By Mark Baier
Staying current on regulatory updates, authorizations, and country-specific requirements can be tricky for pilots flying internationally.
Pilots need to be organized and have all flight operation elements in place well ahead of a trip. In too many cases, poor preparation could actually keep an aircraft grounded at its departure or destination due to a failed ramp inspection.
Procedures – content is crucial
Operators should have an up-to-date international operations/procedures manual to ensure they are conforming to current required procedures and industry best practices when operating across the Atlantic and in Europe.
This is the go-to reference for ramp inspectors to check for current procedures for North Atlantic High-Level Airspace (NAT HLA), RVSM, PBN (RNP/RNAV), and if the aircraft is CPDLC-equipped.
Anything out of date, missing or incomplete could keep a flight from happening. Authorizations also can’t be overstated. FAA provides some leeway for general aviation flights in the US, but the moment a flight leaves US airspace, Letters of Authorization (LoAs) become crucial. It is advisable to obtain LoAs for all operations the aircraft is capable of, even if an international flight isn’t planned soon.
One common misconception is that an LoA is no longer needed for RVSM operations. It’s true that US operators with appropriate ADS-B equipment can operate in domestic RVSM airspace without an LoA, but an authorization is still needed when flying internationally.
Since it can take weeks or even months to get LoAs, I encourage you to apply as early as possible. Using outdated materials may create delays in processing LoAs and can affect operations. Pilots should make sure that LoAs are issued with the name of the entity with operational control of the aircraft. This is critical but not always clear-cut. If in doubt, an aviation attorney should be consulted.
Flight planning – it’s all in the details
Errors often occur in the flight plan. There are a number of things pilots should pay attention to when planning a trip, such as operational capabilities, fuel compliance, and oceanic waypoints. Increased scrutiny on flight plans is becoming more common, mainly driven by SAFA inspections. Key things that might be checked are fuel compliance and properly coded equipment.
Be aware of ICAO requirements for contingency fuel (ie, 5% of your trip fuel) and be sure the fuel is labeled clearly on your fuel block. Your total fuel may be compliant, but inspectors may still consider it a finding if they can’t identify the right quantity quickly.
Crews should also be aware of equipment codes that apply in items 10 and 18 of the coded ICAO plan. For example, there are seven “J” codes associated with data link capability, and one, several, or nearly all of them could apply. Errors could cause issues with CPDLC networks and result in you being denied airspace entry. Such mistakes are then likely to be caught by a ramp inspector.
Training – keep learning, keep climbing
Updated training is another area to pay close attention to. Crews need to keep up with new procedures in their international ops manual. Many regulatory bodies consider any training older than 24 months to be obsolete. International operations are constantly changing, so regulations and procedures from a year ago have often already been replaced or updated.
For example, oceanic contingency procedures (eg, 5 nm offset) that took effect in March 2019 are anticipated to expand in November 2020. As these programs grow and procedures change, manuals need to be updated. Outdated certificates can also be a source of additional delays in LoA processing, so crews should be on top of all new rules and practices.
Organization is king
Staying current and up to date on everything may not be enough, though. Crews should make sure they have everything well organized and handy, ready to provide to inspectors and regulatory bodies. Carry a neat “SAFA” binder or similar portfolio to easily present the operational documents a ramp inspector may want to see. After all, there’s no point in spending the time and effort to get your LoAs if an inspector can’t find them.
Mark Baier is CEO of AviationManuals, a provider of digital operations manuals with update services, as well as SMS software and iPad apps for fixed-wing, rotary-wing, drone operators, and FBOs worldwide.