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

This has been in the news recently.

The Isle of Man registry has been going for some years. They accept ICAO pilot papers (licenses, ratings, and type ratings) which they validate for a specific aircraft (a specific tail number) on the IOM (M-XXXX) registry. This means that FAA papers are acceptable, which is great. However, while they used to accept FAA Part 91 maintenance (which was also great) I have it from a resident there that this has now stopped and they are enforcing EASA Part M rules.

Clearly there must be considerable "leeway" there otherwise a bizjet, formerly operated under Part 91 and containing $500k's worth of STC and Field Approved 337 mods, cannot "just go" on EASA Part M fully, without those mods being either recertified (loads of €€€€ going to an EASA Part 21 company) or ripped out (which nobody is going to do, except for trivia like a CD player).

This issue incidentally applies to EASA's own OPS proposals (pages 7 and 9) whereby "complex" aircraft (5.7T+, 19+ seats, ME TP or jet, etc) will be subject to EASA Part M, as well as the State of Registry's maintenance requirements. Are they going to recognise State of Registry certified mods? If not, that amounts to an eviction of most foreign regs from EU soil, and if yes, the Part M company has no competence to sign the Release to Service

I suspect that the IOM had to go Part M because they are issuing pilot papers which are de facto under the ICAO regime, but they don't have a seat on ICAO, so they were relying on the UK CAA's ICAO seat, so the CAA had them over a barrel, once they got successful...

Anyway, back to the Channel Islands. I wonder if the same will happen, because they don't have a seat on ICAO either.

Administrator
Shoreham EGKA, United Kingdom

Clearly there must be considerable "leeway" there otherwise a bizjet, formerly operated under Part 91 and containing $500k's worth of STC and Field Approved 337 mods, cannot "just go" on EASA Part M fully, without those mods being either recertified (loads of €€€€ going to an EASA Part 21 company) or ripped out (which nobody is going to do, except for trivia like a CD player).

Or would they not just go (back) to the N register?

I'm a bit ignorant here...but is the advantage of M reg (or any future Channel Is reg) over N reg? Is it VAT related or is it pilot qualification related ie can you fly on an FAA IR as a Euro resident?

YPJT, United Arab Emirates

I am no expert but there are several advantages to the M-reg. One is that you can own the plane yourself, whereas an N-reg has to be owned by a US citizen or green card holder (or some other corporate ownership scenarios but some of those have a "minimum time in US airspace" requirement); this avoids the concern about the trustee dying, etc in which case your plane is grounded (which has happened; not all that long ago either). Another is that M-reg is better if flying to places where they don't like US foreign policy (most of the 3rd world, I guess). The IOM registry is really well organised commercially and they do validations within 24hrs, whereas most other places take much longer.

If your "operator" is IOM based then you are exempt from the EASA FCL "screw N-regs" scheme that requires dual pilot papers. IMHO fairly obviously this means that a private owner-pilot living on the IOM is exempt and that alone with be worth a lot to some, especially those facing the full 14 exams.

One could go back to N but the process will, as always, be like going to N initially so the full Export CofA / import process with a US DAR, which is never cheap and usually not simple.

Administrator
Shoreham EGKA, United Kingdom

However, while they used to accept FAA Part 91 maintenance (which was also great) I have it from a resident there that this has now stopped and they are enforcing EASA Part M rules.

The IOM NTI04 seems to say that they are not going to require Part M maintenance:

"The aircraft on the Isle of Man register are based throughout the world and we have chosen not to follow the European model (both now and within the foreseeable future); we do not object if an operator wishes to use the services of a Part M subpart G organisation provided we are given a named individual within the organisation."

YPJT, United Arab Emirates

Too bad this isn't going to work for most of us on this forum - last time I checked, M-reg for sub-5700 kg aircraft was only available to IoM residents.

LKBU (near Prague), Czech Republic

Many thanks for clarifying that, Awqward.

I was wondering how the hell they were going to work it.

M-reg for sub-5700 kg aircraft was only available to IoM residents.

Yes; there used to be a way using an IOM based company but AFAIK they stopped that some time ago.

One owner who did that is no longer flying and sold his plane to Germany, where the owner, astonishingly, promptly threw away the priceless M-reg and went to D-reg

Administrator
Shoreham EGKA, United Kingdom

They have a certain amount of flexibility in the weight qualifications. All the CJs, CJ1s and CJ2s are sub 5700kg (just) as are King Air 90s and 200s. There are plenty of those on the M reg. They are really looking for turbine types, professionally operated.

Darley Moor, Gamston (UK)

Also I believe you can put a TBM on M-reg, as a NON resident owner, and that is well below 5700kg.

Not below 2000kg, unfortunately

I understand from one regular pilot of M-regs that the IOM is most keen to see the "rolling maintenance" (maybe not quite the right term because most of the TPs and smaller jets do actually have an Annual check) regime which is computer-managed and there is good transparency and good reporting of where everything is and what needs to be done.

Whereas in the light piston GA scene you have the Annual and that is often the only time the plane is looked at properly, and the records are held across a variety of logbooks and logbook inserts.

Administrator
Shoreham EGKA, United Kingdom

Yes I agree Peter, but this is really just typical of the maintenence you see on turbine equipment.

For example, the maintenence on a Citation is according to the manufacturers maintenence manual, and includes calendar based checks and also those based on a 150/300/600 hour cycle. The big ones come at the 300 and 600 hour checks

Everything is tracked online on the Cescom system. Hours of use are entered up monthly and every single item of maintenence and every lifed item is tracked and flagged up. In fact there is a fairly good predictive report of future maintenence too. Serial and part numbers of loads of parts, including every avionics item, is tracked with installation dates etc.

C of A renewals are a paperwork exercise annually and usually involve no physical work whatsoever.

Cescom is a marvellous system, although they do charge you to use it!

Darley Moor, Gamston (UK)

This has been in the news again, with some talking about a more favourable tax regime.

Can anybody guess what this may mean - for a UK mainland resident?

I know the IOM for example has no Benefit in Kind, so you can Ltd-Company-own a plane, and not get attacked for having a private access to it. But this doesn't work if you are mainland resident.

Administrator
Shoreham EGKA, United Kingdom
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