Great summary. Thanks!

One item to dispute. The FAA does do ramp checks in Europe, just not very
many. One of our competitors got ramped. The pilot told the FAA inspector
he had no authority. The Inspector gave him a break and told him to call
his Chief Pilot. The pilot was quickly educated, got very apologetic, and
cooperative.

The FAA can ramp a 135/121 operator anywhere in the world. Our POI
(Principal Operations Inspector) asks that question of all of our new
Captains.

"Peter" wrote in message
...

wrote

According to the documents, they are
looking at the fact that something on the order of 21% of the aircraft
in the UK spend all of their time in UK airspace despite being foreign
registered.

The gist of it is that they want to place a time limit on how long you
can keep a foreign registered aircraft in the UK without changing the
regisration. It's only a proposal for now and they are requestion
comments until late October.

The question one must ask is WHY people do this.

The DfT is alleging it is to save money on maintenance. Any N-reg
owner in Europe will know that is bull. I am an N-reg owner and just
about everything costs more, not less, because very few maintenance
outfits are fully FAA certified and they have to "buy" a signature
from an IA at the end of the job. A typical IA charges the equivalent
of US$500 for the signoff. Anything that needs a DER (e.g. structural)
is $1000 for the DER signature - as I know well from a recent exercise
with an ELT antenna. The CAA is much more relaxed about screwing
antennas into airframes than the FAA.

There are two main reasons why people "go N".

(1) To get worldwide IFR privileges - basically for European touring /
business flying.

In the non-jet GA context, this is by far the most common reason. The
European route to this is the JAA IR which involves 1-2 years' study,
mandatory ground school, an additional hearing (audiogram) test where
*each* ear has to pass the -20db limit, and other stuff that's hardly
relevant to noncommercial GA flying. Most people who earn enough money
to get access to an IFR-suitable aircraft (i.e. buy one, or buy into
one of the rare "IFR" syndicates) and to fly it with sufficient
currency, have a life to live and a job to do and can't devote such a
chunk of their life to the exams. 99% of the people doing the JAA IR
are young (often jobless) people, with plenty of time, who want to be
airline pilots.

(2) Certain types are not EASA approved.

The Cirrus SR22 is the best known example. The TBM700C2 turboprop is
another one, AFAIK due to its slightly higher stall speed. Various
turboprops and jets (which I know nothing of in detail) have serious
certification issues if not on N.

There are also many, many items (e.g. avionics) that are FAA approved
only, and for which the European approval route is expensive, or
impossible. I was once quoted US$ 2000 for the paperwork for a backup
oil pressure gauge (CAA L2 approved company). While few owners will
move their aircraft to N just to fit a piece of FAA approved avionics
(because moving to N itself can hardly be done for less than $10k and
often costs 2x or 3x that, for a SEP - as I know very well, with the
DAR alone charging $2600) there are many planes containing equipment
alredy fitted which prevents them going to a different registry.


The DfT asked the CAA to come up with evidence that N-reg planes have
more accidents, and the CAA reported they cannot find any such data.
So the DfT is attacking it from the "lack of maintenance oversight"
angle, which in theory is accurate (the FAA does supervise European
FAA-approved maintenance firms but doesn't do ramp checks) but in
practice is irrelevant because most N-reg pilots are owners, with a
powerful incentive to do the specified maintenance (their life, and
the fact that the insurance is void unless the aircraft is airworthy).
The CAA is practically unknown to do ramp checks on G-reg planes too -
just as well because if they did, many UK flying schools, and JAR145
approved maintenance firms, would be in trouble The worst
maintained planes in the UK are G-reg, not N-reg.

The GBP 250k economic cost in the DfT proposal is low by 2 to 3 orders
of magnitude - working on the cost of moving each plane to G, or
offloading it onto the U.S. market. Many of these are turboprops and
jets. Plus each pilot taking a year to do the JAA PPL/IR. It's a
complete farce.

It may be only a "proposal" now, but the manner in which the UK and
European governments usually structure these things is to make the
process a fait accompli.