Response to the request

Valge 4 / 11413 Tallinn / 620 1200 / [email protected] / www.transpordiamet.ee

Registrikood 70001490

Raino Tubli

Smartlynx Airlines Estonia

OÜ

[email protected]

Lennujaama tee 13

11101, Tallinn

Your ref 21.02.2024 no 1.1-10E/2024

Our ref 22.03.2024 nr 3.3-6/24/3014-2

Response to the request

Dear Mr. Tubli

The legislation you are referring to are. We specify that the Civil Service Act and regulation of the

Government of the Republic, establishes requirements for the Estonian Transport Administration,

which we specify in our internal management system document “Lähetuskord”.

According to Aviation Act § 602 lg 2 p 6 states that where the Transport Administration exercises

supervision over the person specified in subsection 2 of § 601 of this Act or a civil aircraft or flight

simulation training device in a foreign country, the specified person or the operator of the civil

aircraft or flight simulation training device bears the secondment expenses of supervisory officials

of the Transport Administration that are calculated pursuant to the procedure established on the

basis of subsection 5 of § 44 of the Civil Service Act.

It's means that the provision to imposes an obligation to the person (i.e. operator) of supervision

to cover the travel expenses of the supervisory officer of the Transport Administration, but does

not establish the procedure how to cover the travel expenses.

The purpose and necessity of the agreement is do lay down the conditions for it (who, when, what

and how). Therefore, there is nothing different in the agreement than provided for in the Public

Information Act, a regulation of the Government but do provide necessary level of transparency

and to protect both parties. In addition, the agreement is a mechanism to avoid a possible conflict

of interest.

Thank you for your request, and I hope you find these clarifications sufficient.

Yours sincerely

(digitally signed)

Üllar Salumäe

Director

Aviation Division

Anastasia Levin 55943074, [email protected]