Dave Higdon writes about aviation from his base in Wichita Kansas. During three decades in... Read More
Private Jet China
In his continuing series on what pilots can expect when operating in various ATC systems throughout the globe, Dave Higdon discusses China…
For anybody who's cursed a government entity for its oversight of traveling to, from and within the US, consider what it’s like to operate in Chinese airspace.
Flying from Point A-Z within the US requires contact with an FAA facility only in limited circumstances such as transiting Bravo, Charlie or Delta airspace; filing an instrument flight plan due to weather or preference; or filing IFR to fly above Flight Level 180. Such freedom of movement doesn’t exist in China.
Certainly China does not stand alone in requiring adherence to strict regulations and procedures for crossing into, out of, and within its airspace - but compared with other nations employing similarly complex and varied rules, China arguably holds more variations than most. Hong Kong, in particular, operates with variations, a legacy of its decades of rule by the UK and China's special relationship with the former British colony.
Before delving into the many differences that exist in dealing with Chinese airspace, let us consider information that comes from a variety of sources, including China's Civil Aviation Authority (CAAC).
The visa system is not uniform throughout China. For example, China normally requires air crews to possess “C” type visas to fly Business and General Aviation aircraft into its airspace. But there are exceptions, such as operators entering the country at Shanghai Pudong International (ZSPD). There, crew may enter the country with many types of visas. Experts in China travel recommend using a ground handler and checking in advance on the visa requirements for ZSPD.
Passengers must have required visas on arrival – except at ZSPD, Shanghai Hongqiao International Airport (ZSSS) and Beijing Capital International Airport (ZBAA) provided they qualify for 144-hour visa-free entry and are flying on to a third country within the 144-hours.
Throughout the rest of the country, however, standard visa requirements and limitations are in play – including at Hong Kong (VHHH). But visas must be obtained in advance of arrival; they cannot be acquired upon arrival.
Additionally, China treats different visitors of differing nationality differently, where visa requirements are concerned. For example, some nationalities visiting ZSPD, ZSSS, and ZBAA may stay in the region of their landing airport for up to 72 hours without a visa – if they plan only one stop in China. As noted again and again, it pays to check in advance with your specific passenger manifest in hand before you firm up your plans. Requirements can and do change, and without notice.
If the flight originates or ends at an airport in Taiwan, forget about over-flying or landing in China. This restriction also applies to flights overflying Taiwan to another destination.
Permits, Permissions and Slots
As always – think ahead. The CAAC issues overflight permits, landing permits and airport slots. For most of the country Chinese authorities apply rules consistently—but not everywhere. For example, a single landing permit allows a maximum of five stops in the country, and operators need supply no documentation with permit requests. (Happily, a letter from an in-country sponsor is no longer required.)
You will need, however, to supply your complete operating schedule, a business contact, and your plans for flying into and out of the country. There’s one exception: For BusinessLiners (i.e. Airbus' ACJ or Boeing's BBJ), the CAAC wants to see a certificate of airworthiness and the aircraft's interior layout.
Travelers should be aware that CAAC keeps to a 40-hour week (open 0830-1630 local time, Monday-Friday). Outside those hours you must be flying an emergency flight or an air-medical ambulance to get a permit.
Don't plan ahead too far, however, when working on your permit application, which you can file on-line. The CAAC restricts landing-permit requests to no more than four business days before your filed arrival time.
If you request a permit five or more days early, expect the system to reject the application.
Conversely, CAAC is quicker than many other countries in processing landing permit applications, with normal approval times between 24-48 hours before your filed arrival time. CAAC may, though, approve and issue your permit earlier – it's all at their discretion.
For airports that allocate landing slots, you must adhere to your approved time – even more so for your departure. Deviation may cost you the allocated slot, which in turn means requesting another slot, a process that can eat up precious hours. That delay can create a domino effect if your destination imposes similar time constraints.
One piece of good news here: Required slots are usually issued with permits, so a separate process generally isn't needed. Typically overflight permits are easier to obtain since they don't require landing information.
Back to Hong Kong
As previously noted, China does have exceptions to its general rules. Business aircraft flying into VHHH must obtain a landing permit with lead times running at three business days. This requirement applies to both non-scheduled commercial/charter flights as well as private operators.
Landing-permit requests for VHHH are normally submitted online, a free service of CAAC. But like CAAC offices elsewhere, the Hong Kong office works a Monday- Friday, 0900-1600 schedule (closed holidays).
The CAAC does have a procedure for private, non-revenue operators to use for obtaining or revising permits outside normal business hours. Instead of the on-line application, you can submit a form to the airport briefing office, along with required documentation. They, in turn, pass on this paperwork to an Air Traffic Control (ATC) supervisor for completion and approval of the permit. A similar procedure applies to charter flights.
There are special requirements for first-time charters flying into VHHH enabling the CAAC to review additional documentation required of such operators. If there's a mistake or omission that needs correction or clarification, the process is delayed.
Experts counsel first-time charter operators to start their permit-application process two weeks ahead of the planned arrival date to allow for the possibility of problems.
Conversely, the CAAC often accepts landing-permit requests on a shorter lead time if the charter operator's information is on-file – or from private operators whose information is already on-record.
On the upside, Hong Kong landing permits are valid for a 72-hour window, plus or minus, depending on the officials on duty at the time. Any change that moves you beyond this window will require a revision to your landing permit.
All changes outside this validity window require permit revisions. The authorities also want operators to submit information to revise permits accounting for changes to crew or passengers. Conversely, there's no need to show your permit confirmations on your flight plan's ICAO (International Civil Aviation Organization) section.
Customs, Immigration & Quarantine
Upon landing at most airports, keep the aircraft door closed until permission to open comes from the Customs, Immigration and Quarantine officials (CIQ). Opening a door prior to receiving approval likely will result in a search of your aircraft – as well as a possible fine. The fines for failure to comply with this rule vary significantly depending on the airport, and they can be quite heavy at certain locations – such as Tianjin Binhai International Airport (ZBTJ).
Additionally, clearing customs and immigration varies among airports. Locations familiar with Business Aviation handle arrivals at their FBOs, while at other airports may require operators to pass through the same facilities as arrivals on international airline flights. For example, at Hangzhou Xiaoshan International Airport (ZSHC) passengers and crew clear the process in the main terminal. But at ZSSS, the CIQ processing occurs within the FBO.
At ZSPD Customs is processed via the main terminal, but passengers and crew don’t need to physically go to the terminal building. Upon international arrival, CIQ comes out to the aircraft, collects passports and inspects the aircraft. Passengers are then taken to a VIP lounge where they’ll wait for passports to be processed and returned, a procedure that takes 15-20 minutes. The clearance process at ZSNJ is similar to ZSSS, within a General Aviation terminal (GAT).
Privileges granted to crew and passengers holding various visa types vary among China's airports. It is best for operators to confirm in advance the processes in play at a particular destination. Do not assume that what worked at one airport applies to another.
Accommodations and Security
Hotels in China range from facilities catering to the indigenous population to five-star establishments aimed at China's growing wealthy class, international tourists and business visitors. Working with a trip planner or travel agency familiar with the country can help assure your stay is in line with the standards of your passengers and crew.
Be sure to check whether the hotel imposes a minimum number of days for each booking, has caps on rates and other limitations, whether a deposit of down payment is required, and how far in advance a booking must be made.
For security purposes, it pays to contract with a local agent who knows the language, local customs, and who can supply secure transportation between the aircraft and the hotel, and any meeting sites. You may also want to consider security for the aircraft.
Airspace and Flight Plans
CAAC has made further adjustments to its airspace management, announcing plans to continue its aggressive airport-expansion program. All are part of a comprehensive five-year plan to reduce or eliminate barriers to General Aviation expansion and to build the airport infrastructure the vast nation needs to bring aviation access to the far-flung corners of its five time zones.
After the Chinese State Council identified General Aviation as the nation's next big economic-growth area, the government issued a series of reforms to sweep into place the policies needed to drive the growth they seek.
Among these sweeping reforms are changes designed to continue raising the airspace ceiling below which pilots need not file a flight plan.
The change to a 3,000-meter ceiling (9,840 feet msl) for the new observation altitude should help stimulate the lower end of the General Aviation spectrum, something the nation needs to spur flight instruction and business use of smaller aircraft. Previously, the ceiling was a low 1,000 meters (3,280 feet).
China also started reformation of how it processes flight permits, with a target of getting down to two hours from several days – again, depending on location.
Further, China is acting to change the process of acquiring an air-operator certificate (AOC) as quickly as the application can be processed. Previously the process required two years of government supervision before the government would grant the applicant an AOC. The government also eliminated a requirement that an AOC applicant own two aircraft; one is now enough.
Finally, China renewed its airport-construction mandate, targeting the construction of 300 new General Aviation airports by 2020. A prior 100-airport-per-year plan resulted in only about 120 new GA airports. Success with this target would more than double the number of China's GA airports.
Air Traffic Considerations
Tension is ongoing between China and several of its neighbors arising out of China's claims on islands in the South China Sea. China's claims on those islands and control of the South China Sea were rejected by an international tribunal in mid-July, prompting an eruption by China's government over the long-running issue.
With airspace control fragmented between several nations, advance work on flight plans, permits and routes is essential. Depending on routing, the controlling airspace authority may already require the aircraft to use ADS-B as an approved position source and a Mode S transponder broadcasting on 1090 MHz with Extended Squitter (1090ES).
A trip to and through China and other parts of Southeast Asia should improve your appreciation for the ease of flying in North America. If you plan to travel into China’s airspace anytime soon, you are strongly advised to prepare ahead of time, seeking the expertise of one of the many flight planning service within the industry.
China: Permit Requirements
Full operator and aircraft information;
Full schedule, including departure point and destination;
Complete information on crew and passengers (nationality, etc.)