DfT.

Second email

1./ Am I correct in presuming that an "aircraft based in the Channel Islands" is one owned by a resident individual, resident company or resident trust?

Yes, correct.

2./ Re EASA Annex II, why will for example, a locally based US made Piper Cub, Tripacer or Apache or UK made Auster, Chipmunk or Bulldog be barred from registration?.

In line with the standards that other overseas territories apply (ref. OTARs), we will accept type certificates from the following three jurisdictions: Europe (EASA), USA and Canada. We are still considering whether we could extend the scope to other aircraft, e.g. non-Annex II aircraft having a British Type Certificate or equivalent, but in any case we will not accept permit aircraft, i.e. aircraft holding a national CoA rather than a full ICAO CoA.

3./ Am I correct in presuming that, you accept the standard definition that, a "complex aircraft" means an airplane with retractable landing gear, a controllable speed propeller, and flaps. If so why, for non locally based aircraft, is the starting point a single engine Turbo prop?

No, the reference in the proposed ANL to ‘complex non-commercial’ applies to the following aircraft:
(a) any aeroplane having a maximum total weight authorised exceeding 5,700kg,

(b) any aeroplane equipped with one or more turbojet engines

(c) any aeroplane having a maximum approved passenger seating configuration of more than 9,

(d) any helicopter having a maximum total weight authorised exceeding 3,175kg,

(e) any helicopter having a maximum approved passenger seating configuration of more than 5,

(f) any aircraft operation involving the use of aircraft that are operated by pilots employed by the operator for the purpose of flying the aircraft, or

(g) any other general aviation operation as the Director of Civil Aviation shall in the public interest specify

The basis for this is ICAO Annex 6, Part II, Section 3 and refers to those operations where prior operating approval is required.

We will however accept other aircraft that are not locally based, but essentially this will be from single engine turboprop and up. The rationale for this is that the CIAR is both a registry for local residents and an off-shore, commercial registry.

4./ Since neither Jersey nor Guernsey are ICAO "Contracting States", it is interesting to note that you insist on that status to recognise Licences and Ratings issued only by them. Presumably based on that you would not recognise licences and ratings for pilots holding licences, for example, from the Netherland Antilles (Aruba) or Bermuda?

Although indeed both Jersey and Guernsey are not contracting states by themselves, they do have a legal commitment to be ICAO compliant in all aspects of aviation. It is the basis on which the contracting State, the UK, has granted us independence in managing our own aviation affairs. It is also the only basis on which we could anticipate success as an off-shore registry provider. Our clients need to know that they are dealing with a fully compliant jurisdiction to ensure their freedom of movement through and into international airspace. Hence, our policy to validate licences from ICAO compliant jurisdictions acceptable to the DCA. The same applies to the other territories you mention. We do not preclude at this stage to accept licences from those territories.

5./ What is the definition of "larger N registered " aircraft, as mentioned in your answer to paragraph 5./?

See the answer to point 3.

6./ Is the fee for the CAA initial audit and subsequent oversight included in your fee or is it an additional overhead and if so has a price for this been fixed?

It is an overhead cost for us and will be included in our fees. Regular audits by the CAA on behalf of the UK DfT is part and parcel of our commitment to ICAO compliance generally, in terms of our self-management of our aviation affairs. Even without an aircraft registry we can expect regular audit activity to demonstrate our compliance with ICAO SARPs on aerodromes and air traffic service provision.

Third email

1./ It would be appreciated if you could email me a copy of the application form(s) for putting an aircraft on the CI register, or draft thereof.

We are currently developing our procedures and forms, but they are not yet at a stage that I could share them with you.

Further information will be published as and when it becomes available in the public domain.