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 ‘ FLA ’.  These were accepted everywhere, including the UK, until about 6 years ago, when the UK CAA said that FLA registrations were not acceptable, although they then provided alternatives in the form of Permits to Fly for most of the aircraft.

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 FLA registrations!

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, ‘ FLA ’ registrations are being used without any problems in the vast majority of European countries, the only current exception being the UK (see above) and Italy .

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 Western Europe has been Lithuania , which of course has been a source of many of the aircraft themselves.   However a few years ago, the Lithuanian CAA (mainly to ingratiate themselves with JAR countries, which they had recently joined) decided that all Eastern Bloc aircraft would only get Restricted Certificates of Airworthiness, which by definition are not valid outside the country of issue UNLESS, they have ‘over-fly’ permission from the local CAA.  The practicality is that European NAAs have usually been perfectly happy to provide over-fly permission whenever it has been requested.

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 Europe or of a type that is flying in Europe , will be prevented from flying, or will only be allowed to fly with significant restrictions.

March 2008

Su-29 has full Type Certification in Hungary - click here for details of Hungarian registration