Imagine you’re on the German Autobahn. You’re zipping along at 140 MPH in your fine German automobile.
No stop signs, no speed limits, ain’t nobody gonna slow me down
Now you’re leaving beautiful Bavaria and cross the border into France. You keep moving at 140 MPH until the French Gendarmerie nationale pulls you over. You kindly point out your German license plates to the nice Gendarme and explain that you shouldn’t have to abide by his speed limits since your registration is German. Right?
Of course not.
We know things don’t work that way with automobiles and they also don’t work that way with airplanes. Nevertheless when I discuss equipment and operating requirements for a ferry flight I often hear the argument that this or that piece of equipment is not required for my airplane because it is registered in this or that country. That simply isn’t true, you have to comply with the operating requirements for the countries you fly in, regardless of your aircraft’s country of registration.
Aircraft operating requirements vary from country to country due to things like variations in ground-based infrastructure, geography, amount of air traffic, etc. ICAO sets recommendations but it’s up to the individual countries to adopt them.
Some variations on operating requirements are flight rules. For example, Colombia prohibits (with few exceptions) night flight in single-engine airplanes. For ferry flights over the Atlantic, Transport Canada requires that the pilot-in-command holds a current and valid instrument rating, even if the flight is conducted under VFR. Then there are the expensive requirements: the rules that affect equipment installed in the airplane.
For international ferry flights in general aviation airplanes, the following are the most common “equipment requirements”:
- HF radio for the Atlantic Crossing: nowadays the only routes where Transport Canada allows Atlantic crossings without HF radio are CYFB-BGSF-BIKF or at or above FL250 CYYR-BGBW-BIKF. (Ref. TC AIM section 6) Many people still take the CYYR-BGBW route below FL250 without HF radio but you risk being violated and fined. In my opinion if you can’t go to FL250 it’s better to take the far northern route via CYFB to BGSF than to bother with HF radio.
- Mode-S transponder in Europe: the mode-S requirements in Europe vary by country but the basic idea is that in the busiest airspace (UK to Germany to France) mode-S is mandatory for IFR flights and some VFR. The general perception appears to be that mandating mode-S for general aviation airplanes was a bad idea due to the clutter on controllers’ screens but as they say “it is what it is” – as pilots it’s not our place to decide if the rules make sense, which are good rules or bad rules. There are many stories of people flying through areas where mode-S is required with only mode-C onboard but you risk being violated and fined.
- Traditional DME for IFR in Europe: most newer general aviation airplanes in the US don’t have traditional DME (or ADF) installed. GPS can be substituted for DME in the US because most (maybe all?) the instrument approach procedures have been designed for GPS (or radar) in lieu of DME. In Europe that is not the case, there are still many approaches that are specifically designed for DME, so you must have the equipment onboard. GPS might be a better and more accurate system but that doesn’t matter. As pilots we must fly the approach as published and if the approach requires DME then you must have DME.
- 406 MHz ELT: this is another requirement that varies by country. Some countries require a 406 MHz ELT and others (like the US and Canada) don’t. Of the countries that require a 406 MHz ELT, some accept a portable device in general aviation airplanes and others require that it be a fixed, certified installation. On a side note, the system that monitors the old 121.5 ELTs is no longer operational, so if you don’t have a 406 MHz ELT onboard your chances of being found quickly in the event of a crash are not good. In the case of this recent helicopter crash it took days for the crash site to be found.
These are just the most typical issues for general aviation airplanes delivered from the US to Europe. There are other requirements for large airplanes, EGPWS, RVSM, RNP, alphabet soup stuff. Most are avionics issues and expensive ones at that.
Here are some links to regulatory requirements: