This is a post by author Hiroshi Higashiyama. Hiroshi is representative director for Universal Aviation Japan, which has aircraft ground handling facilities in Haneda, Narita, Sapporo and Osaka. Hiroshi is an expert on business aircraft operations in Japan and can be contacted at hiroshihigashiyama@universalaviation.aero.

Japan is making changes to its general aviation processes that are largely seen as positive for the business aviation community and are a first step for liberalization of business aviation regulations within Japan. Firstly, Japan has implemented new charter regulations, similar to the US FAR 135, and these changes are anticipated to promote growth of business aviation charter within Japan. In addition, Japan has introduced revised regulations on flight permit processes that will reduce lead times for non-International Civil Aviation Organization (ICAO) private non-revenue operations. Furthermore, there are changes that will add some flexibility in terms of cabotage. All these changes will to go into effect at the end of October. Here’s an overview of what you need to know:

1. Flight permit requirements for private non-revenue operations

ICAO-registered private non-revenue operators

Currently, ahead of the end of October changes, private non-revenue operators with aircraft registered in ICAO states may overfly, or operate to, designated Airports of Entry (AOEs), without a permit. This will not change after the changes take effect at the end of October.

All non-ICAO registered aircraft

Non-ICAO registered aircraft, however, need an overflight or landing permit to operate over or into any airport in Japan. Permit lead time is currently 10 business days. Under the new regulations, the time will be reduced to three business days.

All private non-revenue operators

Permits, however, are needed for any private non-revenue operators for the following legs:

• Internal/domestic-only operations
• First arrival and/or last departure to/from non-AOEs
• Special airworthiness certificate flights
• Round-robin flights (takeoff and subsequent landing at the same airport without landing at another airport). This includes demonstration flights when the aircraft departs and arrives at the same airport.

2. Charter (non-scheduled commercial) operations require landing permits

Charter operations by ICAO- and non-ICAO registered aircraft require landing permits for all operations into Japan.

3. Permit lead times and validity

Plan on a minimum of three days’ lead time for ICAO-member charter permit requests when planning internal flights within Japan and when operating to non-AOEs. In emergency cases, for business purposes, permits can usually be obtained within 24 hours.

Permits for non-ICAO private and charter flights now require only three business days’ lead time after the end of October changes. The exception being that you will be able to obtain a permit with a minimum of 24 hours as long as the flight is for business purposes only.

For all other permit requests by ICAO-registered private non-revenue operators, lead times remain unchanged.

While permit validity is not specified in the updated regulations, permits are usually valid for the entire calendar day. Permit revisions are necessary when there are changes to operating dates. A new permit must be obtained if you’re changing routing or airport destinations within Japan. Blanket charter permits are not possible for Japan.

4. Air ambulance permits can be obtained quickly

The Japanese Civil Aviation Bureau (JCAB) is accommodating in cases of medical emergencies and air ambulance operations. For short-notice air ambulance permit requests, be sure to provide the patient’s condition and/or medical report, along with hospital and doctor information.

5. Landing permits are needed for tech stops for non-ICAO registered aircraft only

Normally, ICAO-registered aircraft, including charter flights, do not require permits for tech stops. Non-ICAO registered aircraft, however, must have landing permits for any tech stop within Japan. Keep in mind that if you’re making a tech stop at a non-AOE, landing permits are required for operation of both ICAO and non-ICAO registered aircraft.

6. Multiple stops within Japan may be restricted

There are no restrictions on private non-revenue operations in terms of number of domestic legs permitted within Japan. For charter operations – currently, ahead of the end of October change – internal flights are only permitted when ferrying aircraft, and these ferry flights may not have passengers on board. Under the updated regulations effective at the end of October, foreign-registered charter aircraft (both ICAO and non-ICAO registered) may transport passengers internally, between two or more airports within Japan, on the condition that passengers are arriving from/departing to international destinations aboard the aircraft. These passengers may get off the aircraft at any airport; however, the aircraft is not allowed to pick up any passengers originating in Japan for an internal-only flight within Japan. As always, it’s recommended to speak to your 3rd-party provider to ensure that your particular charter trip doesn’t involve legs that aren’t possible.

7. Cabotage is a consideration within Japan

Cabotage is strictly controlled in Japan for charter aircraft. Note that while charter operators are not permitted to transport passengers solely between two or more Japanese airports, they are permitted to pick up/drop off passengers for international legs or transport passengers on domestic legs if the passengers arrived with the aircraft from outside Japan or will depart Japan with the aircraft. Multiple stops within Japan are now feasible for charter operators in certain cases. Other cabotage regulations that are already in place will remain the same. However, as with any trip, it’s always best to check in advance to ensure that the trip you are looking to operate is permissible. For this reason, it’s always best to check with your 3rd-party provider or ground handler.

8. Know the permit request process

Permit requests are processed by JCAB, which is a part of the Ministry of Land, Infrastructure, Transport and Tourism (JMLIT). JCAB and JMLIT operating hours are Monday-Friday, 0930-1200 and 1300-1750 local. When requesting permits, you’ll need to provide to your 3rd-party provider the operator name/address, aircraft type/registration, flight number, full schedule (with approved airport slot times), crew and passenger information and passenger business titles (in the case of business trips), along with purpose of trip, airport slot allocation time and ground handler contact information.

9. Documentation required with Japanese charter permit requests

• Charter contract between air operator and customer
  • “Customer” must be an individual or a party other than air operator
  • Air operator cannot be a charterer, as it will be considered a “Wet Lease operation,” which is not permitted
  • Contract must indicate charter price and be signed by both operator’s representative and customer
  • In order to satisfy JCAB’s requirements, a contract must be prepared directly between the air operator and the office of the principal passenger.
• Aircraft registration certificate
• Airworthiness certificate
• Aircraft insurance certificate
• Aircraft noise certificate
• Air operator certificate
• Pilot license and medical certificate of all pilots operating into Japan
  • All the information, including validity and rating, must be clearly readable
• Certificate or letter confirming that the aircraft is equipped with traffic collision avoidance system (TCAS)
• Power of attorney
• Any other documents specifically required by JCAB

Conclusion

The above changes represent an important easing of regulations for both non-ICAO registered business aircraft, as well as business aircraft charter operators, and are expected to promote more business aircraft operations to Japan.

Be mindful that permits for Japan, as well as airport slot requests, can be relatively complicated procedures. As the Japanese permit application process can be difficult to understand, best practice is to work with your 3rd-party provider and ground handler early in the trip planning phase in order to ensure that you’re complying with the latest rules/regulations.

Questions?

If you have any questions about this article or operating to Japan, contact me at hiroshihigashiyama@universalaviation.aero.