Jan. 23, 2020

NBAA participated on an FAA and industry working group, co-led by the General Aviation Manufacturers Association (GAMA) and the Flight Technologies and Procedures Divisions, which recently issued a final report to FAA including six recommendations to streamline and expedite the current process for issuing Letters of Authorization (LOA) for communications, navigation and surveillance for Part 91 operators.

“Many members have expressed frustration after taking ownership of a brand new, technologically advanced aircraft and the delay until they are able to fully utilize that aircraft due to the wait for required LOAs,” said NBAA Director, Flight Operations and Regulations, Brian Koester, CAM. “We hope these recommendations will help reduce those delays.”

The working group noted that the sophistication, complexity and rapid evolution of aviation technologies places an undue burden on the FAA. Streamlining the process for the most requested authorizations by Part 91 operators, the group concluded, would reduce demand on the FAA and produce the largest benefit for the business aviation industry while maintaining the safety of the largest aerospace system in the world.

“Each Part 91 LOA application requires a review and approval of three essential elements: aircraft capability, pilot training and an operator’s procedures,” said Koester. “The working group identified key areas for improvement that would offer authorizing FAA inspectors an alternate, streamlined method to review and issue a letter of authorization. We are excited about the changes to come and look forward to working with the FAA to ensure these recommendations are introduced smoothly and quickly.”

The six recommendations are:

  1. GAMA should develop an Aircraft Statement of Capability template and release it online for use by aircraft manufacturers free of charge.
  2. Aircraft manufacturers should develop Aircraft Statement of Capability documents using the industry template.
  3. Manufacturers providing an Aircraft Statement of Capability also should establish a process to maintain and update the document.
  4. The FAA should consider the aircraft make, model and series, serial number or operator name rather than an aircraft’s registration number when reviewing a Part 91 operator’s application.
  5. The FAA should create and/or update all guidance material necessary to create a new LOA Training Statement of Compliance form for international operations training providers.
  6. The FAA should develop an additional process to provide a statement of compliance for vendors that sell International Operating Manuals to Part 91 operators.

Initially, these recommendations will apply only to new aircraft delivered to operators once the new policies have been implemented.

View the recommendations. (PDF)