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I am not a pilot, my understanding about flight is limited. EASA CPDLC will require airplanes to be capable of PM-CPDLC data communication to fly above FL285.

For an airline with multiple 767-300 and 757-200 airplanes, would it be feasible to consider the option of flying below FL285 in European airspace, instead of ceasing operation in the region or investing millions of dollars for avionics upgrades?

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Unlikely. The extra fuel burned would cost a lot more than the required Avionics upgrade.

Both the 75/767 would be well below optimum cruise level.

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    $\begingroup$ Generally true, but I would say that it depends on the route. Flying from the US to London would probably be okay because you would be descending anyway. Flying to (or within) Eastern Europe would be another matter though.... $\endgroup$
    – Lnafziger
    Commented Nov 17, 2014 at 22:04
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The adoption of CPDLC is more or less voluntary, because they have created "exceptions" for practically every single aircraft that does not have it built in. Flying below 28K is not practical except for short flights, but it does not matter because it unlikely they will start banning aircraft that do not have the equipment. Note that there are international treaties in place that mandate countries allow commercial overflight and if you just started banning various aircraft, you would be in violation of those treaties.

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