International Operations

 - April 30, 2010, 10:48 AM

Flying  a business air plane outside the U.S. isn’t all work. It’s also an adventure that offers U.S. pilots a chance to see how the other half–or actually the other 90 percent of the world–lives. Let’s be serious: Americans are spoiled by our own version of the aviation industry, such as when it comes to working the ATC system. A last-minute trip appears in Atlanta and we file a quick flight plan from our iPhones. Fifteen minutes later we’re on our way. In Europe, though, things don’t work quite so quickly. Slots are required for practically any kind of flight, except VFR. Want a quick primer on IFR flying in Europe? Think of the hassles associated with flying in and out of La Guardia on a bad day and you might be close.

A three-hour flight within the U.S. could take a business airplane from Los Angeles to Chicago. That same distance in Europe or South Asia could translate into the crossing of three or four different countries, each with many of its own local requirements. To the rescue of even the most well intentioned of crews comes ICAO, the International Civil Aviation Organization (, an arm of the United Nations. ICAO’s pragmatic mission is a simple one: ensure that the rules for international aviation are as standard as possible to prevent confusion, delays and accidents.

Operations outside the U.S. also bring a host of other concerns unknown to domestic crews, with SAFA checks (European ramp checks), overflight permits, landing permits, international garbage issues, RNP navigation, mode-S transponder requirements, ADS-B and C, safety management systems and carbon emissions trading, to mention just a few.

The range of educational topics necessary to complete a flight safely and effectively outside the U.S. is so vast in fact that a number of companies–such as Air Training International and Scott International Procedures–have developed a business model focused solely on international operations training. FlightSafety International also provides international operations training as part of its wide range of other aviation subjects. Interestingly, the FAA does not mandate international procedures training, requiring only that aircraft operators be familiar with the topics necessary to safely plan and execute a flight, which often leaves open many more traps for the inexperienced international pilot.

For those operators considering going it alone the first time they take the boss and the crew across the pond to Europe or out across the Pacific, NBAA suggests a visit to the International Operators Conference (IOC), where for three-and-a-half days, flight crews can absorb some of the major operational topics of the day. The NBAA conference does not bill itself as an alternative to a good international procedures class, but merely as an opportunity to listen in on a few dozen experts offering their opinions and expertise on topics the NBAA’s IOC committee believes are the ones flight crews need to focus on during any given year.

Nearly 500 people were signed up for the first day of this year’s IOC, an increase of about 15 percent over 2009’s event. The word in the halls was that the hours put on business airplanes for trips outside the continental U.S. is on the upswing. A number of crews told AIN they were now flying more international hours than before the recession began, with Asia becoming a regular destination region for many.

This year’s IOC topics included legal issues facing flight crews around the globe; Nav Canada and North Atlantic airspace updates; carbon emissions trading and safety management systems (SMS). In addition, international medical concerns; operations in Russia and China; international altimetry; flying in Africa; Pansops; a customs and immigration review; weather tools for international flying and a review of procedures to operate in Europe and the Middle East were also the subject of discussion.

Foreign Corrupt Practices Act (FCPA)– This law requires operators to know the handlers with whom they are working. Remember that handler everyone calls for a last-minute permit or a visa? It costs a little more to use that company, doesn’t it? Did you ever ask how that agent manages to accomplish feats of bureaucratic daring and bravery or do you simply prefer not to know? The FCPA makes it clear now is the time to begin asking questions.

If that handler is somehow putting cash directly into the hands of a government official in a foreign country, ostensibly on your behalf–whether you’re aware of it or not–your company could be held liable for bribery. A number of countries across the globe have stepped up their efforts to combat bribery, resulting in a substantial increase in the number of new cases being brought to trial, and with a focus on prosecuting any and all individuals involved. Siemens, for example, was fined $450 million in an FCPA case in December 2008.

The question most international crews ask is when is handing cash to someone
in a foreign country a tip and when does that same stack of greenbacks become a bribe? The answer is not always clear. What is clear, however, is that through arms of the World Bank, the WTO and the International Monetary Fund, efforts to curb corruption can be found on almost every continent.

The FCPA applies only to bribery of government officials, whether it’s something a crew attempts on its own or it’s a trick up some handler’s sleeve. The FCPA has two distinct provisions for flight crews to consider when outside the U.S. First, the anti-bribery provision makes it illegal to make payments with a corrupt motive directly or indirectly to foreign officials or foreign political parties, or any other person acting as a conduit for payments to foreign officials for the purpose of influencing the official to in any way assist in obtaining or retaining business.

The second, the books and records provision, requires companies that file reports with the SEC to maintain records that accurately reflect transactions and the nature and quantity of corporate assets and liabilities. Some key ideas to consider include the fact that there is no materiality threshold, that actions of an agent acting on behalf of a company are attributed to the company itself and that should even the appearance of potential corruption appear in the foreign subsidiary of a U.S.-based company, the American company will be held liable.

U.S. flight crews should ask questions about how the money they pay in foreign countries is being used and document the precise reason any money was paid out to handlers abroad.

ADS-B–Anyone who has attended the IOCs over the past decade has at one time or another probably heard Air Training International president Dave Stohr tell the audience about the coming tidal wave of technology that will be required to cross the North Atlantic and to use much of the Upper Canadian airspace as well. To quote Stohr, “If you don’t have the right toys, you won’t be able to play in the sandbox.” Year after year, the warning has been the same: those not owning the proper toys will find themselves excluded from an ever-growing chunk of airspace.

A few years ago, non-participating RVSM aircraft began running up against exclusionary airspace in parts of the globe at altitudes above FL280. Now most of the world demands RVSM. Last year, an exclusionary sign went up over the first chunk of Canadian airspace in the Hudson Bay region adjacent to some portions of the transatlantic routes used by both the airlines and business aviation. ADS-B-equipped aircraft can expect priority routing between Europe and North America when flying between FL290 and FL410. Nav Canada says non-equipped aircraft  should plan to carry extra fuel to deal with the reroutes necessary to avoid the airspace. ADS-B is the heart of NextGen, and it’s coming to airspace near you soon.

Flying the North Atlantic–For decades, operators have viewed the North Atlantic from either of two perspectives. They flew in areas where there was positive radar coverage or they were flying in a totally non-radar environment. Non-radar standards, primarily based upon time and aircraft speed, require enormous chunks of airspace to ensure adequate protected airspace to all who fly there. The goal of employing evolving technologies such as ADS-B is to reduce separation both laterally and horizontally and increase the number of aircraft able to use the North Atlantic tracks each day. Vertical separation was already reduced from 2,000 feet to 1,000 feet with the initiation of RVSM. Aircraft crossing the Atlantic are currently separated by two degrees of latitude, which normally translates into 120 nm wingtip to wingtip and 10 minutes from nose to tail.

North Atlantic airspace regulators and operators are moving away from defining airspace in radar/non-radar terms in favor of the more precise surveillance or non-surveillance monikers, both related to the upcoming requirements for ADS-B and ADS-C technologies for over-water operations, according to Stohr.

The goal of all airspace innovation remains essentially the same, making certain that all operations can achieve and maintain at least a 95 percent standard of safety at all times. Stohr offered an example to illustrate the current system’s vulnerabilities should pilots not understand their responsibilities. “On an ISA day with a clearance that requires an airspeed of Mach .80, a difference of simply Mach .01 on a four-hour flight could result in a three-minute difference between when ATC expects an aircraft across a point and when it actually appears.” With 1,200 North Atlantic crossings per day, separation standards can easily be violated if more than one aircraft is off speed.

As traffic increases, separation standards are expected to be reduced to one degree laterally, which puts aircraft about 60 nm wingtip-to-wingtip. At first glance that seems like an enormous amount of airspace. But pilot errors in North Atlantic airspace continue to occur at an alarming rate. Last year alone there were more than 210 gross navigational errors (GNE). A GNE is defined as flying off-course laterally more than 25 nm, vertically more than 300 feet and longitudinally more than three minutes off the assigned fix crossing time.

Last year, even with only a small percentage of mistakes attributed to general aviation aircraft, the most common link was pilot transcription error, or crews flying the flight plan they filed, rather than the clearance they were given by ATC before they began the crossing.

The question, of course, is why? Stohr believes the two biggest reasons for these mistakes are a general lack of oceanic procedures knowledge and the failure of crews to follow their own standard operating procedures.

By comparison, this kind of mistake almost never occurs in domestic airspace, Stohr added. Forty of the recent GNEs involved aircraft that were 25 nm off course, a number that is still quite unthinkable here in the states. Interestingly too, 80 percent of total GNEs occur after a reroute. Imagine 80 percent of pilots misinterpreting their instructions after a reroute here in the states.

Stohr added a few thoughts on emergency contingency plans over the water, reminding pilots that just as in domestic airspace, there can be traffic everywhere, despite the fact that non-radar separations seem to be large. All contingencies begin by attempting to contact ATC as early as possible into the emergency. “If an aircraft is unable to maintain altitude, the PIC should turn the aircraft no more than 45 degrees off the current heading and be as diligent as possible to slow the rate of descent until the aircraft is clear of the track,” Stohr said. “The goal is to set up a 15-degree offset before continuing the descent. If the need to divert across the tracks should occur, use the same 45-degree turn while setting up the same 15-degree offset. Since the tracks have vertical limits of FL290 to FL410, the crew should attempt to climb above 410 or back down below 290.” Stohr adds that contingencies also mean broadcasting intentions on 121.5, which most operators monitor across the ocean, as well as turning on all available aircraft lighting. Keeping a close eye on TCAS is also extremely important.

Safety Management Systems (SMS)– One year ago only a few people asked questions about safety management systems. The formal deadline of Nov. 18, 2010, to comply with ICAO’s Annex 6, Part II seemed a long way down the road. Now, the U.S. deadline for non-commercial operators flying jets or aircraft weighing more than 12,500 pounds to possess a fully functioning safety management system to fly outside the U.S. is but a few months away.

A number of factors are driving the upcoming SMS requirement. ICAO believes most member states field too few inspectors to adequately keep an eye on all aviation activities and that the operators themselves must take a larger role in the process. Another is recognition of the fundamental movement within the aviation industry to promote SMS as a mechanism for aviation safety improvement. Another is to bring U.S. operators into compliance with the ICAO requirement that actually has most foreign countries significantly in the lead on the SMS front. The FAA has not yet mandated an SMS for operations in the states and sources inside believe an agency decision on it is pretty far down the road. Another reason for SMS is the belief that aircraft accidents can be reduced if all companies subscribe to an international standard that requires individually tailored policies and procedures about how to operate aircraft and best use flight and cabin crews and maintenance personnel.

Right now, the safety atmosphere in much of Europe is focused on identifying potential accidents early enough to prevent fatalities. In the U.S., the FAA’s stance has been aimed at punitive reactions, despite recent rhetoric to the contrary. We still live in a blame culture for our industry when in reality we need to identify where the system broke down to prevent future incidents and accidents. Experts believe SMS is the answer.

An SMS is focused on the organization and not the individual during a failure because the punitive direction simply encourages people to hide problems. Don Spruston, director general of the International Business Aviation Council, said, “SMS is seen as a way to get everyone systematically involved in safety, from the top of the organization right down to the field worker level. It is, in effect, a way to make performance-based rule provisions work.”

Don Baldwin, a retired aviation director for Coca-Cola, is president of Baldwin Aviation, one of 46 organizations listed on the IBAC Web site as ready and able to help a flight department cope with the complexities of developing an SMS.
“An SMS has four components,” Baldwin said. “Those include a corporate policy from the CEO that supports the concept of an SMS. The second component is hazard identification of the risks associated with operating the aircraft. Third is tracking data to mitigate risk and finally safety promotion, or the sharing of safety data within an organization. An SMS is about looking for problems before they happen, not simply dealing with the results after they do.”

Baldwin says an SMS can be developed in house, but that it can be complex, even if the company already possesses an operations manual. He said there are many flight departments still operating complex aircraft without any sort of operations manual because so many managers still believe passing along the day-to-day knowledge verbally is just fine. Baldwin believes that adding more pilots makes effectively passing along that knowledge quite difficult and does not easily lend itself to mitigating the actual risks of operating the aircraft. He also says a good SMS includes a risk-mitigation checklist that not only delivers answers to the real-time operational questions–is that runway long enough or has the crew had enough rest to complete the trip safely–but will also automatically gather information that analyzes the trip for safety hazards.

The Baldwin Aviation product also allows a flight department subscriber to gauge where the operation ranks among other similar corporate operators, but without allowing access to specific data by the outside world. Baldwin believes that if a flight department is organizing an SMS in house, it should plan on at least a year to make it all come together. In contrast, “We’re typically getting flight departments up and running in as little as four months.”

Putting a Price on Carbon–Ready or not, carbon trading is coming to a country you’re bound to visit soon. Although the European version of carbon trading does not become mandatory until 2012, most operators that have regularly traveled to the area have already been in touch with some EU entity to begin the preparation work. While Europe, including Switzerland, is really the vanguard of the carbon emissions trading program, other countries are not far behind.

To some, the carbon-emissions trading program appears to be no more than a smoke-and-mirrors method of raising money for local government. The stated goal is to reduce carbon emissions from all polluting entities. Aircraft are included here despite the relatively small slice of the polluting pie we produce, currently about 2 percent of all emissions, with business aviation accounting for a tiny portion of that 2 percent.

The reason for a trading scheme rather than a pollution tax seems clear, at least to the Europeans. The EU believes that simply taxing carbon emissions won’t cut the total volume anywhere close to the target range, although it would keep the price consistent. That defeats the purpose of the entire system, which is to control total emissions while allowing the price of each traded unit to be determined by the marketplace, an angle much deplored by most of the aviation industry.

The pre-compliance stage of the EU’s carbon trading scheme (ETS) has already begun. Each U.S.-registered aircraft that has traveled to the EU since early 2006 should already have been assigned an EU country that will act essentially as its sponsor and guidance counselor through implementation.

Once the operator has registered with the sponsor country, it will be asked to produce a plan for approval that details how it will track the carbon emissions of each aircraft the operator intends to fly in EU airspace. Initially, there will be a period of tracking and reporting to verify a baseline limit on carbon for each operator. Once reports are verified, trading begins–in 2013–followed by regular reports with the trading certificates included. Each company that signs up now will be offered some limited number of trading credits to begin. Companies flying old smokers had better be prepared to open their pocketbooks to purchase more credits regularly or, of course, dump that old airplane and purchase a newer one that pollutes considerably less.

Those operators thinking of simply ignoring the entire ETS program might want to reconsider. Compliance on an average year in EU airspace might run about $37,000 for a Citation X and about $58,000 for a Global Express. Penalties on these same aircraft for regular violations could top $122,000 for the Citation and $270,000 for the Global.

Flying in Russia–Flying in this portion of the now defunct Soviet Union is challenging. Russian airspace is one of the few places on Earth where RVSM is not a part of the ATC system. You’ll enter Russia in only a few specific points along airways and immediately face the need to convert all U.S. measurements, such as altitudes, from feet to meters.

Before entering Russian airspace, all pilots must clearly understand which units they’ll be working with. Will they make the alterations in the cockpit that allow the instruments to display some of the new units directly or stick with U.S.

measurements and employ the services of any number of conversion charts? Russia is also not a WGS-84-compliant country. During winter ops when the surface temperature is less than 0 degrees C, plan to use the altitude correction numbers on decision heights.

Be prepared in Russia for the use of that new word–heights–rather than altitude, not to mention QFE as a chosen method of operating all aircraft altimetry. In Russia, the transition altitude is FL1500 meters (about 5,000 feet). Expect the aircraft altimeter to read zero once you’re on the ground. Finally, a reminder that the use of Vnav in Russia is prohibited.

While the IOC does not actually count as training, it allows crews to listen to people from all regions of the world share their knowledge. The other reason to attend the IOC is for the opportunity to network with hundreds of other pilots from around the world to hear their individual experiences. Next year the IOC returns to San Diego.   
To find answers to 20 common questions about international operations, visit www.