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

“We’re convenient registers, not registers of convenience.”

Now, that sounds like a university philosophy course entrance exam question in the making

EGKB Biggin Hill

Lol ! I thought that too.

And really some of those registers are not convenient. When looking at the ambiguity with pilot and engineer licence validations that they issue, and the will they / won’t they have a validation that can be used then why bother ?

Spain

I guess that the thing that makes them most inconvenient is the increased chances of ramp-check.

You can be fairly sure that anyone using a “convenient register” is doing so for a reason: trying to avoid something, or get some advantage.

And it is a commonplace that people don’t ringfence their behaviours, so someone trying to duck under one set of rules has an increased liklihood of ducking under others, so are extra fair game for a random check.

Just a theory.

EGKB Biggin Hill

Well, exactly. I think you make good points. Just looking at some of those businesses and individuals that are on these registries confirms your points.

And yet it continues to happen, somewhat iffy, and if one may add possibly morally bankrupt documentation churned out from these registries at breakneck speed, leading to the aircraft and crew being potentially being worse off than if they had stayed on their national registry.

Spain

You can be fairly sure that anyone using a “convenient register” is doing so for a reason: trying to avoid something, or get some advantage.

Isn’t that true for all of life?

Europe has screwed up the private IR and it should not be surprised if people who want it hard enough use a different route.

A lot of this M-reg etc activity is done for the tax treatment. It isn’t done for pilot licensing because 99% of the >5700kg scene (which is basically all that the IOM allows, unless you live there) is flown not by the owner but by a paid crew of two, and you can “always” dig out two EASA CPL/IRs who will jump at the chance of that sort of life. And tax avoidance is 100.000% legal and everybody should do it because it is fully in accordance with the law. If you assert illegality then you are asserting tax evasion.

The problem is that when a Person X reaches a certain standard Y, with a lot of work, X thereafter likes to block others achieving Y using a smaller effort. Accordingly, what I have found in any meeting of “old” UK IR holders (and I used to go to such meetings until 2-3 years ago) is that the “old guard” mostly

  • did their IRs via the 700hr route (but rarely mention this while telling everybody about the wisdom in the 14 JAA ATPL exams )
  • slagged off the N-reg scene (not for a moment suggesting that this is anything to do with the N-regs being new $500k+ planes doing 150hrs/year while the “old” CAA IR guys had 30 year old stuff and doing 30hrs/year)
  • moaned about “continually dropping CAA IR test standards” e.g. no longer testing the gate method in NDB holds
  • moaned about “new IR” pilots not knowing about PBN, RNAV, PRNAV, fly-by waypoints v. fly-through waypoints, etc

A slightly tongue in cheek caricature but you get my drift I am sure…

UK issued EASA pilot licences may possibly be invalid when the U.K. leaves the EU next year

No, because they are ICAO licenses. Valid for a G-reg worldwide, as always. You just won’t be able to (automatically) fly e.g. a F-reg or a D-reg on them. We did this in another thread recently. It may affect airline pilots who may have to do their next revalidation with a CAA of the country which issued their airline’s AOC.

and if one may add possibly morally bankrupt documentation churned out from these registries at breakneck speed, leading to the aircraft and crew being potentially being worse off than if they had stayed on their national registry.

This is getting a bit too hyperbolic, for me to think it is coming from someone totally uninvolved in, say, in a G-reg AOC charter operation, or even working in the DfT I’ve been hanging around this business for almost 20 years…

Administrator
Shoreham EGKA, United Kingdom

Well we are just having a discussion, right ? We are exploring the possibility that maybe some of these registries issue paperwork that might be possibly less than legitimate, or maybe not.
Perhaps you are right about EASA UK licences after Brexit, but although ICAO they might not be viewed as such if we are no longer part of EASA which seems to be a very distinct possibility. The following article is advising that there may be an entirely different licence regime in the U.K. I doubt that would leave EASA issued UK licences valid any longer.

https://www.flyer.co.uk/uk-must-leave-easa-brexit-says-eu

Spain

That EU position statement has been doing the rounds in various forms for ages. Of course it is hard-hitting – that is their job, to screw the UK so that others who may be getting the same idea don’t follow it through.

One previous thread for the “EASA exit etc” is here and you already posted in there, here.

This is largely off-topic for the IOM etc registry discussion.

We are exploring the possibility that maybe some of these registries issue paperwork that might be possibly less than legitimate, or maybe not.

There is only you making that assertion, without evidence AFAICS.

Administrator
Shoreham EGKA, United Kingdom

Ok, well you have made your points, and maybe you are right regarding EASA UK licences, we will see, but I don’t believe it’s a done deal, you might be surprised.
In fact you used the wrong word regarding the registry discussion, assertion means a confident and forceful statement of fact or belief. This is not what I have said, possibly was the word used.

This forum header indicates it’s a place for high-spirited discussion of matters often overheard in the airfield hangar (or bar!). So afaik that’s what we are having. And yes these questions need to be asked when in receipt of the knowledge of owners and operators who will remain nameless, still being allowed to use these registry validations by them while permanently in Europe without any EASA papers. In this case the validations should be cancelled or not issued in the first place, it hasn’t happened.

Spain

still being allowed to use these registry validations by them while permanently in Europe without any EASA papers

Where is the problem, assuming that

  • the validations are issued IAW the laws of the country or province running the registry
  • the country or province has an ICAO seat, or has been authorised to use the ICAO seat of another country (of the UK, in the case of the IOM or the CI)

The registry is doing nothing wrong.

The pilot flying on the validated papers has valid licenses under ICAO. He might be in contravention of the EASA FCL attack on non EU regs but the wording of that reg is so vague that nobody seems to understand it… and that’s before you get onto the repeated derogations and their wording. This is however not a problem for the registry, in the same way that it is not a problem for the UK CAA if somebody is using their UK PPL in Botswana or whatever…

Administrator
Shoreham EGKA, United Kingdom

Peter,

I think you miss my point. I am only saying that people who go out of their way to push to the edges of avoidance may be the same kind of people who might also step a short way into evasion. (You can rail against that, but I reckon in your heart you know it to be true.)

Now, that does not mean that every hard-core avoider is also an evader. Far from it. But if, say, 20% of them are, then it might be more worth a tax inspection than on someone who does not engage in “schemes.”

I am simply saying that EU NAA ramp inspectors may just think that the same is true of people who go to the lengths of going T7, 2, M or whatever. I am thinking more of that crowd than the N, which I think are the ones that you are defending so emphatically.

As Hurricane says, these are just interesting theories for discussion, and I wonder, just wonder, if the lady doth protest too much.

EGKB Biggin Hill
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