Italian Charter Permits: What you need to know

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Italian charter permits and associated requirements have changed a few times in recent years. Today, permit requirements vary depending upon where your aircraft is registered, passenger seating capacity, where you’re operating, and how recently you’ve conducted a charter operation to Italy. As a general rule, the Ente Nazionale per l’Aviazone Civile (ENAC), which is the Italian Civil Aviation Authority, is very strict in regard to regulations and to the documentation that needs to be submitted.


Italian charter landing permit requirements

All charter (non-scheduled commercial) flights by non-European Union (EU)-)-registered aircraft require landing permits. For any aircraft with up to 19 passenger seats, these operations are referred to as “air taxi flights.” A blanket permanent charter permit or one-shot permit is available for a single flight. A  charter blanket permit covers an operator’s entire fleet, assuming all aircraft have been specified on the EASA TCO. The permit is only granted validity through the term of the insurance and all the other relevant documents validity. For example, if the insurance is only valid for an additional six months at the date of application, then the permit will only be valid for six months.

Air taxi Definition: An air taxi flight involves transporting passengers, with their own freight (baggage), under a single charter contract for the entire capacity of an aircraft with no more than 19 passenger seats.


Exemptions for EU-registered aircraft

EU-registered charter aircraft with 19 passenger seats or less do not require landing permits. While such operators should submit a ground handling request and file a flight plan, ENAC does not require a special permit or notification.


Processing of landing permits

Processing time for an annual Italian charter landing permit is up to 40 days, assuming the operator has landed within the EU as a charter within the last two International Air Transport Association (IATA) seasons. IATA seasons are March-October and October-March. Otherwise, the permit processing time is 45 business days.


Permit processing hours

ENAC processes charter permits Monday-Friday, 0900-1700 local. The office is closed on weekends and holidays. No after-hours permit processing is possible under any circumstances, and after-hours contact numbers are not available.


Requirements for non-EU-registered aircraft

Operators applying for the first-time charter to Italy – or those who have not operated to Italy during the past two IATA seasons – must submit specific documentation to the Italian Air Transport Development Division and Must apply for accreditation to EASA TCO and to ENAC.


Domestic operations

Your charter landing permit specifies which Airports of Entry (AOEs) you may travel to within Italy. In order to travel to a domestic airport, you must first arrive/depart via an Italian AOE. Note that, for domestic travel within Italy, you may not carry passengers that are not associated with your international legs, which would be considered cabotage. In other words, you may not board any additional passengers that you did not bring into Italy. At some point in the future, it’s anticipated that Italy may expand its cabotage restrictions – to include travel to and within other EU countries – but this has not yet occurred, and no date for implementation has been announced.


TCO requirements

Ente Nazionale per l’Aviazione 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 valid a the time of the Italian landing permit requests. If the TCO authorization is not valid, your landing permit will not be processed.


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 is 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.
  • A letter from the civil authority in the country in which the aircraft is registered stating that the operator’s security program has complied with International Civil Aviation Organization Annex 17 is usually found within the operator’s security program.
  • A 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 trip support provider (Universal Aviation Italy) 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).

Additional notes: The insurance 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.


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, specifically 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:

  • An FOQ validated by the applicant’s aeronautical authorities—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

10. 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 a notification to ENAC with a minimum 24-hour lead time, and this notification must include an applicable flight schedule.


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 a notification to ENAC with a minimum 24-hour lead time, and this notification must include an applicable flight schedule.


Permit revisions – for all charter permit 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 the processing time is generally five business days. In order to completely renew an approved Italian landing permit, however, the lead time is 30 business days.


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 on board 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.


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.


Conclusion

Keep in mind that if regulations are not followed or proper documentation is not submitted, ENAC will not process your charter landing permit. For permit renewals, you’ll only need to submit documents that may have expired or will expire shortly (within the next year). Documentation that remains valid does not have to be re-submitted with your annual charter permit renewal.

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.

All 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, as well as for inclusive tours and special event charter flights.

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.


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