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Pros and cons of non-certified aircraft

Airborne_Again wrote:

But those students don’t have a part-FCL license, do they?

No, you’re right. But the principle still remains. EASA is concerned with legislation. They aren’t out there “in the field”.

Peter wrote:

The LAA regime seems to work very well here in the UK

I meant the LAA IFR program only – and in the context of improving the local regulations where you are living. It’s the only correct way to improve things and be reasonable sure they have a lasting effect.

Peter wrote:

That does sound a little “elitist” i.e. once “you” have achieved something through hard work, you don’t want others to get it with less work.

I guess it sounds like that, but it is not meant like that. You have to look at this in the correct context and include the history. The idea behind homebuilt aircraft has always been to allow people to build, restore and modify aircraft, then fly them and maintain them. It was never meant as a substitute for certified aircraft, or certified aircraft production.

30 years ago building an aircraft consisted of purchasing drawings and raw materials, saying goodbye to the world for 5-10 years, and finally exit the cave with an aircraft. Today it is 2 weeks at a factory. This will:

  1. Dramatically increase the number of aircraft
  2. Let pilots who otherwise would never think of building an aircraft, “build” their own.

There is nothing fundamentally wrong with this IMO, but what happens is a gradual industrialization that the authorities sooner or later simply cannot ignore because it wanders far away from the situation for which the regulations initially were made. The authorities will eventually do something, but what?

The elephant is the circulation
ENVA ENOP ENMO, Norway

A better option is to do what the LAA does, even if it takes lots of work over years and years.

The LAA regime seems to work very well here in the UK. Due to the annual involvement by an LAA inspector, the builder has the same self maintenance rights as a subsequent owner; something which is not the case on many other regimes. OTOH this leads to the necessity to maintain a close relationship with your inspector, which means he can get a lot of beer but arguably it leads to a reduction in transparency. Also mods have to be approved; you certainly cannot just screw what you like into your G-reg LAA type.

is to bypass the rules and regulations in your own country. You kind of show the finger to the more “serious” builders there as well, and the whole community.

That does sound a little “elitist” i.e. once “you” have achieved something through hard work, you don’t want others to get it with less work. One gets that in all of human activity. The reality is that the (vast?) majority of homebuilts flying were not built by the current owner. Very few people can put in the 2k-3k hours of work, or even a fast build RV kit which I am told is 500hrs, and these figures assume you know what you are doing, whereas most builders are learning how to do riveting.

That the long term basing of foreign reg homebuilts is being restricted is not surprising. It undermines national CAA income, for a start

Has there ever been any attempt at harmonisation of European rules for homebuilts?

The ECAC proposal from the 1980s (various previous threads) is the main one, and this has been adopted to varying degrees around Europe. Not enough to fly around freely like you can in a certified plane, but well enough to keep most of the owners happy.

My take on the future, looking especially at the recent UK and French moves which seem to have been coordinated, is that flying around may become easier while long term parking will become limited or impossible. There seems to be a tendency to prevent the creation of a unified Europe-wide homebuilder scene like they have in the USA (which is just one country of course).

Administrator
Shoreham EGKA, United Kingdom

LeSving wrote:

Oh yes they can, and they do. The Norwegian CAA accept no students taking lessons at foreign RFs.
But those students don’t have a part-FCL license, do they?

ESKC (Uppsala/Sundbro), Sweden

Peter wrote:

Actually this was done before e.g. here. Such permits seem to pop up fairly randomly. AFAIK the only case which is almost automatically (actually it depends on the build process and the avionics) without a VFR-only restriction is an N-reg, but you can’t base those usefully in Europe and fly them anywhere useful (legally) IFR.

LN reg, SE reg and possibly OH reg (maybe also Spanish and Portuguese, I think) would be my choice above N reg for flying in Europe (IFR) or VFR for that matter. LN reg being by far the better option of all. But, unless you are Norwegian, Swedish or Finnish, you will run into lots of linguistic troubles I would think. Besides, IMO the only reason to do that, unless you are from those countries but living abroad, is to bypass the rules and regulations in your own country. You kind of show the finger to the more “serious” builders there as well, and the whole community. You are doing no one any good in the long run. A better option is to do what the LAA does, even if it takes lots of work over years and years.

Homebuilt aircraft are by very definition national aircraft. They are meant to be built, operated and maintained from the country of origin. Import export of homebuilt aircraft should not be restricted. However, “long time parking” of foreign imported aircraft is really very far from the original idea (my opinion only), as you bypass not only the building part, but also the operational/maintenance part. EASA could have made an entire new EASA homebuilt category, independent of all other, but have said they have no interest in doing that.

France is tightening in on the “long time parking” issues. I don’t know the reason for that, but the result is in line with the European “norm” that has grown out of ECAC. Aircraft are allowed to fly freely around Europe, but not parked indefinitely in a foreign country, which ECAC say nothing about. None of this prevents a foreigner taking his aircraft with him for longer stays, at least not as these things are written in regulations (how the practice is can vary of course). I think this hasn’t been an issue initially. But in the last 20-30 years, the average homebuilt has become better and better while the average certified aircraft just becomes older. A homebuilt looks better, performs (much) better, is cheaper, easier to maintain, no EASA bureaucracy. I mean, the choice is rather simple.

Mooney_Driver wrote:

With an EASA Part FCL license no national authority within EASA can tell you that you can’t fly in their country and not fly their airplanes.

Oh yes they can, and they do. The Norwegian CAA accept no students taking lessons at foreign RFs. They started this after examiners simply couldn’t pass them due to lack of flying skills (stick and rudder) and lack of basic knowledge. How this will be handled with DTOs (in practice) remains to be seen.

I think what is wrong with EASA is it doesn’t have any “foot soldiers”. It’s all regulations and industrial standards kind of things. EASA works well in a large industrial context where everything can (and must) be organized, and those organisations have high competence, not only technically but also about legal stuff, administrative stuff. For light GA a much more individual approach is needed, for a whole bunch of reasons actually, but cost being the main issue. EASA needs “foot soldiers”, individuals that report only to EASA, not via some private “approved” organisation.

The elephant is the circulation
ENVA ENOP ENMO, Norway

Has there ever been any attempt at harmonisation of European rules for homebuilts?

LeSving wrote:

You actually believe that? ICAO sets the “standard”, not EASA.

ICAO sets the framework but has next to no direct influence over the national authorities other than that what they do has to correspond to ICAO rules as a lower limit. Basically, ICAO has shown no initiative at all against the gold-plating so many of it’s member states have done and they also have not been effective at all in unifying the regulation on a world wide basis. Otherwise we would not need EASA or the FAA or any national authority, if everything was simple ICAO rules.

What EASA has accomplished in Europe in very recent years (after the nightmare of the first couple of years) is that they actually enforce their rulemaking towards wayward national authorities who think they know better. Not always and not every time effective but there is an effort. Before EASA (even under JAA) every national authority could gold plate as much as they wanted, with EASA that is no longer the case in theory, it doesn’t always work out this way but that at least is the idea.

With an EASA Part FCL license no national authority within EASA can tell you that you can’t fly in their country and not fly their airplanes. Part NCO has done away with some very annoying gold plating in several countries particularly for IFR but also for other things. ELA1 has done away with countries who enforced engine and prop TBOs even calendar wise and more of the same. EASA is trying to do more of the sort (with the odd bad rule in between but generally rather pro GA in recent years) but appears to be in a deadlock with the European Comission about certain things. But EASA has in fact made flying in Europe easier BECAUSE their rulemaking is binding. No NAA can ban a certain EASA certified crew or plane very easily, but they have free go at anything which EASA does not regulate.

Apart from the fact that many NAA’s used EASA as a big brother type of thing to gold plate stuff they wanted themselfs until EASA finally caught up with them, there was a lot of lying and scheming going on in certain NAA’s to keep their pet regulations alive. This worked under the former leadership but not anymore.

LSZH(work) LSZF (GA base), Switzerland

He’s done well to keep off the plane spotters – very few people escape them

Looks like you can find where he may be based. But then if F-WOAH did have a permit without a VFR-only restriction, there is no automatic transfer of that to a PH reg. Are there any PH-reg homebuilts without a VFR-only restriction?

Actually this was done before e.g. here. Such permits seem to pop up fairly randomly. AFAIK the only case which is almost automatically (actually it depends on the build process and the avionics) without a VFR-only restriction is an N-reg, but you can’t base those usefully in Europe and fly them anywhere useful (legally) IFR.

Administrator
Shoreham EGKA, United Kingdom

Done

Curiously, and very unusually, PH-FFA doesn’t come up on google at all. That almost certainly means it has never (or almost never) flown, or it flies only in very remote areas.

Administrator
Shoreham EGKA, United Kingdom

@Peter, could you correct my previous post? The new reg is PH-FFA, not PH-FAA.

Belgium
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