Dear Mr. Kneepkens, thank you for your deliberate answer dated ...

for all-in operation costs (depreciation, maintenance, insurance, hangar, fuel, airway
fees, etc.). Without the cost for a pilot per flight hour we estimate:
Aircraft Type
Operation cost all in per flight hour
Single-engine piston EUR 150 to EUR 300
Multi-engine piston EUR 400 to EUR 800
Single-engine turboprop < 5,7 to EUR 1.000 to EUR 2.000
Multi-engine turboprop < 5,7 to EUR 1.000 to EUR 3.000
Small twin-engine jet < 5,7 to EUR 1.800 to EUR 3.000
Bigger twin-engine jet > 5,7 to
EUR 3.000 to “unlimited”
Part-ORO will require the operator in the future (once it has passed legislation)
amongst other things to:
• significant runway length for all aircraft with a V1 specified in the manual, which
is probably the case for all jets and no turboprops, but which will rule 90 % of all
German airfields out for these small jets (see NCC.POL.125 (b))
• develop an operations manual (ORO.GEN.110)
• apply for air operator certificate and get it granted (ORO.GEN.115)
• develop and maintain a management system (incl. safety management system)
(ORO.GEN.200)
• record keeping (ORO.GEN.220)
• regular auditing (ORO.GEN.135)
In contrast to NPA 2009-02g we estimate that for the operation of a single aircraft for
personal use or company travel this will require additional 2 employees. At total cost
of EUR 100.000 per employee this will increase the cost of operating a small twinengine
turboprop or jet by EUR 200.000 per year. So in the past a small turboprop was
operated for e. g. 200 hours * EUR 1.000 per hour = EUR 200.000 per year. Your
additional requirements thus double the cost of operating that aircraft.
Now let us look at the safety benefits: Your regulations still allow to fly these aircraft
with one appropriately trained and rated pilot (see ORO.FC.100). This pilot has been
licensed under JAR FCL rules – and thus this pilot is competent to safely
operate the aircraft. Since he or she is already competent to safely operate
the aircraft, he or she will not gain any additional safety from your new
regulations.
In our example we are looking at a safety-aware pilot flying either for personal use or
for company travel, he or she has already invested into a twin-engine turboprop. Your
new regulations now either force this operator to tolerate twice the cost he
or she previously incurred without gaining any additional safety or the
operator will go to a less safe “non-complex” aircraft such as a single-engine
turboprop.
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