Do I Need an LOA for ADS-B Out?

Countries can set their own requirements for authorizations for ADS-B Out operations. A few years ago, the FAA discontinued the ADS-B Out LOA (A153) and no longer issues authorizations to US operators. However, we recommend that US operators carry a copy of Notice 8900.491 to show to foreign inspectors if they are requested to provide authorization. In essence, Notice 8900.491 is provided by the FAA to summarize why it no longer provides authorizations for ADS-B Out.  It is important to note that an LOA is still required for most ADS-B In operations.

Setting the scene

Back in 2010, the International Civil Aviation Organization (ICAO) determined that operators needed to request operational approval for Automatic Dependent Surveillance-Broadcast (ADS-B) Out from their Civil Aviation Authority (CAA). While the FAA never required an LOA to use ADS-B Out in the United States, they previously issued OpSpec/MSpec/LOA A153 or A353 to satisfy foreign CAAs that did require authorization.

However, in September 2015, ICAO Member States adopted new guidance that gradually phased out operator authorization requirements to use ADS-B Out. As stated in Notice 8900.491, “continuous monitoring of equipment performance has proven to be the most effective means of oversight.” By overseeing the data of ADS-B Out, the FAA and other CAAs can identify aircraft performance. Any aircraft with a negative safety impact on Air Traffic Control could be restricted from flying in airspace requiring ADS-B Out. Additionally, with rising demand in OpSpecs, MSpecs, and LOAs, the FAA has become understandably stretched. Removing the need for any LOA can help minimize the burden placed on both regulators and operators.

What has changed for the ADS-B Out LOA and what should I do?

The FAA decommissioned OpSpecs/MSpecs/LOAs A153 and A353, also known as the ADS-B Out LOA in 2019. No action was required then (nor is required now) on the part of US operators. However, it’s strongly advised to carry a copy of Notice 8900.491 on the aircraft. If any foreign inspectors or officials ask about the LOA for any reason, operators can show the Notice explaining why the FAA is no longer issuing an authorization.

Different airspace will have different regulations, so be sure to research equipage requirements when planning your overseas journey anyway – especially in regard to the ADS-B Out mandate.

If you have any further questions, don’t hesitate to contact us. If you want to know more about our FAA LOA Support Services, you can find more information here.

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.