D-reg. vs. N-reg.

Inspired by the other thread about the german annual IFR avionics checks (and by the current discussion about TBOs) I thought I’d try to summarize the various pros and cons of D-reg. and N-reg.
This applies to a private owner with EASA pilot license who has decided to buy an aircraft and needs to decide whether to go D-reg. or N-reg. Let’s presume has wants to fly IFR and the aircraft of choice is a certfied piston four seater.
Of course, I am a little biased , but I will try to be as neutral and objective as possible and – where possible – try to give a ballpark figure about the money amounts involved.
I hope this is useful for some.
It would be nice if others could add any missing important pros or cons relevant for registries other than the D-reg.

Let me start with the CONs:

1. For non-US citizens, owning and operating an N-reg. will require a trust. The “hassle” that’s involved is very little. After setting it up, it merely requires a yearly payment of the admin fee via bank wire or credit card. No big deal. Costs vary with different trusts. As a ballpark figure, setting up the trust may cost around 1000 Euros and yearly fees vary between 400 and 700 Euros.

2. Maintenance will have to fulful US requirements. For that, an A&P will be required (plus an IA for the annuals). That does in fact restrict the “choice” of shops to some degree and might induce the need to fly half an hour or so to the shop instead of having the work done at the “local” shop. Also, those shops that do FAA maintenance (but don’t have an IA permantly on staff) will sometimes levy an extra “IA charge” ( a few hundred Euros) for annual inspections. (However, the bigger shops usually don’t do that.

3. Due to the noise schemes applied on landing fees in Germany and Switzerland, being N-reg. might mean occasionally paying slightly higher landing fees. This subject has many facettes and shades of grey. In a nutshell, according to the german regulation, airport personell is required to accept foreign noise certifications; however, in practice it is sometimes a little different. That’s because foreign aircraft cannot technically have a genuine german noise certificate with the “Bundesadler” stamped on it. However, we are talking a few Euros here and there. Most of the time, does not object when the pilot produces some credible noise values for the aircraft concerned.
(In reality, there is much more to this subject, for example, the lack of “erhöhter Lärmschutz” on foreign regs can severely restrict the ability to fly repetitive circuits at german airfields, but as we are speaking primarily of “touring” aircraft, this doesn’t play much of a roll).

3. Landing fees in Greece will be higher. However, landing fees are currently completely waived in Greece. Even if they decided to stop the waiver in the future, we are only talking a few Euros per landing. Most of us will not be flying to Greece more than a couple of times a year.

4. The process for obtaining overflight permits in Turkey is different for ECAC and non-ECAC registered aircraft. In fact, private ECAC registered aircraft don’t need permission at all, whilst non-ECAC aircraft do. One more thing to do with an N-reg., but not a cost factor, since the permits are free of charge. Again, how often do you fly to Turkey?

5. Licensing: N-reg. aircraft will in future require both FAA and EASA licenses and ratings; EASA aircraft only require EASA licenses and ratings. So, when the starting point is a german pilot with a german pilot’s license, the difference is that, if he decides to go N-reg., he will additionally need FAA pilot papers.
For a plain PPL, that is very simple. It doesn’t even require a trip to the US, as it can be done throuh Adam House. Costs: roughly 500 Euros. If the pilot wans to fly IFR, he will also have to validate his EASA IR. That is merely a short written multiple choice test, but it involves a little learning and a little bit of travel (Paris). However, it’s a one-off thing and there are no recurring issues with holding FAA pilot licenses. With 61.75 FAA license (i.e. a "validation of the EASA license) one doesn’t need to hold a US medical – the EASA medical will suffice (this is different if one choses to go for the full “standalone” US license), but that’s another topic. For the purpose of this comparison, the 61.75 FAA license will suffice.

What is definitely required though is the flight review (formerly: biennial flight review; BFR). However, in Europe it is rather easy to find an FAA CFI who also happens to be EASA FI, so one can usually combine the flight review with the unavoidable EASA biennial “training flight” for revalidation of the EASA SEP rating (or with the annual IR revalidation flight).

6. The uncertainty deriving from the question “how long is it going to last?”. As an example, EASA might eventually mandate Part-M also for non-complex (in EASA speak) aircraft, just the way they did it for the complex ones.

Now, the PROs:

1. Application of TBOs. This is a huge and quite complex topic, so just a few notes. First of all, due to EASA, there is currently a lof of uncertainty how manufacturer recommended TBOs will be treated in future by the german LBA. However it will come, there is no system (not even the german) which is currently as “pragmatic” about recommended TBOs as the US system (i.e. TBOs which are no airworthiness limitations are in the complete discretion of the owner and his mechanic). It is very difficult to estimate the financial advantage of this, though. It depends a lot on how far the owner is ready to “use” that discretion in order to go over the manufacturer recommended TBOs (which, in turn, obviously depends on how “savvy” the owner is. It also depends a lot on the aircraft type. The SR22 is probably an extreme example in that it has a truckload of useless TBOs in its maintenance manual (such as: replacement of all fuel drain valves every 24 months). According to my shop, the difference in maintenance bills between N-regs. and EASA-regs is really significant, each and every year. But I understand that in the case of other aircraft types, the difference might be less pronounced.

2. Application of SIDs. See the current issue of Cessna singles. Some big money at stake.

3. Application of SBs. AFAIK, in the context of D-reg. vs. N-reg. this is not a big aspect, though (i.e. no mandatory compliance with SBs as Sweden did so far).

4. Just as a few keywords: STCs, 337s, field approvals, logbook entries. No EASA “minor” and “major” mods and their incredibile fees. (This is not to say modifications on N-regs. don’t incur any fees).

5. No famous german annual IFR equipment check and subsequent check certificate.

6. No EASA Part-M maintenance programs. Creation, approval, modifications…all costs money.

7. Under D-reg, even if no major work is performed, every aircraft needs to be re-weighed periodically (every five or ten years, I don’t remember). No such thing under FAA rules. There are many more of those minor brainfarts and other goldplating efforts from the german LBA (the famous Feuerlöscher NfL or the seat belt thing for example)… I guess every european country has a few of these. None I can think of from the FAA.

8. No insurance tax for N-reg. aircraft. This tax is four or five percent in Germany, so depending on the amount of insurance and the subsequent premiums, we are talking maybe a couple of hundred Euros a year.

9. EASA equipment mandates. Here, one has to distinguish between those that effect all aircraft operating in european airspace (which, therefore, don’t mean any advantage for N-regs as they need to comply as well) and those that are applied to aircraft on the D registry only. Lately, most of these equipment mandates are of the former type, though, so there is not really a lot to be gained there if operating N-reg.

10. The (non-financial) “humiliation” aspect of being an owner “under” the LBA. Experiences very widely, but the current uncertainties regarding the future of recommended TBOs are just one example. The FARs, while sometimes very pragmatic and sometimes very strict, usually contain far less ambiguities and contradictions than the european regs.

In summary, it is difficult to draw conclusions and give clear cut recommendations. I think it depends a lot on the type of aircraft, too. The more complex the aircraft is, the more I would tend to say the costs saved due to TBOs, STCs, SIDs, etc. will outweigh the costs involved operating an N-reg. (the cost for the trust, for example, is mostly independent from the size of the aircraft). In other words, in the case of a Piper Warrior, it probably doesnt pay off to go N-reg. (unless the aircraft isn’t_ already on the N-reg_.; in that case, it’s a different story, also because going N-reg. —> D-reg. has proven to be very costly for many owners). I deliberately didn’t use the example of the Cessna 152, because of the current SID uncertainties.
On the other end of the scale, would I recommend going N-reg. if we are talking P210, Piper Mailbu, Cirrus SR22, or even a Piper Seneca? You bet.
The question remains for everything in between, such as a Mooney M20J, a Piper Arrow, or a Cessna182.

Thoughts?