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Channel Islands / Isle of Man / San Marino aircraft registry / register (merged)

All I can tell you is when I registered my Previous aircraft on the M reg ( it was the 7th on the register) we were allowed to adopt FAA maintenance. Six months in the then CEO Brian Johnson rang me and said that firstly the FAA were unhappy with the adoption of their system and secondly the UK CAA said as the M reg was a sub register of theirs (by piggy backing on the UK ICAO seat) the M reg had to adopt their maintenance regime.
This immediately caused me the have to have the prop rebuilt on the then CAA 6 year rule plus other issues I don’t now recall. This is why my next aircraft stays on the N reg even though I could put it on the M reg as an Isle of Man resident.
However, it’s some time since I had a chat to the guys at the M registry. I’m waiting for Peter’s next trip to the island and I intend to take Peter to meet the IOM registry and no doubt Peter can report back the latest position. I have not heard of any major changes.
What I find bazaar is the cheapest way to operate an aircraft IFR as a resident of the Isle of Man is still the N reg because you can adopt FAA maintenance and being outside Europe the EASA April 2015 date does not apply here so I can still fly IFR in Europe in my N reg plane on my FAA IR.

EGNS/Garey Airstrip, Isle of Man

Apparently, the official launch of the 2 reg in Guernsey is tomorrow. There is a TBM (I think) sitting in ASG’s hangar all painted up as 2-PLAY.
AND……they say FAA maintenance is accepted. Hmmmmmm. This will be interesting.

EGNS/Garey Airstrip, Isle of Man

How long that will last for… ?

It’s possible that the CAA opinion/pressure reported by Mr Johnson with regard to the IOM registry having to go Part M may have just been some “lavatory cleaner grade” in the CAA giving his/her personal opinion – it really does happen and the CAA has on occasions got into hot water over such letters when their tried to prosecute somebody.

But I would expect him to have investigated that aspect carefully because Part M is a huge issue for many.

I wonder how they deal with FAA modifications – Minor mods, and Major mods done as 337+STC or 337+Field Approval? An EASA CAMO has no authority to sign a release to service for a plane with non EASA mods. All that an EASA CAMO can do is sign off that the maintenance was done IAW FAR Part 91, and perhaps force component life limits (like your prop).

Administrator
Shoreham EGKA, United Kingdom

Does anyone have first hand experience of San Marino registration on the face of it would seem to be an alternative to the N reg???

My airplane was “T7” before I bought it. I did not leave it on San Marino, although it would been possible to register it by eMail. Here’s some more information: http://www.caa-mna.sm/benefits.php?w=b

If you have an FAA licence and IR rating you could use that, that’s one of the main advantages of the T7 registration. For some countries you need to apply for overflyimhg rights, AFAIK

There used to be a S.M. registered SR22 parked in the hangar at Biggin where I do my maintenance. It belonged to another pilot (an Italian) on here. He was the one who arranged the T7 reg and he ought to know about whether it is effective. One UK VAT specialist is of the view that it is not effective for VAT – except possibly inside Italy where things work differently… We have had multiple threads here on San Marino – I suggest a search.

Administrator
Shoreham EGKA, United Kingdom

The one you are talking about is my SR22 :-) It was T7-BIG then, G-YORC now. I bought it in B.H.., Valerio has another SR22 now, he’s here too!

Last Edited by Flyer59 at 17 May 14:41

Flyer59 is there a specific reason you did not keep your aircraft on the T7.
I’m try to find out the ongoing charges and sent them an email that hasn’t been answered yet.

I have two aircraft in Spain one Commander 114A on the N reg and I maintain that in it’s entirety myself having an FAA A&P plus Inspection authorization and I am investigating the same possibility with the San Marino registry for my G reg Scottish Aviation Bulldog as I have to employ engineers from UK to visit Spain to sign out the Annual inspection and the three year airworthiness inspection is a pain!.

I looked into San Marino a while ago.

According to one aviation VAT specialist, T7 is of zero value for VAT (the San Marino certificate of free circulation is worthless because SM is not a distinct EU member State). I have a long email from him somewhere.

It is IMHO of zero value for EASA FCL protection because the “operator” will still be based inside the EU and will be operating in and out of the EU (the most common GA pilot-owner scenario).

Its value for airworthiness is suspect in the long term because SM has no ICAO seat and if they do issue CofAs then they must be doing it on the back of Italy’s seat and, exactly as has happened to the IOM (M-reg) registry, the seat holder (UK in the IOM case) is likely to eventually turn around and tell them to stop issuing these CofAs because the Italian CAA is getting p1ssed off with the loss of revenue on bizjets and such. The IOM got in under the wire for a while, until it became big. I had a meeting with the IOM Director of Aviation (before he retired) and it was clear that any maintenance advantages were dead and buried – everything (even an IOM based TB20) was fully EASA Part M, all lifed parts mandatory, etc. The only advantages of the M-reg lie in financial (tax) structures and perhaps confidentiality (not revealing the real beneficial owner) for certain applications.

T7 wanted something like £20k for the TB20, for no advantages.

So, in summary, I don’t think T7 is of any value to a EU based owner-pilot. Unless he is an Italian in which case he may get certain advantages as is customary in Italy (and other southern countries) if one speaks the language and has local connections Then, everything is possible….. I just wouldn’t pay 20k for trying it.

N-reg is much easier and as things look nowadays, much safer. It is a solid robust regime, with well defined airworthiness and pilot licensing principles, and the only issue is EASA FCL which forces the pilot to obtain duplicate European papers. Those are a lot of work but IMHO not worth 20k even if San Marino delivered solid protection.

I also would not fancy arranging an Export CofA with my nonexistent Italian if I wanted to get it out of T7 one day, especially if the T7 registry is having problems.

If anyone knows information to the contrary, I am sure many will be interested, but I haven’t seen it yet.

Administrator
Shoreham EGKA, United Kingdom

SM has no ICAO seat

Yes it has, according to ICAO’s own list of member states.

Last Edited by Airborne_Again at 19 May 06:41
ESKC (Uppsala/Sundbro), Sweden
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