Нашел про прелести и тонкости использования N-регистрации при полетах по Европе. Без перевода:
Moving an aircraft to the N (USA) registration
Why?
To obtain worldwide privileges of a Rating, it is (in general) necessary for the country that issued the Rating to be the same as the country in which the aircraft is registered.
The above isn't true for a License and for example a UK PPL can fly a French registered aircraft in both the UK and in France and probably also elsewhere. But with Ratings there are very few exceptions to the above rule.
Trust Ownership
US-registered aircraft must be owned by a US citizen, or a US corporation (with a minimum US shareholding requirement) or a US based Trust (which must own at least 75% of the aircraft). This is a legitimate device and countless thousands of N-reg aircraft around the world are owned by such trusts. Many are based in Delaware. The trust charges for the service, of course, and the charges vary widely according to the sort of market the outfit is going after. There are a number of trusts with UK offices that are reasonably priced, around a few hundred pounds a year, and some that go after the bizjet market and charge accordingly more. I went with Southern Aircraft who have been recommended by a number of other N-reg owners and whose pricing is very good.
Benefits and Drawbacks of N-reg (Part 91 operation assumed; listed not in any order of importance)
Benefits:
a) A pilot with the FAA IR gets worldwide FAA IR privileges. This is the #1 reason pilots do it, in most cases.
b) No Insurance Premium Tax (saves 5% on the premium)
c) Easier approval for user modifications. The approval route (337, DER, etc) may not be cheap but it is usually do-able if you know an FAA IA who knows the process. In theory one can obtain UK CAA approval for anything on a G-reg but the process is very expensive for even small mods (example: about ?2000 for the paperwork alone to fit a backup oil pressure gauge) and is plain impossible in many cases.
d) Can fit aftermarket accessories which are already approved in the USA but aren't not CAA approved e.g. much better landing lights.
e) Pilot maintenance is permitted, to an extent which is currently superior to the UK Private CofA regime. This is a bit of a complicated subject; the two regimes were very similar until EASA came along, but now EASA is treating as "mandatory" a lot of things which previously were not mandatory. One example is the 12 year engine life limit which prevents the issue of an initial G-reg CofA, for no apparent reason given that the rest of the world isn't worried about it.
e2) For EASA-reg aircraft, there is currently a CAA/EASA requirement to comply with all ADs that apply to the aircraft regardless of the country of the AD issue. So if you have a G-reg it has to comply with ADs from the FAA that affect it or any components on it, whereas an N-reg aircraft (Part 91) needs to comply only with FAA ADs even if it contains parts that are subject to an EASA AD. The degree to which this saves costs is probably questionable in most cases, but it is a good thing given the past tendency of for example the UK CAA to generate large numbers of ADs which every other country thinks are pointless. There are few if any important EASA ADs which are not also FAA ADs. The reference for this requirement is currently in CAA CAP411 5.1 All applicable Airworthiness Directives issued by EASA, the CAA and any applicable Third Country Airworthiness Authority which is responsible for the state of design must be complied with.
f) In some situations, reclaim of duty on parts is possible with an End User Certificate.
g) The CAA Notice 75 propeller inspection, generally regarded as causing more problems than it prevents, is not required. Update 10/2007: Notice 75 has been replaced by CAP747 Generic Requirement 17. Mostly the 3 year/6 year cycle has been replaced by overhaul in accordance with manufacturers recomendations, normally 6 years or 2000hrs.
h) Can freely buy and install parts by mail order from the USA provided an 8130-3 form is obtained. There is the usual FUD (fear, uncertainty, doubt) being spread by some UK maintenance companies suggesting that 8130-3 forms from smaller US companies are not acceptable, but it's easy to verify whether the company issuing the form has an FAA approval and if it has then the 8130-3 is good. It is OK to fit a part with an 8130-3 to a G-reg aircraft but if it is used for Public Transport / AOC work then the 8130-3 has to come from a JAR145/EASA145 approved company (there are some in the USA but not many) and special words to certify this need to appear in box 13 of the 8130-3 form.
i) If an SB (Service Bulletin) becomes an AD (Airworthiness Directive) then it becomes mandatory and must be implemented. The majority of ADs track between CAA/EASA and the FAA but there are still CAA ADs which the FAA has not mandated. Given that around 75% of the world's General Aviation is in the USA, this appears pointless regulation. However, the FAA is gradually implementing a process whereby mandatory SBs on European-manufactured aircraft are automatically converted into FAA ADs and thus the work must be done on such an aircraft even if it is N-reg - additional info here. This applies to future EASA MSBs only; it is not retrospective.
j) The USA has filed some differences to ICAO on the medical front and has not imposed the audiogram requirement (reference here) which is required for a JAA CPL/ATPL or a JAA PPL/IR (it is not required for a plain JAA PPL). This unreasonable requirement means that a pilot with one perfect ear and one ear which doesn't meet the specification (a common enough condition) cannot get a JAA IR - even though the headsets are monaural so one bad ear doesn't matter. To compound the irony, the JAA renewal requirements include a "demonstrated ability" route, and a pilot can be thoroughly deaf in both ears, to the extent of being almost completely unable to communicate (without hearing aids) in day to day situations never mind a typical jet cockpit where headsets are not worn en-route.
k) In some situations where an aircraft is technically "rented" but not in the normal sense of the word (e.g. an individual owns a business which owns the aircraft, and the aircraft is rented back to the individual; this is a common procedure done under the UK Inland Revenue Benefit in Kind rules) an N-reg aircraft is legal if maintained under Part 91 rules, whereas a G-reg aircraft thus operated would arguably need to be maintained to a Transport CofA regime, and that is significantly more expensive (50hr checks, 150hr checks, all done by a JAR145 company, plus a lot of pointless maintenance) and is pointless given that the actual operation is identical to a fully privately operated aircraft flown by the very same pilot.
l) It's easier to find good freelance maintenance engineers to work on N-reg aircraft than on G-reg. This means you can assemble a group of very good people who you can trust. For the Annual you may still have to go to a large-ish firm (because of the amount of work involved, not many freelance engineers can do Annuals) but for everything else you can make sure that the job is done properly, preferably with you present and helping out. With a G-reg, and particularly if on a Transport CofA, you have to go to a certain kind of firm and have no choice about the standard of the work done. In my experience, some JAR145 companies cannot even tighten cowling screws without chewing them up, and after a few years of this "maintenance" the aircraft looks like it has been to Mongolia and back.
Drawbacks:
a) For full worldwide privileges, the pilot needs an FAA License. One can fly an N-reg on a UK/JAA license but only within the UK (not the Channel Islands). In fact any ICAO license is OK but FAR 61.3 limits its use to the airspace of the country that issued it. Whether the UK NPPL is OK is a good question; similarly there has been some doubt over whether the UK IMC Rating is valid or whether a UK/JAA PPL with a night qualification can be used to fly an N-reg at night in the UK; more info here.
b) There was a question mark over the ability to rent out an N-reg aircraft, and whether a Dry Lease is required if one does so. The legislation (FAA and UK) is silent on this subject, so it should be legal and extensive enquiries have not found anything to the contrary. A phone call on 1st March 2005 to Roger Kinsey at the DfT confirmed that renting is OK provided the renters don't do any aerial work in it. The DfT will never give permission to anyone who has rented an N-reg aircraft, even for any form of training and that includes a BFR (unless the instructor does it for free - see the link in g) below). So anyone renting an N-reg aircraft (UK airspace) needs to already be legal to be PIC in the type.
c) Cannot do PPL Cost Sharing. Even though the FAA does have such a scheme, it cannot be operated in UK airspace on a foreign registered aircraft as this would breach 2005 ANO Article 140. Passengers are not permitted to make any contribution to costs in UK airspace. There is also the theoretical possibility that a payment from a passenger on a flight which took place wholly within a country where the aircraft is not registered could be regarded as cabotage. I carry a letter from a senior French Customs official assuring that cabotage will not be applied to private flights, but there is the possibility that they might not regard such as a "private" flight to start with. The safest thing is for the pilot to not accept any money from passengers, in an N-reg flying in Europe, and make this very clear before the flight preferably before witnesses.
d) The French and some others don't like N-reg planes very much and do document checks, so documents must be carried on board and be in order. In particular, they look for a document showing EU VAT has been paid on the aircraft, and for the pilot's IR if he arrived via an IFR flight plan / instrument approach. Under an EU treaty, a country has the right to query the VAT status of any aircraft which is registered within that same country, or outside the EU.
e) While a lot of maintenance shops do FAA maintenance, very few of them have FAA approvals for anything. They can do the work by getting an FAA IA to come in and sign it off, but for many items (e.g. pitot-static system test) they have to get someone to come in who charges substantial hourly and travelling fees. So a CAA (EASA) approval for e.g. a Mode S transponder in a G-reg might cost ?160 whereas fitting it under N-reg is going to be over ?500. The maintenance shop may not advertise the fact that they are having to charge so much because they have to pay someone to come in to sign it off.
f) Prices charged to N-reg owners are more likely to get inflated than to G-reg owners. It pays to get educated on how much something should cost before getting work done. This is probably because N-reg planes tend to be owned by the pilot and so they get looked after better than the average G-reg self fly hire machine.
g) Any aerial work (which includes instruction or BFRs, if the instructor is being paid for it) requires permission from the DfT. More details here.
h) The trust requires you to sign the aircraft over to somebody that you have to trust and in theory they could just run off with it. I am not a lawyer but apparently this is very difficult for them to do (because the trust document obliges the legal owner to allow the beneficial owner to do more or less whatever he likes) and some also have insurance to cover various things. I have checked with one of the UK's largest aviation insurance firms and it is not possible for the beneficial owner to insure against a breach of the trust. They were unconcerned about it however, stating that one can get more problems if the US citizen that runs the trust dies. It's worth checking with him what provisions have been made for such cases.
i) If flying under a standalone FAA license, the pilot needs the FAA Class 3 medical as a minimum. The FAA Class 3 has stirred up some controversy, perhaps because it doesn't include an ECG. However The FAA Class 2 doesn't have an ECG either, below a certain age. ICAO does permit a national authority to impose its own medical requirements on resident pilots; this is rarely invoked but in 2004 the Irish CAA has reportedly taken advantage of this and refused to accept the FAA Class 3 for Ireland-based N-reg pilots. For some reason a FAA Class 2 is a lot cheaper than the CAA Class 2. For me, ?60-80 against ?150 for the CAA Class 2, both being very similar and done within 2 weeks of each other, and the FAA one was slightly more stringent (for me) on the eyesight. The FAA Class 3 is valid for an extra year but I reckon that one may as well go for the FAA Class 2, to avoid any potential for future trouble. Personally I hold an FAA Class 1 medical, which still costs only about ?80, for both initial and renewals, while the CAA Class 1 initial is about ?300.
j) An ELT is mandatory. It is probable that around 2009 the FAA will mandate it to be one which works on 121.50+406MHz, rather than the more common and cheaper 121.50+243MHz types. The installation can be suprisingly expensive due to the extra metalwork.
k) The FAA will not accept some modifications that the CAA (now EASA) will accept (and vice versa). The FAA is fussy in some departments; for example a TB20 aircraft with full TKS is certified for flight in icing on a G-reg but not on the N-reg - this is because the FAA requires two alternators and other items.
l) There are sporadic instances of non-EU aircraft requiring longer PPR notifications e.g. 24hrs instead of 3hrs. This has been noticed in Greece but there are likely many others. Entry into Turkey needs 24hr prior notice from the Turkish CAA (confirmed 2007). It is always worth faxing the destination airport regarding PPR requirements, giving the N- tail number so they can see in advance it is US registered, in case they are different to the published ones.
m) The recent American TSA regulations have caused havoc with FAA training. A useful summary is here and here and it's worth noting that the TSA applies even to certain classes of FAA instruction (mainly PPL and IR) outside the USA! The Visa situation is more of a grey area but it is most likely needed for a PPL or an IR. Getting FAA training in the UK is not much of a problem but getting checkrides organised in the UK is difficult.
n) FAR 91.175 prohibits an instrument approach other than using an official instrument approach procedure (IAP), and this applies to N-reg aircraft worldwide. This is an interesting one, and is an example of the interminable debate around how FAA rules (drafted mostly with only the USA in mind) apply in the UK. In the UK, this practice is not prohibited on private flights, despite an attempt by the CAA a few years ago. It is widely done, not least because most of UK's GA airfields do not have published IAPs. Many UK airfields have IAPs which were once real but became unpublished after ATC left (the CAA requires, among other things, full ATC for any airfield with an IAP); these IAPs are still known to the locals who use them. At other airfields, pilots do their own procedures, usually based on GPS. FAR 91.175 appears to make this illegal with an N-reg aircraft, but one can legally fly an N-reg in IMC, OCAS (i.e. Class G) at the MOCA (in non-mountainous terrain, this is 1000ft above the highest obstacle within 4nm of track) without ATC clearance and if the airfield becomes visible then one can execute a visual approach; this amounts to the same thing as an IAP with an MDH of 1000ft - not unreasonable. However, an instrument rated (UK IMC Rating or a JAA IR) pilot, flying a G-reg aircraft, can legally descend down to zero height in the UK for the purpose of a landing (yes, really!), so it appears that, within the UK, a pilot who is flying a G-reg on his IMC Rating has greater privileges for DIY approaches than if he is flying an N-reg on the FAA IR. Outside the UK, this isn't a problem as IFR flight OCAS isn't normally done, and an IFR flight would terminate at an international airport, with an IAP, anyway.
o) Going back to G can be problematic. Think about this carefully! There are, I understand, cases where an aircraft with certain certification issues can exist on a G-reg, but it could not be placed on G-reg today. In fact there are many G-reg aeroplanes under the Private CofA regime right now, which could not be placed on G-reg today. Of course they have to get a CofA every 3 years, but that is not the same as an initial CofA. If you go to N-reg and then want to go back, you might get caught by this. The EASA 12-year engine life issue is one recent problem which affects the majority of UK aeroplanes. However, the whole EASA business is in a state of flux and nobody knows what will happen.
Benefits and Drawbacks Summary
For most private pilots and given an aircraft that can be registered under G or is already, there is no significant benefit in the N registration, particularly given the cost of the transfer (see more details below). The most pressing reason is likely to be the FAA IR. Other reasons might be the wish to fit certain items (typically avionics) for which obtaining EASA approval is unrealistic, or the wish to purchase an aircraft (from e.g. the USA) with such items alreadu fitted. In a few cases it can be medical issues related to the JAA IR which is probably the JAA audiogram requirement.
Transfer to N-reg
Obviously if you buy (or import) an N-reg plane then you don't have to do a transfer. Just leave it on the N register but unless you are a U.S. citizen you will need to transfer the ownership to a Trust, or to a U.S. citizen who you can trust to not run off with it
In my case, the aircraft was transferred to N-reg during an Annual inspection. This is the best time to do it because it saves the ?600 (approx) CAA fee for the tri-annual (Star) CofA. The Annual was also done earlier (in February even though it wasn't due till May) because for a non-de-iced aircraft February normally has the worst weather.
The transfer process consists of
1. Reserving a suitable FAA registration
The FAA website is here (start with Interactive Aircraft Inquiry) and a registration costs $10 which you pay with a credit card.
Personal preferences aside, it's advisable to pick a number which is very quick to pronounce without twisting your tongue, and whose digits are distinct and will be easily understood by foreign ATC personnel. Most of the really nice (or short) numbers have been taken.
A couple of weeks later you get a letter like this from the FAA confirming the number has been reserved for one year. It also gives the Mode S aircraft code which you show the avionics installer when he puts in the Mode S transponder. This number will be programmed into the transponder and will identify your aircraft uniquely, worldwide!
2. Make sure all documents are in order
This is absolutely vital and it must be done while the aircraft is still legal to fly on its old registration. In my case, this check was not done until after the aircraft was de-registered which meant that the aircraft was stuck in the hangar for a number of weeks extra. In such a situation, you are totally stuffed...
The obvious thing to check is that all work that's been done is recorded in the logbooks. It is OK for it to be recorded in work sheets which are then referenced in the logbooks. If the aircraft has had any modifications these are likely to require a 337 approval. It is important to identify any such items and consult with the FAA IA engineer who will be involved and make sure he is happy with them, or he can issue a 337 that covers them. Otherwise, they will have to come out!
Increasingly nowadays, the FAA is unwilling to accept modifications that were done under a CAA approval, so a CAA approval for e.g. a GPS antenna is likely to be insufficient. In my case, a lot of paperwork irregularities were discovered and I had to go back to the original firm who did the work and get them to produce additional logbook entries. This is an area where 10 different people will give 10 different answers but it is the view of the particular IA that matters, and then the DAR after him at the very end.
There is no substitute for using a firm that's done this before, and done it on the particular aircraft type. Anybody will offer to do it, however.
3. Applying any modifications that are easier/cheaper under EASA
There may be quite a few of these, not because EASA is cheaper but because most UK aircraft maintenance organisations don't have the FAA approvals and have to pay somebody who is FAA approved to sign off the job, or do some of the work. Some firms have FAA approvals for some types of work, or some aircraft types, only, so check beforehand that their approval covers the work and, if not, how they are getting the paperwork straight.
In my case, there was nothing in this category.
4. Deregistering from the CAA
This involves writing on the back of the existing G-reg Certificate of Registration that the aircraft is being transferred to the USA and sending it to the CAA. Within about a week they send through a certificate of de-registration. This particular aircraft happens to be owned by a UK limited company and curiously the new owner is written on the form as the same limited company (i.e. no change) even though the legal owner is the U.S Trust.
The CAA do this commendably quickly and if you phone them up (0207 453 6666) and ask nicely they will fax you the certificate of deregistration so the rest of the process can continue.
5. Applying any FAA modifications that can be done with the aircraft registration in limbo
The main one is probably the ELT installation.
An ELT is mandatory for FAA, reference. These are made by various firms e.g. Artex and Kannad. All emit on 121.50MHz; the old ones also emit on 243MHz and the latest tri-band ones emit on 121.50MHz, 243MHz and 406MHz. To be legal one needs just the first one or two but to be practically useful one needs a 406MHz ELT. A good reference for ELTs is Sartech. According to Artex, most ELTs are installed under a 337 field approval, not under an STC. Like most parts for an N-reg aircraft, you will need to get an 8130-3 form from the supplier of the ELT to be able to install it.
In some planes one can install the ELT such that it can be easily removed in a hurry, and a built-in aerial can be used. Most ELTs come on a bracket from which they can be relatively quickly un-clipped, but this doesn't mean the ELT can then be activated manually. This in effect gives you a handheld EPIRB beacon, and a portable beacon certainly does want to have the 406MHz output. In the subject aircraft, however, the only place to fit the ELT was in the boot.
Like a kitchen/bathroom fitter, an avionics fitter buys goods at a discount from whatever price you get quoted, so he prefers to do a "supply and fit" job. That way he makes the money without his labour charge looking too excessive. So it's best to get them to supply the hardware. However, in the case of the ELT, I had seen the rip-off prices that some other people paid for unnecessarily pricey ELTs (the typical consequence of taking a plane to an avionics shop and giving them a blank cheque) so I spent a lot of time on the phone sorting out the best one to buy, preferably one that would utilise the existing Socata ELT wiring, and then I bought the ELT myself from Adams Aviation, complete with an 8130-3 form. The Adams website contains their products but (presumably to prevent end users seeing the list prices) they don't have an index though one can sometimes find links with Google etc.
There are antenna issues. Below a certain speed, about 160kt IAS, one can use a whip antenna which is a lot cheaper then the rigid type. However a single whip antenna cannot (according to Artex) be used for a tri-band ELT. The rigid antennae tend to be sold with the more expensive ELTs. I chose an ELT with a rigid antenna.
When the avionics shop got around to fitting the ELT, they reported that the new (rigid) antenna constitutes a structural change and cannot be fitted without a DER approval which costs ?500! By this time the aircraft had been grounded for a few weeks so, to save time, I told them to supply and fit the same cheap little ELT that Socata fit as standard on N-reg planes, the ELT200, and a whip antenna which just screws into the existing mounting plate that Socata fitted during manufacture. The whole ELT200 kit costs only about US$600 (end user list price, the avionics shop gets a discount off that) which was less than the paperwork alone for the antenna for the proper modern tri-band unit! Also, while the Artex ELT200 uses just 3 wires between the ELT and the instrument panel control switch, the Artex G406 tri-band ELT uses 4 wires so an extra wire has to be run. I had originally chosen the G406 because Artex told me it will use the existing ELT200 wiring.... The lowest quote I've had for installation only of this ELT is about ?2000. The ELT200 is nearly useless as an ELT (the 243MHz network is being phased out by 2009, references here) but it meets the paper requirements and gives me time to play with. Artex are now selling a new smaller ELT, the ME-406, which does 121.50/405MHz and uses a whip antenna - this is exactly what is wanted and would not cost "too much" to install. In the end I sold the Artex G406 ELT on Ebay - another lesson expensively learnt - and will review the situation if and when the FAA regulations change.
You will also need to remove (or modify) anything that is not FAA approved, or get some extra paperwork for it. Anything of significance may require an approval from a DER. This is another nice moneyspinner. There are no DERs in Europe and most European FAA maintenance organisations/individuals use a U.S. firm called DER Associates, which charges around US$300 for each item to look at. So for example an ELT which needs a mounting bracket (and is heavier than any ELT previously certified in that position) and a wiring modification will require two signoffs (structural, and wiring) which costs US$600. This may appear as ?600-?1000 on the UK invoice you get...
6. Registering with the FAA
One has to wait for the FAA to generate the certificate of registration. This document is sent by the FAA to the administrator of the Trust, who then gives it to you and you need to show it to the FAA DAR. The DAR can in fact check its validity on the FAA website; just as well since the postcard-sized original takes some weeks to turn up in the mail.
In my case there was a further delay because Socata has allocated an N number to the aircraft when they originally built it - I knew about this and told everybody but somehow this bit of info got lost on the way. The FAA, noticing that an N number had already been attached to that serial number threw out the first application and it took a fax or two to get things moving again.
The Trust company I used, Southern Aircraft, dealt with everything promptly.
7. Getting the aircraft FAA certified (FAA CofA issue)
This involves a visit from two people: an FAA IA and an FAA DAR who will both inspect the aircraft in turn. The IA charges a few hundred pounds, and the DAR (there are only a few of them in Europe) charges about ?1300. I am not clear about their precise functions.
The FAA DAR will be fussy regarding documentation and it is the IA's job to make sure everything is right. In some cases a CAA Export CofA will be required; this is another ?700 or so of which slightly over ?500 is the CAA fee; I was able to avoid this with a letter from the French DGAC certifying that the aircraft met FAA requirements when it was manufactured, and with a complete maintenance history since then. It is essential that everything that's been done to the aircraft is written up in the airframe/engine/prop logbooks or, if (like most major work) it doesn't fit in the logbook, is written up in a works order and that works order is referenced in the appropriate logbook. If you have the works order sheets but the maintenance shop forgot to do the logbook entry, they are in breach of the regs but you have a problem; you can either send them the logbook and get them to write the entry in, or get them to send you a logbook insert which you glue in.
The full detailed maintenance records are legally a part of the aircraft logbooks (airframe, engine, prop as appropriate) and this is true for both the CAA and the FAA. Some weeks previously I had retrieved the entire CAA-regime maintenance record from the original dealer; it turned out that without it the transfer to N-reg would have been quite impossible. A lesson learnt here: make sure you either have all the maintenance records, or have a copy of them. Maintenance companies move on, go bust, lose records, and an aircraft without a full maintenance history will be worth a lot less. Under CAA, the maintenance shop does not have to keep a copy and if there are any problems, just tell them you will raise it with the CAA. Under FAA, the maintenance shop has to keep a copy so they are entitled to charge for the copying; a portable scanner or a digital camera is a good way to get a free copy. After a mere 3 years, my maintenance records were spread out in no less than four places...
Finally, the DAR issues the FAA CofA and the aircraft can be legally flown.
Some companies have "FAA house approval" but this may be limited to specific aircraft types, and this needs to be checked in advance. Such a firm can still do the work provided they bring in an IA to sign it off, but this is best sorted out before commencing work because you must get the IA to overview the entire documentation to make sure there are no problems. Many aeroplanes will have something (for example a missing document) which on the face of it prevents the transfer to FAA...
For me, issues raised at the IA stage included certain modifications (e.g. a 2nd GPS antenna) which had been fitted by the original dealer without having been properly documented under the original CAA regime. This included GAMI injectors, which could not have been legally fitted to a G-reg aircraft (at the time, pre-EASA) without an AAN. The DAR might have accepted these had the CAA paperwork been straight but it wasn't, so some additional costs were incurred by the IA. The FAA is a lot more fussy than the CAA on structural issues like rooftop-mounted antennae - even though the aircraft is not pressurised.
As stated before, the moral of this story is to get the IA (or someone suitably experienced in this precise job function) to look over the aircraft while it can still be legally flown. This prevents getting trapped on the ground, with a de-registered aircraft which cannot be flown anywhere. Then, when all papers are in order, one can ground the aircraft, do the annual and while that's being done, de-register it from G, re-register it on N, call in the IA and the DAR and the whole job should be done within 4 weeks.
8. Installing any remaining modifications
These can be done anytime because the aircraft is now FAA certified and can be freely flown around. I will get the new Artex ELT fitted, together with the Garmin Mode S transponder when I get around to it.
9. Certifying an IFR GPS installation
Under FAA rules, the POH (pilot operating handbook, called Flight Manual in the USA) needs to contain a supplement, approved by the FAA, specifying the conditions under which the GPS can be used for IFR. Typically, these will be that the database must be in date (updated on the 28-day cycle) OR the pilot must manually verify the lat/long coordinates of each waypoint. The latter is not practical so for IFR flight one needs a current database.
The supplement needs to be FAA approved on an individual basis and this involves a test flight; the cost in the UK is around ?500. However, if the GPS was certified (for IFR) by the aircraft manufacturer then it should be covered by the FAA type certificate, but watch out! Some manufacturers (including Socata in my case) have been lazy and been selling planes with an "IFR approved GPS" whose supplement is worded in a manner which effectively limits the installation to VFR only. As an example, the TB20 KLN94 supplement requires not only a current database but additionally requires the pilot to verify the coordinates of every waypoint, which is not very reasonable. So, in order to have an IFR approved GPS, to be able to fly BRNAV routes in Europe, some additional paperwork may be needed but in fact the same issue would have applied to the original G-reg aircraft - had anybody bothered to read the GPS supplement!
A UK avionics company that has an in-house FAA approval for avionics has contacted the local FSDO (Heathrow, London) and the man there said that if the KLN94 supplement is DGAC approved (which mine is) then the FAA will accept that, without an aircraft-specific endorsement being required. Given the restrictive wording in the standard supplement, this won't be any good for flying in the USA, but I won't be doing that anyway. I just want to be legal for European BRNAV, with a current database if necessary.
There is an additional twist if wishing to fly GPS approaches. These are only just coming in in Europe, and currently there is always a conventional IAP which can be flown instead. Or the conventional IAP can be flown "officially" but its "overlay" version (which is normally in the IFR GPS database) can be used to monitor the aircraft path.
However, there is an issue with certification of the GPS installation for approaches. If you have an FAA certified installation (possible only on an N-reg aircraft) then it will be certified for both enroute and approaches, by default. However, if you moved for example a G-reg to N-reg, and had a BRNAV approved IFR GPS installation, this may be acceptable to the FAA (as described above in the KLN94 example in the TB20) and will be legal for enroute BRNAV but will not be legal for approaches. You will need to get a proper FAA supplement to fly the European approaches overtly.
The cost?
This worked out approximately as follows (on top of a normal ?1500 Annual):
Avionics Annual ?150
FAA bi-annual (pitot static and transponder check) ?460 (note 1)
FAA DAR (Designated Airworthiness Representative) inspection ?1350 (note 2)
FAA Annual and modification certification fees ?125
ELT purchase ?1100 (Artex G406)
ELT Installation ?75 (note 3)
FAA POH and supplements ?360
FAA logbooks ?50
Registration removal (peeling off adhesive letters) and applying new ?100 (note 4)
Note 1: This figure would be about ?200 if done by a maintenance firm that can do the FAA bi-annual check in-house and doesn't need to pay someone to visit.
Note 2: This is a nice little earner
Note 3: This was the installation of the simple dual-band ELT for which the aircraft was laready wired. For a new tri-band unit, bank on fitting a new reinforcing plate for the single ELT antenna, and the 337 approval for the installation. There is a potential cost of a DER structural approval for fitting the antenna reinforcing plate. The cost could be ?500 plus the cost of the ELT itself which is ?1000-1500.
Note 4: This would have been a hell of a lot more if the original numbers had been painted and had to be stripped off.
On top of that were other costs of about ?500.
The Mode S transponder (Garmin GTX330) lists at about ?2000 and the installation cost for the simplest installation is about ?500. This doesn't stop most avionics shops asking for ?3500 (all plus VAT). The FAA bi-annual check has to be re-done when a transponder is fitted or changed, but it is legal to fly the aircraft to a place which can do that (obviously provided one keeps out of airspace where a transponder is mandatory) with the transponder placarded INOP.
So, the lowest likely cost of the transfer only from G to N is likely to be about ?5000 - the detail depending on what one does about the ELT.
I think it's a good idea for the aircraft owner to closely follow the whole process; the alternative is either an open cheque book, or interminable delays, or both. There are a few firms in the UK who are experienced in this work, and getting someone else to do it is a total waste of time and money. There are many rules and regulations and it is usually possible to interpret something pedantically, to create more work or to create delays.
Was it worth the hassle?
For the FAA IR privileges, definitely. One wouldn't bother doing it for maintenance reasons. For an aircraft which is already legally on G and which can be operated on the Private CofA regime, any cost savings are negligible relative to the cost and hassle of moving to N and the occassional extra cost of FAA approved maintenance.
The Future of N
The short answer is that nobody knows what will happen in the long term.
The Dept for Transport and the CAA are keen to end the stampede to N. The driving factors include loss of licensing income (fees for crew licenses, airframe and accesory certification, maintenance organisation approval fees, instructor licensing fees, etc), perceived lack of oversight, and covert but definitely significant lobbying by UK flying schools who would like to force FAA licensed pilots to get the expensive JAA IR. None of these are good reasons when examined in detail but that doesn't make them less powerful.
The DfT moved in 2005 to evict foreign registered aircraft from the UK after a stay of 90 days. A proposal along these lines was circulated and drew the predictable fierce response. Objectively, it was a stupid proposal because anybody able to circulate a number of planes around (such that any particular one met the 90 day requirement) would circumvent the ban completely. There were other obvious weaknesses which would have made a mockery of it. It's also hard to believe that the UK would in effect strip all UK based N-reg IR pilots of their worldwide IFR privileges. This would look very bad on the safety front. The argument that these people can all go back to G and pop into their local school and get a JAA IR doesn't wash. The DfT finally publicly abandoned the proposal in November 2006. France proposed something similar around 2004 and abandoned it much faster. This now appears to be the end of national proposals within Europe along these lines.
EASA is next in the line to try something. It has already taken over certification and some factions within it appear to be sympathetic to the FAA in accepting FAA approved items. The process for this is currently problematic (the U.S. holder of the STC has to apply to EASA, but most U.S. companies aren't interested in foreign markets) but at least there is a route. EASA will also be taking over pilot licensing and it is not known what they will do about IR. A "European IMC Rating" is extremely unlikely, partly due to objections from some members and partly because the airspace outside the UK prevents the sort of free and easy IFR flight which the UK allows. The question is whether an IR will be created whose theory content is more appropriate to PPL flight.
EASA have stated on various occassions (2004, local copy) that they wish to bring foreign-reg planes under its maintenance regime (rather than evict them). This appears to mean that an N-reg owner might be able to remain N-reg but would have to maintain his aircraft to some local maintenance regime. This leads to the question of how one could subject an aircraft to an EASA maintenance regime without concurrently subjecting it (and everything inside it) to an EASA certification regime! It is my view that EASA will eventually have to accept FAA certification completely, otherwise a requirement to submit to EASA maintenance requirements would still amount to an eviction of the aircraft from the EU.
EASA has also proposed to introduce a Europe-wide pilot license, with the possibility of attaching an IR to it. This is an astonishing proposal and some of the text is very frank in its assessment of why GA in Europe is stangating while GA in the USA is doing well. However, it may be too much for some States' regulators to swallow in one piece. If successful, it would amount to a carrot which would cause the N-reg scene to dry up, which is probably the only way Europe is going to succeed in getting rid of N-reg aircraft.
As a very conservative policy (not necessarily justifiable) I have decided to avoid modifications which would make a reversion to G-reg problematic or impossible without ripping them out. This is a shame; for example one can fit really good landing lights to an N-reg aircraft.
Last edited 31st October 2007.
This summary was written to help those considering a transfer of their aircraft to N-reg. There is a lot of false information, and a lot of deliberate disinformation, going around.Any feedback, reports of dead links, corrections or suggestions much appreciated
Оригинал находится тут:
http://www.peter2000.co.uk/aviation/faa-nreg/nreg.html
