Do I Need an LOA to operate in RVSM airspace?

Authorization is required for RVSM. However, the FAA has changed the requirements allowing some aircraft equipped with ADS-B to operate within the contiguous United States RVSM airspace without applying for operator-specific authorization. Since the guidance does not specify how an operator can verify authorization, we are still recommending that ALL operators carry an operator-specific authorization (LOA). Operations outside of the contiguous U.S., including flights to Alaska, Hawaii, Canada, Mexico and the Caribbean, still require a formal LOA application under ALL circumstances.

What is an RVSM LOA?

RVSM or Reduced Vertical Separation Minimum decreases the specified standard vertical separation of aircraft flying between FL 290 (29,000 ft) and FL 410 (41,000 ft) from 2,000 ft to 1,000 ft minimum. This allows more aircraft to fly safely in a particular airspace.

Since this type of operation requires aircraft to be equipped with certified equipment and crews to have specific training, operators need to gain permission to fly in RVSM airspace. That’s where the LOA comes into play. LOAs grant aircraft operators the FAA’s authorization to exercise particular activities, in this case RVSM.

What’s changed?

As of January 22nd,2019, the RVSM LOA is considered to be automatic for operators with a compliant ADS-B system and will not be formally issued unless applied for. This change allows some operators to skip the application process but DOES NOT exempt having an authorization. Due to a certain amount of current ambiguity, in order to demonstrate proof of authorization, we are still recommending that ALL operators carry an operator-specific authorization (LOA).

As of now, if you meet all of the following criteria you are theoretically automatically authorized and do not need to submit a formal LOA Application:

  1. Your aircraft is fitted for ADS-B Out, and is transmitting sufficient ADS-B data;
  2. Your ADS-B Out system is compliant with 14 CFR 91.227;
  3. Your aircraft is maintained in accordance with all the mandatory maintenance tasks (such as air data and transponder checks) and is meeting height monitoring specifications;
  4. Crews are trained in RVSM;
  5. The crew has no other need for a specific document confirming they are RVSM-authorized;
  6. You do not ever operate outside of the contiguous United States.

It is critical to keep in mind that noncontiguous, foreign and international airspaces (including Alaska, Hawaii, Canada, the Caribbean and Mexico) still require formal authorization: any operator who intends to conduct international flights still needs to apply for the RVSM LOA.

If you are not able to answer yes to all 6 items then you will need to apply for the RVSM LOA. This may include your operation if ANY of the following applies:

  • You intend to fly in RVSM airspace outside the contiguous 48 United States;
  • You still have to install ADS-B Out, or you have any reason to doubt that sufficient ADS-B data is being broadcast;
  • Your ADS-B system does not comply with 14 CFR 91.227;
  • You need direct evidence that you are specifically authorized for RVSM, for any reason.

Also, if your aircraft is not yet equipped with ADS-B Out – don’t forget that deadline is looming so make sure your aircraft is equipped by January 1st, 2020.

How will this progress?

For now, there has been no further discussion on whether other countries will be following suit after the FAA’s decision, nor whether the automatic authorization is internationally recognized. However, it is unlikely other countries will follow without the benefit of certain processes to verify specific airframes and their ADS-B data.

Whether the FAA will be publishing a database of operators or aircraft presumed to be automatically authorized has not yet been discussed. But if this does progress and is accepted by other countries, there might be an application-free future peeking on the horizon. AviationManuals will be keeping an eye on international operations and watching this space to provide you with the latest updates.

We still recommend carrying an RVSM LOA until further clarification from the FAA. Still need an LOA package, application, or an RVSM Operations Manual? We can help.

What Should You Do to Respond To the Data Link LOA A056 Changes

The FAA introduced a new template for LOA A056 for Data Link communications in November 2017. The new template adds two pieces of information that were not previously tracked. The changes focus on the PBCS capabilities, in order to meet the March 29, 2018, PBCS implementation, and the name of the service provider used for Data Link services for each aircraft.

Here are four paths to take when responding to the Data Link LOA changes, depending on your status:

I already have an approved LOA A056 and it is in the new format:

  •  You are in compliance with both the PBCS implementation and Data Link mandate already. No further action is needed.

I already have an approved LOA A056, but it is not yet in the new format:

  • Fill out a new A056 application and ask FSDO to reissue your A056 in the new format.
  • In rare cases your FSDO may issue you the new LOA A056 without a full resubmission. Be sure to speak with your inspector to get a better idea of what exactly they would like you to submit.

I do not have an approved LOA A056, but have submitted an application OR I have submitted a request to add a new aircraft to my LOA A056:

  • Be sure your submission has been prepared using the FAA’s newest format.
  • If you submitted prior to November 2017, and your request hasn’t been approved yet, you will need to re-prepare and re-submit.

I do not have an approved LOA A056, and have not yet applied:

  • Be sure to have your aircraft upgraded to meet Data Link requirements as soon as practical if you intend to keep operating in the NAT. Right now, Data Link is required for any NAT operations at FL340 to FL390.  Beginning in January 2020, Data Link will be required for all NAT operations at FL290 and above.
  • Apply for an LOA A056 using the FAA’s newest format.

To learn more about how AviationManuals can help, contact us today.


MEL 2017 in Review

With numerous changes to Minimum Equipment Lists (MELs) having gone into effect in 2017 and with more to come in 2018, now is a great time to ensure your MEL is up-to-date and compliant.

The most notable change last year was the enforcement of the ICAO Annex 6 and EASA requirements requiring operators to have a specific MEL for their aircraft when operating to or from EASA member states.

U.S. Part 91 twin turboprops and jets flown in Europe are now required to operate with an MEL developed for a specific aircraft under Letter of Authorization (LOA) D195, rather than with a manufacturer’s aircraft model Master MEL (MMEL) approved by the FAA under LOA DO95.

In addition, there were also a number of required revisions introduced to FAA Master MELs and policy letters during the course of 2017.

Check the list below to see if your aircraft is on it. If so, you will need to make sure that your MEL is up-to-date. Operators have 90 days from the date of the MMEL to revise their manuals.

What’s new in 2018?

This year, we expect to see significant changes to MELs for U.S. Part 91 operators and further updates to MMELs. So far, there have already been two updates to MMELs in 2018, including for the Citation 500 series.

The FAA is reportedly planning to release a Notice requiring all aircraft operating internationally to have an individual MEL and D195 LOA. It is also anticipated that EASA will announce that, while they will continue to enforce the D195 LOA mandate for U.S. Part 91 operators, they will grant a 12-month grace period to allow operators time to comply.

Revised FAA MMELs include:

  • Boeing 737 – Rev 59 – 02/13/2017
  • Challenger 600 – Rev 10a – 01/06/2017
  • Falcon 7X/8X – Rev 11 – 11/06/2017
  • Falcon 900EX EASy, 900DX – Rev 8 – 01/19/2017
  • Embraer EMB-500 (Phenom 100) – Rev 3 – 05/11/2017
  • Embraer EMB-545 / EMB-550 (Legacy 450, Legacy 500) – Rev 2 – 07/28/2017
  • Gulfstream G280 – Rev 3 – 10/31/2017
  • Gulfstream V Series – Rev 9 – 12/18/2017
  • Cessna Citation 500 Series – Rev 10 – 01/03/2018

Policy letter changes include:

  • Navigation Database text – 6/1/2017
  • Protective Breathing Equipment (PBE) – 12/4/2017

Can You Take Off with a Broken Cup Holder?

NEF, MMEL, LOA, MEL, aviation, business aviation

Nonessential Equipment and Furnishings Program (NEF): Allows operators to use the deferral authority granted in the MMEL to provide relief for inoperative, damaged, or missing nonessential items.

Operators who hold an LOA authorizing the use of an MMEL as an MEL or a customized MEL can only defer items listed in their MELs or via their NEF Program. Therefore, if an operator does not have an NEF Program, any inoperative nonessential items must be operative for flight.

Need an NEF Program to cover your cup holders? Let AviationManuals support you.

10 Facts About Letters of Authorization (LOAs)

Just because you have one or two LOAs stored in your aircraft doesn’t mean you understand them. AviationManuals gets to the facts.

Although LOAs are a common requirement for Part 91 operators, there remains considerable confusion as to the details.

To clear the air, let’s look at some LOA facts.

Learn More: LOAs – what they are, who they’re for and how to get them

  1. An LOA is tied to the aircraft and operator, not the documentation.
    Whenever an aircraft is sold or the operator changes, you must apply for a new LOA. If, however, the only change is to the documentation supporting the LOA (i.e., training certificates or operations manuals), then you do not need to apply for a new LOA.
  2. LOAs do not expire.
    Yes, way back when Reduced Vertical Separation Minimum (RVSM) was a new thing, LOAs came with an expiration date. However, this is no longer the case except in rare circumstances. Therefore, you do not need to renew LOAs on a regular basis.
  3. Get it. Store it.
    LOAs are typically ‘one-and-done’. Once you have it, stick it in your aircraft and leave it well enough alone. There’s rarely – if ever – a need to follow up with your Flight Standards District Office (FSDO). In fact, there’s only two reasons to speak to an FSDO about an existing LOA: to add an authorization (such as a new aircraft or capabilities) or to revise its information.
  4. The FAA has authority to pull an LOA.
    The FAA does have the authority to revoke an LOA. However, it is unusual for them to exercise this authority. For example, if you report an incident to the FAA, they could place a hold on an LOA while reviewing your records.
  5. Only an operator (or their authorized representative) and the FAA have the authority to withdraw an LOA.
    In other words, unless specifically authorized to do so, a third party cannot request that your LOA be withdrawn.
  6. Part 91 operators don’t need to have IOMs regularly reviewed by the FAA.
    Part 135 operators must have all changes to the IOM submitted as they happen.
    Although the FAA doesn’t require Part 91 operators to update IOMs, they do expect you to stay current on changing procedures. Therefore, it is highly recommended that you invest in an update service.
  7. You do not have to notify the FAA when you switch manual vendors.
    You can change your vendor to your heart’s content without ever giving notice to the FAA. That being said, it’s always a good idea to inform your Principal Operations Inspector (POI) about any changes.
  8. RVSM maintenance programs are no longer required.
    The days of the RVSM maintenance program are gone, so you can stop maintaining them.
  9. If you’re worried about losing an LOA when switching manuals, consider starting your manual as an additional IOM.
    While the additional IOM is being reviewed, keep your current manual as is. Once you get the ok from the FAA, cancel the old service. This eliminates any ‘gap’ that could be misconstrued as being non-compliant with your LOA. Even though you would never actually be non-compliant, this strategy gives you an additional layer of support.
  10.   If you do run into trouble, seek the advice of an experienced, responsive vendor like AviationManuals.

To learn more about how AviationManuals can help, contact us today.

You Don’t Need an LOA for RNAV… Unless You Do!

Part 91 operators aren’t required to obtain a Letter of Authorization (LOA) for RNAV or GPS-based ILS procedures (also called RNP APCH). So why does the FAA offer such an LOA – what’s the point? AviationManuals explains.

In the US, RNAV procedures are commonplace. That’s because the FAA’s Wide Area Augmentation System (WAAS) – a Satellite Based Augmentation System (SBAS) that augments GPS to improve its accuracy, integrity and availability – has been helping pilots land at small and regional airports around the country for years. Because of this history, Part 91 operators do not need a Letter of Authorization (LOA) to use RNP APCH procedures within the US.

Outside the US, however, it’s a different story.

As SBAS is so effective at opening up small and regional airports to general and business aviation traffic, many other regions are now building their own SBAS systems. For example, Europe’s EGNOS system is already fully operational and capable of augmenting both GPS and Galileo signals.

First the good news…

For international operators, the good news is your WAAS-capable avionics is most likely fully compatible with many of these other systems, so you can already take advantage of these new satellite-based procedures.

The not so good news, however, is that in order to do so, you first have to show that you are authorized to fly RNAV procedures.

This is because unlike in the US, in Europe, for example, these procedures are a relatively new concept that require not only that an aircraft have the corresponding airworthiness approval, but also that the pilots have the appropriate training, checking standards and operational procedures in place.

You can’t go wrong with an LOA

Although in Europe, EASA is working to amend some of these regulations, as a general rule, all operators are required to follow the necessary operational procedures. CAT operators must therefore amend their operational manual accordingly as part of their air operator approval. But don’t worry, there’s no additional training required. All you need to do is to get an LOA C052 from the FAA, which shows that your aircraft is capable of SBAS-augmented approaches.

If you frequently conduct international operations, it’s probably a good idea to add this authorization to your LOAs. On the one hand, this covers you in any country that does require specific authorization for RNAV procedures, such as Hong Kong. On the other hand, even where such authorization isn’t required, a country, such as the UK, may require you to have a valid state authorization in order to use MDA as a DA/DH with the approach. The MDA as DA/DH authorization is given under LOA C073, and a prerequisite for this is – you guessed it – the C052.

AviationManuals is able to assist you in obtaining both a C052 and C073 authorization. The overall process is simple and affordable and dovetails easily with your existing International Operations Manual. Contact us today for a quote.