EASA part SPO frequently asked questions

EC Regulations define an operator as “any legal or natural person, operating or proposing to operate one or more aircraft or one or more aerodromes.”

Operators must:

• Have an operations manual
• Have a management system.
• Have an approved minimum equipment list (MEL) for each aircraft.
• Complete and submit a declaration to us which details their aircraft type, their operational and continuing airworthiness arrangements, any approvals held etc.
• Ensure that the pilot(s) flying the aircraft hold(s) a Part-FCL licence or a validation issued under Annex III to Part-FCL

EASA's definition of “commercial operation” is as follows:

 'Commercial operation' shall mean any operation of an aircraft, in return for remuneration or other valuable consideration, which is available to the public or, when not made available to the public, which is performed under a contract between an operator and a customer, where the latter has no control over the operator.

“non-commercial” has no specific definition but is classed as anything not falling into the remit of “commercial” as defined above.

Operations can begin immediately once a declaration has been made.

The CAA will verify the details supplied and may get in touch with the operator to confirm or query information, but this should not halt operations in the meantime. However, high risk operations will require prior authorisation.

Operators can switch between these parts depending on the purpose of the flight.

The applicable Part works on a flight-by-flight basis. The crew would need to know the basis under which they were flying and which rules were applicable. AOC holders must make a separate SPO Declaration if also conducting SPO flights.

Declarations made in one EASA country will be recognised by all other member states.

However, for high risk activities in another state the operator needs to ensure that both competent authorities are satisfied.

Aerobatic flights (for example practice flights) need to comply with Part-NCO/SPO outside the airshow environment.

The management of airshows is covered under the Air Navigation Order (ANO).

The requirement for a Part-SPA approval applies only to AOC/CAT operations such as sea pilot transfer.

For Part-SPO operators there is not the same requirement for the Specific Approval but Articles 88 & 89 of the ANO 2016 will still apply.

Someone operating photographic equipment would be considered a Task Specialist rather than a passenger as long as they are undertaking their specialised tasks as assigned by the operator.

Where not undertaking their specialised tasks, or not being positioned to undertake specialised tasks, they would be defined as passengers.

Exemptions and permissions for low level flying will still be issued.

Such exemptions are not part of SPO but continue to be governed by the Rules of the Air Regulations.