Viewpoint: Three Lessons Learned From Developing LOA Applications
Successfully applying for Letters of Authorization can be a daunting task. The challenge starts when you try to unravel which LOAs you need, and it continues when you try to gather all the documents to support them.
After you have everything ready to complete a request, AviationManuals generally sees a turnaround time of 45-to-60 days for the FAA to review your submission. However, the wait time could be even longer if they note any inconsistencies or request additional evidence of your capabilities.
After producing more than 2,500 LOA applications in 2022, we learned a few things that can simplify the process and help you fly stress-free.
Lesson 1: Ensure your flight planning company has the correct equipment information for your aircraft.
We see incorrect flight planning codes in flight plans quite often, which can cause delays in the FAA approval process as well as confusion when the flight plan is sent to ATC. Reviewing the equipment data pertinent to the codes in Items 10a/10b and Item 18 of your flight plan with your flight planning provider to make sure they have the best data possible can avoid hiccups during the process. If you require additional information on the capabilities of your aircraft, we recommend consulting the Limitations section of your AFM or AFM supplements.
Lesson 2: Pay attention to your crew training frequency (and content).
While there is no defined recurrency period for crew training for FAA Part 91 operators, the FAA tends to prefer training at least every 24 months, as it is a good metric to certify they are up to date with the latest information. We also recommend that you vet your international training vendor(s) carefully to ensure they cover all topics pertinent to oceanic operations – when in doubt, be sure to request a detailed copy of the vendor’s training syllabus. (The FAA is likely to ask for it, too!)
Lesson 3: Apply for all the LOAs the aircraft is capable of, not just what you think you need.
In many cases, the documentation and review processes for a lot of LOAs overlap, and you can save time by applying for as much as you can at once. It is not uncommon for us to hear about operators that need to fly on a route they were not expecting, and then having to rush or be worried about the FAA’s turn time in order to execute the trip successfully.
Having the LOA approved beforehand will provide peace of mind and make future flight planning much easier.
Although the elements of an application seem straightforward, the details within those documents can be tricky to get right.
Authorizations take time to be reviewed and processed, so plan ahead and carefully check your work before submitting it to the FAA or partner with a service provider that is experienced in working with the FAA to help you avoid delays and ensure approval.
After 14 years at AviationManuals helping operators get their authorizations, I still very much enjoy the research and challenges related to LOA’s and compliance.
Josiah Chiappelli is senior advisor of International Operations and LOAs at AviationManuals.