Italian Charter Permits: Part 2 of 2 – Permit Approval Process
This is a post by author Stefano Bruno. Stefano is the station manager for Universal Aviation Italy – Milan-Linate, which has Fixed-Base Operator (FBO) and ground support locations at Rome (LIRA), Venice (LIPZ), Milan-Linate (LIML), and Milan-Malpensa (LIMC). Stefano is an expert on business aircraft operations in Italy. He can be contacted at firstname.lastname@example.org.
This business aviation blog post continues from our article last week, entitled "Italian Charter Permits Changes – Part 1 of 2: General requirements."
Lead times for Italian charter permits are firm, and short-notice permit requests are not normally possible. Note that once a charter permit application has been made, with all required documentation submitted, the operator may travel to Italy without notice once the permit is approved.
The following is an overview of what you need to know and the charter permit approval process, based on your charter fight classification:
1. TCO requirements
Ente Nazionale per l’Aviazone Civile (ENAC), the Italian Civil Aviation Authority, began requiring the Third Country Operator (TCO) authorization as part of the landing permit requirements in 2013. Specifically, until November 25, 2014, it was recommended that operators submit TCO authorizations, but this was not a requirement. As of November 26, 2014, TCO authorizations must be submitted with all Italian landing permit requests. If the TCO authorization is not submitted, your landing permit will not be processed.
2. Required information
When you request a charter landing permit, the following information/documentation is required:
- Air Operator’s Certificate (AOC)
- Operation specification D085 (aircraft listing)
- A003 aircraft authorization
- A999 certification statements
- Operator’s full address and information
- Insurance certificate for Italy (ENAC’s format) that must include all aircraft – both owned and leased fleet – that are being submitted for the permit—. ENAC’s specific verbiage and format need to be followed. You cannot use a generic EU insurance format, as that will be rejected.
- Letter from civil authority from the country in which the aircraft is registered stating that the security program that the operator has complies with International Civil Aviation Organization Annex 17. This is usually found within the operator’s security program.
- Foreign operator’s questionnaire (FOQ) is only needed if the landing permit application is for aircraft with more than 19 seats.
- Letter to authorize your 3rd-party provider to be able to process the permit on your behalf, as the 3rd-party provider will be representing the operator with submitting the application to ENAC. This letter needs to be on company letterhead, signed, and notarized. (This is a power of attorney.)
- TCO certificate – or proof that the application has been made (ENAC will double-check with the European Aviation Safety Agency that this has been done). The deadline for operators to submit for a TCO was November 25, 2014. This is the latest requirement that ENAC requires.
Additional notes: For the insurance, it needs to be in the special format provided by ENAC, and it’s recommended that the insurance that is submitted be valid for the year that the permit is valid. If this is an issue, another option is to submit the new insurance before the one submitted will expire. If this isn’t done, ENAC will not consider the permit valid, and if the operator travels to Italy after the original insurance was submitted, ENAC may fine the operator. ENAC holds the operator accountable for submitting updated documentation to ENAC, such as the insurance.
3. Air Carriers – charter aircraft with more than 19 passenger seats
If your charter aircraft is not EU-registered and has more than 19 passenger seats, you’re considered an "air carrier" and must submit a different type of landing permit request, specific for air carriers. This particular type of Italian landing permit is available as a one-shot or annual permit, which requires submission to ENAC with all relevant documentation, as well as a FOQ. Carriers applying to operate a first time charter to Italy (or who have not operated a charter to Italy during the past two International Air Transport Association seasons) must submit their application to the Air Transport Development Division and include:
- A FOQ validated by the aeronautical authorities of the applicant – except for carriers registered in the U.S., Canada, and Turkey
- AOC with complete operational specifications
- Certificates of registration, airworthiness, and noise, as well as ACAS II EGPWS certification
- Insurance certificate issued according to EU Regulation 785/2004 and in compliance with ENAC standards (special format issued by ENAC)
- A completed security program
4. Processing time for an Italian air carrier landing permit
Processing time to approve an air carrier landing permit is 45 business days. When making a permit application, the operator may include all aircraft in the fleet with more than 19 passenger seats. Any aircraft with 19 or fewer passenger seats must be processed separately, under the "air taxi" classification. Note that EU-registered charter aircraft under the air carrier classification do not require permits but must submit notification to ENAC with a minimum 24-hour lead time, and this notification must include applicable flight schedule.
5. Permit revisions – for all charter permits types
Once a charter permit is approved it can be revised if another aircraft needs to be added to the listed fleet. To do this, documentation for the additional aircraft is forwarded to ENAC, and processing time is generally five business days. In order to completely renew an approved Italian landing permit, however, lead time is 30 business days.
6. All-inclusive tour and special event charters
All applicants for inclusive tours and special event charter flights must also submit:
- A copy of the charter contract signed by the "airline" and the "tour operator."
- Website address of the tour operator who advertised and sold the applicable flights in question.
- A shipper’s declaration listing the origin and/or destination of all goods onboard the aircraft.
Application for traffic rights (landing permits) concerning all-inclusive tours and ad-hoc flights must be submitted five days in advance of a single flight and 15 days in advance in cases of a series of flights. Note that a special event charter flight is considered one where the aircraft is chartered for passengers attending a sport, cultural, professional, etc. events. For such flights the origin and return destination (after traveling to Italy) must be the same and it must be operated with aircraft that have more than 19 passenger seats.
7. Expedited permits
Expedited landing permits are normally only possible for diplomatic and/or air ambulance/emergency flights. In most cases diplomatic flights – even though they may be charters – are exempted from Italian charter landing permit requirements, so long as they’re classified correctly and go through appropriate diplomatic channels for flight approval. It’s recommended that your 3rd-party provider confirm this information for your flight.
As of November 26, 2014, TCO authorizations must be submitted with all Italian landing permit requests. Otherwise, your landing permit will not be processed. Note that landing permit requirements change for aircraft over 19 seats, and for inclusive tours and special event charter flights.
As mentioned in Part 1 of this article series, always pay close attention to Italian cabotage restrictions and regulations. If you have questions on Italian cabotage restrictions, then it’s recommended that you speak with your 3rd-party provider.
If you have any questions about this article or would like assistance planning your next trip to Italy, contact me at email@example.com.