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What are the differences in allowable self maintenance between a G and N Reg in the UK

I fly a N reg on a US PPL in the UK, I have read on here and other forums where people seem to be paying extremely large sums for annuals and routine maintenance on there G Reg, C of A aircraft, why is that? do G reg planes not have similar type rules on self maintenance and "owner assists" that the N reg craft have?

Farm strip in Angus Scotland

Its a completely different philosophy. The EASA regulatory regime intends to prevent aircraft owners from being involved with the maintenance of their own property, and sees that possibility as a threat. In contrast, the FAA regime figures as long as a certificated mechanic or inspector is watching what is going on with a certified aircraft and is willing to sign off the work, everybody wins. I think the net result on EASA registers is (1) a considerable amount of maintenance being done off the books, probably benefiting safety regardless of legality and (2) outrageous costs for maintenance on the books, including the periodic taxes which the EASA system facilitates.

I think it would be a lot cheaper to fly your IA from Los Angeles every year than to become entangled with EASA.

Its a completely different philosophy. The EASA regulatory regime intends to prevent aircraft owners from being involved with the maintenance of their own property, and sees that possibility as a threat. In contrast, the FAA regime figures as long as a certificated mechanic or inspector is watching what is going on with a certified aircraft and is willing to sign off the work, everybody wins.

I have to disagree once again What you are describing is the CAMO (continuous airworthiness maintenance organization). For private owners, there is no requirement to have your aircraft in a CAMO. Instead, you can have your own airworthiness program (which costs money to get approved) and then you can basically do what you describe: whatever your IA will sign off on.

The only real drawback I see from being on EASA reg as opposed to FAA is that the number of STCs is far more limited. With regard to CAMO/Part M, there appears to be hope. EASA are reconsidering their approach at the moment and I am starting to believe that they are serious about it.

I pay nothing to EASA, only times and material to my AP/IA and a few hundred Euros extra to the IA to cover his EASA induced expenses. I don't think it would be much cheaper on FAA reg.

My annual inspections for two aircraft combined total about $400 per year. I have no documented or approved 'airworthiness' program of any kind for either aircraft and never will. My aircraft have never left my hangar for maintenance, their maintenance has involved precisely zero interaction or paperwork with government. No taxes have ever been paid in relation to maintenance, and the last government record of maintenance in relation to either of my aircraft was about 30 years ago (Auto Fuel STCs in both cases)

No paperwork is required for parts installed on my aircraft, the judgement of the legality of parts installed (new or used) is made by my friend the non-professional A&P, who got his mechanics certificate about 35 years ago on the basis of working in an aircraft factory. His real job is now in a hospital, and he's had no interaction with government since they gave him the certificate. The only record of maintenance work or parts installed is his entry in the aircraft log, which is my private property.

One of my aircraft was disassembled to the extent that the fuselage was un-riveted into three sections. When after five years the work was finished the aircraft ready to fly the 'release to service' was two log book entries, airframe and engine detailing how some skins were replaced and the engine was field overhauled by the mechanic who signed the log.

Its not quite the same.

I've been G-reg 2002-2005 and N-reg 2005-present, with the same plane.

Let's first start with the assumption that you are not flying some long-neglected/abused piece of wreckage. Such examples are common - look at the first PA28-181 you see for sale for €10k. Or indeed the first TB20 you see for €40k GA is full of such examples - because so many people try so hard to "somehow fly" but really they can't afford it. Not long ago a friend was looking for a PA28-181 and one he visited was so badly rusted that the oil filter rusted through... the owner hadn't flown it for 9 years, and was looking for a sucker to buy it.

Let's also assume you are not flying a type which is affected by some massive AD. This is not my area but I believe some Cessna twins had these on wing spars, for example.

When one looks at the maintenance costs, it soon becomes apparent that doing your own 50hr checks is a huge saver. I would be paying £600, which might be say £1200/year. But each one costs just the oil and the oil filter (£100 and that includes a £20 bottle of Camguard!). The foregoing is same for G and N.

The next chunk is the Annual. I would pay £3000. It is obvious that if you are hangared where "freelance" maintenance work is allowed (a priceless privilege, not available to the vast majority of European CofA aircraft owners, due to airfield politics), then I could use a freelance A&P (plenty of them in Europe) to do the work, get a freelance IA to sign it off (likewise), and get it done for about £1000. Much less if "customer assisted" which of course it would be (I am sure Silvaire does that; he knows his stuff) given the hangarage arrangement The foregoing is similar for G and N, with differences mainly in the paper management.

The one big extra cost of G is the 150hr check, which has no FAA equivalent, and which costs almost as much as an Annual. But few private owners reach 150hrs/year. Syndicates often do, and they either do the Annual sooner (thus in effect inflating the cost of the Annual) or they ground the plane until the Annual comes up. The FAA has a 100hr check but this applies only to a) paying passengers or b) training others in your plane; US schools have to do these, but if a plane is close to 100hrs they can choose to not train in it until the Annual comes up (use it for hire only).

So really there is not much difference...

The big differences are in modifications and in parts sourcing options.

You can apply US certification (FAA STCs) directly, likewise with other forms of Approved Data used towards field approvals for Major Mods (example). EASA has complicated this process, largely IMHO to channel business to EASA Part 21 design companies which swing a lot of power within EASA (via incestuous EASA recruitment practices, starting at the very top). The FAA delegates most certification decisions ("is this mod Major or Minor?" etc) to individual IAs but EASA has removed most power from the "field" thus inflating costs all around. A lot of kit was never certified in Europe. One could go on and on. No central database of mods, so even EASA's grandfathering of all European mods to be valid in all EASA countries (one of the very few smart things it has ever done) has been largely wasted. EASA could have spent 0.0001% of its obscene budget on knocking up such a database. But the degree to which the foregoing matters to you depends on what (if any) mods you are doing. Most GA owners don't do any great mods. Also, especially with Garmin now owning the known universe, most kit you might want to install is already EASA approved. In fact there are mods which are easier and cheaper under EASA, but all cases I have seen were caused by difficulties in getting a US FSDO to process a field approval, which is perverse - example.

Parts sourcing continues to be a money saver on N-reg, because you can get most stuff with an 8130-3 and even that is not needed for Part 91 ops (you need evidence of traceability, and actually that is true for a G-reg too but very few people know that). The notorious JAA/EASA Form-1 has been used to inflate costs, by some firm getting a JAR145/EASA145 approval (lots of €€€), buying in bits from the USA, and then printing out EASA-1 forms for the cost of laser printer toner. I was once offered a Hartzell prop for $9k (8130-3) or £11k (JAR-1 form). That is a 2x price increase. But in general, parts for scheduled maintenance don't cost that much.

So... lots of little facets which individually are usually not a huge issue but when you add them all up, they can be very important.

And the ability to use totally freelance people on N can save a lot of money and hassle - because so much on aviation depends on who you know. An aircraft owner goes up a steep learning curve to build a set of relationships with good people, and this much easier on N than on G - because while the USA vests authority in a person, Europe vests it in an organisation and this enables all kinds of crap work to be done with no comeback because the organisation is approved... anybody who runs a manufacturing business knows what a total sham ISO9000 can be if you so choose. I work closely with an A&P/IA and do all maintenance with him - even the 50hr checks.

Also, a lot of people maintain according to "Hobbs time" (whatever that means). Actually you should maintain according to airborne time only. If your hobbs meter starts running during taxi, and you do short flights, your maintenance is probably costing you 10-20% more than it should. In your pilot logbook you log brakes off to brakes on. The foregoing is true for both G and N.

But, in Europe, fuel costs dominate. So why not learn to lean correctly? The savings dwarf everything else.

Shoreham EGKA, United Kingdom

Peter - re "traceability" of parts installed on FAA Part 91 private aircraft... on the rudder of one of my aircraft you can just make out the N-number of another aircraft. Google that N-number and you find that it spun in and all on board were killed (really). Does that make it traceable? :-)))

The way parts are done for 60 year old FAA certified aircraft is very often that a used part is found and rebuilt per FAA Advisory Circular 43.13, which serves as approved data. A logbook entry is made to note that a "used serviceable" part was installed by an FAA mechanic. That logbook entry may or may not reference the work done on the part.

That's how acres of immaculate FAA-certified antique types show up at Oshkosh every year, many of which haven't had a "support organization" since before the owner was born. It is true that 337s get filed for radio installations etc on those aircraft, but usually by working with the right people this is a formality with no associated cost.

Peter, thanks for taking the time to explain the issue in such detail, Silvaire is " FAA Advisory Circular 4130" also known as the " yellow tag".

Farm strip in Angus Scotland

Sorry, I wrote AC 41.13 initially as AC 4130, now corrected. I may be many things but a good typist is not one of them.

No, the infamous yellow tag is FAA form 8130-3 (as mentioned by Peter), and it is actually not required for parts installed on Part 91 private aircraft. All that is required is that the A&P deems the part legal and fit for service. That said, any part that goes to an FAA repair station will get shipped back to the mechanic with a yellow tag when released for service, and both mechanics and owners like to have them for something like the component parts of a field engine overhaul (which is perfectly legal, BTW).

FAA Advisory Circular 41.13 is something different. It is a wide ranging manual on aircraft repair, and allows the mechanic to repair structures and parts without specific approval, as long as the work is done in accordance with the document. It serves as (all) the approved data needed by the mechanic.

Google that N-number and you find that it spun in and all on board were killed (really). Does that make it traceable?

You followed the route whereby an A&P (in some cases I believe an A&P/IA is required) has the authority to inspect a part and deem it fit for use.

But it has to be an "approved" part. You can't buy a hinge from a car spares shop, have an A&P look at it and say "this is plenty strong enough" (even if it is) and install it. So really all he is doing it "inspecting" it and optionally "overhauling" it.

The latter ("overhauling") is a frequent convenient route / scam (according to your position) whereby an EASA 145 firm can buy in say an airframe part with an 8130-3, "overhaul it" by replacing just one rivet, and selling it with an EASA-1 form.

With G-reg, it has historically been possible to salvage a part and transplant it, following an inspection by a licensed engineer. I don't know the current rules for this, but e.g. one EASA145 company owner told me he won't do it unless he sees a valid CofA for the donor aircraft (kind of hard if it is crashed!). No prize for guessing a lot of this is done off the books, because the vast majority of parts have no serial numbers. I would suspect that current rules are that the part has to be inspected by an EASA145 company which has scope for that work, and a fresh EASA-1 form has to be generated - because there is no "history documentation" at all. There are 2 firms not far from where I live which make a very lucrative business out of breaking up say a 747 and generating EASA-1 forms for all the bits.

Incidentally, one can fit parts with an 8130-3 to a G-reg (non-AOC ops) provided the part is new. This means that if you send your engine for an overhaul to a highly reputable US engine shop which is not EASA approved, you cannot reinstall it, because it is no longer "new". You have a useless engine, which has to "pass through" an EASA145 shop, for a fee However, there is a route from an 8130-3 to an EASA-1 form which doesn't involve this charade; it is a much simpler process which not many people know about. It involves an EASA Part F company. This option could be very useful because overhauling stuff in the USA opens up access to a wide range of very good firms, but obviously all such parts are not "new".

Shoreham EGKA, United Kingdom
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