新政策的狂想與解讀

U-Jet： The Regulations states that except for nine scenarios， general aviation missions do not need to undergo application and approval procedures， but it follows that flight plans have to be submitted for approval. Isn’t it self-contradictory？

Jin Junhao： It is not self-contradictory. The 2003 Regulations for General Aviation Flight Control states that general aviation in China has to go through two levels of approval： the “flight mission” approval， which is about the nature of the flight， under the jurisdiction of the flight control department of the Air Force， and “flight plan” approval， which is about flight schedule， route， altitude， origin and destination airport， under the jurisdiction of CAAC. If you understand this difference， you will find it easier to understand the statements in the Regulation. From now on， except for the nine scenarios， general aviation activities will no longer need to go through “flight mission” approval， but “flight plan” approval is still required. The two statements are not contradictory to each other.

U-Jet： So you are saying the Regulation has no direct relation with the opening-up of low altitude airspace.

Jin Junhao： You can say that. The Regulation is issued mainly to simplify general aviation approval procedures. It has no direct link with low altitude airspace. Due to the misunderstanding of the two concepts， “flight mission” and “flight plan”， the statement “except for the below nine scenarios， general aviation missions do not need to undergo application and approval procedures” is misinterpreted as airspace opening-up. But the ultimate goal is the same—to make it freer and more convenient for general aviation， only that the Regulation works on simplifying procedures， while low altitude opening-up aims to expand free flying airspace.

U-Jet： With the Regulation， how much faster would it be for general aviation approval？

Jin Junhao： It depends. General aviation activities not included in the 9 scenarios will surely get approval faster. But how much faster will depend on each individual case. The Regulation fully exemplified the principle of “no prohibition means permission”， where all activities other than the nine listed are exempted from approval. It is a huge progress. As the approval criteria for “flight plan” gets more specified， general aviation will get fairer and freer treatment.

U-Jet： What is the nature of the Regulation in a legal sense？

Jin Junhao： The Regulation is a document jointly issued by PLA General Staff Department and CAAC. Strictly speaking， it is not an administrative regulation， but a document with legal force issued by CAAC. It will become an administrative regulation and gain more legal force in the future.

Article 5 of the November 18， 2013 Regulations on the Approval and Management of General Aviation Missions （hereafter referred to as “the Regulation”） stipulates that “Except for the below nine scenarios， general aviation missions do not need to undergo application and approval procedures， but before flight operation， flight plans with detailed description of the nature of missions should be submitted for approval according to national flight control regulations. “ It follows with nine scenarios involving national defense and diplomatic matters， which are very rare in general aviation.

While the statement “Except for the below nine scenarios， general aviation missions do not need to undergo application and approval procedures” gives hope that general aviation will be fully opened up， the following sentences raise doubt as to whether general aviation need to undergo application or approval at all.

To clear the above misunderstandings， U-Jet invites Mr. Jin Junhao， Director of General Aviation Division， CAAC to offer authoritative interpretations.

快速鏈接——新政策成效立竿見(jiàn)影

At 1400， November 28th， 2013， Reignwood Asia Aviation 400-6105-999 received an emergent mission from International SOS. An Italian patient with multiple thromboembolism need to be transported to Hong Kong for immediate treatment.

As the Regulation states that except for nine scenarios involving borderline or national security， all other general aviation missions do not need to undergo application and approval procedures， Reignwood was able to save a lot of time. By 1800， they had already obtained approval from CAAC while its medical team transported a 200kg ICU to its operating base in Tianjin.

At 0300， November 29th， 2013， the emergency relief flight arrived at Hong Kong after a 4-hour flight. Sun Yongan， President of Reignwood Asia Aviation calls for bigger support， “As a social undertaking business， government support played a critical role in our successful mission. If on the basis of the current fast track， the government could provide priority approval and dispatch， it will be a huge step forward for China’s medical emergency flight services.”

2013年11月28日上午14時(shí)許，華彬亞盛接到國(guó)際救援中心的緊急轉(zhuǎn)運(yùn)任務(wù)，一名因下肢多發(fā)血栓栓塞的意大利男子急需轉(zhuǎn)運(yùn)至香港接受進(jìn)一步治療。

由于《通用航空飛行任務(wù)審批與管理規(guī)定》出臺(tái)后，規(guī)定只有9種涉及國(guó)境線、國(guó)家安全的情形需要進(jìn)行“飛行任務(wù)”的審批，此外的普通通用航空飛行任務(wù)都無(wú)需“飛行任務(wù)”審批。所以此次空中救護(hù)隊(duì)申請(qǐng)大連到香港的飛行大大節(jié)省了審批時(shí)間。當(dāng)天下午18時(shí)許就獲得了民航局的批復(fù)。與此同時(shí)，高空醫(yī)護(hù)團(tuán)隊(duì)攜帶著重達(dá)200千克的全套ICU設(shè)備趕赴天津基地。

2013年11月29日凌晨3時(shí)許，華彬亞盛航空醫(yī)療急救飛機(jī)歷時(shí)4小時(shí)飛抵香港機(jī)場(chǎng)，圓滿完成了本次轉(zhuǎn)運(yùn)任務(wù)。華彬亞盛孫永安總裁呼吁：“作為社會(huì)事業(yè)型企業(yè)，政策的支持對(duì)我們?nèi)蝿?wù)的順利進(jìn)行起到了至關(guān)重要的作用。如果政府在現(xiàn)有的綠色通道基礎(chǔ)上，能夠給予優(yōu)先審批、優(yōu)先放行的支持，將有助于中國(guó)航空急救的長(zhǎng)足進(jìn)步！”