Earlier this year, a joint FAA/industry working group issued a final report to the agency that included 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 NBAA members have expressed frustration that, after taking ownership of a brand-new, technologically advanced aircraft, they are unable to fully utilize that aircraft’s capabilities due to the wait for required LOAs,” said Brian Koester, CAM, NBAA’s director of flight operations and regulations. “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. Therefore, the group concluded that streamlining the procedures for the most-requested authorizations by Part 91 operators would result in a more efficient process that effectively uses FAA and industry resources, while maintaining safety.
“Many NBAA members have expressed frustration that, after taking ownership of a brand-new, technologically advanced aircraft, they are unable to fully utilize that aircraft’s capabilities due to the wait for required LOAs”
Brian Koester CAM, Director of Flight Operations and Regulations, NBAA
“Each Part 91 LOA application requires a review and approval of three essential elements: aircraft capability, pilot training and an operator’s procedures,” explained Koester. “The working group identified key areas for improvement that would offer authorizing FAA inspectors an alternate, streamlined method to review and issue an LOA.”
The six recommendations are:
- The General Aviation Manufacturers Association should develop an “Aircraft Statement of Capability” template and release it online for use by aircraft manufacturers free of charge.
- Aircraft manufacturers should develop “Aircraft Statement of Capability” documents using the industry template.
- OEMs providing an “Aircraft Statement of Capability” also should establish a process to maintain and update the document.
- 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.
- The FAA should create or update all guidance material necessary to create a new “LOA Training Statement of Compliance” form for international operations training providers.
- 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, the policies carrying out these recommendations will only apply to new aircraft. The group hopes to expand the program shortly after proving these concepts increase efficiency.
“We look forward to working with the FAA to ensure these recommendations are introduced smoothly and quickly,” concluded Koester.
The current process for FAA issuance of Part 91 LOAs is insufficient to meet industry demand. To enable the operational implementation of NextGen and other advanced capabilities, it is necessary to improve the authorization process.
NBAA led and participated in multiple FAA/industry working groups and aviation rulemaking committees to improve the LOA approval process.