Updated Feb. 4, 2021
On Jan. 30, 2020, the World Health Organization (WHO) declared that the outbreak of Coronavirus Disease 2019 (COVID-19) constitutes a Public Health Emergency of International Concern (PHEIC), and, on March 11, 2020, WHO characterized the outbreak of COVID-19 as a pandemic.
The evolving situation around the globe also highlights the importance of proper guidance and resources to assist in planning domestic and international operations in the months ahead. The information below reflects guidance from US government agencies for operating restrictions and precautionary procedures that should be observed for travel to, from, or within each region of the world.
- U.S. Arrival Restrictions
- FAA ATC Facilities Affected by COVID-19
- State Directives
- FAA Guidance for Airport Sponsors and Local Authorities
- Travel Restrictions to Europe
- Global Travel Restrictions
- FAA Training Exemptions
- FAA and CDC Passenger an and cdd Crew Precautions
- Be Prepared
- Precautions at the Destination
- Hotel Arrangements and Rendezvous Points
U.S. Arrival Restrictions
The Centers for Disease Control and Prevention (CDC) has published an order requiring pre-departure COVID-19 testing for all passengers arriving to the U.S. from international locations. Passengers must be tested no more than three days prior to their departure and must provide proof of the negative result or documentation of having recovered from COVID-19 to the aircraft operator.
Crew members are exempt from this requirement when acting in an official capacity or deadheading. Operators may print and provide crews a letter to use as proof of their exemption when deadheading on other air carriers.
FAA ATC Facilities Affected by COVID-19
Review the latest information about FAA Air Traffic Control facilities affected by COVID-19. This map will be updated every evening by 7 p.m. EDT and throughout the day, based on the nature of developments. The information presented is preliminary and subject to change.
U.S. State Governors have implemented a variety of measures in response to COVID-19 infections in their states. These state-based restrictions change frequently and usually do not appear in FAA NOTAMS, so operators should review each state’s published guidance for the latest information.
If travel is to a state that does not have a stay-at-home order in place, operators should be able to proceed based upon their own operations risk analysis.
FAA Guidance for Airport Sponsors and Local Authorities
In response to efforts of local authorities to limit access to airports during the COVID-19 crisis, the FAA issued the following guidance to airport sponsors. “The FAA’s primary concern is that federally obligated airports remain safe and open to the traveling public and aircraft. Particularly during this public health emergency, airports play an essential role. The FAA continues to expect all airports to operate safely and to stay open.”
Aircraft operators should be aware that in most cases local authorities do not have jurisdiction to close or restrict aeronautical activity at federally obligated airports without direct approval from the FAA. As expressed in the guidance, the FAA is approaching these requests on a case-by-case basis.
NBAA has long worked to maintain access to airports and airspace for general aviation, a vital lifeline in times of crisis, and to prevent a patchwork of local policies as some elected officials take hasty actions that exceed their authority.
Travel Restrictions to Europe
On March 16, 2020, the European Commission recommended the EU member states apply a temporary restriction of non-essential travel from third countries into the Schengen area for 30 days. Travel by U.S. citizens to Europe would largely be prohibited during this restriction.
The temporary travel restriction would exempt nationals of all EU member states and Schengen region for the purposes of returning to their homes. This exemption would also apply to:
- all EU citizens and citizens of the Schengen Associated States, and their family members
- third-country nationals who are long-term residents under the Long-term Residence Directive and persons deriving their right to reside from other EU Directives or national law or who hold national long-term visas
Global Travel Restrictions
Operators seeking the latest updates for flying to a particular foreign destination can find the most recent information from the U.S. Department of State. Each embassy is providing continuous updates on restrictions, practices, and travel bans.
FAA Training Exemptions
The FAA has issued and extended exemptions for some Part 135 training and currency requirements.
FAA Exemption 18509B (PDF) – This exemption allows crew members to use alternative methods to conduct recurrent or upgrade training, testing or checking of emergency procedures or drills that requires the crew member to don or use emergency equipment that must be placed on or over the head,
FAA Exemption 18510D (PDF) – This exemption allows up to a total of three grace months to complete training required by 14 CFR §§ 135.293(a) and (b) 135.295, 135.297(a) and (b), 135.299(a), 135.337(f), 135.338(f), 135.339(a)(2), 135.340(a)(2), 135.343, and 135.505(a).
FAA Exemption 18685 (PDF) – This exemption extends the timeframe for a check airman to conduct a proficiency or competency check under the observation of an FAA inspector or an aircrew designated examiner from 24 to 36 months, subject to certain risk mitigations.
In addition, the FAA has provided relief from certain proficiency and medical requirements for pilots and other FAA certificate holders due to ongoing challenges related to COVID-19. As a result of NBAA’s efforts, the FAA issued Special Federal Aviation Regulation (SFAR) 118 on April 29, 2020, that contains relief for a significant portion of the general aviation community. Learn more about SFAR 118.
FAA and CDC Passenger and Crew Precautions
Passengers on all forms of public transportation into, within or outside of the U.S., including charter operations and at transportation hubs including FBOs, must wear face masks, according to a Jan. 29, 2021, order from the DC. Private conveyances for personal, non-commercial use are exempt from the rule, meaning passengers of private Part 91 operations are not required to comply.
Anyone on layover should stay in their hotel rooms to the extent possible, limit their activities in public, and practice social distancing. Social distancing means avoiding crowded places, not going to mass gatherings and generally staying about 6 feet from others, when possible.
Traveling individuals should also pay attention to their health at all times and remain in communication with their employer’s occupational health program. If anyone develops a fever, cough, or difficulty breathing, they should immediately self-isolate and be excluded from work on flights until cleared by public health authorities.
Crew members with high-risk exposures to COVID-19 may also need to be excluded from work until no longer at risk for becoming infectious. A person is considered high-risk if exposed to a sick household member or intimate partner, or providing care in a household to a person with a confirmed case of COVID-19.
Proper planning begins with conducting a risk profile of your intended destination, including any current issues at the location, such as labor strikes, political unrest, pandemics or extreme weather. If the risk profile indicates that it is safe to travel to the locale but that there is the potential for danger, establish plans for performing an extraction or diversion.
“Use all of the tools available to you, including third-party service providers, NBAA Air Mail groups and onsite handlers to get local information,” recommends Kellie Rittenhouse, director of aviation at Hangar Management. “Continue to evaluate the conditions before and during the trip.”
Also, different scenarios call for different preparations and risk management. An emergency departure due to civil unrest or a political coup will require different plans than an emergency departure from a developing nation due to a medical concern of a crew member or passenger.
One aspect of a good extraction or diversion plan is defining what works for your particular organization. Don’t just look at runway length and fueling capabilities, but consider what the best option is for your passengers and crew. Are medical facilities available and sufficient, if needed? Will passengers need visas and, if so, can they be obtained on site without advance notice?
“Define ‘suitable’ for your organization and know your passenger mix, as some nationalities might influence your diversion or extraction destination choices, particularly during regional conflicts,” said Rittenhouse.
Regardless of what unique requirements your operation may have, experts advise that all travelers should notify the U.S. embassy in the destination country of their travel plans. This includes identifying where you are staying locally and how the embassy can contact you while in state. Using the Smart Traveler Enrollment Program (STEP) program to convey this information enables the local U.S. embassy or consulate to contact registered U.S. citizens and nationals in the event of an emergency and offer assistance in certain circumstances.
In extreme scenarios, consider sending an additional qualified pilot along on a trip. Pilot illness or injury puts all passengers and crew members at risk and potentially makes the aircraft a useless asset.
Also, it can be difficult to obtain departure permits in very fluid political situations or in scenarios involving civil unrest or labor strikes. In high-risk areas or scenarios, consider getting departure permits for each day you’ll be on location to give yourself departure flexibility.
Even if disruptive events or conditions are not anticipated at your destination, they might occur in an area you plan to fly over. Therefore, all international trip planning should consider appropriate diversion points along the way to account for conflicts, severe weather or a medical emergency.
Precautions at the Destination
Once at your destination, experts recommend you take a number of steps to facilitate a potential emergency departure.
First, although the appeal of a cozy hotel bed or nice meal is strong after an international flight, pilots should order and wait to receive fuel upon landing. Make sure you have enough fuel – Rittenhouse calls it “go somewhere gas” – to fly away to a safe place. This is a good policy in almost any location – international or domestic – as any number of scenarios can hamper or prevent fueling when you need to depart immediately.
In some overseas travel scenarios – for example, when passengers are nationals of the destination country and want to be dropped off there in spite of conflict, or if passengers are part of an incident or emergency response effort – it makes sense to relocate the aircraft and crew to a nearby but safer location.
Second, during international trips, communication between the flight crew and passengers is key. Experts recommend conducting a briefing upon arrival that involves the flight crew, passengers and security personnel (if on the trip).
Upon leaving the airport, use secure, vetted ground transportation to travel to your hotel or meeting place, especially in the developing world. If there are indications of impending danger, make sure the ground transportation stays nearby so you can evacuate quickly, if needed. If you can’t get back to the airport during an urgent situation, the aircraft is of no value.
“The crew is just as important as the passengers,” noted Phil Linebaugh, chief operations officer at International Trip Planning Services LLC. “If you use secure transportation for passengers, use it for crew members, too.”
Hotel Arrangements and Rendezvous Points
It’s common for passengers and crew to stay in separate hotels, but in potentially dangerous or volatile situations, it can be beneficial for passengers and crew to stay in the same hotel. In certain scenarios, it might be preferable for the flight crew to stay in the hotel during the entire trip, rather than going out on the town, say some experts. In all situations, the flight crew should establish a rendezvous location with the passengers.
“Don’t use a rally point where 1,000 hotel guests are assembling, even for a hotel fire or other evacuation,” said Mark McIntyre, director of flight operations for Mente LLC. “Establish your own location to be sure the crew and passengers are easily accounted for.”
McIntyre also recommends establishing during the arrival briefing a code word to indicate that crew or passengers are under duress. Such a word should be one that can be comfortably inserted into conversations between passengers and crew members to indicate a problem without being easily detected by nefarious parties.
In cases of civil unrest or other emergencies, it’s not uncommon for cell phone and other communication lines to be down, so contingency plans to communicate need to be made.
“If a situation is really volatile, have regular, daily check-in times between crew members and passengers,” said Linebaugh. “If communications go down and either party misses a check-in, have an established meet-up point, ideally at the aircraft.”
Perhaps most important, when making contingency plans for emergency departures or diversions remember to use all the resources available, including third-party flight planning and service providers. Let your service provider know you are diverting or departing under duress and get them involved as soon as possible.
“The earlier you get your service provider involved, the more effective they will be,” said Linebaugh.
Dec. 21, 2020 – FAA Exemption 18510D – Grace Month Grant for 135 Operators
July 30, 2020 – FAA Exemption 18509B – No Touch Grant for 135 Operators
July 30, 2020 – FAA Exemption 18510B – Grace Month Grant for 135 Operators
May 28, 2020 – Review the DHS Federal Register Notice 2020–11576
March 13, 2020 – Review the DHS Federal Register Notice 2020-06217
March 19, 2020 – U.S. CBP Carrier Liaison Program: Clarification for Boarding Crew
March 13, 2020 – U.S. CBP Carrier Liaison Program March 13, 2020, Bulletin
March 13, 2020 – DHS Federal Register Notice 2020-05606