When traveling internationally, it is important to point out that FAR 91.703 (a) (2) states “When within a foreign country, comply with the regulations relating to the flight and maneuver of aircraft there in force”. In this newsletter, we will discuss the common requirements for Aircraft, Crew and General documentation for making international flights.
Every aircraft must have a valid Airworthiness Certificate and Registration Certificate. As simple as that sounds, many times these documents have become a major issue for some pilots making international flights. One common mistake is having an expired Registration Certificate or having a Registration Certificate that will expire during the trip. Either one of these issues will prevent you from getting any required prior permissions or worse. Another common problem is when recently purchased aircraft are operating with an AC 8050-1 form (also known as a “Pink Registration Certificate”) which has the words “OPERATIONS OUTSIDE THE UNITED STATES ARE PROHIBITED BY LAW” stenciled in capital letters across the front, need I say more? If you have not yet received your permanent Registration Certificate and need to make an international flight, you can request a fax temporary authority from the FAA commonly known as a “fly-wire”. Your Title Company should know exactly what this is and how to get it from the FAA.
Another issue we see is when aircraft owner/operators have changed aircraft tail numbers and are operating with FAA Form 8050-64 titled “ASSIGNMENT OF SPECIAL REGISTRATION NUMBERS” which authorizes the aircraft to be flown with the new tail number while the FAA sends the new Registration Certificate. Two issues arise from this form. First, foreign civil aviation authorities or drug enforcement agencies may not accept this form and believe that the aircraft is improperly or falsely registered. The second issue is that aircraft operators sometimes fail to go their Flight Standards District Office within ten days of placing the new number on the aircraft and continue to fly with the old Airworthiness Certificate that has the old tail number on it.
If you do not have a specific Letter Of Authorization (LOA) from the FAA authorizing you to conduct RVSM operations, then you cannot legally fly in international RVSM airspace. This is an issue for aircraft that have added ADS-B and are operating under Appendix G of Part 91 which authorizes them to fly within US RVSM airspace without a specific LOA for RVSM ops. You should plan your fuel calculations based on flying the trip either above, or below, RVSM airspace as appropriate.
Another issue is Required navigation Performance (RNP) operations in international airspace. If you plant to fly across the Gulf Of Mexico (GOMEX) or in the West Atlantic Route System (WATRS) or anywhere else where RNP-10 or RNP-4 routes exist, you also need a specific LOA for the appropriate RNP operations. This does not necessarily mean that you cannot fly RNP routes but due to the additional separation required for non-RNP aircraft, ATC may not authorize the route, altitude or desired departure time that you file in your flight plan. You should not select RNP capability in your PBN codes if you do not have this LOA.
Aircraft insurance becomes a major issue when flying internationally. There are four common issues that we see with aircraft insurance policies. First, some foreign regulations require that you possess a printed copy of your insurance policy aboard the aircraft. Second, be sure that your territory coverage is consistent with the geographic area in which you wish to fly to, and over. Third, most countries have specific liability insurance minimums. Some countries, like Mexico, have a flat amount independent of aircraft Maximum TakeOff Weight (MTOW) whereas other countries, like Bermuda, have extremely high liability insurance requirements based on MTOW that surprise many aircraft owner/operators. Fourth, make sure that the printed policy(s) that you bring with you have policy period dates that cover the dates you will be flying internationally.
FCC and international regulations require that US registered aircraft operating outside of the United States posses a Radio Station License. These can be obtained online from the FCC website.
One last required document that can sometimes be overlooked is the US Customs and Border Protection (CBP) User Fee decal which should be purchased prior to departing the USA. While you can technically obtain one on arrival, you will become one of the least popular pilots in the eyes of the CBP officer that receives you and that is definitely NOT a good thing.
While not a legally required document, it is always important that you bring a notarized letter from the owner, or officer of the company, that owns the aircraft. The letter should detail the tail number, make/model of the aircraft, serial number, names of crew and names of passengers. The letter should declare that the crew is authorized to fly the aircraft internationally, that the passengers are the owner(s), friends and/or family of the owner and that all flights are private with no commercial purpose.
All pilots must have a valid Airman Certificate with the appropriate Category, Class and Type Ratings for the aircraft they plan to fly. For pilots flying as a required SIC, it is important to remember that FAR 61.55 (a) (3) only allows you to fly without a Type Rating on domestic flights within the USA. For international flights, the SIC must have a Type Rating. If you plan to fly as SIC in an aircraft that is Type Certificated for single pilot operations and you do not have a Type Rating, then list yourself as a passenger and make sure that the PIC has the appropriate Type Rating for single pilot operations. If you have recently added a rating and are in possession of a Temporary Airman Certificate, it is valid for international flight. Effective March 5, 2008 pilots with powered aircraft ratings who operate internationally must have the words “English Proficient” stamped on the back of your Airman Certificate. If you do not have this, request a new Certificate from the FAA and they will automatically add it when the new card is printed.
One important issue that we have dealt with, which was unique to the Citation Jet family, was the “Single Pilot Waiver” (Exemption) issued by the FAA which allows pilots operating CE500 aircraft (500, 550, S550, 552, 560) which are Type Certificated for a minimum of 2 crew, to fly the aircraft with 1 crew. As the FAA only has jurisdiction inside the USA, the Exemption has no legal validity in foreign countries and most countries will expect to see whatever minimum crew is on the aircraft Type Certificate. The FAA used to have a limitation on these Exemptions that stated “This exemption is not valid for operations outside the United States”. Some pilots failed to heed this limitation and landed themselves in serious trouble with the civil aviation authorities in at least one foreign country. This limitation has recently been amended to read that the Exemption may be valid when the holder obtains authorization from the civil aviation authorities of the country in which they plan to operate. It is important to point out that those CE500 aircraft that have obtained Supplemental Type Certificates (STC) that change the minimum number of crew from 2 crew to 1 crew can be used for international flights with an appropriately rated single pilot. However, STCs are granted to a specific aircraft whereas Exemptions are granted by the FAA to a specific pilot.
US regulations governing Medical Certificates differ from ICAO guidelines. Civil aviation authorities in some countries struggle with the concept of “owner flown” aircraft and have difficulty accepting a PIC with a Private Pilot rating and a Third Class Medical Certificate. Another problem is their inability to grasp the concept of what “privilege” is being exercised by the pilot and the corresponding Medical Certificate class required to exercise those privileges. Throw in the fact that a FAA First Class Medical Certificate becomes a Second Class, becomes a Third Class and you have the perfect storm. Some countries require jet aircraft operators to have at least a Commercial Rating and a First Class Medical Certificate. Other countries expect the holder of any pilot rating to possess the corresponding Medical Certificate class for that rating regardless of what privileges the pilot may be exercising. Another issue has to do with the expiration date of US Medical Certificates where foreign civil aviation officials do not respect the FAA regulations stating that a medical certificate is valid until the end of the last day of 6/12/24/60 months after the date of examination. Therefore, you should get properly briefed to determine if the foreign country exercises reciprocity with the FAA Medical Certificate regulations or if they have their own regulations that they will enforce on US pilots.
In addition to a Radio Station License, FCC and international regulations require that at least one crewmember have a Restricted Radio Operator Permit (or better). These can also be obtained online from the FCC website.
Before departing or arriving in the USA, you must file an eAPIS electronic manifest with CBP. A number of foreign countries in Latin America and the Caribbean have also implemented their own APIS systems and regulations. Be sure that you are aware of the requirements and how to comply.
For any international travel, everyone on board the aircraft should have a valid passport and many countries require that the expiration date of the passport be at least 6 months beyond the date of entry into their country. If there are any minors on board the aircraft who are not accompanied by both parents, then the non-traveling parent should submit to the traveling parent or guardian a notarized letter authorizing the travel of the minor outside the USA. While US citizens can travel without VISAs to most countries, there are some countries that require you to obtain VISAs or register on their immigration portals prior to arrival. It is important that you review your Medical insurance policy to understand what type of medical assistance will be covered when traveling internationally.
If you plan to take any items of considerable value like professional photographic/video equipment, expensive jewelry or any other item that could be dutiable, then you should present CBP form 4457 to a CBP officer before leaving the USA. Also note that foreign countries have varying regulations covering the type and value of items which may be brought into their country duty free and that tobacco and alcoholic beverages can be subject to strict restrictions.
If you travel to countries that are considered “at risk” by the World Health Organization (WHO) for Yellow Fever, then many subsequent countries that you visit will require all persons on board the aircraft to present an original Yellow Fever Vaccination Certificate demonstrating proper immunization. Failing to have the vaccination can expose you to health risk and also get you barred from entry into another country.
Lastly, if you absolutely, positively, have to bring along the family pet, then you must determine the regulatory requirements for each country you plan to travel to. Regulations can range from the logical and straightforward to the impossible. Avoid having your pet stuck in quarantine (or worse).
- As seen on Citation Jet Pilots (2019)