March 20, 2023

Special authorizations for Part 91 operators, granted through letters of authorization (LOAs), are frequently a point of confusion for flight department managers. New entrants in business aviation or management positions may be unfamiliar with the need for LOAs or the process for applying, while evolving technology and changing FAA policies compound all operators’ confusion.

To combat some of the confusion, NBAA’s Domestic Operations Committee recently developed “The Whys and Hows of Special Authorizations – Part 91 LOAs” as a resource guide for Part 91 flight department managers and others responsible for regulatory compliance.

“There’s been rapid expansion in business aviation in the last few years. Consequently, there are a lot of people who have been hired directly into a new position they haven’t held before or people who are starting new flight departments,” said Eric Canup, chair of NBAA’s Domestic Operations Committee. “When you’re thrust into that arena, you might not be aware of the need for LOAs or which you need when.”

The guide explains the history of special authorizations, current status of special authorizations, tips on applying for LOAs and frequently asked questions.

“A lot of small operators don’t have the resources or the knowledge to truly understand these authorizations. This guide will help walk an operator’s manager through the process,” said Dave Keys, chief pilot of Peace River Citrus Products and Vice Chair of the NBAA’s Domestic Operations Committee. “We wanted to provide straight-forward guidance for new entrants to business aviation, new managers and anyone who continues to find LOAs confusing.”

Finding LOAs confusing is understandable as the landscape is never static, Canup and Keys explained. Technology advancements frequently impact LOA requirements. For example, an LOA is no longer needed to use reduced vertical separation minimum (RVSM) in U.S. airspace, but an LOA is now required for controller-pilot data link communications (CPDLC) in certain areas of the world. LOA requirements also change based on FAA policy or ICAO changes as LOA names and designations change.

LOA requirements and application processes are featured in NBAA’s Small Operator Learning Series (SOLS), a series of online courses to address issues flight departments face every day. The ABC’s of LOA’s Part 1 is available now; Part 2 is coming soon.