FAA Releases LOA Guidance for Part 91 Operators

The update outlines streamlined compliance with various communication, navigation, and equipment approvals.

The FAA’s guidance allows for a new process in which Part 91 operators can obtain approval for implementation of new aircraft with NextGen communications, navigation, and surveillance technology into their operations. [Courtesy: NBAA]

The FAA has released updated guidance for Part 91 operators to streamline the application process for certain letter of authorization (LOA) approvals governing the use of specific communications, navigation, and surveillance equipment. 

The published report follows collective efforts between the General Aviation Manufacturers Association (GAMA), the National Business Aviation Association (NBAA), and the FAA’s Flight Technologies and Procedures divisions. 

According to the FAA, the process now “streamlines the review of aircraft capabilities, training compliance and procedures compliance, and bundles a request for multiple common LOAs in a single application.”

“This should make what has been an extremely frustrating process for owners of new, technologically advanced aircraft significantly less burdensome, with much greater clarity on the requirements for aircraft, crews, and operational procedures,” said Brian Koester, NBAA’s director of flight operations and regulations. “We expect these standardized procedures to greatly enhance the efficiency of the LOA application process due to more consistent review and presentation of information.”

The guidance covers Part 91 operators who purchase new aircraft directly from OEMs, but Koester believes this is just the beginning. 

“Basically, we needed to start somewhere,” he said. “As both operators and the FAA gain experience with this new guidance, we should see similar procedures extended to other LOA application scenarios as well.”


In 2009, a joint industry and government task force identified five “areas of concern” that they foresaw as NextGen technology began to enter the flight deck and require operators to gain approval for use of the new systems. In September 2018, the FAA established the LOA Process Improvement working group, which convened to focus specifically on NextGen technologies, including communications (data comm, ADS-C); navigation (performance-based navigation, or PBN); and surveillance (ADS-B Out utilization outside the U.S.) authorizations, as well as other aircraft capabilities such as enhanced flight vision systems (EFVS).

A report was released in January 2020 offering the working group’s recommendations for modernizing the policy mechanism and information that the FAA, aircraft OEMs, training providers, and operators use to allow Part 91 operators to conduct certain operations that require authorization for communications, navigation, and surveillance.

The most commonly requested LOAs include:

  • enhanced vision systems
  • equipment necessary to fly in North Atlantic High Level Airspace and certain other oceanic regions
  • area navigation and required navigation performance terminal operations.
Based in Maryland, Julie is an editor, aviation educator, and author. She holds an airline transport pilot certificate with Douglas DC-3 and CE510 (Citation Mustang) type ratings. She's a CFI/CFII since 1993, specializing in advanced aircraft and flight instructor development. Follow Julie on Twitter @julieinthesky.

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