If you have ever been involved in an aerial survey project, you know what it takes to be ready for this moment where all the details line up. Aircrafts and staff in place and ready to go, reference stations running, weather looking good, … the list goes on and on. In April of this year, the deadline for implementing the new “Part-SPO” regulation by the European Aviation Safety Agency expired. This directly affects aerial survey companies as they had to prepare and implement required changes beforehand. Even if you are on the customer side of such projects, these new regulations can indirectly affect your work. How? Let’s have a look…

What is Part-SPO?

“Part-SPO” is an annex to the air operations regulations set by the European Aviation Safety Agency (EASA). In this annex, any regulations regarding specialized operations are defined. Part-SPO is not the only annex of the regulation that applies to aerial survey. Other parts that regulate general (commercial) aviation always apply as well for aerial surveys.

Specialised operations (SPO) are declared as: “any specialized operation, commercial or not, where the aircraft is used for specialized activities such as agriculture, construction, photography, surveying, observation and patrol, aerial advertisement”.

The criteria to determine whether an activity falls within the scope of specialized operations are:

• the aircraft is flown close to the surface to fulfill the mission;
• abnormal maneuvers are performed;
• special equipment is necessary to fulfill the mission and which affects the maneuverability of the aircraft;
• substances are released from the aircraft during the flight where these substances are either harmful or affect the maneuverability of the aircraft;
• external loads or goods are lifted or towed, or persons enter or leave the aircraft during flight

Under previous regulations, these areas used to be called “aerial work”. With aerial survey being a commercial application, it falls more specifically into the “SPO-COM” category.

Some activities may be deemed to be “high risk” (mainly with regards to the safety of third parties) and be subject to prior authorization by the aviation authority (mainly with regards to the safety of third parties).

How does this affect aerial surveys?

The Part-SPO regulations define various part of a standard aerial survey: general requirements, operational procedures, performance and operating limitations as well as instruments, data and equipment used. Some examples how this affects daily aerial survey operations:

Declaration

Every SPO operator (thus all aerial survey companies) has to declare that they are compliant with the latest regulatory update. An air operator certificate does not cover SPO operations. In this declaration, an operator confirms that they are fully following the regulations given in the EASA regulations and its associated procedures.

Some of the components and procedures that need to be in place for compliance with the new regulations:

• Safety risk management, hazard identification, and risk assessment
• Manage safety risks related to change
• Identify a person who fulfills the role of Safety Manager
• Safety policy
• Emergency Response Plan (ERP)
• Compliance monitoring
• Conduct risk assessment, assessing the complexity of the activity
• Based on risk assessment, establish Standard Operating Procedures (SOP)

Passengers

When SPO related rules apply to a flight, passengers cannot be carried on board such flights. Only task specialists indispensable to the mission may be permitted. Any staff that operates the equipment, therefore, becomes a task specialist and thus a member of the plane’s crew. At the same time, persons that are not part of the survey are not allowed onboard during aerial survey work.

Staffing

Duty times for pilots is nothing new, but with changes to the regulations, few details have to be kept in mind. With operators now being part of the crew as task specialists, they are now also affected by duty time limitations. Accordingly, they have a maximum amount of hours they can work and require regulated rest periods between working shifts.

Additionally, post-flight duties are to be included in the duty time calculations. This means that any work a navigator (or pilot) does after a flight is equal to operating in the air. On-site processing tasks (for example post-flight QC work) will therefore directly impact the possible flying times during a project unless such tasks are assigned to dedicated ground staff.

Aircraft resources

Given the unpredictable nature of aerial survey, it is not uncommon that a survey company will add temporary resources to their own fleet. Under the updated regulations though, special considerations and checks have to be made as using such external resources can have an impact on the companies part-SPO compliance. Consequently, this restricts the forms of collaboration and adds additional steps to the process.

Sensor use

Equipment installed on an aircraft should not affect or risks the aircraft’s own performance. It has to be ensured that any sensor mounted and plugged into the aircraft’s power supply does not have any effect on the aircraft or other installed components (for example because of reduced power or electromagnetic emissions). Testing or even certifying an installation of a sensor into a new aircraft will take time (and money) and is going to reduce the operational flexibility of aerial survey companies.

Conclusion

I’m no aviation expert, but it even to me it seems clear that the new Part-SPO regulations will certainly have an effect on aerial surveys for both operational as well as financial aspects. With weather conditions dictating the suitable flying conditions, it is crucial for aerial surveys to be ready whenever the skies are blue. Adding the restrictions of the updated regulations, operators will be forced to find new ways to ensure such readiness. The easiest solution is to add resources, but this directly leads to higher operational costs. But will clients be willing to pay the extra price? Trying to avoid such increase in operational cost, some companies might interpret the new regulations a bit more freely. By doing so they will accept the risk of any sanctions EASA might decide upon after auditing the company, which will take place for all aviation organizations within a two years period. It is still to be seen how severe such punishments will be, but theoretically, an organization can even lose their operational license.