GEN 1.7  Differences from ICAO Standards, Recommended Practices and Procedures

NumberAnnexEditionDifferences
1Personnel Licensing11NIL
2Rules of the Air10

Chapter 3, § 3.2.2 (Belgium and Luxembourg)

An aircraft that is aware that the manoeuvrability of another aircraft is impaired shall give way to that aircraft.

Chapter 3, § 3.2.2.4 (Belgium and Luxembourg)

Sailplanes overtaking: a sailplane overtaking another sailplane may alter its course to the right or to the left.

Chapter 3, § 3.2.3.2 (b) (Belgium and Luxembourg)

Unless stationary and otherwise adequately illuminated, all aircraft on the movement area of an aerodrome shall display lights intended to indicate the extremities of their structure, as far as practicable.

Chapter 3, § 3.2.5 (c) and (d) (Belgium and Luxembourg)

(c) except for balloons, make all turns to the left, when approaching for a landing and after taking off, unless otherwise indicated, or instructed by ATC;

(d) except for balloons, land and take off into the wind unless safety, the runway configuration or air traffic considerations determine that a different direction is preferable.

Chapter 3, § 3.3.1.2 (Belgium and Luxembourg)

VFR flights across international borders but remaining within the Schengen Area do not need a flight plan as far as the Brussels FIR is concerned.
A pilot is required to file a flight plan when planning any flight at night if leaving the vicinity of an aerodrome.

Chapter 3, § 3.8 and Appendix 2 (Belgium and Luxembourg)

The words “in distress” are not included in EU law, thus enlarging the scope of escort missions to any type of flight requesting such service. Furthermore the provisions contained in Appendix 2 Parts 1.1 to 1.3 inclusive, as well as those found in Attachment A, are not contained in EU law.

Chapter 4, § 4.3 (Luxembourg only)

VFR flights at night may be authorised under the following conditions:

  1. They are operated exclusively in controlled airspace except for flights who have been granted exemptions for special operations;
  2. A complete flight plan shall be filed;
  3. Except when necessary for take-off or landing, or except when specifically authorised by the CAA, VFR flights at night shall be operated at a level which is at least 1 000 FT above the highest obstacle located within 8 KM of the estimated position of the aircraft;
  4. Visibility and distance from cloud minima in visual meteorological conditions at night are the following:
Altitude bandAirspace classFlight visibilityDistance from cloud
At and above FL 100C D8 KM1 500 M horizontally
1 000 FT vertically
Below FL 100 and above 3 000 FT AMSL, or above 1 000 FT above terrain, whichever is the higherC D5 KM1 500 M horizontally
1 000 FT vertically
At and below 3 000 FT AMSL, or 1 000 FT above terrain, whichever is the higherC D5 KM1 500 M horizontally
1 000 FT vertically

However:

  1. the ceiling shall not be less than 1 500 FT
  2. in airspace classes C and D, at and below 3 000 FT AMSL or 1 000 FT above terrain, whichever is the higher, the pilot shall maintain continuous sight of the surface

Chapter 4, § 4.6 (Belgium and Luxembourg)

Except when necessary for take-off or landing, or except by permission from the CAA, a VFR flight shall not be flown:

  1. over the congested areas of cities, towns or settlements, or over an open-air assembly of persons at a height less than 300  M (1 000 FT) above the highest obstacle within a radius of 600 M from the aircraft;
  2. elsewhere than as specified in (a), at a height less than 150 M (500 FT) above the ground or water, or 150  M (500 FT) above the highest obstacle within a radius of 150 M (500 FT) from the aircraft.
3Meteorology19NIL
4Aeronautical Charts11NIL
5Units of Measurement to be Used in Air and Ground Operations5NIL
6Operation of Aircraft
Part I: International Commercial Air Transport - Aeroplanes10NIL
Part II: International General Aviation - Aeroplanes9NIL
Part III: International Operations - Helicopters8NIL
7Aircraft Nationality and Registration Marks6NIL
8Airworthiness of Aircraft11NIL
9Facilitation14NIL
10Aeronautical Telecommunications
Volume 1:
  • Part 1: Equipment and System
  • Part 2: Radio Frequencies
6NIL
Volume 2: Communication Procedures including those with PANS status7

Chapter 5 § 5.2.1.4.1 (Belgium and Luxembourg)

(a) Transmission of numbers

(1) All numbers used in the transmission of aircraft call sign, headings, runway, wind direction and speed shall be transmitted by pronouncing each digit separately.

(i) Flight levels shall be transmitted by pronouncing each digit separately except for the case of flight levels in whole hundreds.

(ii) The altimeter setting shall be transmitted by pronouncing each digit separately except for the case of a setting of 1 000 hPa which shall be transmitted as “ONE THOUSAND”.

(iii) All numbers used in the transmission of transponder codes shall be transmitted by pronouncing each digit separately except that, when the transponder codes contain whole thousands only, the information shall be transmitted by pronouncing the digit in the number of thousands followed by the word “THOUSAND”.

(2) All numbers used in transmission of other information than those described in point (a)(1) shall be transmitted by pronouncing each digit separately, except that all numbers containing whole hundreds and whole thousands shall be transmitted by pronouncing each digit in the number of hundreds or thousands followed by the word “HUNDRED” or “THOUSAND”, as appropriate. Combinations of thousands and whole hundreds shall be transmitted by pronouncing each digit in the number of thousands followed by the word “THOUSAND”, followed by the number of hundreds, followed by the word “HUNDRED”.

(3) In cases where there is a need to clarify the number transmitted as whole thousands and/or whole hundreds, the number shall be transmitted by pronouncing each digit separately.

(4) When providing information regarding relative bearing to an object or to conflicting traffic in terms of the 12-hour clock, the information shall be given pronouncing the digits together such as “TEN O'CLOCK” or “ELEVEN O'CLOCK”.

(5) Numbers containing a decimal point shall be transmitted as prescribed in point (a)(1) with the decimal point in appropriate sequence indicated by the word “DECIMAL”.

(6) All six digits of the numerical designator shall be used to identify the transmitting channel in Very High Frequency (VHF) radiotelephony communications except in the case of both the fifth and sixth digits being zeros, in which case only the first four digits shall be used.

Chapter 5 § 5.2.1.7.3.2.3 (additional provision) (Belgium and Luxembourg)

For transfers of communication within one ATS unit, the call sign of the ATS unit may be omitted.

Volume 3:
  • Part 1: Digital Data Communication Systems
  • Part 2: Voice Communication Systems
2NIL
Volume IV: Surveillance Radar and Collision Avoidance Systems5NIL
Volume V: Aeronautical Radio Frequency Spectrum Utilization3NIL
11Air Traffic Services14

Chapter 2, § 2.6 and Appendix 4 (Belgium only)

Pilots shall maintain continuous air-ground voice communication watch and establish two-way communication, as necessary, on the appropriate communication channel in class G RMZ.
The Director General of the CAA may exempt aircraft types, which for technical or safety reasons exceed the 250 KT speed limit.

Chapter 2, 2.6.1 (Luxembourg only)

The CAA may exempt aircraft types, which for technical or safety reasons exceed the 250 KT speed limit.

Chapter 2, 2.6.3 (Luxembourg only)

The CAA may exempt aircraft types, which for technical or safety reasons exceed the 250 KT speed limit.

Chapter 2, 2.13.5 (Luxembourg only)

Annex 11 Appendix 3, 2.1.1. (e) requires that the word “visual” is used in the plain language designator when the route has been established for VFR, whereas the EU rule extends it to IFR in VMC as well. (same difference is replicated in paragraph 5.3 Annex 11 Appendix 3). Annex 11 Appendix 3 paragraph 6 (MSL/RNAV) is not transposed. Annex 11 Appendix 3 paragraph 7:7.2 is not transposed. Annex 11 Appendix 3 paragraph 8 is not transposed.

Chapter 2, 2.15.3 (Luxembourg only)

Annex 11 Appendix 2, paragraph 1.1 the terms “preferably VHF or higher frequency aids” are not transposed. Paragraph 4.2, 5.7 and 5.8 are not transposed.

Chapter 2, 2.19.1 (Luxembourg only)

The EU regulation refers to “air operations” instead of “activities”, therefore restricting the scope of the requirement. The EU regulation does not specify with whom the co-ordination should be affected by omitting to specify the “appropriate air traffic services authorities”.

Chapter 2, 2.19.4 (Luxembourg only)

Art. 3c of Regulation (EU) 2017/373: Art. 3c(2) refers to Art. 3c(1), which is the transposition of paragraph 2.19.1 of Annex 11, therefore the same difference applies.

Chapter 2, § 2.26.5 (Belgium and Luxembourg)

Time checks shall be given at least to the nearest minute.

Chapter 3 and Appendix 4 (Belgium only)

When requested by the pilot of an aircraft and agreed by the pilot of the other aircraft and if so prescribed by the appropriate ATS unit in airspace classes D and E, a flight may be cleared subject to maintaining own separation in respect of a specific portion of the flight below FL 100 during climb or descent, during day under VMC.

Chapter 3, 3.3.4 (Luxembourg only)

When requested by the pilot of an aircraft and agreed by the pilot of the other aircraft and if so prescribed by the ATS, a flight, in airspace classes D and E, may be cleared subject to maintaining own separation in respect of a specific portion of the flight below 3 050 M (10 000 FT) during climb or descent, during day in VMC.

Chapter 3, § 3.7.3.1 (Belgium and Luxembourg)

The flight crew shall read back to the air traffic controller safety-related parts of ATC clearances and instructions which are transmitted by voice. The following items shall always be read back:

  1. ATC route clearances;
  2. clearances and instructions to enter, land on, take off from, hold short of, cross, taxi and backtrack on any runway; and
  3. runway-in-use, altimeter settings, SSR codes, newly assigned communication channels, level instructions, heading and speed instructions; and
  4. transition levels, whether issued by the controller or contained in ATIS broadcasts.

Chapter 3, § 3.7.3.1.1 (Belgium and Luxembourg)

Other clearances or instructions, including conditional clearances and taxi instructions, shall be read back or acknowledged in a manner to clearly indicate that they have been understood and will be complied with.

Chapter 3 (additional provision) (Belgium and Luxembourg)

Special VFR flights may be authorised to operate within a control zone, subject to an ATC clearance.
Except when permitted by the CAA for helicopters in special cases such as, but not limited to, medical flights, search and rescue operations and fire-fighting, the following additional conditions shall be applied:

  1. such flights may be conducted during day only, unless otherwise permitted by the CAA;
  2. by the pilot:
    1. clear of cloud and with the surface in sight;
    2. the flight visibility is not less the 1 500 M or, for helicopters, not less than 800 M;
    3. fly at a speed of 140 KT IAS or less to give adequate opportunity to observe other traffic and any obstacles in time to avoid a collision, and
  3. an air traffic control unit will not issue a Special VFR clearance to aircraft to take off or land at an aerodrome within a control zone, or enter the aerodrome traffic zone or aerodrome traffic circuit when the reported meteorological conditions at that aerodrome are below the following minima:
    1. the ground visibility is less than 1500 M or, for helicopters, less than 800 M;
    2. the ceiling is less than 180 M (600 FT).
Chapter 4, 4.3.7 (Luxembourg only)

The braking action will not be provided through ATIS.

Chapter 4, 4.3.8 (Luxembourg only)

The braking action will not be provided through ATIS.

Chapter 4, 4.3.9 (Luxembourg only)

The braking action will not be provided through ATIS.

Chapter 6, 6.1.2.1 (Luxembourg only)

The EU Regulation allows flexibility in the available radio coverage subject to approval by the competent authority.

12Search and Rescue8NIL
13Aircraft Accident Investigation11NIL
14Aerodromes
Volume 1: Aerodrome Design and Operations8Note: Differences below are only applicable to the aerodromes certified according to the European regulation. The aerodromes are listed in AD 1.5 Status of Certification of Aerodromes.

Chapter 1, §1.4.1 (Belgium only)

European regulation applies only to aerodromes open to public use, which serve commercial air transport, having a paved instrument runway of 800 M or more. These aerodromes are certified under European regulation, with a possible exemption for aerodromes below 10 000 commercial passengers per year and 850 freight movements per year.

Aerodromes not covered by European regulations are certified when they accommodate more than 10 000 commercial passengers over 3 consecutive years.

All aerodromes out of the scope of European Union regulation are subject to runway homologation by the Competent Authority.

See AD 1.5 Status of Certification of Aerodromes.

Chapter 3, §3.8.1 (Belgium only)

The provision of radio altimeter operating area is optional for CAT I runways.

Chapter 3, §3.9.12 (Belgium only)

Regulation requires a suitable strength for taxiways and not the strength of the runway they serve.

Chapter 3, §3.13.6 (Belgium only)

The regulation offers the possibility to reduce the clearance distance for height limited objects if the stand is restricted for aircraft with specific characteristics.

Chapter 4, §4.2.16 (Belgium only)

For code letter F aerodromes, the width of the inner approach surface and the length of the inner edge of the balked landing surface are increased to 140M, irrespective of the type of avionics.

Chapter 5,§5.2.10.5, §5.2.10.6, §5.2.10.7 (Belgium only)

Only pattern A2 and B2 are used.

Chapter 5, §5.2.13.1 (Belgium only)

Markings may not be provided where appropriate procedures are in place.

Chapter 5, §5.3.5.36 (Belgium only)

The regulation does not foresee that the approach slope should be appropriate for the aeroplanes.

Chapter 5, §5.3.5.44 (Belgium only)

The regulation foresees one more case where an object or an extension to an existing object may penetrate the obstacle protection surface, that is, when after a safety assessment, it is determined that the object would not adversely affect the safety or significantly affect the regularity of operations of helicopters.

Chapter 5, §5.3.20.1 (Belgium only)

Stop bars are provided when the runway is intended to be used with an RVR less than 550M.

Chapter 5, §5.3.22.1 (Belgium only)

The regulation describes only the purpose of the de-icing/anti-icing facility exit lights and does not require the provision of the lights.

Chapter 5, §5.3.24.1 (Belgium only)

The provision of floodlighting on de-icing/anti-icing facilities is not mandatory.

Chapter 5, §5.3.28.1 (Belgium only)

Road-holding position lights are provided when the runway is to be used with RVR below 550M.

Chapter 5, §5.4.3.5 (Belgium only)

Intersection take-off signs are mandatory.

Chapter 8, §8.1.10 (Belgium only)

Essential security lighting and essential equipment and facilities for the aerodrome responding emergency services, are not covered by the regulation.

Chapter 9, §9.1.7 (Belgium only)

The regulation allows the possibility for a mobile command post not to be available.

Chapter 9, §9.1.11 (Belgium only)

The regulation allows the possibility for communication systems not to be provided.

Chapter 9, §9.1.13 (Belgium only)

The regulation does not foresee the possibility of “modular tests in the first year and a full emergency exercise at intervals not exceeding 3 years”.

Chapter 9, §9.2.4 (Belgium only)

The regulation uses the principles contained in 9.2.5 and 9.2.6 for establishing the level of protection for an aerodrome; however the regulation allows the reduction of the required level of protection based on the number of movements of the larges aeroplane at the aerodrome.

Chapter 9, §9.2.16 (Belgium only)

The regulation does not require supplementary water supplies to be available.

Chapter 9, §9.2.29 (Belgium only)

The regulation does not include a certain response times to any other part of the movement area. The response times are calculated and included in the aerodrome emergency plan.

Chapter 9, §9.2.31 (Belgium only)

The regulation foresees the arrival of vehicles, other from the first responding vehicle, by taking into account the time that the first vehicle should respond plus one minute.

Chapter 9, §9.2.32 (Belgium only)

The regulation foresees the arrival of vehicles, other from the first responding vehicle, by taking into account the time that the first vehicle should respond plus one minute.

Chapter 9, §9.9.4 (Belgium only)

In addition to the cases foreseen in the relevant specification, the regulation allows the presence of equipment/installations also after a safety assessment regarding safety and regularity.

Chapter 10, §10.5.8 (Belgium only)

The regulation applies for taxiway operations under 550M RVR.

Chapter 10, §10.5.9 (Belgium only)

The regulation applies for taxiway operations under 550M RVR.

Volume 2: Heliports4NIL
15Aeronautical Information Services16Chapter 6, 6.3.2.3 (Luxembourg only)

Not all the additional cases introduced with amendments 40 and 41 of Annex 15, for NOTAM origination are covered.

Chapter 6, 6.3.2.4 (Luxembourg only)

A NOTAM is also required to be originated and issued in case of unavailability of a runway due to runway marking works or, if the equipment used for those works can be removed, a time lag required for making the runway available.

16Environmental Protection
Volume 1: Aircraft Noise8NIL
Volume 2: Aircraft Engine Emissions4NIL
17Security10NIL
18The Safe Transport of Dangerous Goods by Air4NIL
19Safety Management1NIL

(*) References marked with an asterisk are differences from Recommendations.

NumberDocumentEditionDifferences
4444Procedures for Air Navigation Services - Air Traffic Management (PANS-ATM)16Chapter 6, § 6.3.2.3

In Belgium, standard clearances for departing aircraft do not contain the cleared level. They will contain the initial level, except when this element is included in the SID description.

Chapter 6, § 6.3.2.4

In Belgium, when a departing aircraft on a SID is cleared to climb to a level higher than the initially cleared level or the level(s) specified in the SID, the aircraft shall follow the published vertical profile of the SID, unless such restrictions are explicitly cancelled by ATC.

The phraseologies specified in § 6.3.2.4 are not used in Belgium.

Chapter 6, § 6.3.2.5

In Belgium, clearances will refer to the initial or intermediate level instead of the cleared level.

Chapter 6, § 6.5.2.3

In Belgium, standard clearances for arriving aircraft do not contain the cleared level. They will contain the initial level, except when this element in included in the STAR description.

Chapter 6, § 6.5.2.4

In Belgium, when an arriving aircraft on a STAR is cleared to descend to a level lower than the level or level(s) specified in the STAR, the aircraft shall follow the published vertical profile of the STAR, unless such restrictions are explicitly cancelled by ATC. Published minimum levels based on terrain clearance shall always be applied.

The phraseologies specified in § 6.5.2.4 are not used in Belgium.

Chapter 8, § 8.5.4.1

Where an aircraft's Mode C displayed level differs from the cleared flight level by 90 M (300 FT) or more, the controller will inform the pilot accordingly and the pilot shall be requested to check the pressure setting and confirm the aircraft's level.

4444Procedures for Air Navigation Services - Air Traffic Management (PANS-ATM)

Chapter 12, § 12.3.1.2, level changes, reports and rates

In the Brussels FIR, above FL 245, the words “TO” and “FOR” shall not be used in connection with assignment/reporting of levels.

Chapter 12, § 12.3.1.2, items (z) to (kk)

In Belgium, following additional phraseologies are used:

  • clearance to cancel level restriction(s) of the vertical profile of a SID during climb: “CLIMB TO (level) [LEVEL RESTRICTION(S) (SID designator) CANCELLED (or) LEVEL RESTRICTION(S) (SID designator) AT (point) CANCELLED]”;
  • clearance to cancel level restriction(s) of the vertical profile of a STAR during descend: “DESCEND TO (level) [LEVEL RESTRICTION(S) (STAR designator) CANCELLED (or) LEVEL RESTRICTION(S) (STAR designator) AT (point) CANCELLED]”.

In Belgium, the phraseologies for the following circumstances are not used:

  • clearance to climb on a SID which has published level and/or speed restrictions, where the pilot is to climb to the cleared level and comply with published level restrictions, follow the lateral profile of the SID; and comply with published speed restrictions or ATC issued speed control instructions as applicable;
  • clearance to cancel level restriction(s) of the vertical profile of a SID during climb;
  • clearance to cancel specific level restriction(s) of the vertical profile of a SID during climb;
  • clearance to cancel speed restrictions of a SID during climb;
  • clearance to cancel specific speed restrictions of a SID during climb;
  • clearance to climb and to cancel speed and level restrictions of a SID;
  • clearance to descend on a STAR which has published level and/or speed restrictions, where the pilot is to descend to the cleared level and comply with published level restrictions, follow the lateral profile of the STAR and comply with published speed restrictions or ATC issued speed control instructions;
  • clearance to cancel level restrictions of a STAR during descent;
  • clearance to cancel specific level restrictions of a STAR during descent;
  • clearance to cancel speed restrictions of a STAR during descent;
  • clearance to cancel specific speed restrictions of a STAR during descent;
  • clearance to descend and to cancel speed and level restrictions of a STAR.
Chapter 12, § 12.3.2.2, item (b) (3)

In Belgium, the phraseology “FLIGHT PLANNED ROUTE” is used.

Chapter 12, § 12.3.3.1, item (f)

In Belgium, the phraseology “CLEARED VIA (designation)” is used.

Chapter 12, § 12.3.3.1, item (g) and (h)

In Belgium, the phraseology for clearance to proceed direct with advance notice of a future instruction to rejoin the SID is not used.

Chapter 12, § 12.3.3.2, item (a)

In Belgium, the phraseology “CLEARED (or PROCEED) VIA (designation)” is used.

Chapter 12, § 12.3.3.2, item (b)

In Belgium, the phraseology “CLEARED TO (clearance limit) VIA (designation)” is used.

Chapter 12, § 12.3.3.2, item (c)

In Belgium, the phraseology “CLEARED (or PROCEED) VIA (details of the route to be followed)” is used.

Chapter 12, § 12.3.3.2, item (d) and (e)

In Belgium, the phraseology for clearance to proceed direct with advance notice of a future instruction to rejoin the STAR is not used.

Chapter 12, § 12.4.1.6, item (k)

In Belgium, the phraseology “RESUME PUBLISHED SPEED)” is not used.

Appendix 2, item 8, page A2-3, M if MIL

In addition to MIL operations, operators of customs or police aircraft shall insert letter "M" in item 8 of the ICAO flight plan form.