Equipment mandates and other considerations when flying to and within the European Union.
By Grant McLaren
The European operating environment for general aviation (GA) can be very different from that of North America, but, with adequate trip planning, it’s certainly a manageable proposition.
So long as crew and equipment meet appropriate certifications and qualifications to deal with the North Atlantic Organized Track System (NAT-OTS), operators should be well prepared to fly within the European regulatory arena.
“Europe remains a fairly easy and straightforward operating environment for business aviation, particularly when flying private, and it has not become much more difficult recently from a regulatory perspective,” says Jeppesen Vendor Relations Mgr Mark O’Carroll.
“The situation, however, can become more complex in the case of charter operators, as prior accreditation and landing permits are routinely needed.” International support providers (ISPs) note that night closures and curfews can be a limitation at many European airports.
In addition, overnight or long-term parking is not guaranteed at many major airports and at popular Mediterranean locales during high season. COVID-19 has been affecting GA ops to the European Union (EU). Because of this pandemic, certain airports remain closed even to movements of European-registered aircraft, and health-related restrictions change from day to day.
ATC and airport services strikes and labor action, particularly in France, also continue to adversely influence European movements from time to time. Avfuel Account Exec David Kang points out that the EU operating environment has become more welcoming, manageable, and efficient over recent years for well-prepared operators.
“In some ways, ops to Europe have become easier in terms of more GA facilities, services, and airports that are more focused today on business aviation needs,” he says. “But the regulatory environment has become stricter in terms of enforcing regulations, particularly as they try to squash charter operators pretending to be private.
Authorities often take a closer look at paperwork from operators who routinely make multiple stops in the EU. Safety assessment of foreign aircraft (SAFA) checks have also ramped up across the EU.”
In order to maximize airspace utilization, new mandates for controller–pilot datalink communications (CPDLC) and Automatic Dependent Surveillance–Contract (ADS-C) have been put in place for the NAT-OTS over the past year.
More datalink requirements are being considered within the EU, together with RNAV 1 approaches and additional coordinated slots at certain airports. “Incremental improvements have made the European operating environment better and more efficient in many ways,” points out UAS Ops Mgr Duke LeDuc.
“Keep in mind that the EU can be a less flexible operating environment than its Stateside counterpart. You’ll be dealing with both airway and airport slots, prior permission required (PPR) at certain locations, flow control, and scheduled airways.
At some locations, you may really need to adhere to schedule and/or be prepared to deal with last-minute changes.” At larger airports in Europe, you may be at the mercy of local airport authorities if you miss a confirmed slot time. Should you cancel a slot and file for 1 hour earlier, you’ll be placed in the back of the line.
Slots and overnight parking
Overnight GA parking may not be available at many Mediterranean destinations during peak season. Absent extreme circumstances, NAP (Naples, Italy) rarely allows overnight parking, and FLO (Florence, Italy) often requires repositioning.
Airports on the Croatian coast are busy during summer, while both BCN (Barcelona, Spain) and LIS (Lisbon, Portugal) are highly congested during the season. “If you’re operating to JTR (Santorini, Greece), CFU (Corfu, Greece), or IBZ (Ibiza, Spain) during summer, you’ll be able to drop and go, but there’s no overnight parking,” adds LeDuc.
Access and parking may be challenging even at larger airports. NCE ((Nice – Côte d’Azur, France), for example, is always congested from May through September. “Airports in Paris and Rome usually seem to have overnight parking availability, but FRA (Frankfurt, Germany) can be tough in terms of slots and parking,” says Kang.
“EDI (Edinburgh, Scotland) runs out of overnight parking, so you may need to reposition to PIK (Prestwick, Scotland). ATH (Athens, Greece) is also getting increasingly busy. Until the beginning of last summer, ATH was only guaranteeing parking 24 hours out, but this has now eased somewhat.”
In southeast England, parking at popular LTN (Luton) and STN (Stansted, London) has become more challenging and cannot always be guaranteed. There will be no available airport slots or parking at LTN at times, and this location tends to run out of night slots during summer months.
At STN, on the other hand, access may be fine during the day, but there may be only 10 night slots available, and parking can be difficult. While the London area has become more congested, there are so many airport options that parking is still possible.
“You may not be able to get the airport slots or parking you want at LTN, and night slots/parking may be difficult to obtain at STN,” says Jeppesen Vendor Relations Mgr Ian Humphrey. “Some operators opt to land as far away as SEN (Southend) – a 60–75 min drive into central London – to ensure overnight parking of aircraft as big as ACJs or BBJs.”
Noise, airways, coordinated slots, and strikes
When operating within the EU, be aware of noise restrictions and limited airport hours. As a general rule, many European airports are open about 18 hours a day (rather than 24 hours as in North America), so plan accordingly.
Some smaller airports offer overtime, but this depends on local noise abatement policies. Kang recalls a recent case of a Gulfstream G650 client receiving a noise bust ticket out of LTN. “This particular fine was for about £1500, so noise busts can be significant.
Note that noise abatement rules tend to change year to year, particularly during summer months. You cannot always rely on what the situation was last year, or even what’s posted in the AIP.” ISPs point out that more direct routing options within the EU are possible these days, particularly when flying FIR to FIR at either side of a country.
However, it’s not always straightforward to determine this from airway charts, so it’s best to seek guidance from Eurocontrol’s trip validator options. Airport collaborative decision making (A-CDM) slots exist at a number of European airports.
This involves strict procedures on when to start up, when to call in for push, and clearance. “As many foreign operators are not familiar with coordinated slot procedures, this can throw you off a little as you’ll need to make requests in a specific order and time frame,” explains Kang.
“While this is not that difficult, it’s an awareness issue.” New datalink mandates are beginning to affect GA ops within the EU for aircraft over 100,000 lb MTOW.
Also, RNP requirements pop up here and there. “NCE has implemented RNP-1 procedures on certain approaches,” says Jeppesen Trip Support Specialist Paul Dowling. “Although these requirements are not yet fully mandated for foreign-registered operators, we envision such requirements expanding across Europe.” Note that ATC and airport strikes happen across Europe from time to time.
“We’re seeing more and more strikes across the region,” says LeDuc. “While strikes can happen quickly, we usually have some sort of advance notification, and operators are usually able to route around affected areas.”
Charter operators have faced more challenges in the EU in recent years. These activities need third country operator (TCO) certification, and it’s important that operators ensure that every aircraft in their fleet is properly registered with the European Aviation Safety Agency (EASA).
The process of obtaining a TCO can take more than 30 days. “Operating conditions have become more stringent for charter, and the EU is now adhering more strictly to ICAO recommendations,” says ITPS Ops Mgr Ben Fuller. “We recently had a charter operator with a TCO that added a new aircraft to its fleet.
The operator had to postpone a charter flight until the new aircraft was registered on the TCO. No charter permit was issued until this was accomplished.” ISPs suggest that passengers on private flights carry evidence of their connection to the company or aircraft owner.
“Even just carrying some sort of company ID can help you get around a lot of potential cabotage problems, and it shows a level of diligence,” notes Kang. As of Dec 2019, higher levels of insurance have been mandated for charter operators within Europe.
“Many operators had not been notified of this, so they’ve been scrambling in order to ensure these new requirements are met,” adds LeDuc. Be mindful that the UK requires collection of air passenger duty (APD), a kind of departure tax for all passengers leaving the UK that poses a significant cost.
“Rates keep going up,” notes Fuller. “For a long-haul GA flight in aircraft over 20 metric tons, the tax/duty is now about £515 per passenger. Rates tend to increase each April.”
Activity at smaller airports
When operating to secondary and smaller airports in the EU, be prepared for service limitations. Not all smaller locations offer lav and water services, and catering may need to be sourced from local hotels. Also, airport hours are often limited, fuel services may be less than reliable, and credit could be an issue.
“You may want to use a regional handling service from a nearby larger airport to assist you with credit, handling, parking, and language barriers,“ says Kang. “In Europe, pilots do not enjoy the elevated status they have in the US. For example, they may not be given much attention, or they might just be told to wait.”
In addition, operators can run into unique restrictions at chain FBOs at larger airports in Europe. A case in point is LTN, where operators may be restricted as to which fuel trucks are permitted on the ramp, and they may not have the ability to self-cater via outside providers.
SAFA ramp checks take place across Europe with increasing frequency, say ISPs. “Carry a SAFA checklist and make sure your equipment and certifications are up to date,” recommends ITPS Sr Ops Specialist Curt Kurshildgen. “A ramp check can take 30–60 min if everything is in order, or 1–2 hours if inspectors think things may not be in order.”
LeDuc suggests crews have an electronic binder with all required documents in the same order as on the SAFA checklist, while also having hard copy docs available.
“Make it as easy as possible for the inspectors,” he adds. “Don’t let them sense that you’re incompetent or disorganized in any way.” Kang notes that SAFA inspectors usually arrive a couple of hours prior to departure, and do not spring a check on you 30 min prior with passengers already on board.
“Page 1 of the SAFA check includes basic documents, and involves a walk-around looking for aircraft damage, leaking fluids, etc. If they catch you, it will usually be on the major stuff right out of the gate. Then they’ll start digging deeper, and they may review your maintenance logs.”
Be mindful of the possibility of reduced schedule flexibility when operating to and within Europe. “Larger international airports in the EU may occasionally be difficult in terms of maximizing operating flexibility and your ability for schedule revisions,” cautions Dowling.
For 1st-time operators to Europe, ISPs recommend some degree of international ops training, as well as flying with a flightcrew member who has some experience in the European country you’re visiting. “You want at least 1 pilot on board who’s been to this region before and is familiar with NAT-OTS procedures,” observes Kang.
“For 2 rookie pilots heading to the EU, using self handling and just kind of winging it, everything will be a surprise and it could turn into a bad day. Dealing with a different set of regs can be hard enough, but wait till you’re on the ground – your nightmare may just have begun.
Ground crew may not respond to you in the way you expect, and there may be challenges in dealing with customs/immigration, filing paperwork, and arranging prompt refueling. Consider using an ISP to assist with regulatory awareness and to smooth out the process.”