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etienne.phillips(at)gmail
Guest

Posted: Sun Nov 24, 2013 10:10 pm Post subject: Registering a non-TC in the UK

Hi All



After seeing that there are a number of members on this list in the UK and operating non-TC aircraft, I would like to find out what the process is really like registering a non type-certified aircraft in the UK. I realise this isn't an electrics problem, so any replies can be off-list.

 



I've read through the regulations, and as far as I can tell, it doesn't look like an onerous process. However, the rumours are that one would be better served by repeatedly bashing one's head against a concrete lintel!

 



The history of my aircraft is that it started it's life as a TC Champion Citabria 7ECA. It was then flown into a tree, and broken rather badly. The subsequent re-build was done here in South Africa, where the aircraft was registered as an experimental, non-TC aircraft with a number of modifications from the original design (bungy undercarriage, no upholstery, raised belly to remove the pregnant look...).

 



Clearly, this isn't an existing "approved design" by the UK CAA's standards, it's not a kit, and it's not a TC with a different label on it. I've heard from the grapevine that I would need to get all the modifications that have been done since it was in a TC state approved individually, but I would like to confirm that it is the case, or if there is an alternative, more suitable route to follow...?

 



Any advice would be greatly appreciated!

Thanks

Etienne



  [quote][b]

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peter(at)sportingaero.com
Guest

Posted: Mon Nov 25, 2013 1:00 pm Post subject: Registering a non-TC in the UK

Etienne,

     

     Short version for all, longer version available off list if required     (let me know - might take a few days).

     

     In the UK non-TC aircraft operate on a 'Permit to Fly' issued by the     CAA. All permit aircraft are subject to a design investigation to     substantiate the basic airworthiness of the design, with the basic     data supplied by the builder, against the relevant airworthiness     code - for example CS-VLA or CS23. Compliance must be shown with all     of the requirements, but some non-compliance is often tolerated. The     level of evidence required is typically less than a TC design -     exact amount probably depends on CAA surveyor assigned. Fees are     charged for surveyor time - I believe around £250 per hour.

     

     For amateur built aircraft the most straight forward route is to     build under the supervision of the Light Aircraft Association. Their     engineering department approves designs - to CS-VLA or CS23 as     appropriate - and a team of several hundred inspectors around the     country oversees build projects and provides stage inspections. No     deviations from 'approved' plans are permitted without approval -     the infamous 'mod' process. Fees are much lower than CAA - £300 to     register a kit built project, £600 when applying for first permit to     fly, most inspectors only charge expenses. However only aircraft up     to 260hp, (I think) 2700lb max weight, 4 seats max and max 60mph     stall speed are covered, aircraft must also be built for education     and recreation of builder - no professional builds. There is also a     51% rule. All aircraft limited to day VFR. Old TC aircraft, where no     TC holder exists, are also being transferred to LAA permits as CAA     doesn't want to know. Annual permit renewal fee of around £200.

     

     Imports that were built outside the UK are permitted, but must be     built exactly to drawing (detailed survey required) and engine must     have been signed off by someone certified to do so - ideally a     repair station. The import process takes a long time.

     

     For a broken TC aeroplane, the owner would have to convince LAA Eng     that they should take on the aeroplane, LAA would in turn have to     seek permission from CAA as its not an amateur built. I suspect if     it could be restored to TC standard then CAA would insist it is and     would not allow the permit route - but difficult to tell for unusual     cases. They may insist on CAA permit route with the costs involved.

     

     Hope this is of interest to some.

     

     Peter

     

     Do not archive

     

     On 25/11/2013 06:07, Etienne Phillips       wrote:

     

     [quote]       Hi All         

         

         After seeing that there are a number of members on this           list in the UK and operating non-TC aircraft, I would like to           find out what the process is really like registering a non           type-certified aircraft in the UK. I realise this isn't an           electrics problem, so any replies can be off-list.

         

         

         I've read through the regulations, and as far as I can           tell, it doesn't look like an onerous process. However, the           rumours are that one would be better served by repeatedly           bashing one's head against a concrete lintel!

         

         

         The history of my aircraft is that it started it's life as           a TC Champion Citabria 7ECA. It was then flown into a tree,           and broken rather badly. The subsequent re-build was done here           in South Africa, where the aircraft was registered as an           experimental, non-TC aircraft with a number of modifications           from the original design (bungy undercarriage, no upholstery,           raised belly to remove the pregnant look...).

         

         

         Clearly, this isn't an existing "approved design" by the UK           CAA's standards, it's not a kit, and it's not a TC with a           different label on it. I've heard from the grapevine that I           would need to get all the modifications that have been done           since it was in a TC state approved individually, but I would           like to confirm that it is the case, or if there is an           alternative, more suitable route to follow...?

         

         

         Any advice would be greatly appreciated!

         

         

         Thanks

         Etienne

       

        	  Quote: 	
		  



	
     [b]

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uuccio(at)gmail.com
Guest

Posted: Mon Nov 25, 2013 1:51 pm Post subject: Registering a non-TC in the UK

Peter

I would be interested in the longer version if you decide to write one (might be moving to the UK soon). 

Regards

Sacha



Do not archive



On Nov 25, 2013, at 21:58, Peter Pengilly <peter(at)sportingaero.com> wrote:



 	  Quote: 	
		   Short version for all, longer version available off list if required (let me know - might take a few days).

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etienne.phillips(at)gmail
Guest

Posted: Tue Nov 26, 2013 1:52 am Post subject: Registering a non-TC in the UK

Hi Peter



That does help a great deal. Not really what I wanted to hear though! I'll

give the LAA a shout and see what they think the chances are that my

aeroplane can be imported and registered in the non-TC category.



Thanks

Etienne

On 25 November 2013 22:58, Peter Pengilly <peter(at)sportingaero.com> wrote:



[quote]  Etienne,



 Short version for all, longer version available off list if required (let

 me know - might take a few days).



 In the UK non-TC aircraft operate on a 'Permit to Fly' issued by the CAA.

 All permit aircraft are subject to a design investigation to substantiate

 the basic airworthiness of the design, with the basic data supplied by the

 builder, against the relevant airworthiness code - for example CS-VLA or

 CS23. Compliance must be shown with all of the requirements, but some

 non-compliance is often tolerated. The level of evidence required is

 typically less than a TC design - exact amount probably depends on CAA

 surveyor assigned. Fees are charged for surveyor time - I believe around

 £250 per hour.



 For amateur built aircraft the most straight forward route is to build

 under the supervision of the Light Aircraft Association. Their engineering

 department approves designs - to CS-VLA or CS23 as appropriate - and a team

 of several hundred inspectors around the country oversees build projects

 and provides stage inspections. No deviations from 'approved' plans are

 permitted without approval - the infamous 'mod' process. Fees are much

 lower than CAA - £300 to register a kit built project, £600 when applying

 for first permit to fly, most inspectors only charge expenses. However only

 aircraft up to 260hp, (I think) 2700lb max weight, 4 seats max and max

 60mph stall speed are covered, aircraft must also be built for education

 and recreation of builder - no professional builds. There is also a 51%

 rule. All aircraft limited to day VFR. Old TC aircraft, where no TC holder

 exists, are also being transferred to LAA permits as CAA doesn't want to

 know. Annual permit renewal fee of around £200.



 Imports that were built outside the UK are permitted, but must be built

 exactly to drawing (detailed survey required) and engine must have been

 signed off by someone certified to do so - ideally a repair station. The

 import process takes a long time.



 For a broken TC aeroplane, the owner would have to convince LAA Eng that

 they should take on the aeroplane, LAA would in turn have to seek

 permission from CAA as its not an amateur built. I suspect if it could be

 restored to TC standard then CAA would insist it is and would not allow the

 permit route - but difficult to tell for unusual cases. They may insist on

 CAA permit route with the costs involved.



 Hope this is of interest to some.



 Peter



 Do not archive

 On 25/11/2013 06:07, Etienne Phillips wrote:



 Hi All



  After seeing that there are a number of members on this list in the UK

 and operating non-TC aircraft, I would like to find out what the process is

 really like registering a non type-certified aircraft in the UK. I realise

 this isn't an electrics problem, so any replies can be off-list.



  I've read through the regulations, and as far as I can tell, it doesn't

 look like an onerous process. However, the rumours are that one would be

 better served by repeatedly bashing one's head against a concrete lintel!



  The history of my aircraft is that it started it's life as a TC Champion

 Citabria 7ECA. It was then flown into a tree, and broken rather badly. The

 subsequent re-build was done here in South Africa, where the aircraft was

 registered as an experimental, non-TC aircraft with a number of

 modifications from the original design (bungy undercarriage, no upholstery,

 raised belly to remove the pregnant look...).



  Clearly, this isn't an existing "approved design" by the UK CAA's

 standards, it's not a kit, and it's not a TC with a different label on it

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Bill Allen

Joined: 24 Aug 2009
Posts: 42
Location: UK

Posted: Tue Nov 26, 2013 9:30 am Post subject: Registering a non-TC in the UK

Hi Etienne,



I'm involved with the LAA (and the PFA before it) and watched some years ago while a buddy was made to jump through hoops (full structural load tests) over importation of a US made VariEze.

  I also know of a case whereby a Cyprus built Rutan Defiant was imported into the UK and the guy tried to get a Permit to Fly from the CAA. He supplied copious data, but was tripped at the final hurdle when he could not produce the records of the "PPM dust contaminate for each structural layup".

 



Your aircraft is "neither fish nor fowl" and although you may not find anyone in authority man enough to say "you're wasting your time" you will find people suggesting that you apply in writing to formalise your request etc etc. 

 



The strategy seems to be one of "when we have exhausted him with a long series of requests, he will go away, but we can never be accused of actually denying a request"

 Bear in mind that an administrator never lost his job for preventing something happening, but could loose employment by approving something which later turned out to be an embarrassment. They have no incentive to help you.

 



If you enjoy crusades, have a go, but if you hold in mind that "your time is our life, and your life is your time" maybe you could burn your time in more fun and productive ways...

 



Just my take on it have been round that racetrack for a few laps.

best,

Bill Allen

LongEz 160 N99BA FD51

CZ4 G-BYLZ EGBJ

 

On 25 November 2013 08:07, Etienne Phillips <etienne.phillips(at)gmail.com (etienne.phillips(at)gmail.com)> wrote:

 [quote]Hi All



After seeing that there are a number of members on this list in the UK and operating non-TC aircraft, I would like to find out what the process is really like registering a non type-certified aircraft in the UK. I realise this isn't an electrics problem, so any replies can be off-list.

  



I've read through the regulations, and as far as I can tell, it doesn't look like an onerous process. However, the rumours are that one would be better served by repeatedly bashing one's head against a concrete lintel!

  



The history of my aircraft is that it started it's life as a TC Champion Citabria 7ECA. It was then flown into a tree, and broken rather badly. The subsequent re-build was done here in South Africa, where the aircraft was registered as an experimental, non-TC aircraft with a number of modifications from the original design (bungy undercarriage, no upholstery, raised belly to remove the pregnant look...).

  



Clearly, this isn't an existing "approved design" by the UK CAA's standards, it's not a kit, and it's not a TC with a different label on it. I've heard from the grapevine that I would need to get all the modifications that have been done since it was in a TC state approved individually, but I would like to confirm that it is the case, or if there is an alternative, more suitable route to follow...?

  



Any advice would be greatly appreciated!

Thanks

Etienne



   	  Quote: 	
		  



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[b]

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etienne.phillips(at)gmail
Guest

Posted: Tue Dec 03, 2013 1:23 am Post subject: Registering a non-TC in the UK

Thanks everyone for all the replies... I'll continue the investigation and see where it leads!

Etienne



  [quote][b]

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nuckolls.bob(at)aeroelect
Guest

Posted: Tue Dec 03, 2013 6:59 pm Post subject: Registering a non-TC in the UK

Tim Allen wrote:



 

  	  Quote: 	
		  The strategy seems to be one of "when we have exhausted him with a long series of requests, he will go away, but we can never be accused of actually denying a request"



 Bear in mind that an administrator never lost his job for preventing something happening, but could loose employment by approving something which later turned out to be an embarrassment. They have no incentive to help you. 	




  Tim's assertions brought to mind the words of

  Alexis de Tocqueville committed to paper . . .



 "After having thus successively taken each member of the community in its powerful grasp and fashioned him at will, the supreme power then extends its arm over the whole community. It covers the surface of society with a network of small complicated rules, minute and uniform, through which the most original minds and the most energetic characters cannot penetrate, to rise above the crowd. The will of man is not shattered, but softened, bent, and guided; men are seldom forced by it to act, but they are constantly restrained from acting. Such a power does not destroy, but it prevents existence; it does not tyrannize, but it compresses, enervates, extinguishes, and stupefies a people, till each nation is reduced to nothing better than a flock of timid and industrious animals, of which the government is the shepherd."



  Alexis reads like an individual who would offer some

  really useful conversation over beer and burgers . . .



  BTW, I'm presently taking a 20 hr class that purports to

  'guide' interested individuals in the rigors of compliance

  with yet another boat load of 'recommendations' (DO-330 and

  331) piled on top of DO-178 which is up to revison C.



  A sample quote from one of the reference documents:



 To summarize, we found that analyzing the relationship between require-

 ments coverage and model coverage provides a promising means of assessing

 requirements quality. Nevertheless, the effectiveness of this approach is highly

 dependent on the rigor and effectiveness of the coverage metrics used, and aware-

 ness of the pitfalls of structural coverage metrics is essential. For instance, in this

 experiment we found that the UFC metric was surprisingly sensitive to the struc-

 ture of the requirements, and one has to ensure that the requirements structure

 does not hide the complexity of conditions for the metric to be effective.



 

   Now THERE's a crystal clear illumination of the problem!

   What was it de Tocqueville said?



 "Such a power does not destroy, but it prevents existence; it does not tyrannize, but it compresses, enervates, extinguishes, and stupefies a people . . ."



   Methinks he had it pegged 180+ years ago.



 

   Bob . . .     [quote][b]

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Bill Allen

Joined: 24 Aug 2009
Posts: 42
Location: UK

Posted: Wed Dec 04, 2013 2:17 pm Post subject: Registering a non-TC in the UK

We think in similar ways Bob.



An aphorism I'm fond of is "forgiveness is easier to obtain than permission"

another is "rules are made for the obedience of fools and the guidance of wise men"

 



The problem comes when clever men (administrators and lawyers) are paid to write rulebooks.

 They never get fat from thin rulebooks, and have never been known to say "these rules are enough. Our work is done. Make us redundant and we'll look for other work...."

 Especially over in 'Yurp, where the feeding frenzy is multiplied by the number of languages involved.

Bill Allen

( not Tim Allen, - I have a cousin Tim, but he's a farmer :^)

 

On 4 December 2013 04:58, Robert L. Nuckolls, III <nuckolls.bob(at)aeroelectric.com (nuckolls.bob(at)aeroelectric.com)> wrote:

 [quote]  Tim Allen wrote:



 

  	  Quote: 	
		  The strategy seems to be one of "when we have exhausted him with a long series of requests, he will go away, but we can never be accused of actually denying a request"



 Bear in mind that an administrator never lost his job for preventing something happening, but could loose employment by approving something which later turned out to be an embarrassment. They have no incentive to help you. 	


  Tim's assertions brought to mind the words of

  Alexis de Tocqueville committed to paper . . .



 "After having thus successively taken each member of the community in its powerful grasp and fashioned him at will, the supreme power then extends its arm over the whole community. It covers the surface of society with a network of small complicated rules, minute and uniform, through which the most original minds and the most energetic characters cannot penetrate, to rise above the crowd. The will of man is not shattered, but softened, bent, and guided; men are seldom forced by it to act, but they are constantly restrained from acting. Such a power does not destroy, but it prevents existence; it does not tyrannize, but it compresses, enervates, extinguishes, and stupefies a people, till each nation is reduced to nothing better than a flock of timid and industrious animals, of which the government is the shepherd."



  Alexis reads like an individual who would offer some

  really useful conversation over beer and burgers . . .



  BTW, I'm presently taking a 20 hr class that purports to

  'guide' interested individuals in the rigors of compliance

  with yet another boat load of 'recommendations' (DO-330 and

  331) piled on top of DO-178 which is up to revison C.



  A sample quote from one of the reference documents:



 To summarize, we found that analyzing the relationship between require-

 ments coverage and model coverage provides a promising means of assessing

 requirements quality. Nevertheless, the effectiveness of this approach is highly

 dependent on the rigor and effectiveness of the coverage metrics used, and aware-

 ness of the pitfalls of structural coverage metrics is essential. For instance, in this

 experiment we found that the UFC metric was surprisingly sensitive to the struc-

 ture of the requirements, and one has to ensure that the requirements structure

 does not hide the complexity of conditions for the metric to be effective.



 

   Now THERE's a crystal clear illumination of the problem!

   What was it de Tocqueville said?



 "Such a power does not destroy, but it prevents existence; it does not tyrannize, but it compresses, enervates, extinguishes, and stupefies a people . . ."



   Methinks he had it pegged 180+ years ago.



 

   Bob . . .      	  Quote: 	
		  



_blank">www.aeroelectric.com

.com" target="_blank">www.buildersbooks.com

="_blank">www.homebuilthelp.com

="_blank">www.mypilotstore.com

ank">www.mrrace.com

_blank">http://www.matronics.com/contribution

ist" target="_blank">http://www.matronics.com/Navigator?AeroElectric-List

tp://forums.matronics.com

	




[b]

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