Frequently asked questions
A Letter of Authorization (LOA) is an approval document issued to a Part 91 operator by the FAA granting them to conduct certain operations. Below is a list of the most common LOAs issued to Part 91 operators.
This is the most common question we get! The FAA targets 60 days to review and issue LOAs, assuming there are no significant findings or issues with the submission. The time frame could be shorter or longer depending on FAA inspector availability and scheduling and the quality of the submission. Part 91 LOAs are every FAA office's lowest priority task, as "higher level" safety assignments take priority (such as 121, 129, 135 management, accident investigations, pilot action, etc). We have seen some LOA requests take 24 hours and others take eight months due to lack of FAA office inspector staffing and availability.
The FAA does not offer an expedite process for Part 91 LOA requests. They do, however, offer a streamlined LOA application process for operators who meet specific criteria with newly manufactured aircraft delivered from the factory within 60 days.
As was recently communicated to Jet RVSM from a FSDO, the FAA is concentrating resources on oversight of certificate management that has the highest (safety) risk. Part 91 LOA’s are not certificate management and are at the bottom of the FAA priority list, and as a result, everyone suffers because the FAA doesn't have the staff to address these in what you would consider a reasonable time frame.
The LOA does not expire, but it can become invalid for any of the following reasons:
The operator named on the LOA ceases to be the operator (sells the aircraft or no longer leases the aircraft);
It is voluntarily surrendered to the FSDO for cancellation;
It is canceled, rescinded or revoked by the FAA;
The Responsible Person signing the LOA relinquishes responsibility;
The aircraft or equipment identified on the LOA is no longer used for the operation;
The aircraft listed on the LOA changes its' registration number; or
The aircraft listed on the LOA is issued an experimental Special Airworthiness Certificate for research & development.
When you change your N number, the FAA-issued LOAs must be updated to the new N number, reissued by the FAA, and signed by the FAA and LOA Responsible Person. B046, D095 and D195 LOAs identify the aircraft registration number. They become invalid for use the moment the new N number is placed on the aircraft and the transponders are re-strapped.
The LOAs can be updated by submitting an "administrative change" request to the FAA office that issued the authorizations. A copy of the reissued airworthiness certificate identifying the new N number along with either the registration hard card or signed/dated 8050-64 form must be submitted along with the formal letter of request. The FAA will update the LOAs, sign them, reissue them and send them to the LOA Responsible Person for signature. The LOAs are valid for use again when the FAA receives the signed LOAs back from the Responsible Person. The new LOAs must be placed onboard the aircraft and the old LOAs must be removed.
If the operator changes an address identified on the LOAs as either the Principal Base of Operations Address or Mailing Address, it must notify, in writing, the FAA office of its new location and mailing address within 30 calendar-days following relocation.
If the new Principal Base of Operations Address falls within another FSDO's service area, the operator must notify the losing FAA office that the LOAs must be transferred to the FAA office that services their new address. The losing FAA office must transfer the LOAs to the FAA office that services the new address. The LOAs will be updated, reissued and sent to the LOA Responsible Person for signature.
The person identified to sign the LOA is referred to as the "LOA Responsible Person". This person must have legal authority to sign the LOA on behalf of the operator and meets the following requirements:
Has ongoing knowledge of the operations & maintenance status of the aircraft;
Be either the individual who acts as operator, or if the operator is a company/entity, must be an officer, employee or person designated to act on behalf of the operator;
Assumes responsibility for ensuring the operator complies with all applicable regulations, requirements, limitations and provisions of the LOA.
If the LOA Responsible Person is no longer involved in the flight operations of the aircraft, the LOAs become invalid and must be updated, reissued and signed with the new LOA Responsible Person's name, email address and phone number. The FAA identifies this as an "administrative change request".
This information is extracted from AC91-85B Section 5.7
The answer to this question depends on where you operate and your aircraft capabilities. The following is general information. Refer to the State AIP for specific LOA requirements for each country you plan to operate in.
If you fly a turbine powered aircraft within the contiguous U.S. 48 states, the only LOA you need is an MMEL LOA D095 or MEL LOA D195 to defer maintenance of inoperative equipment (see 14 CFR 91.213).
If you plan on flying outside U.S. controlled airspace, you will need an RVSM LOA to fly between FL290-410. There are also additional LOAs required depending on where you fly.
If you plan on flying in the Pacific, you will need an RVSM and RNP-10 authorization. There are some routes that require CPDLC equipment as well. If your aircraft is equipped with FANS 1/A+ datalink, you will need a CPDLC LOA.
If you plan on flying in the North Atlantic, you will need RVSM, RNP-10 and NAT HLA authorizations to fly between FL285-420 along the Blue Spruce Routes. If your aircraft is equipped with FANS 1/A+ datalink you will also need a CPDLC LOA to fly the Datalink Mandate routes.
EASA countries generally require an RNAV-1/RNP-1 LOA for RNAV-1/RNP-1 arrivals and departures, and an LNAV/VNAV/LPV LOA to conduct LNAV/VNAV/LPV approaches.
Below is a list of common Part 91 LOAs:
