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

I won’t expand on our particular benefits, as that is private to the owner, but I will say that T7 brings together many of the advantages of both N and EASA reg.

One obvious benefit is that it can be flown by pilots licensed under either regime, with their full privileges (so I can fly as an EASA ATPL, while my FAA ticket is PPL, and vice versa for the other main pilot.) Another is that any FAA STC can be applied etc.

Whether T7 has any benefits over 2-, M- or anything else, I cannot say. I understand that M- will only take larger aircraft. I also suspect that M- may call upon itself rather more frequent ramp checks (because of the known VAT position).

Speaking personally, I would always operate my own aircraft under the local authority (my aircraft is G- reg) but if people see advantages, which are legal, I guess that that’s up to them, but it does seem to cause a lot of heartache.

But I am looking forward to Brexit with gloom (for this and many other reasons.)

EGKB Biggin Hill

IOM Flight Crew licence validation isn’t worth the paper it’s written on. Might as well write your own on an A4 piece of paper headed by ‘Island of Fantasy Aviation’ with a comical rubber stamp of your own as the IOM validation carries about this much weight. The piece of paper they issue apparently just validates your existing privileges, so if you have an FAA licence (or other) then their piece of validation paper is really just stating that they agree you have an FAA licence, and that they have checked your docs (medical, currency and so on) and that is it. Regardless of what you are initially advised by them, be really careful of this.
The IOM validation allegedly doesn’t entitle you to fly the aircraft reg issued on it unless you have complied with the country licensing requirements where you are based (even though IOM have already checked your docs and issued the 3 year validation and they haven’t mentioned the above to you) I don’t know if Guernsey or San Marino is any different but if not I would hope they would be a bit more clear cut on the policy so pilots know where they stand.
You could for example fly an IOM reg aircraft that is based in different countries so would need to comply with all local flight crew licences, again your IOM flight crew validation is worthless.
I see that most of these registries are run by either retired ex pat pilots or other civil aviation personnel, nice work if you can get it, all expense trips to Ebace and other shows, where do we sign up ?

Spain

And perhaps now is the time to start closing some of these small outfits that masquerade as an ‘aviation authority’ If they cannot offer aircraft and crew documentation that can be trusted to be valid, then they deserve no place in the industry. If they consistently advise people to ‘call the national aviation authority for the relevant policy’ then really what is the point ? That, along with large aviation companies basically telling these small aviation authorities how to run things, and in some cases dictating policy and procedure to them.
It’s just one scandal after another…. whether it’s the televised VAT debacle or the documents that they churn out, and when you call them regarding intricate policy you might get to speak to some advisor that was working in a shoe shop until a couple of weeks ago.

Spain

Peter wrote:

One interesting thing I heard is that you can go N-reg to 2-reg without doing an Export CofA, which is super because it avoids having to dig out an FAA DAR.

I have a client that went this route, ie. N reg > 2 reg about 18 months ago.

I was asked to get a Geurnsey A&P Licence based on my FAA A&P licence which was just a couple of forms and a small fee.

That said, I was surprised when about 6 months after having performed an Annual Inspection I received a call from a Dutch national that was “renewing the C of A”.

It turns out that only a “state appointed” Inspector can renew the C of A, for a fee, which means an FAA A&P/IA does NOT have Inspection Authority with Geurnesy.

FAA A&P/IA
LFPN

Presumably the Guernsey registry will have a list of CofA inspectors who they have authorised.

You still need an FAA A&P/IA to sign any 337. Does Guernsey need their CofA inspector to sign off any mods too? In fact what is the 2-reg position on acceptance of FAA approved mods after the plane has gone onto the 2-reg?

Can one fly a 2-reg on EASA papers (licenses and medical)?

Administrator
Shoreham EGKA, United Kingdom

Michael, what does your experience to you suggest about the usefulness of your A & P validation ?

As for EASA on 2-reg it would likely be fine. Word of advice re dual papers and validations. If you fly predominately under FAA with type ratings on your licence and receive a validation for IOM or similar, then you will also need an EASA licence with associated type ratings endorsed and up to date to comply and make your validation legal. It’s not enough just to fly on FAA with type ratings and to hold an EASA licence with no type ratings. Your validation in this case would be worthless.

Spain

what does your experience to you suggest about the usefulness of your A & P validation ?

Yes indeed the key Q is whether an FAA A&P can continue to maintain a 2-reg, and do so fully using Part 91 rules, with the only “non US” bit being the Guernsey inspection for the ARC issue.

The other part of the big 2-reg Q is the pilot papers requirement. I am told by someone who knows that they accept any ICAO papers, and validate them specifically.

For UK owners, this leads to the “post brexit Q”: if a UK resident is required to have UK papers (and this happens despite the UK leaving the EU and thus cancelling the “resident in the Community” words in EASA FCL; we just don’t know what the UK regulators will do post-brexit in this department) then there will be no point in running the FAA papers. You may as well drop them and save yourself the money. You don’t have this option if remaining N-reg, of course.

The savings can be significant, and there are other factors. FAA medicals are hardly cheaper than EASA ones nowadays, because the FAA AMEs are scarce, and they are potentially much more expensive if you have an FAA Special Issuance, due to the extreme scarcity of FAA AMEs who are willing to do them and know their way through the SI maze. And some people cannot get an FAA medical at all but can get an EASA one (e.g. some cases of prostate cancer under surveillance; the FAA allows non-meta only). Post-stent the FAA demands a nuclear perf scan every 2 years… not only very pricey but some cancer risk.

Plus of course there is no FAA trust fee.

Word of advice re dual papers and validations. If you fly predominately under FAA with type ratings on your licence and receive a validation for IOM or similar, then you will also need an EASA licence with associated type ratings endorsed and up to date to comply and make your validation legal. It’s not enough just to fly on FAA with type ratings and to hold an EASA licence with no type ratings. Your validation in this case would be worthless.

I am not sure I understand this… The IOM validates any ICAO papers, surely. Only for a specified airframe(s) though.

Administrator
Shoreham EGKA, United Kingdom

Peter wrote:

I am not sure I understand this… The IOM validates any ICAO papers, surely. Only for a specified airframe(s) though.

If the operator is based in the EU, then they also must have EASA papers just like they would if the aircraft was N-registered.

Manx based operators won’t need to do this, of course, since they aren’t based in either the EU or an EASA jurisdiction, but there aren’t many Manx-based operators on M-reg (there are probably more on N reg than M).

Last Edited by alioth at 16 May 10:34
Andreas IOM

OK, yes, that’s clear. You have to live on the IOM, for the M-reg to unambiguously protect you from the EASA FCL dual papers requirement (well, until you get into the “operator” meaning). But everybody knows this because they have read the bible

Administrator
Shoreham EGKA, United Kingdom

As Alioth says, flying IOM registered aircraft outside the IOM means that you need EASA papers, although the reality is the IOM will validate any ICAO just like 2-reg and provide you with a 3 year airframe specific validation. The validation in this case is rendered meaningless unless you have an EASA licence which begs the question why they issue a validation in the first place when they are quite obviously aware of aircraft permanent location ?
Even if you hold an EASA licence you will need the relevant type rating and currency, and you can’t just rely on it being listed on your FAA licence. If you don’t also have the type on your EASA licence then your validation is worthless.
There has been much supposition regarding IOM flight crew validations, and it hasn’t been made crystal clear by them. But it can be assured that the above is correct and if you are not compliant then your validation is rendered the equivalent of papier toilette. The operator location doesn’t hold any meaning if the aircraft is hangared in an EU country.
Not looking good for these registries, worthless flight crew and engineer validations for a start.

Spain
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