I agree with Alan and this is also the view at LBA.
Fine, and I didn’t say otherwise. But let’s wait and see what the Italian CAA, or French CAA or Swiss CAA will have to say about it…
BTW: EASA are very unhappy about “registration shopping”, i.e. trying to benefit from regulatory arbitrage by choosing your tail number in a different state. They think this just shows that the system is still broken and they want to make sure the reasons for this disappear. I think that’s a good attitude.
They have been saying that the last 100 years.
All the time they vest trust in organisations not individuals they are barking up the wrong tree.
But it’s true that N could become the choice of a small % of proactive owners.
With Part M-Light for ELA2, the advantages of N-reg become much smaller.
Already today I consider EASA-reg to be more convenient for me and I will not go N-reg. They’re on a good mission at EASA and nobody can say they’re not delivering on their promises. Things do come in rapid succession.
Even without anti N-reg measures, it will probably decline over time thanks to more sensible EASA legislation.
The main advantage of N-reg isn’t the one most often quoted – ignoring component life limits. The cost of life limited parts is normally a fairly small part of running an aircraft sufficiently old for it to be relevant. Fuel dominates these days… even on a Diamond which has lots of lifed parts. Nobody wants to spend 1000 quid replacing heater hoses which look perfect, every 10 years, but “you” probably spent 50k-100k (quite possibly a lot more, for high-hour pilots) running that plane in those 10 years.
The main advantage of N-reg is for the proactive owner who can closely work with his A&P and make sure everything is done right. With EASA-reg you are generally pushed to use a company and then your options on close supervision are severely limited unless you want to push a lot of noses out of joint.
EASA has Part-66 engineers as well. They are less common than in FAA land but they do exist.
I do the same type of maintenance you describe with the Part 145. I do it all myself, decide myself — obviously the IA has to be comfortable. This type of owner-maintenance-on-Part-145-premises is quite common in Europe. My previous shop did, too. In Europe, the aircraft mechanic does not need to have any formal qualification at all, only the IA needs to have the right approvals and verify the work. Whether a Part 145 employee has no formal qualification or I have no formal qualification really does not matter — as long as I have good relationship with the Part 145 and they trust in my abilities.
So I don’t buy this argument. The biggest pros of Part 91 for me are no lifed components and more STCs and one-off approvals to choose from (the 337 not outside the US though). On the other hand, there are many drawbacks to having N-reg in Europe:
)I have the knowledge and the means to go N-reg any time (even have a N tail number reserved and the original file and POH) but I think it would not improve things at all, on the contrary.
Some of those points are not valid, Achim, e.g. the cannulas (the key is a “fitted system”). The rolling currency is a non-issue by a factor of several times, for anybody who flies IFR with any frequency appropriate to any currency.
achimha wrote:
BTW: EASA are very unhappy about “registration shopping”, i.e. trying to benefit from regulatory arbitrage by choosing your tail number in a different state. They think this just shows that the system is still broken and they want to make sure the reasons for this disappear. I think that’s a good attitude.
I agree with EASA on that, but the problem is as long as EASA states still gold plate or even pervert those very rules, then it will go on.
We just now have a major situation in Switzerland, where, following a deadly accident a few years back involving a criminally badly maintained airplane and an equally criminal case of lack of oversight, the Swiss FOCA has published a “technical message” basically doing away with on condition for any airplane, private or not, they now also declare calendar TBO binding. They have also declared every service bulletin, every service instruction and every other recommendation as binding law. This is a major setback for HB- register and a LOT of people are thinking seriously about going to a flag of convenience.
In order to get around this, you can apply for on condition but you will get massive restrictions for doing that, such as pulling cylinders all 3 years in order to inspect the cramshaft and other horriffic stuff. Also, quite a lot of people have found that they are life time limiting engines now to 24 years (IFR or VFR night) or 36 years (Daylight only) after which they are no longer accepting on condition and demand an overhaul.
The very bad thing about this, if it can get any worse, was that they did not even publish those age limits but people only found out when their proposed maintenance programs got rejected.
I am in a relativly good position now that both my engine and propeller are within calendar TBO, but will now have to comply to full calendar TBO if I do not want to get my engine pulled apart every 3 years or other such horrible garbage. Apart, prop TBO is fully binding now. So I will have to pulll my prop off again in 5.5 years and the engine which was overhauled in 2011 in 2023, regardless of hours.
Switzerland has just moved form a fairly attractive registrar state into one where people will flee by the dozens once they realize the implications. There is a thread about this including the sources here where it became pretty obvious that people at first failed to grasp the significance until the first few that actually got grounded popped up.
As long as single states are still allowed to do what the hell they want as long as it is more restrictive then EASA, ELA 1 will most probably not have any impact whatsoever, as states will gold plate what they deem necessary and therefore the whole program is not worth the paper it is printed on for people with register in those states. And of course, people will move to a more friendly register as long as that is allowed.
Peter wrote:
Some of those points are not valid, Achim, e.g. the cannulas (the key is a “fitted system”).
I have a fitted system so the point is very valid 
Not that I would care much though, not a lot of witnesses around up there.
The rolling currency is a non-issue by a factor of several times, for anybody who flies IFR with any frequency appropriate to any currency.
If you have an IAP at your home airfield maybe. Also there are many reasons why people fly IFR and how they fly IFR. Not everybody is keen on CAT I 200ft approaches. Sometimes people just fly for pleasure when the weather is nice and use their IR to make it easy. For such people, the rolling currency can be a huge problem. If I look at my IFR career so far, there were several moments where I would have fallen out of currency in the FAA system but thanks to the EASA system I did not have this problem. Most of my IFR flights are from VFR aerodrome to VFR aerodrome(*). There is nothing I hate more than having to do some stupid flight just in order to prevent my privileges from lapsing. That for me is the opposite of pleasure flying. Following the same logic, I generally do not fly IAPs when there is no need because I am an impatient person. When the weather is nice, I ask for a visual for a quick landing. I think nothing is to be learned from flying CAVOK ILSes anymore.
So show me which of my points is not valid
The main advantage of N-reg isn’t the one most often quoted – ignoring component life limits. The cost of life limited parts is normally a fairly small part of running an aircraft sufficiently old for it to be relevant. Fuel dominates these days… even on a Diamond which has lots of lifed parts. Nobody wants to spend 1000 quid replacing heater hoses which look perfect, every 10 years, but “you” probably spent 50k-100k (quite possibly a lot more, for high-hour pilots) running that plane in those 10 years.
I think if people in the US had calendar life limits on their aircraft components, the non-Experimental GA scene would very quickly die. People have lots of options when spending their money, and I think very few people are so in love with owning and flying a certified aircraft that they would waste money in that fashion. Beyond that, half the fun of owning a plane is taking care of it. With life limits set for the worst case of an abusive owner, its like being slapped in the face if you have to overhaul a part that you’ve taken care of (a propeller or seat belt for instance) and which is barely into its serviceable life. A propeller owned by a guy with multiple aircraft might have only 200 hrs over 6 years, have been continuously stored in a warm, dry hangar and polished after every fight. I don’t know many people who enjoy taking both injuries and insults in their hobbies.
FWIW my hangar rent dominates my aviation expenses (around $5K USD per year) but provides a lot of utility and enjoyment outside of actually operating the plane. Avgas is around $2500/year. I think the additional cost for life-limited parts all over the plane would be quite noticeable in comparison to my total expenses combined.
The main advantage of N-reg is for the proactive owner who can closely work with his A&P and make sure everything is done right. With EASA-reg you are generally pushed to use a company and then your options on close supervision are severely limited unless you want to push a lot of noses out of joint.
In general I agree with that, but it goes a little deeper than you describe. I do know people personally in Germany and elsewhere who do what Achimha describes, working with maintenance companies in maintaining their own certified aircraft – not everybody who operates such a company is a jerk, worldwide As you say, people are not the problem, in my experience they are more often the solution. For me probably the biggest advantage of the FAA system is that it charges the A&P or IA no fees or taxes, doesn’t regulate the facility in which he works, and doesn’t necessarily expect him to be doing the work as a business or writing invoices etc. Therefore lots of people in the US have A&P or A&P IA certificates and they often work together with owners in their spare time, without financial pressure to take short cuts. My maintenance labor cost is therefore not much above zero, paid in cash.
The other significant benefit is no pre-documented or pre-planned maintenance program other than the annual inspection and compliance with airworthiness directives.
