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Flight Crews: Ensure You Qualify for Euro CPDLC Exemption

While most of the general aviation fleet is exempt from the EASA’s controller pilot datalink communication (CPDLC) mandate, it is still prudent for business aircraft operators planning flights to Europe to ensure their aircraft are not subject to the equipage mandate and that they log that exemption in their ICAO flight plan forms.

EASA’s datalink services implementing rule requires that aircraft operating above FL 285 must be properly equipped with CPDLC. The rule also requires flight crews to be appropriately trained to use the system.

“EASA’s datalink services implementing rule requires aircraft operating above FL 285 to be properly equipped with CPDLC. It also requires flight crews to be appropriately trained to use the system.”

However, under EASA regulation No. 2019/1170, the European Union’s datalink requirements exempt some aircraft, including those with an airworthiness certificate first issued before Jan. 1, 1995. The regulation also exempts aircraft that have a certified maximum seating capacity of 19 passengers or fewer and a maximum certified takeoff weight of 100,000 pounds or less that hold a first individual certificate of airworthiness issued before Feb. 5, 2020.

These exceptions essentially exempt most of the U.S.’s general aviation fleet from EASA’s CPDLC mandate, with the exception of very large cabin business airplanes, such as the Gulfstream G650ER, along with business aircraft from commercial airliner manufacturers like Airbus and Boeing.

In addition to the exemption, business aircraft operators wishing to use CPDLC should also be aware of the “Logon List,” which until this year was known as the “White List.”

This list, according to Eurocontrol, is an operational response by some of the EU’s air navigation service providers to improve the performance of datalink by not allowing aircraft that are observed to perform poorly from logging on.

“This list considers the type of aircraft and the avionics packages available to those aircraft to determine whether the aircraft is permitted to log on to datalink. Quite a few of those are corporate aircraft,” said a senior official at a large flight department.

Business aircraft operators using FANS 1/A for transoceanic flights should also be prepared for the transition to Europe’s VHF-based ATN B-1 datalink.

“In most cases, the transition is automatic and seamless, but in some cases you will have to log off of FANS 1/A and then re-log on to the ATN B-1 system,” noted the flight department official.

Shawn Scott, co-founder of Scott International Procedures, also points out that while EASA’s CPDLC exemption is automatically granted, Eurocontrol still requires that aircraft operators enter certain information into their ICAO flight plan forms.

Operators should enter the letter “Z” in item 10 of their ICAO flight plans. In addition, operators should enter “DAT/CPDLCX” in item 18. With these items appropriately logged, the aircraft will be cleared to fly above FL 285.

“It wouldn’t be a bad idea for operators to include a hard copy of the waiver in their Safety Assessment of Foreign Aircraft (SAFA) binder in case they are subject to a ramp inspection on arrival in the EU,” added Scott.

“I’d also advise every [U.S.] operator flying to Europe to call ahead. Just like with any other rule, call ahead and make sure you’re not surprised by anything,” said Scott.

Review NBAA’s international resources at nbaa.org/intl.

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