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Benefits/drawbacks of N-reg vs YR vs PH with new Part-ML

You seem very lucky Gallois. It is not the same everywhere.

Between Part ML and Part 91 in Europe, the remaining key factors are :

  • do you have a good Part66 or A&P available in your area ? If you have both you are very lucky
  • how does the dutch authority enacts Part ML ? Some countries drag their feet more than others.
LFOU, France

gallois wrote:

I think this is the same at many airfields throughout France.

I have never heard anyone in Sweden complain about “airfield politics” either.

ESKC (Uppsala/Sundbro), Sweden

Our CCI has just agreed to proposals from our owners club to allow the building of more individual hangars on the airfield. Yes, you have to build your own hangar but for the lease of the land to build it on works out at €400 per annum for a single hangar and €800 pa for a double.
Rental of a space in an existing communal hangar works out at around €140 per month here and about €150 -€160 per month at La Rochelle LFBH.
No problems with working your own aircraft in the hangars, most do, although at LFFK there are 2 very good, not expensive, maintenance facilities including painting and auto pilot repairs and the same goes for La Rochelle. You can usually work alongside the professional mechanics if you so choose and in most, take advantage of their tools and expertise.
I think this is the same at many airfields throughout France.

France

The US scene benefits from many factors, compared to Europe:

  • higher earnings
  • 10x more planes so economies of scale on parts supply
  • most parts are US made so $5-$10 for UPS Ground versus $150 to Europe
  • more competition between suppliers
  • more general avionics and parts repair facilities
  • much more expertise in narrow areas e.g. autopilots
  • lots of 145 companies → instrument repair done more officially → better availability
  • generally more land → lower land values → easier hangarage → landowners less powerful → less airport politics
  • more acceptance of GA by general population
  • much more utility value due to many more runways
  • lots of IAPs
  • lots of A&Ps
  • lots of places to fly to and all in just one country
  • the country has a CAN DO attitude
  • the list can go on and on

To fly GA in Europe, with a decent mission capability, you need to be seriously dedicated bordering on obscessive, throwing lots of money and time at it.

Those who have created a nice happy flying life are those who sorted their ground situation properly first, and having the right maintenance setup (which includes the right aircraft reg) is a key part of that.

Administrator
Shoreham EGKA, United Kingdom

Malibuflyer wrote:

Yes, maintenance is a bit less expensive (also due to taxes) and hangar space is a lot less expensive (but here as there heavily depending on the airport you are located).

My hangar at EHRD (second largest airport in NL, serving airline traffic) is 400 euros per month, which seems like a pretty good deal to me. A similar field where I’m from in the US (Atlanta) would have a 10-year waiting list for hangar space, and would be much more than that.

EHRD, Netherlands

Peter wrote:

This is a minor point but the UK VAT reg threshold is over £80k and an individual mechanic is not going to get near that unless he supplies a fair amount of parts too

Well, the UK has the highest threshold of the whole former EU28. France has approx the same threshold, but only for manufacturing/resale/lodging activities; all other service activities have thresholds of approx 35 000 or 45 000 EUR. Other countries vary from as low as 2 850 EUR (Sweden), 6 700 EUR (Denmark), 10 000 EUR (Greece, Portugal, Finland) to 50 000 EUR (Slovenia, Slovakia). See https://ec.europa.eu/taxation_customs/sites/taxation/files/resources/documents/taxation/vat/traders/vat_community/vat_in_ec_annexi.pdf

There, Spain and Netherlands ared listed as “None” which suggests you have to register for VAT starting the first (or third?) cent, and Ireland as “NA”… Not sure what that means.

ELLX

Silvaire wrote:

The culture of light aircraft ownership in the US depends on it, FAA regulations anticipate it, and if it were not the case the US would have a little GA as Europe.

Don’t agree to that. It’s a myth that aircraft ownership in the US is less expensive than in Europe. Fuel prices is a big difference (nothing to do with aviation – just fuel in general is less expensive in the US. The difference between regular fuel and avgas in the US is even higher than in Europe), but beyond that, ownership costs are the same if not more expensive in the US.

Friend of mine operates a pretty similar Malibu in the states: Yes, maintenance is a bit less expensive (also due to taxes) and hangar space is a lot less expensive (but here as there heavily depending on the airport you are located). But that is overcompensated by a lot higher insurance premiums – he is paying almost double the premium although his liability insurance is limited to 1mio while mine covers up to 5.

Therefore the higher degrees of freedom come with a much higher liability risk that has its price.

Germany

Peter wrote:

This is a minor point but the UK VAT reg threshold is over £80k and an individual mechanic is not going to get near that unless he supplies a fair amount of parts too

It happens. The guy who does my permit is essentially a one man band, and he’s well over the VAT threshold.

Andreas IOM

Peter wrote:

I know you can in theory go the SDMP route but

in practice very few owners have done this, for reasons posted elsewhere here
an SDMP will need to transfer component life limits from the MM, so for e.g. a TB20 you are stuck with the many pages of life limited items
The engine is a separate thing. That can be on-condition in both FAA- and EASA-land.

I will update my writeup – the main change is Part-ML, but as I say the benefits are heavily qualified by airport politics / revenue generation.

Even before Part-ML, I’d say 80% of the piston fleet in Germany/Austria where on SDMPs and operated engine and prop on condition.

Now with Part-ML, it applies to all EU/EASA countries.
A significant development.

Concerning Self declared AMP acc. Part-ML you can decide to
- maintain according EASA Min Insp. Program (which is essentially just a generic list, similar to an FAA annual) or

- DAH (design approval holder) ICA (instr. for cont. airworthiness). In this case, you can elect to deviate from any of those instructions except for airworthiness limits and ADs.

For a Cirrus SR22, for example, it is 3 items:
1) The airbag seatbelts
2) The chute and lines
3) The airframe – 12000h
+ any ADs

Anything else you can deviate from and put
on condition (inspection once a year or 100 hours whichever is first). If it is wise, if your maintenance shop/or person likes it or not is irrelevant, legally an owner has the right to do it.

With this right comes responsibility and liability. The owner has a very liberal regime for maintenance but personally bears all responsibilities. A very US thing actually. Same goes for the owner pilot maintenance which is now possible here.

It takes 2 hours to write an AMP, sign it and go fly.

I’m know GA as a system is much better in the US, but Part-ML has very positive effects for GA in Europe (also for import of third country planes, no more zero timing fears etc..).

A sum up is here EASA Part-ML

always learning
LO__, Austria

This is a minor point but the UK VAT reg threshold is over £80k and an individual mechanic is not going to get near that unless he supplies a fair amount of parts too, which will not help him since not being an “authorised dealer” he won’t be getting automatic discounts. He can for sure get a trade price on stuff but mostly this is passed on to the customer, by getting the customer to procure the part and – optionally – have it delivered to the mechanic’s address.

I say “minor point” because this is worth just the VAT which is ~20% in Europe, and only the VAT on the labour. A much bigger point is the freelance v. company saving which is at least 2x, or 100%, or 200% in Daily Trash terminology And that’s before you throw in the “peace of mind” bonus that the guy working freelance is working for you and has done exactly what he told you he has done.

We all speak only from our personal life experiences and these are mine, over 19 years of ownership Others vary, as one would hope.

Administrator
Shoreham EGKA, United Kingdom
48 Posts
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