Under Part-SPO, a High Risk commercial specialised operation means:
Any commercial specialised aircraft operation carried out over an area where the safety of third parties on the ground is likely to be endangered in the event of an emergency, or, as determined by the competent authority of the place where the operation is conducted, any commercial specialised aircraft operation that, due to its specific nature and the local environment in which it is conducted, poses a high risk, in particular to third parties on the ground.
Any commercial SPO operator conducting a high risk activity will require a High Risk Authorisation (HRA) under Part-SPO.
The HRA does not replace ANO 2016 and SERA requirements for third party protection, nor the need to apply for the appropriate permissions, exemptions and approvals to conduct the activity.
Who needs to apply for a High Risk Authorisation?
What are 'high risk' activities?
High risk activities are those which pose a high risk in particular to third parties on the ground. Each activity will need to be assessed by the operator. If they believe the activity will pose a high risk they must apply to the UK CAA or their EASA member state Competent Authority for a High Risk Authorisation.
Each activity will need to be assessed against:
- the specific nature of the activity
- the environment in which it is conducted
- whether the activity poses a high risk in particular to third parties on the ground
Such activities could include (but are not limited to):
- Underslung loads, including such activities as helicopter external loads operations and construction work flights, including stringing power line operations and clearing saw operation
- Dropping of articles outside of a controlled/aerodrome environment, which could include such activities as maritime funeral operations and cloud seeding
- On shore power line inspections, including helicopter survey operation
- Surveying, including helicopter survey operations, aerial mapping operations, pollution control activity
- Air to air filming and air to ground filming over congested areas, including aerial photography flights, news media flights, television and movie flights
- Research flights, such as scientific research flights (other than those under Annex II to Regulation (EC) No. 216/2008)
- Aerial advertising
- Thrill flights, such as sensational flights e.g. flights involving extreme aerobatic manoeuvres carried out for the purpose of allowing the persons on board to experience zero gravity, high G-forces or similar sensations
How do I know if I should apply for a High Risk Authorisation?
We have published a decision flow chart to help SPO operators identify whether they should apply for a High Risk Authorisation.
High Risk Authorisations are issued against each activity the operator is carrying out. If an operator is changing the nature or location of the High Risk Activity, a new High Risk Authorisation will be required.
What if I am a UK Operator, but the activity is taking place in another country?
All UK commercial SPO operators will need to apply to the UK CAA for a High Risk Authorisation.
If the activity is taking place in another EU member state the operator should check whether that member state believes the activity to be high risk with the relevant Competent Authority. They should then make sure that the Competent Authority is aware that an application for a High Risk Authorisation is being made to the UK CAA. The UK CAA will assess the application in liaison with the relevant Competent Authority.
If the activity is taking place in a non-EU member state by a UK registered aircraft or by an operator based in the UK, an application for a High Risk Authorisation should still be made to the UK CAA. The operator will also have to ensure that they comply with any other relevant regulations applicable in the country where the activity is taking place.
What if I am an operator based overseas and the activity is taking place in the UK?
If you are an operator based in another EU Member State, and the activity is taking place in the UK, you will need to apply to your National Aviation Authority for a High Risk Authorisation. They will issue a High Risk Authorisation in co-ordination with the UK CAA. You will also need to apply for any relevant permissions and exemptions under the Air Navigation Order (ANO) 2016 and SERA in order to conduct the activity in the UK.
If you are an operator based in any other country (outside of the EEA), you will need to comply with Article 252 of the ANO in order to conduct commercial operations in the UK.
We have published a decision flow chart to help you identify whether you need to apply for a High Risk Authorisation.
How long will the High Risk Authorisation be valid for?
The validity period for a High Risk Authorisation will depend on the nature and length of the activity. Operators may apply for an authorisation for a one-off event or for an ongoing activity.
We will assess the nature, location and risk to third parties of the activity and will either issue an authorisation for a one-off event or for a period of up to one year.
Where operators are granted a High Risk Authorisation for a period of one year, they will need to apply for a renewal once the initial HRA has expired.
Will the High Risk Authorisation cover me for more than one activity?
The High Risk Authorisation will only cover the operator for the activity which has been applied for.
If any aspect of the operation changes, such as the type of activity, location or environment, operators should either apply for a new High Risk Authorisation or a variation to their existing High Risk Authorisation.
How much does a High Risk Authorisation cost?
There is currently no charge associated with the High Risk Authorisation. However, the CAA is required to recover its costs from those it regulates through the Scheme of Charges and a charge will be introduced in due course.
Applying for a High Risk Authorisation
Operators will either need to declare to the UK CAA as an SPO operator before applying for a High Risk Authorisation or make the High Risk Authorisation application at the same time as the SPO declaration.
HRA applications will need to be received a minimum of 30 days before the activity is due to take place to allow the necessary checks to be performed.
Operators who believe they will be conducting high risk activities will need to provide the CAA with:
- A description of the Operator’s Management System, including the organisational structure
- A risk assessment for the activity
- Copies of all relevant Standard Operating Procedures