Essentially, yes. Worth noting that „campo di volo“ isn‘t even a defined legal term. It is simply an area used for takeoffs and landings which is not classified as an „aeroporto“ or „aviosuperfici“. Given the certified aircraft must only use aeroporti or aviosuperfici, it follows that campi di volo may ony be used by ultralights and such.
The new regulation for aviosuperfici will come into force tomorrow. ENAC, being behind on allowing the gestori to comply with the new requirements, has today issued a letter by which a tiny bit of leeway is given to the operators of existing aviosuperfici and the pilots operating there, but this is far from being a solution.
At the same time, at least they have published study materials for the gestori to prepare themselves for the exams, which shall be possible starting from 13/12/2023. They also provided documents that show in which format the gestori (with the help of a registered architect) are to provide the technical airfield information. See here.
A lot of faff. Some aviosuperfici will die (i.e. at least be downgraded).
Given the certified aircraft mist only use aeroporti or aviosuperfici, it follows that campi di volo may ony be used by ultralights and such.
What about say an RV6?
Not 100% sure, but I believe that homebuilts are formally also restricted to aeroporti and aviosuperfici.
I believe the definition of a ‘campo di volo’ is a landing site not approved by the Italian Civil Aviation Authority (ENAC) for use by aircraft they regulate, including an RV homebuilt and not being limited to C of A aircraft. Italian ultralights are separately regulated by the Italian Aero Club (AeCI) so are not limited to operation where ENAC approves.
I looked into this some years ago when considering basing a N-registered standard category aircraft in Italy, but one with performance characteristics much like an ultralight. My conclusion right or wrong was that it would not be a good idea to operate from campi di volo in anything with a conventional registration number.
What about say an RV6
That sure wouldn’t work. The more so if G- reg. Exacerbated by non-italian speaking crew…
Picture images of ENAC, guardia di finanza, etc, surrounding said culprit… sure hope not to witness any of the messy slaughter that would ensue 
Desparate letter by AOPA Italy to ENAC, now that many many aviosuperifici will cease to exist on Christmas this year. Text copied here as translated into English by DeepL:
Dear Sirs,
We take note with extreme disappointment of the publication on ENAC’s website on 7 December, of the material in question and of the very serious communication specifying: "On the aviation-hydro-heliport areas already surveyed at the date of publication of the Regulation of 9 June
2023, for which the respective operators have not uploaded the documentation by the date of 26/12/2023, flying activity is suspended".
All this in spite of our request to extend the date of the entry into force of the new regulations, more than justified not only by the presence of absurd EASA regulatory references intended for commercial airports that have no correspondence in most of the same minor airport infrastructures currently managed by ENAC, but also by the failure to promptly publish adequate Informative Notes or Guidelines by ENAC in these 6 months, to allow the operators to comply with the new regulation without interrupting their legitimate activities.
In the light of the facts, and after a careful analysis of the material deliberately published two days before the deadline, and in conjunction with the Christmas holidays, it is clearly clear to all that the actions implemented by ENAC have the sole purpose of drastically reducing or eliminating the valuable private flight infrastructure at zero cost to the community, built by free citizens and associations in compliance with the law of 2 April 1968, no. 518 and related Decrees, through a deliberate patchwork of regulations, inadequate and oversized technical requirements – as well as highly onerous obligations – that discourage even the most willing operators, against an increase in safety for even the most willing operators, in the face of a significant increase in the safety of the community.
deliberate patchwork of regulations, inadequate and oversized technical requirements – as well as highly burdensome fulfilments – such as to discourage even the most willing of operators, in the face of a zero increase in flight safety. At the same time, it can be deduced that the risk of possible legal action against ENTE officials, arguably the only real reason for rewriting the regulations, will also be drastically reduced.
Subsequent to the publication date of 9 June 2023, there were frequent contacts with Engineer Davide Drago, with circumspect requests to examine the notes sent in the name and on behalf of over 130 operators who had signed AOPA Italia’s comments on the draft published for consultation.
The already existing technical-environmental information procedures voluntarily conveyed by the operators through the publication “Avioportolano”, which since 1987 surveys all the national flight infrastructures, updating them punctually, unlike what can be found by pilots on the special section of the ENAC site, which has been inaccurate and outdated since illo tempore.
Despite repeated assurances that the implementing provisions would be simpler and have a low impact on users, and that actions to mitigate and perfect the questionable and inadequate contents of the new regulation would be jointly evaluated, the day after the umpteenth interview, we realised that we had been the victims of decidedly unfair behaviour that has nothing to do with the institutional mission of ENAC, which specifies ‘… Enac is one of the main players in the proactive action aimed at fostering the development of Civil Aviation. It is therefore necessary that this action be pursued through a continuous effort of cooperation and confrontation with the actors involved’.
Coupled with all this, the title of the webinar ‘The future of aviation-hydro-helipads in the light of the new ENAC regulations’ also appears as a further sign of disdain towards operators. What future can one speak of if not the disastrous one of extinction that this regulation will produce?
As a result of the above, since we have not been granted any margin of intervention to mitigate the contents of this illiberal regulation, we will be forced, despite ourselves, to protect the interests of our community, taking the appropriate measures permitted by law, and disseminating our initiatives to the press and through all social channels, so that a clear, simple and transparent regulation can be defined, as has always been in the spirit of the legislature, and when the so-called ‘Corrado Gex Law’ is approved in the Chambers of Parliament.
The Executive Board, 8 December 2023
Rinaldo Gaspari
President AOPA Italy
Thanks for the updates, Bosco.
Do you know the motive of ENAC? Why suddenly this interest from the authority for this matter?
Sure. I mentioned it in the first post. It was the “Castiadas case”. In short, a Commander 114B crashed on approach to that aviosuperficie in Sardinia in 2007. Three people died. Allegedly, the airfield data / information given to the pilot (about runway length, obstacles, etc.), and in the posession of ENAC, was incorrect / imprecise. In 2021 (a mere 14 years later!), the Italian court ruled that the responsibility was 50% with the pilot and 50% with the airfield operator, two inspectors of ENAC and one executive of ENAC! The airfield operator, an airline pilot, was condemned to several years in prison, as where the three ENAC officials.
So, it is assumed that ENAC decided that this shall never happen again and drafted a new regulation that would definitely shift all responsibility to the airfield operator and the pilot, and away from ENAC as the approving authority. Hence this new, budensome regulation.
The irony of the story is that in May of this year, just before the new regulation was finally published in June, the Cagliari Appeals Court revised the previous verdict, and fully aquitted everybody, including the ENAC officials.
As almost always with new regulations, it is all about liability…
Whose liability? ENAC’s?
Which item is actually hard to comply with? Setting up a website isn’t.
To be fair, a decent preparation for an approach into a aviosuperficie, requires more or less the Avioportolano, which is a paid private service. Many of these airfields have no public source on the internet, and the Avioportolano is dependent on input information from the aerodrome operator, in other words: Not always 100% accurate. And even when an aviosuperficie has a website, they often don’t offer decent pilot information.
Other than that, I dearly hope that those aviosuperficie fields will somehow continue operation. Many of those new ‘requirements’ seem indeed to be overkill / unnecessary or even BS, and endangers their operation. A website however, shouldn’t be a show-stopper and is IMHO a good thing, at least when decent pilot / approach information is offered.
