Exporting an Aircraft – How many times?
This article has been produced for aircraft dealers and those moving aircraft in and out of Europe, the Overseas Territories and the United States of America. In looking at where to take our business, we looked and role that an approved organisation can fulfil supporting those who are moving aircraft from one regulatory framework to another, it was clear that guidance and expertise were required, particularly when moving to and from EASA aligned countries.
Whilst carrying out our market research, I was regaled with a story that demonstrated a huge cost, in regulatory fees, that would have to have been borne. There was not one but two export/import actions; the aircraft was purchased from a client operating on an EASA aligned registration, the aircraft was exported/imported to the USA and the “N” register, by the dealer, and finally sold to an operator in an……….EASA aligned country! The aircraft was on the “N” registration for about 200 days in-total!
Why did this aircraft change registration, when there was the potential that it would end up on an EASA registration? Simply put, it is the role out of EASA Part M Subpart G, it states that a complex or heavyweight aircraft must remain under the control of an approved organisation to remain in an airworthy condition. The aircraft will require a new ARC as it has broken the boundaries of the controlled environment, don’t you just love the highly emotive the language of EASA, however, the issuance of a new ARC by the new CAMO will be significantly less than the process of exporting/importing the aircraft from EASA to the FAA, and back again!
Not aware of the details of this particular aircraft, but it should be noted that aircraft when delivered can be delivered to meet an EASA or FAA specification, that may necessitate the introduction of modifications or additional equipment to meet compliance; had the aircraft remained on the EASA registration, under the management of an approved CAMO, it could be based, operated and demonstrated to potential customers anywhere in the world. An aircraft remaining within EASA jurisdiction can transfer registration, provided it has a valid ARC, relatively easily!
Working with the vendor/broker/customer, Mackenzie Morgan can take an aircraft into our controlled environment, manage the continued airworthiness and when finally sold, we will manage the transfer to the new State of Registration. The induction of the aircraft into our controlled environment allows the aircraft to marketed from day 1, there is not a hiatus while the aircraft goes through the change of registration process.
As always we would love to hear from you, your comments are valued!
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It is a practice of Leasing Companies to preserve the aircraft marketability in the USA to transition their aircraft through the FAA certification process, even when both customers are EASA or non FAA operators.
The work will be performed by an FAA Repair Station and released under the FAR 145/FAR 43 rules.
Then an FAA DAR will review the records and determine the eligibility to register it under the FAA rules. A C of A for Export is issued and then the aircraft is registered at its final destination.
Oussama
The case study described here was the sale and purchase of a large business jet as opposed to a commercial aircraft on a lease. I was pointing out that in the current financial situation, it is in the interests of all parties, particularly the brokers to minimise the intervention of the regulatory authorities. The only reason this aircraft was exported to the “N” registration was so the broker could fly/demonstrate the aircraft, it was then sold to a European operator, requiring an another export CofA, and import of an aircraft from outside EASA. Had the aircraft remained on the original EASA registration the change of ownership could of been simplified.
I am a firm believer in if something does not need to be done, don’t do it!
I hope that this clarifies my position?