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Euro reg to N reg transfer / FAA DAR discussion

Another question. If you ferry over an N and after a year or two you want to export (de-register) to an EU reg...can this be handled over paper only...via an US FSDO?

Having called around now quite a bit it looks like the EU DAR route becomes very problematic to put an EU aircraft to N, there is virtually only one operational DAR left....and he is very busy...it takes a very long time to get things going....

The only pragmatic options seem to ferry an aircraft over (heard some horror stories about containerization also...)..as such no DAR...

What happens if teh aircraft sustains a gear collapse or some other major issues..is an IA sufficient..?

Anyway....you have to be a masochist to go for aircraft ownership nowadays it seems...;-(((

EBST

I think a DAR is required for an Export CofA.

But why do you want to transfer the plane to EU-reg?

Administrator
Shoreham EGKA, United Kingdom

In some Eastern parts of Europe (ex Warsaw pact countries..) FAA A&P's are scare's..;-)..e.g for the annual sign off or anything major engine change ...unless you know A&P's who travel and do this stuff for a reasonable price ..? I would maybe consider an N as a temporary solution...

EBST

Is it so difficult to find an AP&I willing to travel to Eastern Europe? I have a N registered plane in Ukraine for about 4 years now and it was never an issue to find an AP&I to do an inspection locally at reasonable cost. And as there are now 5 other GA planes with N registration based near Kiev, some AP&I are coming regularly and so are travel costs further lowered. Cirrus DE has some guys who are travelling around Europe most of their time.

Belgium

I too know a couple of freelance A&P/IAs who will travel, and there are many others in Europe.

I've never heard of anybody having a problem in this area.

The DAR situation is probably harder; the two I have been in contact with (Manfred Herweg and Lloyd Nelson - both are on that FAA DAR contacts page) perhaps having become quite busy recently, but there are almost no good reasons for a registry transfer after you got the plane you want. You can sell an N-reg in Europe OK - unless perhaps it is one of low value (say under €50k) and of a type which tends to be operated mainly by schools or syndicates; in those an EU reg is preferred for obvious reasons.

You would not want to do a N to EU registry transfer because the local Euro CAA inspector could cause a lot of trouble, with equipment and modifications he doesn't like. I have heard some horror stories from people doing this in southern Europe where they treated a TB20 like a 747 - the "southern European way of doing documentation".

Administrator
Shoreham EGKA, United Kingdom

OK, A&P going east bound is solvable then, I guess the DAR availability another, It takes min about three months to arrange things lately. On the other hand I agree that going back to EU reg may be painful exercise given the min, major mod issues and EASA STC's etc..I had some hopes that EASA would sarta more relaxed STC approval but I think that ...maybe I was hallucinating...

Ok so this means I can do some nice approved FAA STC's locally with my eastern friends working under EASA regimeand fly in an A&P to do the 337 or FAA STC approval/check..e.g. new three blade prop under STC, new paint, new outside glass a la BDS speed slope, interior, etc..correct?

EBST

Ok so this means I can do some nice approved FAA STC's locally with my eastern friends working under EASA regimeand fly in an A&P to do the 337 or FAA STC approval/check..e.g. new three blade prop under STC, new paint, new outside glass a la BDS speed slope, interior, etc..correct?

I don't understand you... what exact mods are you proposing and what approved data (STC etc) are they supported by?

Administrator
Shoreham EGKA, United Kingdom

OK, Peter take this hypothetical situation. On Bonanza's you can do a lot of Mod's STC's. ost of them have been approved under FAA STC e.g changing the front windscreen with a more aerodynamic one. Installing Tip Tanks, Removing and installing new instrumetn panels..all this stuff can be done under FAA STC not so in EASA country as everything becomes almost a Major alteration and most of teh STC aren't even approved e.g alternator, even GAMI injectors are technically not allowed as the is no EASA STC unless someone in some country did it before 2003 (grandfather rights).....The newer FAA STC you can forget e.g a scimitar prop from Hartzell and Mcaauhley ...NOT approved under EASA STC..

SO the work can be still performed by very skill full EASA Mechanics (execution of the work) but the sign off (on N reg)needs to be done by an FAA A&P this goes for every work done on the aircraft I assume..

I ask this question as I know very good mechanics who can do the work but not the FAA sign off afer completion...

EBST

SO the work can be still performed by very skill full EASA Mechanics (execution of the work) but the sign off (on N reg) needs to be done by an FAA A&P this goes for every work done on the aircraft I assume.

Anybody can perform work on a N-registered aircraft, as long as its under the direct supervision of an appropriately FAA certificated A&P mechanic.

FAR 43.3 (d) reads "A person working under the supervision of a holder of a mechanic or repairman certificate may perform the maintenance, preventive maintenance, and alterations that his supervisor is authorized to perform, if the supervisor personally observes the work being done to the extent necessary to ensure that it is being done properly, and if the supervisor is readily available, in person, for consultation." Being "readily available" is interpreted by most people to mean the A&P can be called on site by phone, not that he needs to be on site every minute the job is underway.

http://www.sportair.com/articles/Maintaining%20a%20Production%20Airplane.html

In addition, a limited number of maintenance tasks can be performed by a pilot without A&P supervision.

In an ownership based private aviation scene, which is what exists in the US, it would be totally unenforceable to prevent aircraft owners from touching their own aircraft, in their own hangar. Requiring that they work under direct supervision of a certificated mechanic per FAR 43.3 is therefore a practical approach that owners almost always respect.

I am no expert (others here much more detail) but I will have a go:

Most things done under an STC are in fact Major Alterations under FAA, but the FAA STC provides the Approved Data to fully support the Major Alteration application (Form 337), so the 337 is just sent off to the FAA for filing.

Just because a product comes with an STC does not mean the alteration is Major; many STCs are done for marketing purposes (because many mechanics won't or can't read the regs) and replacing Gill batteries with Concorde batteries is a common example.

The other Major Alteration route is a Field Approval (also a 337) but that is now quite complicated to do in Europe, though I am recently informed the FAA office in Frankfurt is now doing them. This or this are examples of Field Approvals and I don't fancy doing it again.

A 337 must be signed by an IA (or an FAA Repair Station).

In Europe, you should try to avoid doing Major mods that are field approvals; in practical terms this will usually lead you to the de facto owner of the known universe (Garmin) If you can structure the job to be a Minor Alteration, it becomes trivial. The Major v. Minor decision is done by the IA, or an FAA 145 Repair Station.

Sometimes the STC does not fully cover the required work, but so long as the non-covered bit can be done in accordance with a generic FAA guide e.g. AC43-13 then you can still do it. This is an example of such a job.

Where the aircraft is physically located is irrelevant. The State of Registry controls the certification regime.

GAMI injectors have been installed in many EASA-reg planes, including my then-G-reg TB20 in 2002, so you have masses of prior approvals.

What you don't have is a pan-European database of mods, and the lack of such a database makes EASA's certification grandfathering (IMHO about the only useful thing EASA has delivered to date!!!) worth little because there is no straightforward way of discovering who else has done this before elsewhere in EASA-land

The UK CAA has a database here but you need to be patient to find anything useful there. The filing has been done stupidly so e.g. one EDM700 install might be found under "EDM700" while another might be found under "JPI".

Work on an N-reg can be done by anyone suitably qualified. No EASA qualifications are required. Usually the work is done by an A&P, or by someone under his supervision. Obviously this option is necessary otherwise nobody could ever learn on the job, and same goes for EASA.

AFAIK an A&P needs to sign off all work which is outside pilot privileges.

The question is how much work are you after?

The EASA STC business is a mess, partly because EASA does not lay down usable rules which would allow the Major v. Minor determination in the field. Their system is the European way i.e. everybody is assumed incompetent by default. And even EASA 21 qualified companies cannot reliably tell which way EASA will fall on a given proposal.

Administrator
Shoreham EGKA, United Kingdom
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