It’s an expensive operating environment, but CAAC is more accessible, and visas and permits are easier to process now.
By Grant McLaren
China is considered one of the most expensive and restrictive business aviation operating environments worldwide, although it has actually become easier in terms of permit request turnarounds, crew visa options, and prevalence of high-quality ground handling services.
Overall, it’s a welcoming and fairly flexible general aviation (GA) arena, say international support providers (ISPs). “Don’t be afraid to operate to and within China. Huge efforts have been made to welcome bizav over the past few years,” says UAS Ops Dir China Carlos Schattenkirchner.
“With proper trip planning and staying on schedule, China is very straightforward, and offers solutions to most issues related to permits, parking, airport slots, or visas. Sponsor letters ceased being a requirement a few years ago, crews now have more flexibility in types of visas that will be accepted, and there are ways to park longer than official parking limitations in the Beijing and Shanghai areas.
We’re even recommending China for international tech stops these days, so long as operators plan ahead and consider all applicable rules.” Avfuel Account Exec David Kang points out that, despite parking being difficult from time to time, operating business jets to China is getting easier.
“The military still controls airways and flight levels, and you’ll face both airway restrictions and altitude hold-downs occasionally. However, it’s now much clearer on what the rules of the game are, and we can live with this,” Kang adds. “In the past, Civil Aviation Administration of China (CAAC) would not notify you of the mistakes you made or wouldn’t direct you on how to correct perceived mistakes.
Now, communication with CAAC is much better, and they’ll tell you what’s wrong with your paperwork and how to amend it. Keep in mind that you need to allow sufficient lead time to make any necessary changes to permits or applications.” ISPs say that, although local and foreign-registered bizav traffic has been down somewhat over the past 2 years, GA ops remain steady.
While current US trade provocations against China have affected N-registered aircraft movements to the country, this decline has been substituted with increased business aircraft movements from the EU, Middle East, and other parts of Asia.
Popular GA airports in China include PEK (Beijing), PVG (Pudong, Shanghai), SHA (Hongqiao, Shanghai), TSN (Tianjin), CAN (Guangzhou), and SZX (Shenzhen).
This past October, PKX (Dexing), a new $11-billion airport located 29 miles south of central Beijing, opened to serve the capital. The plan is for both PEK and PKX to provide access to Beijing, which may provide some relief for GA operators currently struggling for airport slots and parking at PEK. Both PEK and PKX have dedicated GA terminals.
Note that official GA parking limitations for PEK are 24 hours, while both Shanghai airports officially limit GA stays to a maximum of 72 hours. “Nonetheless, it’s possible for ground handlers to negotiate parking extensions, particularly if private hangar space can be sourced on the field,” says Jeppesen International Trip Specialist Jessica Chu.
Overflight and landing permits required for China can be obtained within 3 days – often within 24 hours. “It’s much easier today to apply for and obtain overflight and landing permits, and we often receive approvals on the same day for major airports of entry (AOE),” remarks Beijing-based Jeppesen International Trip Support Specialist Ruby Du.
“However, if you’re going to a location where slots are more limited, it’s still recommended to apply for permits as early as possible. In the case of domestic (non-AOE) airports, you should apply 7 business days in advance for permits and, as expected, there will be additional documentation requirements.”
Your choice of Shanghai airports will be restricted depending on the direction from where you’re arriving. If you’re entering the country from Japan or the northeast, the only approved GA option will be PVG. “Should you wish to use SHA, you’d have to fly down the coast, turn around and approach SHA from the west, but this can be complicated,” says Kang.
Other restrictions of which to be mindful in China include being limited to no more than 6 flight legs and 5 stops within the country. After that, you’ll need to exit China, apply for a new permit, and pay another air compensation fee.
Also, keep in mind that there are several airports, including PEK, PVG, SHA, CAN and SZX, where you’ll only be permitted 1 airport slot between peak hours (0800 and 2300 local), so, if you land at 0900 local, you’ll not be able to depart or reposition until after 2300.
This can create issues for crew who may land at PEK after a long flight and then not be able to reposition to TSN for parking until later. This rule also makes daytime tech stops impractical at these locations. Another item to keep in mind is that aviation authorities in China do not like you to make too many schedule changes.
While there does not appear to be a set limit to the number of permit/schedule changes that will be entertained, ISPs caution operators against making more than 3. “China can be quite resistant to schedule change requests. If you send in multiple changes, authorities may just deny all landing permissions,” says Kang.
“We recommend not trying to make more than 3 changes to an approved permit.” On the good news, cabotage is seldom an issue in China, and you’ll normally be allowed to pick up and fly local nationals point to point within China, say ISPs. Also, CAAC does not differentiate between private and charter ops, so long as the aircraft has fewer than 30 pax seats.
“Aviation authorities here consider all GA flights to be private if you have fewer than 30 passengers,” says Du. “But if you’re attempting to operate a traditional charter with more than 30 passengers, plan on at least 30 days’ lead time, although permit approval is not guaranteed.”
ITPS Sr Ops Specialist Chris Linebaugh says that cost is a factor that should be considered when operating to and within China. “Expect to pay about twice what you might pay to operate to and within India,” he states. “Ground handling and associated charges for a stop at PEK can easily run from $15,000 to $20,000, and you’ll pay about $3000 in airspace compensation fees – all this in addition to nav charges of up to $5000 each time you enter/traverse the country.”
Airways and routings
With each permit request, operators should specify desired routing. However, the routing you’re ultimately given will not necessarily be what you’d requested. “You’ll be kept on airways in China and not necessarily be permitted to choose the most convenient published airways or altitudes,” confirms Kang.
ITPS Sr Ops Specialist Jon Wells points out that certain airways, such as L888 across China toward Europe, are open only to commercial flights. Likewise, direct airways between China and India are only accessible for airline ops. “Unless your aircraft is registered in China or Taiwan, you cannot fly directly between the 2 territories,” explains Wells.
“You’ll need to stop at HKG (Hong Kong), MFM (Macau) or perhaps CJU (Jeju, South Korea) first if heading up to the Beijing area.” UAS Ops Mgr Duke LeDuc mentions that it’s quite common to be held down at non-optimal flight levels when traversing China.
“From time to time, the military shuts down part of the airspace, creating bottlenecks and delays. It’s also common to be held down below FL300, so you need to be conservative in fuel planning. Keep in mind that you cannot easily divert to an alternate to pick up fuel as you can in other parts of the world.
Diversions to alternates are only allowable if you declare an emergency and you may be on the ground for hours to prove to local authorities that your stop was really due to an emergency.”
For years, the rule had been that flightcrew members needed C-type visas to operate into China. In the case of crew arriving and departing by 2 different means – one direction as active crew and the other as an airline passenger – they needed both a C and an L-type business visa.
“This created a lot of issues in the case of crew swaps,” relates Kang. “Some larger cities now allow crew members to go in and out on just a business visa – that is if they’re listed on the gendec.
But it’s not always an easy process, and crew members may be stuck for over an hour at immigration from time to time.” However, this rather onerous crew visa situation seems to have eased somewhat. “Today, in most cases, a business visa is sufficient for crew members and they no longer necessarily need C-type crew visas,” observes Schattenkirchner.
“But still, it’s always best to confirm this with local authorities in advance.” In some cases, GA crew members have been arriving in China and leaving, both as active crew and otherwise, without visas. A number of airports in China now allow visa-free stays of up to 144 hours, as long as you’re in transit from one country to a 3rd country.
If, for example, you’re flying from HND (Haneda, Tokyo, Japan) to PVG and continuing on to DMK (Don Mueang, Bangkok, Thailand), you may be able to take advantage of a visa-free stay. However, this exception does not apply if you’re flying HND–PVG–HND.
“These visa-free rules apply to both passengers and crew, and we’ve been using this quite a lot recently for crews going to China,” adds Schattenkirchner. “On occasion, crews will fly in commercial without a visa and pick up a GA flight out, on the gendec, without a visa.
This is something operators can consider, but it does take some prep work, and it’s best to talk with local customs and immigration in advance.”
Looking to the future
While permit and visa processes have eased somewhat over recent years, ISPs project that China will remain an expensive operating environment into the foreseeable future, and one with more operating restrictions than many other parts of the world.
Congestion and parking issues are likely to affect bizav ops for the long term, although this may ease a little as airport infrastructure is added and expanded. China’s current 5-year plan calls for the construction of dozens of new airports to welcome GA operations.
“Demand for aviation services continues to surge in China, but new infrastructure and airports are being built, which may ease some congestion and free up GA slots and parking options somewhat,” suggests Schattenkirchner. “We expect the new PKX to eventually ease GA access to the Beijing area, and there’s already talk of a new 3rd airport for Beijing some time in the future.
For now, however, operators just have to deal with the congestion, costs, and assorted restrictions. Using a good handling service helps eliminate some of the in-between handling agents that had been necessary previously, and helps ensure the success of your trip to China.”
Despite current trade wars and provocations, China is on a fast track to becoming the global economic leader. We can anticipate much more GA activity to and within this region in years to come. One bright spot is that China remains committed to expanding aviation infrastructure, from the Greater Bay area around Hong Kong and Guangzhou, and throughout the country.
Future generations of pilots will likely be piloting supersonic business jets on routine ops to this part of the world, and enjoying the experience.