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1. 01:05 PM - European 18Ts (Richard Goode)
2. 05:09 PM - Something to consider (Barry Hancock)
3. 11:10 PM - Re: European 18Ts (Jan Mevis)
Message 1
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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:
. 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).
. European regulations for non-certificated aircraft (about a third
of the total) vary from country to country, and there is no consistency.
. 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.
. 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.
. 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.
. A few months later the French DGAC followed suit, and we were left
with a hundred odd aircraft that were grounded.
. 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.
. 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.
. This was fine for a number of years, and was the reason that most
18Ts are currently on the Hungarian register.
. 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.
. 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.
. 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.
. 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.
. 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.
. 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.
. 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.
. 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:
. 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.
. The 18T is a 5-seater, subject to CofG.
. 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.
. 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!
. Hours are flying time only.
. 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.
. Yes, a flight-test is necessary annually.
. 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.
. Not sure why there is a reference to ICAO - EASA establishes all
the rules for this.
. 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.
. 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
<http://www.russianaeros.com> www.russianaeros.com
Message 2
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| Subject: | Something to consider |
Gang,
We are enjoying our passion in an ever more increasingly anti-aviation world.
I have seen a black and white photo of several A-26s at tree top level over a
neighborhood in Orange, CA, with the people outside waiving at them. Those days
are long gone....
http://www.eaa.org/news/2010/2010-04-29_overflight.asp
Happy Flying!
Barry
Message 3
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Thanks, Richard! Very clear.
From: owner-yak-list-server@matronics.com
[mailto:owner-yak-list-server@matronics.com] On Behalf Of Richard Goode
Sent: donderdag 29 april 2010 4:32
Subject: Yak-List: 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:
. 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).
. European regulations for non-certificated aircraft (about a third
of the total) vary from country to country, and there is no consistency.
. 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.
. 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.
. 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.
. A few months later the French DGAC followed suit, and we were left
with a hundred odd aircraft that were grounded.
. 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.
. 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.
. This was fine for a number of years, and was the reason that most
18Ts are currently on the Hungarian register.
. 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.
. 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.
. 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.
. 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.
. 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.
. 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.
. 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.
. 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:
. 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.
. The 18T is a 5-seater, subject to CofG.
. 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.
. 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!
. Hours are flying time only.
. 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.
. Yes, a flight-test is necessary annually.
. 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.
. Not sure why there is a reference to ICAO - EASA establishes all
the rules for this.
. 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.
. 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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