Streamlined Letters of Authorization (LOAs): Good News, Part 2

To get started on the FAA’s new streamlined process, you will need to sign up for an OAPS account with your FSDO or online at https://oaps.faa.gov/ where you can also download the “Streamlined Part 91 Operational Approval” application template. You will also need to obtain an Aircraft Statement of Capability (ASOC), a Training Statement of Compliance (TSOC) and a Procedures Statement of Compliance (PSOC).

The ASOC, provided by your aircraft manufacturer, shows that your aircraft meets the requirements of the LOAs you are applying for. The TSOC(s), provided by your training vendor(s), prove that you have been trained as required by the applicable LOAs. The PSOC(s), provided by other vendors, prove that the procedures you are using comply with the applicable LOAs.  A good example of a PSOC is one provided by a vendor who wrote your international operations manual, proving you are using the correct procedures for the North Atlantic needed by LOA B039.

You will need a flight plan that is representative of what the LOAs allow you to do, and the flight plan needs to reflect the aircraft covered by the LOAs. A flight plan from your service provider certainly works, provided it meets those criteria and is on FAA form 7233-4. Sample flight plans are often rejected because of incorrect aircraft equipment codes in Block 10 and Block 18. 

Another error which trips up many applicants is the format of fuel requirements in the flight plan. The rules for alternate fuel under ICAO are different than for the FAA, and you must use ICAO rules for your LOAs. Destination alternate fuel, for example, must include fuel to go missed approach at the destination, climb to an expected altitude, fly an expected routing, and conduct an approach and landing at the destination. (An “as the crow flies” routing will not be acceptable.)  

Contingency fuel seems to trip people up too. Not only must it be at least 5% of the planned trip fuel, it must be obviously labeled, such as “CONT FUEL” to be counted as such. The same is true with final reserve fuel. Appendix B of the application guide goes into more detail about flight plan codes and fuel requirements.

If you are applying for A056, Performance-Based Communication and Surveillance (PBCS), you will need to apply for PBCS Global Charter Membership. You can join online at https://www.fans-cra.com/charter/stakeholders/.  You will need to attach a screen grab proving your membership to your application.

The application guide will walk you through how to attach documents and provide more information about the various parts of the application.  You will submit the application through OAPS.

Standardized Application Guides, Streamlined Processes…Usually
Chris Morris, an FAA Oceanic Specialist (AFS-10) spoke to the 2023 NBAA International Operators Conference about the streamlined process and admitted that not all FSDO inspectors are familiar with the streamlined process and that Part 91 LOA applications remain the lowest priority FSDO task. To those points I would add that not all FSDOs are created equally.

While most FSDOs appear eager to support their flight departments with every available tool to navigate the LOA process, some are known to be combative in their attitudes. A principal inspector once told me, “The FAA is comprised of 77 FSDOs, each one is independently owned and operated.” I cannot explain why there are a few rogue FSDOs out there, but I can tell you that you are not restricted to using the closest FSDO.  If your FSDO has a record of nonperformance, you can (and should) take your business elsewhere.
 
If, on the other hand, you have a good relationship with your FSDO and have had success in the LOA process, the news is all good. There are more and more application guides which have made the process for previous-owned aircraft far more standardized and easier to complete. If your application is for a brand-new aircraft, the news is even better. The streamlined LOA application process is here and is already producing an impressive number of success stories.

Streamlined Letters of Authorization (LOAs): Good News, Part 1: https://aviationweek.com/business-aviation/airports-fbos-suppliers/stre…;