I'm interested in Part-NCC helicopter operators that support luxury yachts/cruise ships, and whether SPA.HOFO is applied (in whole or part).
The definition of 'helicopter offshore operations' is quite complex under EU/UK rules: it depends on other Air-OPS definitions, as well as the national definition of 'coastline' (assuming it is published in the AIP, as required).
Depending on what you do, it's possible to operate onto/off ships with or without a Specific Approval.
However, it seems that the NPA never intended to capture luxury yachts or cruise ships, but the phrase 'support to ships' (introduced with the CRD [2013-10]) is in the Air-OPS Regulation (GM9 to Annex 1). During rule-making, EASA altered the definition of 'offshore operation', explaining that: 'Parts of the definition are moved to GM due to their detailed and explanatory character. The NPA included operations associated with support of offshore oil, gas and mineral exploration, production, storage and transport, and offshore wind turbines and other renewable energy sources. Operations to marine lights and sea-pilot transfer were also included. Other ships, not associated with the former, were not included. The Agency cannot justify maintaining such a regulatory difference as the associated risks are seen to be valid for the entire operational concept. The GM is, therefore, updated according to the definition of offshore operations.'
I think only the Dutch CAA raised a question about this, but the GM has remained.
Although the regulatory 'hook' is GM and not law, would anyone care to comment on whether the rules are proportionate to the luxury yacht/cruise ship industry?
Starspeed Ltd have had contracts of that kind, up to and including Arctic and Antarctic ops. They’re U.K. based but certainly have had EASA contracts in the past.
