Reduced Vertical Separation Minimum
FAA Eliminates RVSM Maintenance Program Requirement – Effective August 19, 2016
RVSM airspace exists between Flight Level 290 and Flight Level 410 over land throughout the world. In order to fly in this airspace, operators are required to submit an application for operational approval to the appropriate State authority. The FAA issues Part 91 Letters of Authorization (LOA) and Part 135 Operations Specifications (OpSpecs) for FAA registered aircraft operators. RVSM approval is issued to a combination of the Operator, the qualified pilot(s) and the specific aircraft so cannot be “transferred” to a new owner after the sale of an aircraft.
If an aircraft is operated under Part 91, it is important to determine which entity or entities are in Part 91 operational control prior to submitting an application to the FAA. (See our explanation of Part 91 operational control.) If an aircraft is to be operated under Part 91 by the owner and leased to a charter company, then both the Part 91 operator and the Part 135 operator are required to obtain appropriate operational approval from the FAA. Separate authorizations are required for each person or entity in operational control of the aircraft.
Submitting an Application to the FAA
When purchasing a new or preowned aircraft, it is frustrating to learn that the aircraft cannot be flown after closing between FL 290 and FL 410 for a period of time. Due to the unpredictability of FAA inspector scheduling and requirements, the timeframe for review of a Part 91 RVSM application could be a few days or a few months.
The FAA released updated inspector guidance in Spring 2014 in an attempt to streamline the RVSM review process. There are now three authorization groups for Part 91 RVSM applications:
- Authorization Group I: Amend an existing LOA (ie; change in primary business address, Responsible Person or aircraft N number)
- Authorization Group II: Request for a new LOA based on one or more existing approved RVSM authorization elements (ie; if the aircraft was approved by a prior operator, or the pilots were accepted under another operator’s RVSM authorization, or an existing FAA approved RVSM Maintenance Program is being used by a new operator)
- Authorization Group III: New Authorization
Jet RVSM has noticed a significant shortening of review for applications submitted under Authorization Group I. For example, an N number change can be processed within a few days.
The variation lies in the timeframe for Authorization Group II because the level of review is ultimately determined by the individual Aviation Safety Inspectors (ASI) assigned to the application. There has been a wide range in operator experiences based in individual inspector preferences.