Importing a Used Seneca and Putting It Straight onto a Charter AOC
A Nigerian charter start-up purchased a 2008 Piper PA-34-220T Seneca V from a Florida owner. The aircraft arrived at Lagos by sea in a container, partially disassembled, with an FAA export Certificate of Airworthiness, a bill of sale, and evidence that the FAA registration was cancelled. The company did not obtain prior NCAA import approval before shipment. It wants NCAA to register the aircraft as 5N-BQA and immediately place it on its charter AOC. The aircraft still has a US radio station licence, not a Nigerian one. The maintenance records show a repetitive airworthiness directive inspection due at 1,200 hours; the airframe total time is 1,180 hours. The company asks what to do first and whether it can start commercial flights as soon as the registration is issued.
1. What is the correct import and registration sequence for this aircraft?
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The company should not expect immediate registration. The first step is to regularise the import with NCAA: submit the import approval application, the bill of sale, the export C of A, the FAA registration cancellation, the aircraft specification, and the maintenance records. NCAA will check type acceptance, serial number, and title. The aircraft must then be assembled by an approved maintenance organisation and inspected for conformity. Customs clearance and duty payment must be completed. After inspection, NCAA can issue a Certificate of Airworthiness and register the aircraft as 5N-BQA. Only then should the company apply for a Nigerian radio station licence from the NCC and amend its AOC to include the aircraft type. Registration alone does not make the aircraft airworthy or commercially operable. The missing prior import approval is a compliance issue that must be resolved before registration; the company should disclose it and follow NCAA's instructions.
2. How should the company handle the airworthiness directive and the US radio licence?
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The repetitive AD inspection due at 1,200 hours is not yet overdue, but it must be tracked. Because the aircraft is at 1,180 hours, the company should have the inspection scheduled within 20 hours and recorded in the maintenance control system. The assembling AMO should verify all ADs against the aircraft type and serial number and confirm that no earlier AD is outstanding. The US radio licence is not valid for Nigerian operation; the company must obtain a Nigerian radio station licence and call sign from the NCC and ensure the radio equipment meets Nigerian requirements. The aircraft should not be released to service until the AD status is verified, the radio licence is issued, and the C of A is issued. A common error is to treat the export C of A as a Nigerian C of A; it is only supporting documentation for import.
3. Can the company begin charter flights immediately after registration? What else is required?
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No. Registration is only one element. Before commercial air transport, the company needs: a valid Nigerian C of A; a maintenance release; an AOC that covers the aircraft type and the intended operation; approved operations manuals and a safety management system as required; insurance covering commercial passenger operations; a Nigerian radio licence; and crew with the correct licences, ratings, and medical certificates. The aircraft must be on the AOC's operations specification. NCAA will inspect the operator's maintenance control, flight operations, and record-keeping. The company should also confirm that the aircraft's import approval and customs documents are complete. Starting charter flights before these steps would be an illegal commercial operation and could lead to enforcement action, grounding, and insurance denial.