Any help appriciated
As I already started the process of G-registration (mostly because the SID-issue) I would appriciated some advice, as the CAA basicly offers two types of registration. EASA registration,. and NO EASA registration. Which one should I ask for (to avoid the SID mandatory) of course…
Please,if anybody could be helpfull, even as a privat message on: [email protected]
Do you have to use a form approved by the German CAA when doing an avionics test on a D-reg? Do you indicate whether the aircraft meets the German airspace requirements for IFR?
Yes, testing is to be done in accordance with a certain LBA NFL depending on the kind of aircraft and operation. For EASA aircraft this is NFL 25/09 and the LBA form 22 is issued. While most say that this only can be done at also can be done by an appriopriate licensed by Part 66 or Part M-F or Part 145 depending on the kind of aircraft.
I can do avionics and pitot static testing for example on G, PH and D registration and issue the paperwork which is required.
Do you have to use a form approved by the German CAA when doing an avionics test on a D-reg? Do you indicate whether the aircraft meets the German airspace requirements for IFR?
Achimha for sure is right here. These are all airspace requirements.
Their a N flyers who think they can fly IFR on their very basic IFR equipment from the US. This is not the case for most (or all) European airspaces.
The German test is exactly the same is the UK test, or the Dutch test. None of these have to be carried out in the country of registration. Anyone who is rated according the requirements can do these test. I can do avionics and pitot static testing for example on G, PH and D registration and issue the paperwork which is required.
Same is true for most other countries.
Not really, G-reg is not substantially different from D-reg and has a few downsides as well (less liberal on post TBO) but the SID issue is major. I don’t know of anybody who went D-reg to G-reg unless he was a resident of the UK or affected by the SIDs. There are a lot of D-regs operated in the UK as well.
There are still attempts by AOPA and others to talk sense into the German CAA over the SIDs but I don’t give it a very high chance of success. It’s f*cked up EU legislation combined with rigid German interpretation.
Sorry but you got this wrong. First of all, there is no “IFR Certificate” in Germany, there is only an avionics test report as mandated by JAR/EASA. It has a line saying whether this equipment meets the requirements of German airspace for IFR. Have you ever seen this form?
There are requirements for IFR associated to the aircraft being registered in Germany, those are in the 3. DV LuftBO. Those are not associated with avionics, just stuff like compass, airspeed indicator, etc. The avionics requirements are in the FSAV (“ATC equipment directive”) and this law text applies to all aircraft operated in German airspace (i.e. also your aircraft when you fly to Croatia and thereby cross the Langen/Munich FIRs). The avionics check form even specifically references the ATC equipment directive.
If I don’t have a DME, the avionics test report will say “equipped for VFR according to the German airspace ATC equipment directive”. I can still fly IFR in France or UK with my D-reg. If my G-reg does not have DME, I cannot legally fly IFR in Germany and doing so is punishable by law.
Of course it’s annoying nonsense to have this written in the avionics test but there is no “IFR Certificate”, no matter how often you keep referring to it as such…
Only it’s not true. You can swap boxes with an entry in the logbook, like on any other register. The requirements for avionics checks are the same in all EASA countries, just the prices differ. The IFR/VFR/CVFR checkbox only shows if this equipment meets the requirements of German airspace. Whether you can fly IFR is up to the TCDS of the aircraft, the pilot rating and the equipment for the specific airspace and procedure
We have done this before many times, and either all the Germans who posted the contrary were smoking something, or I was smoking something reading it 
The German IFR Certificate is a requirement for a D-reg to be legal for IFR flight, anywhere. Without it, it doesn’t matter what the TCDS says or doesn’t say (usually, AFAIK, the TCDS does not explicitly permit IFR; instead it does not prohibit it e.g. my TB20 POH does not authorise IFR at all and authorises only VFR and Night VFR).
That’s my understanding of the German situation.
The practical issue is that if the German avionics shop refuses to give you the IFR Certificate (eg. because they believe you need 2 × 8.33 when you have only one) then they have you over a barrel. And you can’t get the IFR Certificate from a non-German avionics shop. Plenty of German pilots have expressed a dissatisfaction with that situation.
There is no equivalent situation on G-reg, or N-reg etc. There are radio checks, sure, but crucially the person signing them off is not required to make a personal interpretation of the entire potential collection of regulations (of which there are many today e.g. national, EASA “OPS”, etc and virtually nobody understands the whole picture) and thus nobody has you over a barrel. The guy doing the G-reg merely signs off the radio check and that’s his job done. He couldn’t care less whether the plane is flying VFR or IFR.
move any IFR type off the German register just to avoid the utterly stupid IFR certificate that requires the serial numbers of individual radio boxes, do a box swap of exactly that same unit and you can’t fly IFR until the paperwork catches up ( this can take weeks I am told)……… That is the worst bit of big govenment stupidity I have seen.
Only it’s not true. You can swap boxes with an entry in the logbook, like on any other register. The requirements for avionics checks are the same in all EASA countries, just the prices differ. The IFR/VFR/CVFR checkbox only shows if this equipment meets the requirements of German airspace. Whether you can fly IFR is up to the TCDS of the aircraft, the pilot rating and the equipment for the specific airspace and procedure. A G-reg overflying Germany needs to meet the same requirements as a D-reg stationed there.
The SID’s are a good idea as long as the checks are done in a way preportonate to the current state of the aircraft, and this is what the UK CAA are trying to achive.
The UK has a long political objection to being told what to do by big Govenment and sees the individual’s right to act responsibly within the law as paramount, this is why the individual certifying the aircraft is given the power to decide just how much of the SID’s check is appropriate for that individual aircraft rather than the European super state officals who would not know a Cessna if it bit them in the ass deciding to mandate the whole of a program in a disproportionate way.
If you have an undermaintaned death trap moving it to the UK register is not going to be any cheaper than staying were you are, if you have a well maintained aircraft with a good service history you will save some money.
My own thought is I would move any IFR type off the German register just to avoid the utterly stupid IFR certificate that requires the serial numbers of individual radio boxes, do a box swap of exactly that same unit and you can’t fly IFR until the paperwork catches up ( this can take weeks I am told)……… That is the worst bit of big govenment stupidity I have seen.
