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Transferring a factory built aircraft from LAA permit to CofA

How complicated is it to get a real CoA for a plane that has been factory built, but flies on an LAA permit?

Background: We have been searching for aircraft and several times we found a suitable plane, but it was flying under LAA permit. As it seems, registration in Germany is possible, if the a/c has a CoA. Flying EU-experimental is not an option due to the (well documented) restrictions.

Last Edited by mh at 10 Feb 13:59
mh
Inside the sky.
EDXE, EDXF, Germany

mh wrote:

How complicated is it to get a real CoA for a plane that has been factory built, but flies on an LAA permit?

You mean CofA according to ICAO or national? How is that supposed to happen even in theory without dismantling and replacing every single piece? LAA permit is not even CofA according to any standard. Your best option is to import it to Norway, get a CofA as an experimental vintage. Then you can operate it just like you would if it had an ICAO/national CofA except using it commercially.

Obviously I’ve never done this, and @A_and_C is one person who may know more, but the main challenge is that most LAA types have never been manufacturer certified so can never be certified – under FAA, EASA, or anywhere. An RV is perhaps the best known case.

There are some LAA types which have existed under both CofA and (what was) Annex 2. I vaguely recollect the ex military trainer Bulldog was one of these. I am told by someone close to the LAA that the question is “what has been changed”; it could be easy or it could be uneconomical to restore them to CofA condition. There are not many of these because the CAA position has always been “if it is capable of having a CofA then it must have a CofA”; this is a revenue supporting measure for feeding money to the CAA, the maintenance industry (which pays fees to the CAA), etc. But some types slipped through, many years ago and by means I know nothing about.

A better known example is the famous Gazelle helicopter which was selling for £80k on Permit or £250k on CofA. If I was getting into rotary I would have skipped the whole “Robinson stage” and gone for that, with an ex mil instructor. I spoke to various owners. The CofA version was produced by taking the Permit one, taking it to pieces in a “145 hangar” where every part is “inspected” and an EASA-1 form printed off, put back together, and a CofA applied for, then the CAA inspector checked it and issued the CofA. Why would anyone bother? The Permit version could be flown in the UK and IIRC to France and, being uncertified, that was about it before the hassles started. Also no passengers were allowed, so any passenger had to pretend to be “crew”, so the owners would get their wives/etc to buy a one-piece flying suit, some badges, and “do the radio” That silly requirement was later removed, IIRC.

However the above covers going to a UK CofA. It may be easier to go to say a German CofA. I doubt it though…

Administrator
Shoreham EGKA, United Kingdom

There is a similar, analogous situation with Canadian registered planes that are put into owner maintenance category. It can’t reasonably be reversed so people who do it get a short term benefit at the expense of cutting off most of their resale market, which would have otherwise put the plane into normal category N-register.

I think the LAA situation is less problematic because the UK has a fairly active pool of potential buyers.

I flew out Jodel DR1050 as a C of A aircraft, for 15+ years. It was French DGAC Certified. The two builders, SAN and CEA had both folded. It became an Annex 1 (Annex 2 formerly) “Orphan” under EASA. Day VFR only. LAA Permit. Annual maintenance cost dropped dramatically.
Then the CAA authorised the LAA to permit Night and IFR. The Syndicate objected to getting lights and instruments fitted.
It’s been grounded for 25 months. 13+ months since rebuilt wing was returned, but refitting is very slow.
The Bolkow BO208 Junior is usually an EASA Aircraft, still supported by Airbus, who bought Bolkow. Our one at some point in the past became LAA Permit. Once this has happened, the owner can work on it, and the LAA Inspector checks it.
It can never get back to being an EASA Aircraft, due to that work.
Unless maybe Airbus strip it completely, check everything, and rebuild?? At less than €1 billion.

Maoraigh
EGPE, United Kingdom

LeSving wrote:

CofA except using it commercially.

Well, about that…

Peter wrote:

but the main challenge is that most LAA types have never been manufacturer certified

Okay, that’s a valid point, although I was referring to aircraft that do fly with a CoA in other countries. Within the a/c in question was a DR1050 for instance, that would have been operated by a flying school and a PA18 for use on an AOC. Both were on an LAA permit, but couldn’t be registered in Germany w/o the CoA.

Peter wrote:
It may be easier to go to say a German CofA.

Not to my knowledge, hence the question.

Maoraigh wrote:

LAA Permit. Annual maintenance cost dropped dramatically.

We operate a DR250-160 (same manufacturer) on a standard ICAO CoA. I do not know where you possibly would cut costs on a permit. bureaucratic overhead is less than 400€/a total. And the Radio for my Tempête is just as expensive as the one for the Lake…

Only, being in Germany, operating a factory built a/c under LAA permit is not remotely sensible as to bureaucratic overhead. (Plus, you only get to have the a/c around 140 days/year (something along this line, the figure might be a bit off) based in Germany.

Maoraigh wrote:

Then the CAA authorised the LAA to permit Night and IFR.

That is possible on a CoA for the 1050 w/o further authorisation.

Maoraigh wrote:

Once this has happened, the owner can work on it, and the LAA Inspector checks it.

Same is, of course, true for a CoA aircraft operating under part NCO.

Maoraigh wrote:

It can never get back to being an EASA Aircraft, due to that work.

In that case, putting a plane on an LAA permit seems to be burning money right away.

mh
Inside the sky.
EDXE, EDXF, Germany

Only, being in Germany, operating a factory built a/c under LAA permit is not remotely sensible as to bureaucratic overhead. (Plus, you only get to have the a/c around 140 days/year (something along this line, the figure might be a bit off) based in Germany.

This may be a worthless angle but historically a good number of LAA types were based outside the UK. Various threads about that, including this one. One poster even posted an LAA letter making various (empty) threats but later asked for it to be removed. The only issue was that you had to have a “friendly” LAA inspector who signed it off as if it was in the UK, OR you flew it back to the UK for the annual inspection.

Post-brexit however, an uncertified G-reg may rank equally to an uncertified N-reg i.e. limited to 28 days in most countries… but doesn’t Germany allow 180 days, renewable indefinitely?? Elsewhere in Europe there is a clamp-down e.g. France and UK allows 28 days max for non domestic reg uncertifieds.

putting a plane on an LAA permit seems to be burning money right away.

Unless you want the owner maintenance option, which saves a lot of money (the EASA66 freelancer < 1200kg is a relatively new option, almost nobody knows about it, and in the UK there are almost no EASA66 freelancers because most of them work for companies and would get the boot if they were found out ).

But there is also the NPPL with the medical self declaration – a unique thing in Europe and priceless to many pilots. This is being restricted to non CofAs but that is also changing… and I imagine post-brexit will be ok for certs. Lots of people fly homebuilts (bought assembled of course) just for this reason.

Administrator
Shoreham EGKA, United Kingdom

Peter wrote:

Unless you want the owner maintenance option, which saves a lot of money

You can do the same on an EASA ELA1. The Part66 overview isn’t that expensive, that it would outwrigh the disadvantages.

Germany has different rules for factory built experimentals than for amateur built experimentals. I can base my Tempête (soon on PH-reg) in Germany without restriction, although I could not do it with a CAE-built DR250 on a F-P registration or a DR1050 on LAA permit.

mh
Inside the sky.
EDXE, EDXF, Germany

This seems to be similar to Lycoming certified and uncertified engines. Identical engines, made at the same factory, by the same people. The uncertified engine can never become certified, not a single piece of it. It is literally worthless in a certified world.

Yes indeed. Hence my Gazelle example; it has to be dismantled, inspected by a 145 outfit, and put back together. So it’s not quite worthless. It can be done, if the job is worth enough, and AFAIK it can be wholly via an inspection process. Very likely the CAA had additional requirements e.g. on my TB20 they wanted “EXIT” labels on the doors, and they said the KLN94 is VFR-only so approaches had to be disabled (only to be immediately re-enabled by the dealer)

Administrator
Shoreham EGKA, United Kingdom
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