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richard.goode(at)russiana
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 Posted: Thu Apr 29, 2010 12:05 pm Post subject: European 18Ts |
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European 18Ts
I thought it useful to write an open letter on the Yak List concerning 18Ts, following the mail from Paul Beardsall to European 18T owners.
Clearly this refers only to European issues, but might be of interest to others, and, if nothing else, will show Americans how incredibly lucky they are to have such freedom to fly.
Also, although only of applicability to European issues, I have been forced to read an awful lot of parochial US issues over the years, some of which has nothing at all to do with Yaks!! So the main issues are:
<![if !supportLists]>· <![endif]>When we began importing Yaks into Europe, approaching twenty years ago, in most countries there was no legal framework into which these aeroplanes could be fitted. (Remember there is virtually no “Experimental” category within Europe).
<![if !supportLists]>· <![endif]>European regulations for non-certificated aircraft (about a third of the total) vary from country to country, and there is no consistency.
<![if !supportLists]>· <![endif]>However we then found FLA – The Federation of Aviation Amateurs, a Russian organisation rather like EAA, for home-builders. They had been given the authority to issue Certificates of Airworthiness, but ONLY for Russian based homebuilt aircraft.
<![if !supportLists]>· <![endif]>However they seemed happy to issue what appeared to be internationally valid and normal category Certificates of Airworthiness for all Russian aircraft, and indeed the Russian authorities (GSGA, their CAA/FAA) seem to accept this, or at least did not object.
<![if !supportLists]>· <![endif]>This worked fine for ten odd years, until the UK CAA pointed out the illogicality of giving normal category, and internationally valid, CofAs to aircraft without Type Certification. In consequence they, some ten years ago, refused to accept the validity of FLA documentation, and ALL the aircraft were grounded.
<![if !supportLists]>· <![endif]>A few months later the French DGAC followed suit, and we were left with a hundred odd aircraft that were grounded.
<![if !supportLists]>· <![endif]>Over a period of months we came up with ways of keeping them flying, in that, for example, Yak-50/52 are agreed to be “ex-military” and therefore acceptable for UK “Permit to Fly” etc.
<![if !supportLists]>· <![endif]>One particular avenue that we found was that the Hungarian CAA were quite amenable and flexible, since they already had 18Ts there, and had conducted a sort of Type Certification process. In passing we were then able to add Sukhoi 29 and 31 in a similar abbreviated Type Certification process.
<![if !supportLists]>· <![endif]>This was fine for a number of years, and was the reason that most 18Ts are currently on the Hungarian register.
<![if !supportLists]>· <![endif]>Then EASA came along, controlling all aviation within Europe, and felt that the 18T (along with Su-29 and 31) were aircraft built to a Type Certified standard; had a good record etc, and therefore wanted to include them as Type Certificated aircraft. However the Russians would not co-operate, and were not interested even in providing documentation, let alone funding to enable this process to go through.
<![if !supportLists]>· <![endif]>Fortunately, due to very helpful people at EASA, who could quite easily have grounded the planes on the basis of a lack of appropriate paperwork, first gave these aircraft EASA Permits to Fly, which was a pan-European document, allowing the aircraft to fly anyway, and effectively there were no restrictions.
<![if !supportLists]>· <![endif]>HOWEVER the EASA Permit to Fly is a short-term document, and we were seeking a long-term solution, and after further discussions and meetings, EASA agreed to give these planes EASA Restricted Certificates of Airworthiness, and therefore, by implication, Type Certification through the back door.
<![if !supportLists]>· <![endif]>As we are aware, there are no real restrictions in this documentation, and the long-term ability of these planes to fly within European airspace is assured.
<![if !supportLists]>· <![endif]>Virtually all European 18Ts continued on the Hungarian register, but now with European documentation. The relevance of this is that these planes are not tied to Hungary, and indeed can be registered in ANY European country that is a member of EASA – effectively the whole lot.
<![if !supportLists]>· <![endif]>At the same time, the individual CAAs, like Hungary, were being forced into uniformity with EASA operations. However each had tended to have somewhat different methods of operation, and, in any case in Hungary, they have historically always had an “Operator”, legally responsible for the aircraft, between the CAA and the owner. In the course of time I suspect that this will be phased out, but, today, that is the regulation.
<![if !supportLists]>· <![endif]>Of course a number of 18Ts are on the Lithuanian register, and there is no reason why they should not be on any register, BUT somebody has to go through the exercise of being the first one in any specific country, which I suspect could be quite difficult, although in theory, now that the aircraft have had airworthiness documentation from EASA, a change of registration SHOULD only be a paperwork exercise.
<![if !supportLists]>· <![endif]>In the background to all this, the French DGAC for somewhat extraordinary reasons, decided to accept the Russian FLA registration, and so a number of 18Ts (and of course most Yaks) fly in France on this register. BUT it is not valid in the UK or Italy, and there is a possibility that other countries will also not accept it in the future.
To deal with your specific queries – these are ones that Bela Kobori, your Operator is easily able to answer, but for the record, some points:
<![if !supportLists]>· <![endif]>The question of the number of seats is nothing to do with the Hungarian register – as I say all airworthiness issues are handled by EASA, and Hungary simply inspects the aircraft and issues the paperwork.
<![if !supportLists]>· <![endif]>The 18T is a 5-seater, subject to CofG.
<![if !supportLists]>· <![endif]>I am not aware of any regulations allowing two people to share an individual seat-belt. Certainly within Europe if you have 3 people in the back of an 18T they must have separate seat-belts.
<![if !supportLists]>· <![endif]>No idea why you think a non-Hungarian cannot be the registered owner – to the best of my knowledge you are the registered owner of your 18T, and if not something is wrong with the papers!
<![if !supportLists]>· <![endif]>Hours are flying time only.
<![if !supportLists]>· <![endif]>Yes, a Hungarian inspector does need to inspect the aeroplane once a year. Hopefully this restriction will be removed as Hungary falls into line with Europe.
<![if !supportLists]>· <![endif]>Yes, a flight-test is necessary annually.
<![if !supportLists]>· <![endif]>There is flexibility on the date – again you should speak to your Operator, and one month is normally no problem, and indeed we have obtained permission for aircraft to do a ferry flight well after expiration of the CofA. However these exemptions are done by the Operator, and not through an individual engineer.
<![if !supportLists]>· <![endif]>Not sure why there is a reference to ICAO – EASA establishes all the rules for this.
<![if !supportLists]>· <![endif]>Weight and balance schedules are not that easy – but if you have a problem with them why doesn’t someone prepare a version that is more easy to understand.
<![if !supportLists]>· <![endif]>No reason not to go to Lithuanian register, or indeed any other European register. At least 18Ts are already registered in Lithuania, so no problem to be the first. BUT the aircraft has to be inspected and indeed have its annual inspection done by an EASA 145 organisation certificated for Yak-18T AND approved by Lithuanian CAA, so I suspect that the aeroplane would have to go back to Lithuania for this to be done.
I hope that this helps.
Richard Goode Aerobatics
Rhodds Farm
Lyonshall
Herefordshire
HR5 3LW
United Kingdom
Tel: +44 (0) 1544 340120
Fax: +44 (0) 1544 340129
www.russianaeros.com
[quote][b]
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jan.mevis(at)informavia.b
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| Posted: Thu Apr 29, 2010 10:10 pm Post subject: European 18Ts |
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Thanks, Richard! Very clear.
From: owner-yak-list-server(at)matronics.com [mailto:owner-yak-list-server(at)matronics.com] On Behalf Of Richard Goode
Sent: donderdag 29 april 2010 4:32
To: yak-list(at)matronics.com
Subject: European 18Ts
European 18Ts
I thought it useful to write an open letter on the Yak List concerning 18Ts, following the mail from Paul Beardsall to European 18T owners.
Clearly this refers only to European issues, but might be of interest to others, and, if nothing else, will show Americans how incredibly lucky they are to have such freedom to fly.
Also, although only of applicability to European issues, I have been forced to read an awful lot of parochial US issues over the years, some of which has nothing at all to do with Yaks!! So the main issues are:
<![if !supportLists]>· <![endif]>When we began importing Yaks into Europe, approaching twenty years ago, in most countries there was no legal framework into which these aeroplanes could be fitted. (Remember there is virtually no “Experimental” category within Europe).
<![if !supportLists]>· <![endif]>European regulations for non-certificated aircraft (about a third of the total) vary from country to country, and there is no consistency.
<![if !supportLists]>· <![endif]>However we then found FLA – The Federation of Aviation Amateurs, a Russian organisation rather like EAA, for home-builders. They had been given the authority to issue Certificates of Airworthiness, but ONLY for Russian based homebuilt aircraft.
<![if !supportLists]>· <![endif]>However they seemed happy to issue what appeared to be internationally valid and normal category Certificates of Airworthiness for all Russian aircraft, and indeed the Russian authorities (GSGA, their CAA/FAA) seem to accept this, or at least did not object.
<![if !supportLists]>· <![endif]>This worked fine for ten odd years, until the UK CAA pointed out the illogicality of giving normal category, and internationally valid, CofAs to aircraft without Type Certification. In consequence they, some ten years ago, refused to accept the validity of FLA documentation, and ALL the aircraft were grounded.
<![if !supportLists]>· <![endif]>A few months later the French DGAC followed suit, and we were left with a hundred odd aircraft that were grounded.
<![if !supportLists]>· <![endif]>Over a period of months we came up with ways of keeping them flying, in that, for example, Yak-50/52 are agreed to be “ex-military” and therefore acceptable for UK “Permit to Fly” etc.
<![if !supportLists]>· <![endif]>One particular avenue that we found was that the Hungarian CAA were quite amenable and flexible, since they already had 18Ts there, and had conducted a sort of Type Certification process. In passing we were then able to add Sukhoi 29 and 31 in a similar abbreviated Type Certification process.
<![if !supportLists]>· <![endif]>This was fine for a number of years, and was the reason that most 18Ts are currently on the Hungarian register.
<![if !supportLists]>· <![endif]>Then EASA came along, controlling all aviation within Europe, and felt that the 18T (along with Su-29 and 31) were aircraft built to a Type Certified standard; had a good record etc, and therefore wanted to include them as Type Certificated aircraft. However the Russians would not co-operate, and were not interested even in providing documentation, let alone funding to enable this process to go through.
<![if !supportLists]>· <![endif]>Fortunately, due to very helpful people at EASA, who could quite easily have grounded the planes on the basis of a lack of appropriate paperwork, first gave these aircraft EASA Permits to Fly, which was a pan-European document, allowing the aircraft to fly anyway, and effectively there were no restrictions.
<![if !supportLists]>· <![endif]>HOWEVER the EASA Permit to Fly is a short-term document, and we were seeking a long-term solution, and after further discussions and meetings, EASA agreed to give these planes EASA Restricted Certificates of Airworthiness, and therefore, by implication, Type Certification through the back door.
<![if !supportLists]>· <![endif]>As we are aware, there are no real restrictions in this documentation, and the long-term ability of these planes to fly within European airspace is assured.
<![if !supportLists]>· <![endif]>Virtually all European 18Ts continued on the Hungarian register, but now with European documentation. The relevance of this is that these planes are not tied to Hungary, and indeed can be registered in ANY European country that is a member of EASA – effectively the whole lot.
<![if !supportLists]>· <![endif]>At the same time, the individual CAAs, like Hungary, were being forced into uniformity with EASA operations. However each had tended to have somewhat different methods of operation, and, in any case in Hungary, they have historically always had an “Operator”, legally responsible for the aircraft, between the CAA and the owner. In the course of time I suspect that this will be phased out, but, today, that is the regulation.
<![if !supportLists]>· <![endif]>Of course a number of 18Ts are on the Lithuanian register, and there is no reason why they should not be on any register, BUT somebody has to go through the exercise of being the first one in any specific country, which I suspect could be quite difficult, although in theory, now that the aircraft have had airworthiness documentation from EASA, a change of registration SHOULD only be a paperwork exercise.
<![if !supportLists]>· <![endif]>In the background to all this, the French DGAC for somewhat extraordinary reasons, decided to accept the Russian FLA registration, and so a number of 18Ts (and of course most Yaks) fly in France on this register. BUT it is not valid in the UK or Italy, and there is a possibility that other countries will also not accept it in the future.
To deal with your specific queries – these are ones that Bela Kobori, your Operator is easily able to answer, but for the record, some points:
<![if !supportLists]>· <![endif]>The question of the number of seats is nothing to do with the Hungarian register – as I say all airworthiness issues are handled by EASA, and Hungary simply inspects the aircraft and issues the paperwork.
<![if !supportLists]>· <![endif]>The 18T is a 5-seater, subject to CofG.
<![if !supportLists]>· <![endif]>I am not aware of any regulations allowing two people to share an individual seat-belt. Certainly within Europe if you have 3 people in the back of an 18T they must have separate seat-belts.
<![if !supportLists]>· <![endif]>No idea why you think a non-Hungarian cannot be the registered owner – to the best of my knowledge you are the registered owner of your 18T, and if not something is wrong with the papers!
<![if !supportLists]>· <![endif]>Hours are flying time only.
<![if !supportLists]>· <![endif]>Yes, a Hungarian inspector does need to inspect the aeroplane once a year. Hopefully this restriction will be removed as Hungary falls into line with Europe.
<![if !supportLists]>· <![endif]>Yes, a flight-test is necessary annually.
<![if !supportLists]>· <![endif]>There is flexibility on the date – again you should speak to your Operator, and one month is normally no problem, and indeed we have obtained permission for aircraft to do a ferry flight well after expiration of the CofA. However these exemptions are done by the Operator, and not through an individual engineer.
<![if !supportLists]>· <![endif]>Not sure why there is a reference to ICAO – EASA establishes all the rules for this.
<![if !supportLists]>· <![endif]>Weight and balance schedules are not that easy – but if you have a problem with them why doesn’t someone prepare a version that is more easy to understand.
<![if !supportLists]>· <![endif]>No reason not to go to Lithuanian register, or indeed any other European register. At least 18Ts are already registered in Lithuania, so no problem to be the first. BUT the aircraft has to be inspected and indeed have its annual inspection done by an EASA 145 organisation certificated for Yak-18T AND approved by Lithuanian CAA, so I suspect that the aeroplane would have to go back to Lithuania for this to be done.
I hope that this helps.
Richard Goode Aerobatics
Rhodds Farm
Lyonshall
Herefordshire
HR5 3LW
United Kingdom
Tel: +44 (0) 1544 340120
Fax: +44 (0) 1544 340129
www.russianaeros.com
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psb777
Joined: 12 Aug 2009
Posts: 34
Location: UK
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| Posted: Fri Apr 30, 2010 3:10 am Post subject: Re: European 18Ts |
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Richard,
Thanks for your (as ever) thoughtful and informative contribution.
From what you say it seems maybe I may be able get permission to fly my a/c to Hungary to renew its AWC rather than having to wait weeks for the Hungarian CAA inspector to turn up. It had been indicated to me it wasn't even worth asking. Let's see.
On the issue of two children sharing a seat belt and a seat this is legal in the aircraft of several/many jurisdictions. E.g. Legal in Australian and NZ (I think) and definitely German a/c: http://www.pprune.org/archive/index.php/t-373363.html It just does not matter that it is illegal in the USA or the UK.
But the point that needs to be made is a broader more general one: Unless I can find and read the Hungarian rules how do I know I am flying my Hungarian-registered a/c legally? I suggest we owner/pilots of such a/c are flying blind to some extent - we are obliged to follow the Hungarian rules but we know not what they are.
ICAO member countries are obliged to publish their rules (also) in English. I cannot find the Hungarian ones on the web. Somewhere there must be a list of the variations of Hungarian rules from the ICAO ones. ICAO members are obliged to publish same. I seem to remember once finding the Hungarian list but I can't find it anymore. Anyone?
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_________________
Paul Beardsell
G-PYAK http://beardsell.com/flying/g-pyak
Yak-18T http://beardsell.com/flying/yak18t
Last edited by psb777 on Fri Apr 30, 2010 5:58 am; edited 1 time in total |
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psb777
Joined: 12 Aug 2009
Posts: 34
Location: UK
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| Posted: Fri Apr 30, 2010 3:16 am Post subject: Re: European 18Ts |
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Richard, I know I am the registered owner of the (excellent) aircraft you sold me but my question was, does the registered operator need to be Hungarian? As far as I am aware all HA-registered a/c in the UK (mine included) have one. Is this for issues of practicality or is it a legal requirement?
| | - The Matronics Yak-List Email Forum - | | | Use the List Feature Navigator to browse the many List utilities available such as the Email Subscriptions page, Archive Search & Download, 7-Day Browse, Chat, FAQ, Photoshare, and much more:
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_________________
Paul Beardsell
G-PYAK http://beardsell.com/flying/g-pyak
Yak-18T http://beardsell.com/flying/yak18t |
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richard.goode(at)russiana
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| Posted: Fri Apr 30, 2010 10:30 am Post subject: European 18Ts |
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Hi Paul,
I believe that you have spoken to Bela and that most issues are resolved.
If not,please let me know.
I'm fairly sure the operator must be Hungarian,but Bela must know.
Also,I do find that he sorts out a lot of the problems that can occur with his contacts at Hu CAA.
Regards,and possibly see you tomorrow??
Richard
Richard Goode Aerobatics
Rhodds Farm
Lyonshall
Hereford
HR5 3LW
United Kingdom
Tel: +44 (0) 1544 340120
Fax: +44 (0) 1544 340129
www.russianaeros.com
[quote] ---
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