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European registration and airworthiness issues:
In the 21 years that we have been dealing in Eastern Bloc aircraft, we have encountered a variety of bureaucratic obstacles to their operation.
The fundamental problem is that the total numbers of aircraft are small, the individual National Aviation Authorities are often obstructive, and keen to hide behind their legislation.
An additional problem is that while the operation of fully certificated aircraft – Cessna, Beechcraft, etc – has totally uniform legislation throughout the world, there is absolutely no agreement between different countries on how to handle non-certificated aircraft, however intrinsically safe and well built they might be, and however good their historic safety record has been.
Russian
registrations
Many of these aircraft have been
operating for the last 20 years with Russian registrations – typically those
issued by ‘
Ironically, after this, the French
DGAC, not only said that the Russian registrations were fully legal and
internationally compliant but that Eastern Bloc aircraft flying and based in
France MUST have
If these National bodies (CAA and DGAC) cannot agree – it is inevitably difficult for mere pilots and owners of these aircrafts to decide what is absolutely legal and correct.
Having said that, ‘
It should be noted that the Russian FLA registration is fully international – that is an Airworthiness document according to the Chicago Convention and as such SHOULD be accepted anywhere in the world.
Lithuanian
Registrations
An alternative registration for many
of these aircraft flying in
Developments
with EASA
EASA is still somewhat ‘finding its feet’ in this area but does seem to be genuinely making efforts to unify the European approach to all aircraft, and this has led to considerable progress for Eastern Block non-certificated aircraft. Indeed it has also discovered a lot of National anomalies about other ‘odd-ball’ aircraft manufactured in the West.
EASA has established three categories of aircraft:
Fully EASA certificated – ie aircraft which have historically had normal Certificates of Airworthiness (like Cessna, Piper etc).
EASA ‘Permits to Fly’ - EASA recognised that there were a number of aircraft – many of them being Eastern Bloc – which were perfectly safe; well engineered and indeed in a number of cases Type Certificated, but either to historical Russian standards (which might well be higher than Western) or to the new Russian AR23 Standard, which although paragraph for paragraph the same as the European JAR23 does not have the benefit of bi-lateral agreements with EASA, which would mean that the certifications were automatically accepted by EASA.
It has now been agreed by EASA that all Sukhois; Yak-18T and Yak-55 (and of course many others) will obtain EASA Permits to Fly - of those aircraft with which we are involved over 30 have now obtained EASA Permits to Fly and we believe that this is an excellent solution, giving a totally international document but with no restrictions that would affect the normal operation of that particular type of aircraft.
A further advantage of the EASA Permit to Fly
is that the aircraft can be registered in any European Country. In practice most
Sukhoi Su-29 2-seaters and Yak-18T are registered in Hungary, where they have
been for some time before obtaining EASA documentation. Most owners have
decided to keep to the Hungarian registration, which is relatively cheap;
flexible and hassle-free.
In addition, under the new EASA legislation, maintenance can be done at any EASA
145 organisation throughout Europe, which is a big advantage.
Annex
II - EASA have placed all other aircraft – in
the case of Eastern Bloc – Yak-18A; Yak-50; Yak-52, and indeed a lot of other
Western Types into what is called Annex II.
Annex II is totally controlled by the local NAA, with no involvement from EASA. In some ways this is rather unsatisfactory because it perpetuates the lack of uniformity between different countries and of course allows certain countries not to issue relevant airworthiness documentation for a certain type of aircraft, because they have no obligation to do so. Conversely aircraft with EASA Permits to Fly, give an obligation to the NAA to issue paperwork for that aircraft according to EASA norms.
The
Future
For today the above is the position, but our belief is that EASA are approaching these issues in good faith and are genuinely trying to ensure that all aircraft that are safe will be allowed to fly in European airspace.
Certainly we have had formal
undertakings from EASA that no aircraft flying in
Su-29 has full Type Certification in Hungary - click here for details of Hungarian registration