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Homebuilt regulations UK CAA letter 12/20

Any comments on the letter from CAA regarding homebuilts not needing permission to enter GB dated December 20 2017?

KHQZ, United States

Do you have a URL?

Administrator
Shoreham EGKA, United Kingdom

OK; thanks.

Firstly, @magyarflyer shows in his profile as flying an Evolution, and since all of those actually flying (including the two in Europe, and excluding the one which was for sale in Bulgaria but which appears to have never really flown) are N-reg, this CAA letter is not relevant since it applies only to ECAC registers.

Secondly, has anything of relevance actually changed, given this:

Referring to e.g. here (we have had various threads on the privileges of homebuilts around Europe) the UK has always had a 28 day limit on non-G-reg homebuilts staying in the UK – N-reg or any other reg.

To me this reads like an ECAC-reg homebuilt no longer needs to apply for the permission (but has to carry the stated documents) whereas an N-reg homebuilt will still have to apply for the permission. And in either case you have only 28 days. It doesn’t say 28 days per year or whatever, which is weird because as written it means you are allowed only 28 days in total in the UK, for the lifetime of the aircraft.

Most European countries allow an ECAC-reg homebuilt of a foreign register to remain for 6 months. The UK is unusually tight in the 28 days.

Administrator
Shoreham EGKA, United Kingdom

Peter wrote:

It doesn’t say 28 days per year or whatever, which is weird because as written it means you are allowed only 28 days in total in the UK, for the lifetime of the aircraft

It doesn’t read like that to me. It say, as per your own quote, 28 consecutive days in any one visit.

There is no restriction on multiple visits; just that any one visit can’t last more than 28 days. In theory you could arrive and stay for 28 days, then leave and come back for another 28 days. Obviously you’d eventually run out of luck due to weather or mechanical issue doing that!

EIWT Weston, Ireland

OK but that’s equally dumb because you can bring your N-reg Lancair Evolution to the UK and every 27 days pop over to LFAT for lunch

Actually, strictly speaking, the law doesn’t require a land-away so you would merely need to leave UK territorial waters, every 27 days, which is routinely achieved by flying a long final on Shoreham runway 02

I know these regs aren’t enforced but if one is going to debate regs, this is a good one… It’s a typically badly drafted aviation reg. You would never see such loose drafting in any proper law. It’s almost as crap as EASA drafting

Administrator
Shoreham EGKA, United Kingdom

without the prior permission of the CAA

To me this reads:

  • 28 consecutive days without prior permission
  • indefinitely with prior permission
The elephant is the circulation
ENVA ENOP ENMO, Norway

Says nothing about indefinitely, just that prior permission is needed to stay >28 days. How long that might be would depend on the wording of the prior permission.

LSZK, Switzerland

Why so negative? It is rather obvious to me that the UK CAA cannot time limit a permission, because no such time limit exist in the regulations for them to use (at least not in that document linked to). They cannot just make up regulations as they go (maybe they can in the UK, I don’t no), but that would be a very weird legal system.

Besides, the ECAC recommendation about homebuilds, and from last year also for vintage aircraft is about two things:

  1. to fly freely in Europe with these aircraft. To cross borders without prior permissions
  2. to fly with no other restrictions than those written in the C of A or “permit to fly”

The UK CAA sort of agrees to the first one, at least it’s OK from a practical point of view. But they duly show the finger to the second item in the recommendation. But, at no place does it say that with prior permission, a whole bunch of operational limitations exist. On the contrary IMO, it clearly say that without prior permission, a whole bunch of operational limitations exist, as listed in that document.

The elephant is the circulation
ENVA ENOP ENMO, Norway

LeSving wrote:

But they duly show the finger to the second item in the recommendation. But, at no place does it say that with prior permission, a whole bunch of operational limitations exist. On the contrary IMO, it clearly say that without prior permission, a whole bunch of operational limitations exist, as listed in that document.

That however is the same in Germany. With ECAC-reg. general entry permission is granted with the e.g. the limitation “VFR day”. For the others (e.g. N-reg) an entry permission is required, however without limitations other than the one contained in the permit to fly of the country of registration. Weird indeed

EDLE
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