Benefits/drawbacks of N-reg vs YR vs PH with new Part-ML

I have my FAA PPL + IR

Are you saying you ONLY have FAA papers? In this case, putting it on an EASA registry is out of the question, since then you wouldn’t have the required license to fly it.

And even if you put it on say PH-reg., as a European resident, you do effectively need EASA papers as well.

So, either way, you do need EASA PPL + IR.

With the new Part-ML, is there any benefit to N-reg in Europe?

This is currently amongst the most debated questions in the pilot community in Europe. Those on the N-Reg. say “YES, there definitely still is”, while some of those which are on an EASA reg. will fiercely say “NO”. I guess it depends…

dutch_flyer wrote:

With the new Part-ML, is there any benefit to N-reg in Europe? I have my FAA PPL + IR (all current) and am a US citizen, so the registration and licensing aspects are straightforward enough. But I can’t see any obvious benefit to it, unless I’m missing something.

The major benefit seems to be that you can apply all FAA STCs.

Airborne_Again wrote:

The major benefit seems to be that you can apply all FAA STCs.

Which is a bridge one could also cross if one gets there (i.e. if it’s already legally on EASA registry one could wait with considering n-reg when one wants to do a change that is only possible under FAA STC).

As well as many past threads here, you can find some general reasons for N-reg here.

There are many advantages but whether you can get them depends on your ground / airfield politics situation e.g. here.

FAA STC applicability is a great thing, but how well you can manage the regular maintenance is much more important. I know where I am based I could never make use of a freelance EASA66 mechanic – even if I could find one – because there is no hangar where he could work and where his full time employer would not find out

I don’t think N reg gives a major benefit anymore (trust, „premium“ prices for scarce ap/ia personnel).

The exception is Single Engine Turbine, which require a class rating under EASA (vs only a high performance and complex endorsement under FAA) and if heavier than 2730kg do not fall under part ML.
The class rating is actually a minor issue. The maintenance on a TBM under FAA vs EASA can make a difference. Then again, who in their right mind would pay a couple million for a TBM and then operate everything on condition to save a few bucks?

Now in your case, as a us citizen, you save the trust fee so it’s only about finding an ap/ia.
If you have this lined up, go n reg.

If not, leave it on the romanian register on a self declared AMP. If the romanians turn out to be difficult, get an intra easa registry change (not a big deal).

@peter

Some info in the article isn’t accurate anymore.

Benefits and Drawbacks of N-reg (Part 91 operation assumed; listed not in any order of importance)

Benefits:

a) A pilot with the FAA IR gets worldwide FAA IR privileges. This is the #1 reason private pilots do it, in most cases. From April 2016, for owner-pilots living in the EU, this will probably disappear (see notes at the end).

>>> How is this different to flying IFR in an EASA aircraft (worldwide)?

b) No Insurance Premium Tax (saves 5% on the premium)

>>> Insurance tax applies

c) Easier installation of modifications. The approval route (337, DER, etc) may not be cheap (especially via a UK avionics shop) but the process is usually straightforward. In theory one can obtain UK CAA/EASA approval for anything on an EASA-reg but the process can be very expensive for even small mods and is completely uneconomical in many cases.

>>> Now similar with EASA (owner certified parts)

d) Can fit STCd aftermarket accessories which are already approved in the USA but aren’t not Europe (EASA) approved e.g. much better landing lights. Can also fit FAA-PMA parts. Update 11/2015: EASA is accepting FAA-PMA parts – here subject to some restrictions – local copy

>>> Landing lights can be UNCERTIFIED and changed with C-STAN easily, no STC required.

All FAA STC can be approved for a single airframe with EASA. In practice, for mainstream changes, older STCs are grandfathered and new STCs are issued for EASA anyway.

e) Pilot maintenance is permitted, to an extent which is slightly superior to the EASA Part M regime.

>>> Pilot maintenance is very liberal now with EASA ML.

e2) For EASA-reg aircraft, there is currently a CAA/EASA requirement to comply with all ADs that apply to the aircraft regardless of the country of the AD issue. So if you have a G-reg it has to comply with ADs from the FAA that affect it or any components on it, whereas an N-reg aircraft (Part 91) needs to comply only with FAA ADs even if it contains parts that are subject to an EASA AD. The degree to which this saves costs is variable but it is a good thing given the past tendency of for example the UK CAA to generate large numbers of ADs which every other country thinks are pointless. There are few if any important EASA ADs which are not also FAA ADs. The reference for this requirement is currently in CAA CAP411 5.1 All applicable Airworthiness Directives issued by EASA, the CAA and any applicable Third Country Airworthiness Authority which is responsible for the state of design must be complied with.

>>> Not a lawyer, but either EASA issues an AD, or they don’t. They can’t make anyone follow an FAA AD.

f) In some situations, reclaim of duty on parts is possible with an End User Certificate. This is however possible to achieve anyway using a Form C100 – more details here (local copy).

>>> Aren’t airplane parts without duty US→EU anyway?

g) The CAA Notice 75 propeller inspection, generally regarded as causing more problems than it prevents, is not required. Update 10/2007: Notice 75 has been replaced by CAP747 Generic Requirement 17. Mostly the 3 year/6 year cycle has been replaced by overhaul in accordance with manufacturers recomendations, normally 6 years or 2000hrs.

>>> Not applicable to EASA under ML. On condition for the win.

h) Can freely buy parts (new and overhauled) from the USA. This can be a major cost benefit of N-reg. An 8130-3 form is desirable but not mandatory; the regulations are in FAA Order 8130.21. Some notes on required documentation are here. An 8130-3 is OK for a G-reg aircraft but only if the part is new. Overhauled or used parts with an 8130-3 cannot be fitted to a G-reg; they need an EASA Form 1 which can be generated only by an EASA 145 company and this usually increases the cost substantially. 4/2011: it is widely claimed (and believed) that EASA regs mandate an EASA-1 form for absolutely everything, which is false and if true would be a ludicrous cost inflater.

>>> Same thing possible with EASA. No Form 1 required.

i) If an SB (Service Bulletin) becomes an AD (Airworthiness Directive) then it becomes mandatory and must be implemented. The majority of ADs track between CAA/EASA and the FAA but there are still CAA ADs which the FAA has not mandated. Given that around 75% of the world’s General Aviation is in the USA, this appears pointless regulation. However, the FAA is gradually implementing a process whereby mandatory SBs on European-manufactured aircraft are automatically converted into FAA ADs and thus the work must be done on such an aircraft even if it is N-reg – additional info here. This applies to future EASA MSBs only; it is not retrospective.

>>> Contrary to their wording, MSB are optional under EASA ML. One must follow 1) Airworthiness limitations and 2) ADs. Anything else is optional.

j) The USA has filed some differences to ICAO on the medical front and has not imposed the audiogram requirement (reference here) which is required for an EASA CPL/ATPL or a JAA PPL/IR (it is not required for a plain JAA PPL). This unreasonable requirement means that a pilot with one perfect ear and one ear which doesn’t meet the specification (a common enough condition especially among older people) cannot ever get an EASA IR – even though the headsets are monaural so one bad ear doesn’t matter. EASA permits “demonstrated ability” but only on a renewal medical – this is ironic since all airline pilots who are actually working are flying on renewal medicals!. 12/2010: there is some hope here that this may change.

>>> I don’t think the FAA medical is any easier than the EASA one.

k) In some situations where an aircraft is “rented out” but not to just anybody who turns up (e.g. an individual owns a business which owns the aircraft, and the aircraft is rented back to the individual; this is a common procedure done under the UK Inland Revenue Benefit in Kind rules) an N-reg aircraft is legal if maintained under Part 91 rules, whereas a G-reg aircraft thus operated would arguably need to be maintained to a Public Transport CofA regime, and that is significantly more expensive (50hr checks, 150hr checks, all done by an EASA145 company, plus a lot of pointless maintenance) and is pointless given that the actual operation is identical to a fully privately operated aircraft flown by the very same pilot.

>>> Renting out an airplane for money is NCO and no special maintenance is required. ML is sufficient.
On a related note EASA has the cost sharing benefit though, where FAA forbids „holding out“.

l) It is often easier to find good freelance maintenance engineers (FAA A&Ps) to work on N-reg aircraft than on EASA-reg (EASA66, plus a separate EASA Part M signoff). This means you can assemble a group of good people who you can trust. For the Annual you may still have to go to a large-ish firm (because of the amount of work involved, and the need for a hangar in which work is permitted by the hangar owner) not many freelance engineers can do Annuals) but for everything else you can make sure that the job is done properly, preferably with you present and helping out. With an EASA-reg, you practically speaking have to use a company and the problem with using a company is that it is impossible to attribute bad workmanship to a particular individual. This makes it easier to avoid the numerous crooked maintenance companies; one of many EASA Part M scams is pretending that the first Annual the company does on a particular aircraft needs a “back to birth” inspection of everything…

>>> EASA 66 freelance personell can now also issue the ARC. More and more will be available.

l2) When on a long trip away from Europe, it is much easier to get maintenance on an N-reg aircraft than on an EASA-reg aircraft. There was a case where the Annual on a G-reg expired while passing through Australia. The UK CAA refused to accept Australian maintenance and insisted on a CAA inspector to fly out there (first class) to do it. It was cheaper to transfer the aircraft to N-reg and fly it back that way, which is what was done…

>>> Any EASA mx Organisation can issue a ferry permit.

m) There is no UK CAA 150-hour service. For G-reg pilots who do more than 150 hours per year, this is a major added cost as the 150 hour check costs almost as much as the full Annual.

>>> No 150hour requirement exists for EASA ML

n) There is a relatively straightforward regime for owner produced parts. This is particularly relevant for aircraft types where the original manufacturer is no longer producing the parts. In short, he owner can make the part, for his own aircraft only. However, this is not a free-for-all for making one’s own bits; the part’s manufacture and installation still requires to be documented and is likely to be queried by a subsequent buyer. URL local copy

>>> Isn’t it the same now with EASA. Owner certified parts.

o) The US aircraft market is much bigger than the European one, especially for more advanced types which are much more ubiquitious out there due to the much more accessible IR. This makes an aircraft import from the USA attractive, but transferring the N-reg aircraft to a European reg can be problematic.

>>> Read US-EU BASA TIP, it’s not an issue unless the airplane has been significantly modified from it’s TCDS.

p) Most of what EASA regards as life-limited parts, for no technical/engineering reason, can be operated “on condition” under FAA Part 91. On an N-reg, the only strictly life-limited items are ones listed as such in the Airworthiness section of the POH.

>>> Again, part ML, exactly the same with EASA.

I would get rid of the YR registry and put it on D-reg. All things considered, this is the most highly valued EASA-reg (good for resale). I assume he understands some German, which helps with some correspondence/forms. Otherwise, go PH-reg.

An intra-EASA reg change is not such a big deal.

If there is no striking reason for going N-reg (some specific mod he would like to do or so), in his situation, I would not do it. After all, this change also costs quite some money, and also bears some risk (depending on he DAR doing it, of which there are very very few in Europe). Also note this is a TB10, so there will no FAA STCs for which there is no EASA STC.

Another story would be if the aircraft WERE N-reg right now. In that case, I would keep it as such, unless some specific reason calls for going EASA-reg.

Without knowing any specifics, I would not have bought a YR-reg, no matter how good the deal was, but rather would have found one on D-reg or PH-reg.

Snoopy – a lot of that is not correct. I suggest a search for “N-reg” (with the quotes). And e.g. here.