Benefits/drawbacks of N-reg vs YR vs PH with new Part-ML

Understood, that’s been the case for about five minutes. Whether anything useful will come out of it, or whether it will be crushed by entrenched interests as Peter implies remains to be seen. Good luck.

One reason that FAA regulations are so effective for the “little guy” is because they have always worked in concert with a tax system that does not repress individuals doing business individually for other individuals. The culture of light aircraft ownership in the US depends on it, FAA regulations anticipate it, and if it were not the case the US would have a little GA as Europe.

No sales tax is due on nontangibles in California (in gemeral unless connected with sales of tangibles). Not that California usages have any relevance whatsoever and/or are useful for decision making in an European operational context.

I’ve been looking for the “on condition” quote by Snoopy above, in my N-reg writeup linked above, and I found this

Most of what EASA regards as life-limited parts, for no technical/engineering reason, can be operated “on condition” under FAA Part 91. On an N-reg, the only strictly life-limited items are ones listed as such in the Airworthiness section of the POH.

Isn’t that still correct?

I know you can in theory go the SDMP route but

• in practice very few owners have done this, for reasons posted elsewhere here
• an SDMP will need to transfer component life limits from the MM, so for e.g. a TB20 you are stuck with the many pages of life limited items

The engine is a separate thing. That can be on-condition in both FAA- and EASA-land.

I will update my writeup – the main change is Part-ML, but as I say the benefits are heavily qualified by airport politics / revenue generation.

I think there’s quite a lot of practical tax-payment relevance to Part ML maintenance protocols that don’t always mandate the use of a VAT registered organization. I also think that such a system would NEVER have seen the light of day it wasn’t for FAA regulations providing a starkly clear example of the safer, better, less expensive way for private light aircraft to be maintained, precisely because of that European tax issue. It may also be relevant that EASA isn’t directly on the receiving end of VAT payments – which shows that its a good idea to separate safely related regulation from the temptation to create and oversee an endless revenue stream. This is also the case in the US where the Federal Government does not collect sales tax, regardless of the details of what it may be payable on in a given locality.

Peter wrote:

I know you can in theory go the SDMP route but

The mandate to have a documented and approved “maintenance plan” of any kind to maintain my own property would be enough to dissuade me from owning an aircraft, period.

Silvaire wrote:

The mandate to have a documented and approved “maintenance plan” of any kind to maintain my own property would be enough to dissuade me from owning an aircraft, period.

Doesn’t have to be approved, nor a copy sent to the CAA. It just has to exist, and the CAA can ask for it. However, e.g. the Luxembourg CAA sent a mass mailing asking for all Part-ML maintenance plans…

Silvaire wrote:

I think there’s quite a lot of practical tax-payment relevance to Part ML maintenance protocols that don’t always mandate the use of a VAT registered organization.

VAT has very little to do with any organisation vs individual distinction. Any person/entity that has a turnover from own business/self-employment (not salary) above the threshold (usually a few tens of thousands of EUR/GBP) is VAT taxable, and must be registered to VAT, period.

VAT has very little to do with any organisation vs individual distinction. Any person/entity that has a turnover from own business/self-employment (not salary) above the threshold (usually a few tens of thousands of EUR/GBP) is VAT taxable, and must be registered to VAT, period.

Yes, VAT is the dumbest disincentive to productive work that has ever come along. That said it is obvious that one man (or a lot of them individually) doing A&P work is going to present a harder enforcement/collection challenge to European national governments than a handful of “maintenance organisations” . That is even more true when its not clear if any given individual reaches the threshold for VAT registration. Some might, others would not and the whole point is to avoid wasteful organizational overhead and paperwork nonsense that would prove it.

dutch_flyer wrote:

I’ll probably change reg when I want to paint it, just so I can get the tail number I like!

Not a bad idea, and by that time you’ll have all the experience needed to know what to do.

This is a minor point but the UK VAT reg threshold is over £80k and an individual mechanic is not going to get near that unless he supplies a fair amount of parts too, which will not help him since not being an “authorised dealer” he won’t be getting automatic discounts. He can for sure get a trade price on stuff but mostly this is passed on to the customer, by getting the customer to procure the part and – optionally – have it delivered to the mechanic’s address.

I say “minor point” because this is worth just the VAT which is ~20% in Europe, and only the VAT on the labour. A much bigger point is the freelance v. company saving which is at least 2x, or 100%, or 200% in Daily Trash terminology And that’s before you throw in the “peace of mind” bonus that the guy working freelance is working for you and has done exactly what he told you he has done.

We all speak only from our personal life experiences and these are mine, over 19 years of ownership Others vary, as one would hope.

Peter wrote:

I know you can in theory go the SDMP route but

in practice very few owners have done this, for reasons posted elsewhere here
an SDMP will need to transfer component life limits from the MM, so for e.g. a TB20 you are stuck with the many pages of life limited items
The engine is a separate thing. That can be on-condition in both FAA- and EASA-land.

I will update my writeup – the main change is Part-ML, but as I say the benefits are heavily qualified by airport politics / revenue generation.

Even before Part-ML, I’d say 80% of the piston fleet in Germany/Austria where on SDMPs and operated engine and prop on condition.

Now with Part-ML, it applies to all EU/EASA countries.
A significant development.

Concerning Self declared AMP acc. Part-ML you can decide to
- maintain according EASA Min Insp. Program (which is essentially just a generic list, similar to an FAA annual) or

- DAH (design approval holder) ICA (instr. for cont. airworthiness). In this case, you can elect to deviate from any of those instructions except for airworthiness limits and ADs.

For a Cirrus SR22, for example, it is 3 items:
1) The airbag seatbelts
2) The chute and lines
3) The airframe – 12000h
+ any ADs

Anything else you can deviate from and put
on condition (inspection once a year or 100 hours whichever is first). If it is wise, if your maintenance shop/or person likes it or not is irrelevant, legally an owner has the right to do it.

With this right comes responsibility and liability. The owner has a very liberal regime for maintenance but personally bears all responsibilities. A very US thing actually. Same goes for the owner pilot maintenance which is now possible here.

It takes 2 hours to write an AMP, sign it and go fly.

I’m know GA as a system is much better in the US, but Part-ML has very positive effects for GA in Europe (also for import of third country planes, no more zero timing fears etc..).

A sum up is here EASA Part-ML