The UK Department for Transport’s (DfT) consultation on foreign-registered aircraft based in the UK has come under a lot of fire recently, and quite rightly so.

The consultation paper demonstrates that little thought has been applied to this enquiry, and it appears that no consideration has been given to the substantial financial loss it will force upon aircraft owners and operators.

The flaws within the DfT’s consultation paper are evident from the outset, demonstrating a lack of understanding about the reasons why many UK-based aircraft carry foreign tail numbers.

Tellingly, the paper states that: “We have not included a Regulatory Impact Assessment (RIA) as there is little evidence that this policy will have an impact on the aviation industry.” Quite the contrary – the financial impact will run into tens of millions of dollars and the non-financial impact will be enormous and devestating to an already weak GA industry.

In its proposal, the DfT refers to government licensing fees for the re-registration of aircraft and conversion of pilot licenses, as if these were the only costs that would be incurred. They are, however, just the tip of the iceberg and are wholly disproportionate to the real costs which flow from this proposal.

There would initially be a very short-lived boom for aircraft dealers and ferry pilots but the repercussions to the industry would be devastating. There would suddenly be a surfeit of similar type aircraft on the market at the same time, thereby deflating values. There would be immediate lost business to all affected by the removal of these aircraft from the UK, including maintenance facilities, flight schools, handling agents, airports, aircraft dealers and brokers and insurance companies.

Although much of this financial downturn would be felt in the UK, the proposal would have a ripple effect throughout Europe and beyond. The European aviation industry would earn less from the UK GA fleet, American aircraft manufacturers would sell less aircraft, and so on.

It is ironic that by the DfT’s own hand they would inevitably suffer financially from the lost revenue previously obtained from such aircraft.

The DfT has suggested a figure of £0.25m as the total cost to the industry of their proposal. Allowing that there will be a small proportion of the GA fleet which would re-register onto the UK register it is worthwhile trying to put some numbers to the cost.

Taking a high value Gulfstream or similar aircraft, the certification cost alone will run into around £150,000. There would be de-registration and registration fees, export C of A and UK CAA fees. However the greater part of the certification costs will be attributable to maintenance work necessary to make the aircraft UK compliant with the high probability that the aircraft will have STCs requiring EASA approval.

Then, to requalify the crew from FAA to CAA licenses, one should bargain for around £100,000 and many months away from flying. Professional flight crew will incur far higher costs than private pilots because they will have to undertake the entire JAR ATPL course and after that go through very expensive CAA type rating charges.

At the moment the CAA charges £10,000 per week to send a non type-rated official to FlightSafety to ‘supervise and approve’ a course of simulator training in full three-axis simulators. One high value aircraft in itself will swallow up the DfT’s estimate.

If the DfT attempted to push through this ill-conceived proposal, it would inevitably open itself up to class actions from affected businesses and aircraft owners.

Peter Leventhal, Aviation Manager, Avcorp Registrations.

Avcorp Registrations specialises in the registration of aircraft on the American register for non-US citizens. Its clients are based throughout the world, although a significant proportion are located in the UK.