The secondary legislation in Turkish aviation industry, Regulation on Commercial Air Transportation (SHY-6A) has been changed recently and published on the Official Gazette dated 16 November 2013.
Together with the effectiveness of the new Regulation, it is obviously seen that Turkish Civil Aviation Authority tends to renew the aircrafts at fleets and intolerant to be grounded for any reason. The new regulation has raised concerns of the operator in several perspectives including but not limited to fleet age limitations.
In our article you will find more about the limitations on aircraft age to be implemented by the Turkish Civil Aviation and be able follow the concerns of the industry in this respect.
Accordingly, as of 16 November 2013 Turkish Civil Aviation will not allow to the operations of passenger transportation purpose aircrafts older than 15 years old starting to count from the first registration date to Turkish Civil Aircraft Registry. This applies as maximum 25 years old in aircraft cargo. The limitation is not applicable to fire extinguishing aircrafts and to the aircrafts registered to Turkish Civil Aircraft Registry.
This was declared in many times by Turkish Civil Aviation Authority’s representatives in recent years however a seaplane operator, SEABIRD’s start up with old aircrafts during the time of declarations resulted with the ignorance by many environments in the industry.
Alike the comparison of apple to apple, many companies, people from the aviation industry started to ask about the future of their aircrafts on fleet and favor (!) made to Seabird. Whereas, the articulated aim is clear enough to apprehend the approach of the authority.
As quoted above, the provision of article 19(i) does not refer to the date of manufacture for aircrafts already registered in Turkey under any circumstances whatsoever. It only refers to the first registration date to the Turkish Civil Aircraft Registry that makes difficult to realize the aim of the provision if the interest is airworthiness itself.
Since the aircrafts are much more expensive than sea and land vehicles and there is no certain benchmark for removal from the fleet providing the regular maintenance and overhauls, the new Regulation will have direct effect on insurance policies and this will result with increase in lease agreements. It is obvious that unless the design life projected by the OEMs ends the aircraft age policies only results with the market change in ancillaries.
In this regard, a criticism against provision arises: What should be the applicable age limitations to the aircrafts already registered in Turkey? In construe of the provision the only answer seems as “design life” unless a new limitation to the registered aircrafts applied. The following question arises as: The next question from insurance perspective arises as follows: How will insurance companies make their risk analysis that will structure the premium policies against the operators intending to register a 14,5 year old aircraft? Will same risk analysis be applicable to the operators registered aircrafts 20 years ago?
Namely, the priority of the Turkish Civil Aviation Authority seems that it is just to ensure young fleet operations notwithstanding the design life and insurance costs and MRO market and not certainly the airworthiness or safety at least for short and mid-term.