Streamlined Letters of Authorization (LOAs): Good News, Part 1

One of my favorite parts of each annual NBAA International Operators Conference (IOC) is the “Meet the Regulators” session, a chance to ask FAA inspectors questions and, more often than not, to complain about how “they” are making life more difficult for “us.” For many years, one of the first questions was sure to be about the Letters of Authorization (LOAs) needed to fly internationally.  

“We bought a brand-new aircraft that has already been FAA approved, we have been trained by a Part 142 school that has already been FAA approved, and the international procedures we provided came from a vendor who is also FAA approved. Why does all of this have to get approved again for us to get the authorizations to fly our aircraft?”

The answer has become routine: “We know the system is broken, but a fix is in the works.” 

That was sure to rile up the audience, many of whom couldn’t resist the urge to pile on with the complaints. Three years ago, the frustrated inspector admitted that the average wait for an operator to receive LOAs for a new aircraft was nine months. The record, he said, was an amazing four years. Two years ago, the same inspector showed up with good news, saying a fix was just about ready. For the 2023 IOC, he returned to say that not only was the fix in place for new aircraft, a similar plan was in the works for “previously owned” aircraft.

Awash In A Sea Of Paperwork
So, what is the big deal about LOAs? To understand the need for these kinds of authorizations, you need to look back to the days before the FAA. Early U.S. Civil Air Regulations provided for Operations Specifications (OpSpecs) that added to information relating to a commercial operator’s services, routes, aircraft, maintenance, airmen and weather procedures. OpSpecs were appended to and considered part of the operating certificate. Since then, LOAs have taken on similar importance to Part 91 operators, but as the need for LOAs evolved, so did the process for obtaining them.

I completed my first LOA application in 2000; it was little more than a letter requesting authorization to fly in Reduced Vertical Separation Minimum (RVSM) airspace. I followed the guidance in the RVSM Advisory Circular, and our LOA was quickly issued. Back then, the RVSM LOA had to be renewed every two years and the process changed for the next go around. Flight departments started circulating example templates, but because individual FSDOs had different ideas on how an application should look, these templates were not as helpful as they could have been. 

Savvy operators discovered that the guidance used by FAA inspectors when reviewing LOA applications could also be a help when writing the application itself. The latest innovation came in the form of application guides. Users filled in the needed information in provided blank spaces and tables and then appended any requested attachments.

I submitted my first full set of LOA applications in 2009, requesting eight LOAs for a brand-new Gulfstream G450. I found several helpful templates and some guidance in a few advisory circulars. The formatting of the templates was inconsistent, but each represented what the applicable reviewing agency expected. But that didn’t matter, as each FSDO was free to use their own formats.

I wasn’t surprised by this since the application guessing game has been a part of the LOA process almost from the beginning. In the last several years, a few application guides for selective LOAs provided much needed guidance, but these were the exception.

Now there is good news on this front. We have standardized application guides for the “top 10” LOAs with more to come, all available in one spot. You will need to use the FAA’s Operational Approval Portal System (OAPS) to download the guides. You can request an OAPS account at https://oaps.faa.gov/. Even if you already have bootleg copies of the application guides you need, using OAPS ensures you have the latest versions.

A Streamlined Process For New Aircraft
Even with standardized formats and greatly improved guides, LOA applications tend to be very large, requiring huge extracts from things like your aircraft flight manual (AFM), international operations manual, master minimum equipment list (MMEL) and other sources. Because each application stands on its own, there is a lot of duplication of those extracts when applying for multiple LOAs. Our last effort for six LOAs totaled over 1,300 pages. Filling out the application guide forms and combing through your manuals to cut and paste the requested material takes a lot of time. Our last effort took over 100 hours to complete. But, as we found out during this year’s IOC, a fix is in place for new aircraft.

After years of effort, the FAA has a working solution for Part 91 operators who have purchased new aircraft from the manufacturer. As of February 2023, there have been 160 applications processed using the new “Streamlined Part 91 Operational Approvals” process. The streamlined process requires far less documentation, reduces duplicated effort, and has had a turnaround time of as little as just a few days but rarely more than a few weeks. (The official goal is to have the LOA in your hands on the date of aircraft delivery, plus or minus 60 days.)  Further good news: the FAA is working to expand this program for pre-owned aircraft. This single application can be used to get up to 10 authorizations:

•    A056: Data Link Communications
•    B036: Oceanic and Remote Continental Navigation Using Multiple Long-Range Navigation Systems (M-LRNS)
•    B039: Operations in North Atlantic High-Level Airspace (NAT HLA)
•    B046: Operations in Reduced Vertical Separation Minimum (RVSM) Airspace
•    B054: Oceanic and Remote Airspace Navigation Using a Single Long-Range Navigation System
•    C048: Enhanced Flight Vision System (EFVS) Operations
•    C052: Straight-In Non-Precision, Approach Procedure with Vertical Guidance (APV), and Category I Precision Approach and Landing Minima - All Airports
•    C063: Area Navigation (RNAV) and Required Navigation Performance (RNP) Terminal Operations
•    C073: Vertical Navigation (VNAV) Instrument Approach Procedures (IAP) Using Minimum Descent Altitude (MDA) as a Decision Altitude (DA)/Decision Height (DH)
•    D195: MMEL used as an MEL

In Part 2 of this article, we describe the steps involved in applying for LOAs through the FAA’s new streamlined process.