PA46 - EASA Type Rating

We have had private messaging on EuroGA for some time.

Being able to use ones own plane is the key to bring costs down. But there are problems. EASA apparently requires that the plane be registered for flight training in the training organisations. This may involves:

- A kind of charter agreement (easy)

- Maintenance agreement with a part 145 shop which basically says they will do maintenance if you order them to do so (if you know a shop quite easy)

- CAMO (maybe you already have it)

- Finally in some countries they require that your airplane is maintained to flight school standards which in Germany means to extensions on components. Nearly no private plane will qualify.

I wonder if that is local gold-plating, because in the UK you don’t need most of that.

You don’t need a 145 shop. A 145 shop is required only for AOC operated aircraft. What isn’t allowed is any pilot maintenance since the last Part M maintenance activity. (Same on N-reg; the last person who worked on it and signed it off must be an A&P or in the case of the Annual an A&P/IA).

I am not aware of any component life extension issues – if approved by the maintenance body or person.

Nobody said that in Germany there is no gold-plating going on.
The LBA is actually known for quite a few of these exercises.
All those obstacles are to protect the flying school business in Germany, otherwise, most IRs, type ratings, etc. would be flown on pilot-owned aircraft and the flying school aircraft would sit.

All those obstacles are to protect the flying school business in Germany, otherwise, most IRs, type ratings, etc. would be flown on pilot-owned aircraft and the flying school aircraft would sit.

Why is that not the same in the UK?

Here, nearly all FTO business is young men (and some young women) who want to be airline pilots. Private pilots doing stuff that needs an FTO are extremely rare. No doubt some FTO operators hoped that the anti-N-reg EASA moves would generate some new business but in reality most private IR holders have decided to wait it out and see what happens. Also very few FTOs even cater for private pilots and even fewer are interested in those with their own planes.

Is Germany different, in e.g. having a huge (US-style) uptake of private IRs?

No, not really.

Marc, thanks for info. We could have met at EBKT last Saturday, I had suggested a meeting there given our ministerial initiative – but could not participate myself, anyway, and there was little response.
OTOH I was not suggesting you publish your full e-address and least of all in a machine-readable form…
Happy flying, we’ll surely find an occasion to meet yet.

This matter seems quite complicated on this moment, that’s the conclusion now.
Is it 100 % sure that I have till april 2015 for type rating and HPA? Or is this concerning the matter on the N-registrations?

Marc,

somehow, I get the impression that your move from N-reg. to OO-reg. has been motivated by the recent changes in european pilot licensing regulations which by some have been interpreted as “the end of N-registrations” in Europe.

There is currently nothing substantial to threat N-regs in Europe as such.

In fact, for pilots already previously holding FAA licenses, the future requirement for “double licenses” does not make the licensing side for flying an N-reg any more “difficult” than for an EASA reg. In both cases, pilots will have to obtain the equivalent european licenses and ratings. And maintaining the FAA license (the only additional chore if continuing to be N-reg) is renownedly very easy.

I hope this is all “old hat” to you and that there were other, more pressing reasons to move to OO-reg in your case.

However, your questions regarding the european rating are valid of course, since in any case (N-reg. or EASA-reg.), one will need these in the future.

Re the April 2015 date: that extension was issued by the EU, but it was merely the concession to allow EASA states to extend the opt-out from the already adopted third country aircraft licensing rules. So, it’s actually in the hands of the national CAAs to decide whether the deadline is pushed forward from April 2014 to April 2015. The bad news is that there is absolutely no “overview” anywhere as to which country has moved forward and which hasn’t. Additionally, it has never been officially answered whether it is the pilots’ country of residence whose regulations apply or whether it’s the country being overflown whose regulations apply. And that’s where the good news start: nobody has a clue, all pilots are just doing business as usual, and no authority has the courage to take any action against third country licensed pilots right now. We are all flying within a massive grey area right now. But: a comfortable one it is.

The 2015 derogation is not relevant to a pilot flying an aircraft which in on some EASA registry. That aircraft and pilot needs to comply with national and EASA requirements as they stand right now.

Yes – I too would have never ever gone away from N-reg. A waste of money, picking up some crazy maintenance requirements, and the only things you gain are

• not having to fly an FAA BFR and get an FAA medical every 2 years (the IR is on a rolling currency)
• being more easily able to do major mods which require an FSDO Field Approval (albeit the EASA route is usually a lot of €€€€)

I know we have done this to death already but I don’t see any country enforcing the EASA FCL anti N-reg position because of the near-impossibility of defining the “EU based operator” stuff. It would have to be a court case, which would then become case law, which would then define precisely how somebody could organise their setup so as to avoid the regulation – and the national CAA would not want such a precedent.

However there are a lot of N-reg PA46 owners who are scrambling around looking at ways to do the HPA stuff, because the more onerous interpretations of EASA FCL are that you do need it.

Obviously…., my last paragraph applies only to pilot of third country aircraft flown by pilots who still only have an FAA license.

The fact that Marc asks about the 2015 deadline although the aircraft is now already OO-reg. makes it seem like there is some confusion and/or something went seriously wrong.

Also, one would first sort out the licenses and then (if at all) transfer the reg of the aircraft, not the other way ‘round, because now he can’t legally fly his own aircraft. That’s probably what causes his urgency (see first post).

Could you clarify this a bit, Marc?