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Regulatory Hot Topics

Streamlined Process for Part 91 LOAs Coming Soon

A streamlined process for Part 91 operators to obtain Letters of Authorization (LOAs) may be available in early 2022, the result of a working group of FAA and industry representatives, including several NBAA members.

For several years, Part 91 operators have reported that the process for issuing LOAs has varied from one FAA office to another, or even one inspector to another. Also, the process often resulted in a vendor’s aircraft manual or training course being reviewed hundreds of times by different FAA offices after having already been accepted through the agency’s oversight and certification of training centers and manufacturers.

These inconsistent and duplicative processes often led to significant delays, particularly for newly delivered aircraft, making them unable to operate as designed for weeks or months while awaiting the completion of the LOA issuance process following delivery. Essentially, a piece of paper – or lack thereof – was keeping aircraft from operating as efficiently as possible.

Aircraft manufacturers have had a front row view of the frustrating process.

Jens Hennig, vice president of operations at the General Aviation Manufacturers Association, noted, ”Following our joint work with NBAA to refine the LOA process for RVSM operations in 2013, several of our OEMs asked that we build on that success and review the 10 most common authorizations needed for today’s communications, navigation, and surveillance requirements. FAA’s leadership agreed and three years ago we kicked off a work activity jointly between the agency, representatives from its workforce, operators, training centers and aircraft manufacturers to review the process with the goal of developing a more streamlined approach to authorizing these operations.”

The FAA Reauthorization Bill of 2018 reinforced the activities of the working group and directed the agency to evaluate LOA processes to reduce costs and delays. Subsequently, the working group identified three areas to be evaluated by inspectors and then developed standards to ensure compliance in these areas:

  • Aircraft capabilities
  • Pilot training
  • Operating procedures

“We tried to standardize the process, to take it from a very local, dispersed process to a more consistent process at the national level,” said Paul Scurio, a member of NBAA’s International Operators Committee and the LOA working group. “The bottom line for the operator is a much easier to use process that will allow them to fly a brand-new aircraft as intended, domestically and internationally, as quickly as possible after delivery, substantially minimizing delays.”

Justin Maas, industry chair of the working group, says he can’t speak highly enough of the collaboration between industry and AFS-400, the FAA office responsible for LOA policy.

“The FAA really listened to industry, then took the feedback and developed a better process, working with industry,” said Maas. “It’s really about compliance and helping everyone be above board. Now, inspectors can be confident in their authorizations, and operators can be more efficiently ensconced in compliance.”

The working group provided its recommendations to the FAA in early 2020. The agency is currently testing the streamlined process. The FAA’s new web page for the streamlined process features an applicant guidebook, establishing expectations for both the agency and operators. The guide also will serve as a “force multiplier,” enabling one inspector to do more, consistently and safely.

Review NBAA’s LOA resources at nbaa.org/loa.

Industry Challenge

The application process for Part 91 operators to obtain letters of authorization is inconsistent from one FAA office to the next, resulting in inefficient use of time and resources for both the industry and the FAA.

NBAA Response

NBAA, its members and other trade associations continue to work with the FAA to streamline and improve the LOA process for both operators and FAA inspectors.

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