|
Getting gear across borders can be a hassle, even more so for those
who are in the business.
All a private individual has to do is show that it's his and that
he's not selling the gear. That can be done with a receipt of purchase
or sometimes a registration done through one of the ultralight
organizations. But for a business trying to import machines or motors,
they can fall into numerous pitfalls. Weeks long delays are not uncommon
when some overzealous border agent applies laws that shouldn't be
applied. No doubt the agent means well, they're just mis-applying rules
that aren't meant for other applications.
Such was the case when longtime paramotor importer Francesco DeSantis
was stymied with a shipment of engines from Italy into the U.S.
Thankfully, he shares his experience in case it comes up again.
The shipment was held up because it didn't meet Federal
EPA emissions requirements for
engines. Those requirements don't apply to aircraft which, as you'll see
below, include us even though the FAA has a special place in its heart
for "Ultralight Vehicles."
The EPA did eventually straighten things out for Francesco with this
letter:
Francesco,
For purposes of applying EPA emission
standards, we say that the land-based standards do not apply to
aircraft, which we define as "any vehicle capable of sustained air
travel above treetop heights." The EPA aircraft standards do not
apply to flying things that are exempt from airworthiness
certification at FAA. As such, ultralights are not subject to EPA
emission standards.
If anyone asks questions during the
importation process, you can refer to 40 CFR 1068.310(d), which
specifically says that aircraft are generally excluded from EPA
certification requirements (see the link below). The EPA importation
form does not apply for aircraft engines, but if anyone insists that
you fill it in, I would suggest that you identify this as a
land-based nonroad engine below 19 kW and check the box saying that
these are engines not yet subject to standards.
I hope this helps. Let me know if you need
to follow up.
So if you run into this problem, now at least you'll know where to
look.
Thanks to Francesco for sharing this information.
Material Data Safety Sheet & Declaration
The EPA is only one of your worries. Some shippers have
asked for documentation showing that your gear is not hazardous. Of course the
first thing is to make sure that, in fact, it isn't!
Once you've done all the appropriate cleaning to insure there's
no fuel or oil in the machine (or on it, for that matter), then
you can create a Material Data Safety Sheet. The pilot who reported
needing it sent me a copy of what worked and I created a generic version
for pilots
to download. Then modify it with your own information as appropriate.
Download the Material
Safety Data Sheet sample here. (word XP document)
Download the Hazmat
Declaration sample here. (word XP document)
Fill in your own information then include it with any other paperwork when
you go to ship or check your gear.
Remember that nearly all U.S. airlines WILL NOT take
paramotors as baggage, even brand new ones that have never been run.
Some pilots have tried and got by but others have been stranded when the
airline refused to take it. At most airlines, the official policy is "no
engines."
|
