Since returning from the UK, I’ve been focusing my efforts on my primary project – namely rescuing my latest aircraft acquisition for a new life in France. The transfer of ownership went through last weekend (Saturday 14 September) and deregistering it in the UK was easy. It only took one day and I didn’t even need to put it in my name. Registering it in France has been slightly more difficult, however, but now I’m there and just waiting for the ‘Carte Jaune’ to arrive in the post.
I’ve had to learn all about the French system for registering ULMs in a very short time. The first thing is that only ULMs with a French ‘Code d’Identification’ and/or ‘Fiche Technique’ can be registered in France. This means that only those with a ‘technical dossier’ created by the constructor that proves that the aircraft in question meets the ULM/microlight definition and meets acceptable standards of construction and airworthiness can be added to the French register. When this is done, the aircraft model in question is allocated an ‘identity code’ which can then be quoted by all ‘ULMs de série’ ie all similar models ‘in the series’ for them to be automatically deemed as acceptable. Alternatively, if the ‘identity code’ isn’t known, the reference to the relevant ‘technical dossier’ can also be quoted.
This doesn’t mean that an individual who designs and builds their own ULM can’t get it registered. They can, by applying for a ‘provisional’ registration that starts with the letter ‘W’ which I think only lasts for one year and can then be converted to a permanent one once the owner demonstrates by testing and calculation that the aircraft conforms. However, this doesn’t apply to my aircraft and I’m not absolutely certain of this as I haven’t gone into it in more detail.
I started by applying for a ‘provisional’ registration for my aircraft that I want to bring into France from the UK but was told ‘by return’ that this wasn’t appropriate. It’s an ‘ULM de série’ but made slightly more complicated as it was kit built in the UK. My initial problem was not understanding what on earth I had to do about acquiring an ‘identity code’ as the lady at the DGAC made it abundantly clear that without such a code I would not be able to get the aircraft onto the French register at all, which alarmed me somewhat.
She told me that I needed to contact ‘the constructor’ who would need to provide an attestation that it ‘conformed’ and also met French regulatory construction and airworthiness requirements. This I saw as being a major problem as the UK ‘constructor’, a private individual, assembled the kit around 20 years ago and for all I know, isn’t even around now. So getting this ‘attestation’ seemed to me to be problematic at best.
I suggested that the BMAA HADS (Homebuilt Aircraft Data Sheet) which had been officially signed off by a BMAA inspector not only confirmed that the aircraft met the ULM/microlight definition but also confirmed that it had been built to the required standard but this was firmly rejected by the lady at the DGAC. However, as I’ve found quite frequently with bureaucrats in France, although they will freely let you know when something is unacceptable, they won’t then go the next step and tell you what you need to do to get round the problem, so it was time to take a close look myself at the relevant regulations, namely Articles 3 and 5 that the lady had indicated as being key to my registration request.
First, Article 3 which I’ve posted a copy of below.
This mentions the ‘fiche d’identification’ (technical dossier), its requirements and contents and also the need for an ULM to have user and maintenance manuals for it to be registered. But the single most important statement that struck me was that highlighted in yellow, namely that the ‘fiche technique’ or reference thereof of an aircraft applies for all aircraft sharing the same ‘key characteristics’. As my aircraft is an X-Air built from a French kit, this means that the ‘fiche technique’ that applies for all French-built 582 X-Airs also applies to my aircraft, thus overcoming the first major hurdle.
Now on to Article 5, which I’ve also posted below.
The lady at the DGAC implied that the ‘constructor’ of my aircraft needed to provide an ‘attestation’ of suitability of the aircraft but it seems to me that either I’ve misunderstood her or she’s slightly confused by the meaning of the regulations. Firstly, it’s clear that the ‘constructor’ does not mean the individual or organisation who built the aircraft – it refers to the ‘constructor’ ie the designer/manufacturer of the aircraft or the kit from which it was built.
Secondly, once a ‘fiche technique’ has been issued and archived by the ‘constructor’ it’s implicitly assumed that the aircraft itself conforms. There’s then the need before registration is granted for there to be a declaration that the aircraft conforms to the required standards of construction and is airworthy, but it is clear from Article 5 and the registration form itself that neither the ‘constructor’ nor the actual kit builder have to do that – it is solely the responsibility of the applicant to ‘declare’, as always, that those requirements are met. This is the beauty of the French system – the pilot alone is responsible for the operation and airworthiness of his aircraft.
A bit more digging gave me the aircraft’s French description as an Xair 602T and Randkar, the ‘constructor’ to whom I showed pictures of the aircraft, gave me the Code d’Identité for an Xair 602T SP (sans parachute) which I put onto my latest submission of the paperwork. This joined a weight form (using the BMAA figure), a form confirming de-reg in the UK and a promise to pay 20€ when it was all done that I submitted earlier, so all’s well that ends well, as we say in the UK.
Re getting it over here, I’ve booked Bergerac-Stansted on 4 October for 21.99€ (the cost for my additional case at 12€ was more than my fare of 9.99€) and I’ll be taking with me things like new carb rubbers and new fuel pump mount rubbers as I found that one of the latter was perished when I looked over the aircraft last time. I’m pretty sure that there are no other major problems as although the fuel line ends were stretched and perished, this was because lines of too small a diameter had been stretched onto larger dia fittings. After cutting the ends off, they’ll be OK for now but if I find otherwise, I’ll replace them when I’m in the UK after doing my thorough inspection.
I’ll have to stay over in the UK for as long as it takes for suitable weather and then I intend to fly it over, this time taking 3 days rather than 2 as I did with MYRO. The first problem is that with Abbeville closed, I’ll have to go north to Calais before heading south so on day one I’ll do that and overnight at Abbeville, hopefully at the slightly grotty hotel on the airfield which I’ll book when I know my dates. And now Wanafly has gone, I can’t overnight there either so I’m hoping to stop over at Bellac where Roger, who is bringing his Shadow over from Ireland will be based. Then day three will be a short hop from there into Malbec.
Naturally I’m hoping that the fine weather that we’re enjoying at present will hold through into the first half of October – but luckily the X-Air has got doors and a nicely sealed cabin, so even if it’s a bit chilly, it shouldn’t be a bad flight down. So yet another adventure and I’m looking forward to it immensely 🙂