Subject: RE: high-risk commercial specialised operations
From: Lembit Lehtla <[email-masked]>
To: Holmgren Tobias <[email-masked]>, info transpordiamet <[email-masked]>
Cc: "[email-masked]" <[email-masked]>
Date: Thu, 18 Dec 2025 11:00:30 +0200

Greetings

Thank you for your inquiry. In Estonia, all flights conducted below the SERA minimum heights are indeed classified as high-risk operations and therefore require
prior permission.

That said, I can assure you—subject to your confirmation—that if the operation is conducted with a twin-engine aircraft and takes place at an aerodrome (e.g. low
pass, touch-and-go, or landing), then the flight is most likely not below the SERA minimum height. My reasoning is based on SERA.3105, which defines the minimum height in relation to the aircraft’s ability to make a safe landing (or continue the flight) without
undue hazard to persons or property on the ground. Furthermore, there is an exemption for take-off and landing operations, which, according to the associated GM, also includes manoeuvres such as touch-and-go, go-around, or missed approach when performed at
an aerodrome.

On this basis, such operations would fall under normal risk and would not be considered flights below the SERA minimum heights and may therefore be conducted under
your current Swedish declaration.

Please let me know whether my reasoning matches your view, or if you still expect the operation to be flown below SERA minimum heights. If so, it would be good to
involve your authority so we can look at the remaining risks together. I have also included my Swedish colleague, Ola Johansson, in this e-mail for information.

Also, out of curiosity, do you already know when and what kind of operations are planned in Estonia? Since these flights are not very common here, it would be useful
for me to have an overview and possibly observe the operation in practice if possible.

Regards

Lembit Lehtla

Senior Inspector

Flight Operations and Crew Licensing Unit

Estonian Transportation Administration

www.transpordiamet.ee

From: Holmgren Tobias <[email-masked]>

Sent: Wednesday, December 17, 2025 5:19 PM

To: info transpordiamet <[email-masked]>

Cc: Lembit Lehtla <[email-masked]>

Subject: high-risk commercial specialised operations

Hello,

Saab SFO conduct flights under our SE.DEC.0025 HR for the purpose of airborne inspection of navigational aids and validation of flight procedures (flight inspection/flight calibration). Certain
segments of these flights are conducted below the minimum SERA heights; however, these low-altitude segments occur exclusively within the airport approach path and over the runway.

We request confirmation as to whether the Estonian Transport Administration considers such flights to be classified as high-risk commercial specialised operations and therefore requires a cross-border
authorisation.

Best regards

Tobias Holmgren

Fligt Operations Manager (NP-FO)

Saab Special Flight Operations

Business Unit – Aviation Services

Business Area – Aeronautics

Mobile +46(0)734 468478

[email-masked]

Saab AB

Box 321

SE-611 27 Nyköping – Sweden

Visiting address: Rotevägen 14

www.saabgroup.com

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