UK planning to evict N-registered aircraft
Question:
The UK Department for Transport has published a consultation document; their aim is as stated above.
What’s the stated logic behind this? George Patterson Give a person a fish and you feed him for a day; teach a person to use the Internet and he won’t bother you for weeks.
Response:
The UK Department for Transport has published a consultation document; their aim is as stated above. What’s the stated logic behind this?
http://tinyurl.com/ar229 for all the documents at the DFT website. I’ve not had time to read them, so if someone beats me to it for a summary! D.
Response:
The UK Department for Transport has published a consultation document; their aim is as stated above. What’s the stated logic behind this? http://tinyurl.com/ar229 for all the documents at the DFT website. I’ve not had time to read them, so if someone beats me to it for a summary! D.
The logic is that they are looking at stopping the practice of permanently basing an aircraft in the UK but keeping the ownership and regisration in some other country. According to the documents, they are looking at the fact that something on the order of 21% of the aircraft in the UK spend all of their time in UK airspace despite being foreign registered. The gist of it is that they want to place a time limit on how long you can keep a foreign registered aircraft in the UK without changing the regisration. It’s only a proposal for now and they are requestion comments until late October. Craig C.
Response:
The DfT is alleging it is to save money on maintenance.
Which isn’t quite right. The real reason is to save money on alterations. There are also many, many items (e.g. avionics) that are FAA approved only, and for which the European approval route is expensive
Bingo. But that European approval route is what keeps much of the European GA bureaucracy in business. Ditto those required courses for the PPL and IR. Ultimately, people do keep planes on the N-register to save time, hassle, and money – but that time, hassle, and money they don’t want to put up with is the lifeblood of the aviation bureaucracy and the people who make their living in it. Of course those people want the practice to stop. Michael
Response:
18:12:39 GMT the perfect time to write: The UK Department for Transport has published a consultation document; their aim is as stated above. What’s the stated logic behind this? Faulty. Very, Very Faulty. Wouldn’t it also mean pulling out of ICAO?
No just file an exception – countries do it all the time.
Response:
Great summary. Thanks! One item to dispute. The FAA does do ramp checks in Europe, just not very many. One of our competitors got ramped. The pilot told the FAA inspector he had no authority. The Inspector gave him a break and told him to call his Chief Pilot. The pilot was quickly educated, got very apologetic, and cooperative. The FAA can ramp a 135/121 operator anywhere in the world. Our POI (Principal Operations Inspector) asks that question of all of our new Captains.
– Hide quoted text — Show quoted text – According to the documents, they are looking at the fact that something on the order of 21% of the aircraft in the UK spend all of their time in UK airspace despite being foreign registered. The gist of it is that they want to place a time limit on how long you can keep a foreign registered aircraft in the UK without changing the regisration. It’s only a proposal for now and they are requestion comments until late October. The question one must ask is WHY people do this. The DfT is alleging it is to save money on maintenance. Any N-reg owner in Europe will know that is bull. I am an N-reg owner and just about everything costs more, not less, because very few maintenance outfits are fully FAA certified and they have to "buy" a signature from an IA at the end of the job. A typical IA charges the equivalent of US$500 for the signoff. Anything that needs a DER (e.g. structural) is $1000 for the DER signature – as I know well from a recent exercise with an ELT antenna. The CAA is much more relaxed about screwing antennas into airframes than the FAA. There are two main reasons why people "go N". (1) To get worldwide IFR privileges – basically for European touring / business flying. In the non-jet GA context, this is by far the most common reason. The European route to this is the JAA IR which involves 1-2 years’ study, mandatory ground school, an additional hearing (audiogram) test where *each* ear has to pass the -20db limit, and other stuff that’s hardly relevant to noncommercial GA flying. Most people who earn enough money to get access to an IFR-suitable aircraft (i.e. buy one, or buy into one of the rare "IFR" syndicates) and to fly it with sufficient currency, have a life to live and a job to do and can’t devote such a chunk of their life to the exams. 99% of the people doing the JAA IR are young (often jobless) people, with plenty of time, who want to be airline pilots. (2) Certain types are not EASA approved. The Cirrus SR22 is the best known example. The TBM700C2 turboprop is another one, AFAIK due to its slightly higher stall speed. Various turboprops and jets (which I know nothing of in detail) have serious certification issues if not on N. There are also many, many items (e.g. avionics) that are FAA approved only, and for which the European approval route is expensive, or impossible. I was once quoted US$ 2000 for the paperwork for a backup oil pressure gauge (CAA L2 approved company). While few owners will move their aircraft to N just to fit a piece of FAA approved avionics (because moving to N itself can hardly be done for less than $10k and often costs 2x or 3x that, for a SEP – as I know very well, with the DAR alone charging $2600) there are many planes containing equipment alredy fitted which prevents them going to a different registry. The DfT asked the CAA to come up with evidence that N-reg planes have more accidents, and the CAA reported they cannot find any such data. So the DfT is attacking it from the "lack of maintenance oversight" angle, which in theory is accurate (the FAA does supervise European FAA-approved maintenance firms but doesn’t do ramp checks) but in practice is irrelevant because most N-reg pilots are owners, with a powerful incentive to do the specified maintenance (their life, and the fact that the insurance is void unless the aircraft is airworthy). The CAA is practically unknown to do ramp checks on G-reg planes too – just as well because if they did, many UK flying schools, and JAR145 approved maintenance firms, would be in trouble
The worst maintained planes in the UK are G-reg, not N-reg. The GBP 250k economic cost in the DfT proposal is low by 2 to 3 orders of magnitude – working on the cost of moving each plane to G, or offloading it onto the U.S. market. Many of these are turboprops and jets. Plus each pilot taking a year to do the JAA PPL/IR. It’s a complete farce. It may be only a "proposal" now, but the manner in which the UK and European governments usually structure these things is to make the process a fait accompli.
Response:
The proposal isn’t that you can only keep the plane in the UK for 90 days at a time, it’s for a limit of 90 days in the UK in any 12 months period (the 90 days bit is up for discussion). So you would have to have the plane outside of the UK for the other 9 months.
Do the UK FBOs realize that the government is actively trying to kill them off ? I’m guessing the result would be to discourage fat cats from parking their aircraft in the UK for too long.
Response:
/// in the UK a basic PPL with no ratings can fly IFR, and only needs a Night Qualification to fly at night. I understand that elsewhere, any night flying (as here) is IFR, and IFR is not allowed without a full IR. Hence even night flying requires an IR outside the UK.
This note is wrong in several respects Brian Whatcott Altus, OK
Response:
Not entirely true. You need an IMC rating to fly in IMC but it doesn’t give you the full priveleges of an IR (Class A use, for instance). It is merely to teach you to fly in marginal weather. Also you do need to have a Night Rating (and pay the CAA for the privelege) but it requires neither an IMC nor an IR rating. shawn
– Hide quoted text — Show quoted text – The structure of European airspace, and its weather in many places, are such that without an IFR capability one can’t usefully go anywhere. In the UK there is the IMC Rating; effectively an IR limited to below Class A. This means an IR is not strictly needed for flying purely around the UK. We do have Class A down to 2500ft, and even surface, in a lot of places, but in general one can fly under/around it. In Europe it’s different. Any IMC requires a full IR, and that (flying usefully into Europe, doing instrument approaches and departures) is why people do the IR. And the FAA IR is the only one that’s realistically attainable for most pilots that have work to do. Not to mention that in the UK a basic PPL with no ratings can fly IFR, and only needs a Night Qualification to fly at night. I understand that elsewhere, any night flying (as here) is IFR, and IFR is not allowed without a full IR. Hence even night flying requires an IR outside the UK.
Response:
Juan, In Argentina the same rule applies,
Actually, IIRC, the rule planned for the UK is more sophisticated: 90 days out of 365 are the maximum allowed time in the UK. — Thomas Borchert (EDDH)
Response:
– Hide quoted text — Show quoted text – Not to mention that in the UK a basic PPL with no ratings can fly IFR, Only in VMC and in Class G
and only needs a Night Qualification to fly at night. I understand that elsewhere, any night flying (as here) is IFR, and IFR is not allowed without a full IR. Plenty of countries have VFR allowed at night – the USA is one great example. But yes this can be an issue. However a much bigger issue is that the UK is unique in allowing flight in IMC (i.e. IFR) anywhere, and allowing it without any clearance or even any radio contact in Class G. Outside the UK, to fly IFR, one needs to be on an IFR flight plan (following the proper ATS routes, filed and verified via the Brussels computer, and amended en-route by ATC as they wish) and an IR is mandatory to stay legal. Same in the USA, except their flight plan handling and lots of other details are very different. If the British Govt kicks out N-reg aircraft, in addition to the huge costs (typically, 4-5 figures to move back to G, for a little plane with no certification issues, and impossible for many e.g. the SR22) they will strip a large number of pilots of their IFR privileges for European flight. This is a very poor thing to do for safety.
But a very good thing to do for civil servants/politicians who want control of the populace at any cost. AIUI this isn’t being pushed as a safety measure and it’s not even the CAA doing the pushing but the DFT. Rgds Andy R
Response:
– Hide quoted text — Show quoted text – The structure of European airspace, and its weather in many places, are such that without an IFR capability one can’t usefully go anywhere. In the UK there is the IMC Rating; effectively an IR limited to below Class A. This means an IR is not strictly needed for flying purely around the UK. We do have Class A down to 2500ft, and even surface, in a lot of places, but in general one can fly under/around it. In Europe it’s different. Any IMC requires a full IR, and that (flying usefully into Europe, doing instrument approaches and departures) is why people do the IR. And the FAA IR is the only one that’s realistically attainable for most pilots that have work to do. Not to mention that in the UK a basic PPL with no ratings can fly IFR, and only needs a Night Qualification to fly at night. I understand that elsewhere, any night flying (as here) is IFR, and IFR is not allowed without a full IR. Hence even night flying requires an IR outside the UK. The French allow night VFR, pretty restrictive though, see http://www.sia.aviation-civile.gouv.fr/aip/enligne/METROPOLE/AIP/ENR/…
There are also other things things that make it not impossible to get about without an IR. ie you can fly VFR in most French airways provided you’re not in cloud, and you don’t need to be in sight of the surface. So if you can find a hole to go up through and it’s scattered or better at your destination on occasions you’re actually better off than in the UK with an IMC because you can use the airways. Rgds Andy R
Response:
Clearly it is difficult to achieve an effective timed residence ban such as that proposed (90 days every 365 days) while allowing visiting aircraft, because one obvious work-around is for the pilot to swap aircraft every 90 days. While obviously most private pilots aren’t going to purchase, or rent/lease from outside the UK, a different N-reg plane every 90 days (i.e. 4 a year), a larger fractional ownership operation could be structured so the planes are rotated via other countries. A multinational business operating say 4 jets could keep 3 outside the UK and rotate them every 90 days, thus meeting this requirement. So the proposal would screw the small private pilot, while leaving the larger turboprop/jet groups much less affected.
I had thought of this as well, but it would make for some really complicated group structures ! Why can’t UK owners just park the airplane across the channel in france for some portion of the year ? Surely there has to be a percentage of time resident or similar requirement. So UK owners just lease to a flight club across the channel for a few months of the year.
The proposal isn’t that you can only keep the plane in the UK for 90 days at a time, it’s for a limit of 90 days in the UK in any 12 months period (the 90 days bit is up for discussion). So you would have to have the plane outside of the UK for the other 9 months. As Peter suggested, one way around this (that would work only for larger groups, so still screw the majority of private pilots) is to have a fleet of five (four doesn’t quite do it) planes and move them around the world as required so that none of them exceed the 90 days limit. The issues doesn’t firectly and personally affect me at the moment, but I’ve still put in my objections since it’s guaranteed to affect me indirectly or even directly in the future. One point I made was that it’s a bit rich for our authorities to decide what other countries should be happy with – if the US authorities aren’t happy with it’s ability to oversee aircraft on it’s register that are overseas, then surely it’s up to them to decide what to do about it; if they are happy, then what right have out authorities to tell them otherwise ?
Response:
– Hide quoted text — Show quoted text – The structure of European airspace, and its weather in many places, are such that without an IFR capability one can’t usefully go anywhere. In the UK there is the IMC Rating; effectively an IR limited to below Class A. This means an IR is not strictly needed for flying purely around the UK. We do have Class A down to 2500ft, and even surface, in a lot of places, but in general one can fly under/around it. In Europe it’s different. Any IMC requires a full IR, and that (flying usefully into Europe, doing instrument approaches and departures) is why people do the IR. And the FAA IR is the only one that’s realistically attainable for most pilots that have work to do. Not to mention that in the UK a basic PPL with no ratings can fly IFR, and only needs a Night Qualification to fly at night. I understand that elsewhere, any night flying (as here) is IFR, and IFR is not allowed without a full IR. Hence even night flying requires an IR outside the UK.
The French allow night VFR, pretty restrictive though, see http://www.sia.aviation-civile.gouv.fr/aip/enligne/METROPOLE/AIP/ENR/… Rgds Andy R
Response:
The question one must ask is WHY people do this.
How about also that going "off N status" creates an aircraft that is virtually unsaleable in the USA due to its having a maintenence trail that makes it unfeasable to recertify at reasonable cost for USA sale ? And that the USA market is far better than UK ? How many aircraft have you seen advertised in the UK that are begging to be sold in the USA, or aircraft for UK sale that are bragging about having an N number ?
Response:
Clearly it is difficult to achieve an effective timed residence ban such as that proposed (90 days every 365 days) while allowing visiting aircraft, because one obvious work-around is for the pilot to swap aircraft every 90 days. While obviously most private pilots aren’t going to purchase, or rent/lease from outside the UK, a different N-reg plane every 90 days (i.e. 4 a year), a larger fractional ownership operation could be structured so the planes are rotated via other countries. A multinational business operating say 4 jets could keep 3 outside the UK and rotate them every 90 days, thus meeting this requirement. So the proposal would screw the small private pilot, while leaving the larger turboprop/jet groups much less affected.
Why can’t UK owners just park the airplane across the channel in france for some portion of the year ? Surely there has to be a percentage of time resident or similar requirement. So UK owners just lease to a flight club across the channel for a few months of the year.
Response:
Scott, Why can’t UK owners just park the airplane across the channel in france for some portion of the year ?
Because it makes for a really long drive to the airport. — Thomas Borchert (EDDH)
Response:
In Argentina the same rule applies, foreign aircraft cannot stay for more than 90 days at a time. So they fly to Uruguay for the day (preferably to Punta del Este) and come back. Problem solved.
– Hide quoted text — Show quoted text – Scott, Why can’t UK owners just park the airplane across the channel in france for some portion of the year ? Because it makes for a really long drive to the airport. — Thomas Borchert (EDDH)
Response:
The structure of European airspace, and its weather in many places, are such that without an IFR capability one can’t usefully go anywhere. In the UK there is the IMC Rating; effectively an IR limited to below Class A. This means an IR is not strictly needed for flying purely around the UK. We do have Class A down to 2500ft, and even surface, in a lot of places, but in general one can fly under/around it. In Europe it’s different. Any IMC requires a full IR, and that (flying usefully into Europe, doing instrument approaches and departures) is why people do the IR. And the FAA IR is the only one that’s realistically attainable for most pilots that have work to do.
Not to mention that in the UK a basic PPL with no ratings can fly IFR, and only needs a Night Qualification to fly at night. I understand that elsewhere, any night flying (as here) is IFR, and IFR is not allowed without a full IR. Hence even night flying requires an IR outside the UK.
Response:
George Patterson a