Feb. 24, 2021

Letters of authorization (LOAs), Brexit and other general operations issues sometimes create a confusing business aviation regulatory environment. Experts provided NBAA GO Flight Operations Conference attendees insight on these and other regulatory issues.

Presenters were:

  • Jason Maddux, Garafalo, Goerlich, Hainbach, PC
  • Aoife O’Sullivan, Kennedys
  • Trent Biggler, FAA
  • Merrill F. “Jazz” Armstrong, FAA
  • Eric Parker, FAA
  • Christopher (Scott) McLellan, FAA
  • Justin Maas, Gulfstream Aerospace Corp.
  • Darrel Sheets, NetJets

Letters of Authorization

Maas explained 10 LOAs are typically needed for a Part 91 operator to fly around the world. An industry/FAA working group set out several years ago to streamline the process by standardizing many of the common LOA application information covering aircraft capability, training and operator procedures.

According to Maas, the group found “striking efficiencies,” which together will cut down on the typical processing time.

Parker said the template statements of compliance are a “fundamental change in how the FAA has traditionally done business,” resulting in a must more efficient process without the need for higher-level office coordination.

The initiative is now in beta testing, which should take about six months before incorporating lessons learned and then rolling out to more operators.

Review: NBAA Joins Industry Groups Offering Solutions to Streamline FAA’s Part 91 LOA Approval Process.

International Initiatives

Bigler shared a number of resources for international operators and introduced attendees to the Operations Specifications Working Group, an industry/FAA group focusing on Operations Specifications updates and revisions. Meetings are open to the public and all operators are encouraged to participate.

Currently more than 140 Part 135 operators hold third-country operator (TCO) authorization, allowing operations in European Union member states. The top TOC authorization findings from 2020 involve safety management systems, upset prevention and recovery training, flight data analysis programs, pilot proficiency checks and fuel planning, Bigler reported. Review NBAA’s TCO resources.

FAA Information for Operators (InFO) 20003, published May 18, 2020, provides more information about the European Union Ramp Inspection Program (previously Safety Assessment of Foreign Aircraft – SAFA), which is currently utilized by at least 49 countries. Review the InFO.


Following the long-awaited withdrawal of the United Kingdom (UK) from the European Union, which culminated on Dec. 31, 2020, the two parties signed an agreement addressing high-level aviation policies. However, O’Sullivan emphasized work remains in developing processes for the UK Civil Aviation Authority and EASA to manage these issues.

Bilateral agreements between the U.S. and UK, or between the U.S. and EU ,establish policies for U.S. operators in those countries or vice versa, though U.S. operators should consider cabotage implications when planning UK and EU operations.

Review NBAA’s international operations resources.