FAA Letter of Authorization (LOA) Part-91: Streamlined process for new production delivery
Effectivity: Challenger 350/3500, Challenger 650, Global 5500/6500 and Global 7500 aircraft
ATA: 00
By: Isaac Messallem - Technical Services
In September 2018, an LOA Part-91 Streamlined Process working group was established jointly between the FAA and the General Aviation Manufacturers Association (GAMA), to develop the streamlined process recommendations. The working group received input and support from across the aviation community, including participants from different FAA lines of business and Subject Matter Experts (SME) representatives of the agency's workforce.
The FAA and GAMA have since implemented a new guide to facilitate a formal request for obtaining FAA acceptance of an Aircraft Statement of Capability (ASOC). The LOA streamlined process requires three major components to process the bundled LOA application: an ASOC, Training Statement of Compliance (TSOC) and Procedural Statement of Compliance (PSOC). An ASOC is a critical component of the new Operational Approval Application process and it must have a valid FAA signature. The ASOC facilitates verification that the systems installed on the operator's aircraft are eligible for the applicable LOAs in this process.
Following a pilot launch of the program, the FAA and GAMA formally implemented in June 2022, a guide to facilitate a formal request for obtaining FAA acceptance of an ASOC by OEMs.
Since the initial and successful deployment in 2022, the FAA and GAMA have recently implemented additional updates to the ASOC requirements in a Template Revision 3 of the ASOC. As such, each aircraft OEM had to update and resubmit the ASOCs for FAA signature and republishing. As of Nov. 1, 2023, the FAA Flight Standards District Offices (FSDO) inspectors will be instructed to accept the Template Revision 3 only.
Subsequently, to initiate the process with the ASOC, a customer must obtain a signed ASOC by their respective Bombardier Delivery Center representative. All pertinent Bombardier personnel have been informed of this new FAA requirement, as they will be signing the ASOC attesting a given aircraft serial number is pending delivery within +/- 60 days. It should be noted that this requirement has been established to mitigate the FAA FSDO inspectors’ workload.
More information can be found on the FAA's Streamlined Part 91 Operational Approval webpage.
The Flight Technologies and Procedures Division accepts ASOCs after a review of necessary aircraft eligibility requirements by their respective SMEs.
ASOC Template Revision 3 Objective Summary:
Section-1:
New template has been revised to retain the FAA approval signature in SECTION-1 and add an OEM signature field that remains empty, to allow customer to approach the OEM and ask for a signature attesting that the aircraft serial number is due delivery within +/- 60 days.
This is to alleviate excessive workload for FAA FSDO inspectors who must prioritize customer applications by delivery date.Section-2
Simplified lists of the bundled LOAs which are installed on the aircraft attesting the equipment meets FAA aircraft capability requirements. For each LOA, the OEM enters information that will help determine which S/Ns are compliant with the aircraft capability required for the LOA. If compliance is based on the installation of a Service Bulletin or an STC, the OEM enters Service Bulletin or STC designation and includes what document an operator can use to show proof of installation.
Note: Flight Plan Codes have been removed, as all pertinent FLTPLN info is in Section-4.Section-3
This section provides data needed to populate the LOA templates, while LOA data entry information has been further simplified.Section-4
This section provides information that may help operators determine the correct inputs block 10a, 10b, and 18 on an international flight plan.
Note: Flight Plan Codes have been modified to align with recent changes to the ICAO codes, as well as to add notes clarifying when specific codes should be removed from the main capability string of Flight Plan Codes, if capability is not authorized.
Operational Approval Application and Operator Eligibility:
The Streamlined Part 91 Operational Approval process is available for the following applicants:
Operating under 14 CFR Part 91;
Requesting LOAs or amendments to LOAs for an aircraft delivered directly from the aircraft manufacturer, Original Equipment Manufacturer (OEM) and having no previous owners or modifications to equipment affecting the aircraft capabilities related to the LOAs since production.
Note:
The working group is working together towards expending the Streamlined LOA process to Pre-Owned aircraft, which will first require an OEM developed process to allow a conformity check that the specific tail serial number is meeting the listed capabilities;Requesting any, or all, of the LOAs listed in the "LOAs available in the Streamline Application" as per the list of 10 LOAs below; and
Using the “Streamlined Part 91 Operational Approval Application Guide” (PDF)
Note: The guide complements the inspector guidance and facilitates the streamlining process.Together with the ASOC, the applicants must obtain the respective TSOC and PSOC to complete the application.
What LOAs can be requested?
The Streamlined Operational Approval Application allows an operator to request up to TEN commonly requested LOAs in a single application.
A056 Data Link Communications
* B036 Oceanic and Remote Continental Navigation Using Multiple Long-Range Navigation Systems (M-LRNS)
B039 Operations in North Atlantic High-Level Airspace (NAT HLA)
B046 Operations in Reduced Vertical Separation Minimum (RVSM) Airspace
B054 Oceanic and Remote Airspace Navigation Using a Single Long-Range Navigation System
C048 Enhanced Flight Vision System (EFVS) Operations
** C052 Straight-in Non-Precision, Approach Procedure with Vertical Guidance (APV), and Category I Precision Approach and Landing Minima - All Airports
*** C063 Area Navigation (RNAV) and Required Navigation Performance (RNP) Terminal Operations
C073 Vertical Navigation (VNAV) Instrument Approach Procedures (IAP) Using Minimum Descent Altitude (MDA) as a Decision Altitude (DA)/Decision Height (DH)
D095 MMEL as MEL
LOAs Excluded from Streamlined Process:
Examples of highly specialized Part 91 LOAs, that were not included in the ASOC document due to the complex nature of the required training, procedures, and validation, include the following LOAs, but these will continue to be available as a separate application using the normal process:
B036* This process authorizes the best RNP value (e.g. RNP 2, RNP 4, or RNP 10, as documented on the ASOC).
However, Advanced RNP (A-RNP) functions are not authorized in B036 in the streamlined application.C052** This process authorizes all instrument approaches, as documented on the ASOC.
C063*** The Streamlined application is not used to authorize Advanced RNP (A-RNP) functions covered by C063.
C060 – Category II/III Operations
C081 – Specialized Instrument Procedures
C381 – Special Non-Part 97 Instrument Procedures
C384 – RNP-AR Operations
Who can submit an application?
The Streamlined Part 91 Operational Approval Application is available to operators requesting a specific bundle of LOAs to operate an aircraft assembled and delivered directly from the aircraft manufacturer under 14 CFR Part 91.
How is an application submitted?
Operators are encouraged to use an operator’s guide to help prepare an application for a Streamlined Operational Approval.
The most current guide can be downloaded from the FAA’s Streamlined Operational Approval webpage.
The guide is designed to identify documentation that will assist the inspector in verifying eligibility for the LOAs requested.
The Streamlined Concept
Applicants provide the FAA with documents that streamline the process inspectors use to verify eligibility for the LOAs. An application process cannot be streamlined without the following necessary documents:
ASOC - Aircraft Capability, produced by aircraft OEM
TSOC - Pilot Training, produced by Training Supplier
PSOC - Operator’s Procedures, produced by Procedures Supplier
Aircraft Statement of Capability (ASOC)
A document listing operations that an aircraft can perform.
Prepared by an original equipment manufacturer (OEM) and accepted by FAA specialists.
Used as a quick reference to verify installed systems are eligible to conduct operations authorized in a LOA.
Used to help complete LOAs and verify proper flight plan coding.
ASOC’s LOA Capabilities by Platform
Training Statement of Compliance (TSOC)
A document listing courses offered by a training provider that contain content necessary for authorizing an LOA.
Prepared by a training provider and accepted by FAA specialists
Used as a quick reference to verify a training course or curriculum contains compliant crew training for authorizing an LOA
Procedures Statement of Compliance (PSOC)
A document listing product containing necessary procedures for authorizing an LOA.
Prepared by a procedures provider and accepted by FAA specialists
Used as a quick reference to verify procedures or a manual used by an operator are sufficient for authorizing an LOA
Operator Applicant Responsibilities
Operators are responsible for submitting a Streamlined Operational Approval Application to their FAA Safety Assurance Office.
Use the guide provided on the FAA webpage to help identify all documentation needed.
Ensure all SOCs and supporting documentation are included. SOCs must be obtained from your aircraft manufacturer, training provider, and/or procedure provider. Applications with missing SOCs cannot be streamlined.
Send the application to your FAA Safety Assurance Office.
Inspector Instructions Responsibilities
Inspectors are responsible for verifying an applicant is eligible for the requested LOAs and issuing the LOAs.
Use the submitted application guide, documents, and FAA Order 8900.1 guidance to verify eligibility for the streamline process and the LOAs requested.
Contact policy specialist with any questions about the application. No policy division concurrence is required.
Issue the LOAs through WebOPSS
Operational Approval Portal System (OAPS)
Applicants are not required to submit applications through OAPS and inspectors are not required to input an application in OAPS, but utilizing OAPS increases visibility of the application within the FAA and may facilitate quicker processing.
Note:
While the ASOC are posted on the Bombardier Customer Portal under Services> \Operations> section for customer usage and download, the TSOC and PSOC can be obtained by the customer from the pertinent suppliers for Training and Procedural manuals respectively. It should be noted that each of these documents are released and signed by the FAA as acceptance acknowledgement.
For pertinent contacts to obtain ASOC, TSOC & PSOC, consult the following FAA links “Statement of Capability or Compliance Guide (SOC) (faa.gov)”