Are Your LOAs Up-To-Date?
While it may seem that obtaining Letters of Authorization (LOA) for an aircraft is a one-time event, there are several good reasons to review your LOAs from time to time. If your structure has changed, or if the nature of your operations has changed, you may need new or revised LOAs.
Has Something Changed?
LOAs should name the operator of the aircraft, which is the party exercising operational control of the aircraft. If your structure has changed, and there are new operators, then you need to update your LOAs to be sure that each operator is listed. If there are multiple operators, then each operator needs to be listed.
A review of your LOAs is also a good idea if you will be planning a major change in operations. For example, if you have previously flown only domestically you may have relied on the recent change to Part 91 that allowed operations in RVSM airspace without an LOA. However, that authorization typically only applies in U.S.-controlled airspace. If you are planning the first foreign trip in the aircraft, then you will need to be sure that you have an LOA for RVSM operations. You may also need additional new LOAs depending on where you plan to fly, such as those required for flights North Atlantic High Level Airspace and certain other oceanic areas.
Apply Early
The National Business Aviation Association recently announced a streamlined process for obtaining LOAs, which should expedite processing for new aircraft. However, this process has not yet been extended to other aircraft. FAA processing times vary greatly depending on the office and the type of authorization sought. They can be as quick as a few weeks or as long as six months. Operators should apply as early as possible to help ensure they have the needed LOAs prior to planned flights.
The attorneys at Jetstream Aviation Law can be a valuable member of your aircraft team, providing expertise in spotting and resolving the issues that may cause future problems.
The information provided here is not legal advice and does not purport to be a substitute for advice of counsel on any specific matter. For legal advice, you should consult with an attorney concerning your specific situation.
