There’s no longer a need for Part 91 business jet operators to obtain two-year
renewals of their RVSM letters of authorization (LOA), but because of changes in the way LOA documents look and a new system the FAA uses to track them, many people, including local FSDO inspectors, apparently are confused about the recentpolicy changes.
Under new guidelines, operators no longer need to renew their RVSM LOAs with their regional FSDOs. From now on the authorizations are being added automatically to a central FAA computer tracking system. Part 91 operators who in the past were issued new RVSM LOAs every 24 months will benefit under the new system not just by the elimination of the renewal requirement, but also when traveling overseas because the new LOA papers look almost identical to commercial OpSpecs (operations specifications) documents, and as a result crews should experience fewer hassles from ramp inspectors in other countries.
The problem with the new system lies in the fact that the revised LOAs really aren’t OpSpecs documents, even though many pilots and FSDO inspectors seem to think they are.
“There hasn’t been a lot of publicity on what the FAA has done with regard to the RVSM LOA process,” explained Douglas Carr, NBAA vice president of safety and regulation. “As a result of confusion–not only on the part of our members but also on the part of the FAA–people are being told things that are inaccurate.”
The biggest misconception about the changes to the RVSM LOA requirements, Carr said, is that the FAA is now issuing operations specifications to Part 91 operators, and that is not the case. While the FAA provides Part 91 operators with LOAs to operate in a variety of airspace, including RNP (required navigation performance), MNPS (minimum navigation performance specifications), RVSM and so on, OpSpecs documents are reserved for commercial operators.
After 9/11 the FAA discovered there was no system in place to track and identify–in a single, national database–Part 91 operators with LOAs for operations in various types of airspace. By the time domestic RVSM went into effect early last year, however, the agency had started keeping tabs on Part 91 LOAs using an existing tracking system that had originally been created for commercial operations. This so-called OpSpecs subsystem allows the FAA quickly to identify which operators have what authorizations, deterring flight crews of non-RVSM airplanes from trying to cheat the system and removing the requirement for periodic LOA renewals.
“What this program is attempting to do is track the authorizations that are issued by the FAA,” Carr said. “These are still letters of authorization. The new process does not change what the authorization technically is. The confusion, I think, stems from the fact that the new document looks a whole lot like a Part 135 operations specification.”
Carr explained that the new LOAs–despite appearing almost identical to a Part 135 OpSpec document–clearly state that they are Part 91 letters of authorization. Exacerbating the problem, he said, is an insistence among some FSDO inspectors and pilots to incorrectly call the new documents Part 91 OpSpecs.
“There’s no such thing as a Part 91 OpSpec,” Carr said. “An OpSpec is a commercial operating certificate device, and it can be attached only to an operating certificate of some type, not to the aircraft, not to the owner and not to the pilot.”
Starting on February 6, all new or reissued LOAs come from the FAA’s automated operations safety system (OPSS), and not local FSDOs. The Part 91 database in the automated system currently includes two dozen types of LOA, waiver and authorization.
As the FAA revises and publishes guidance for each of the affected document templates, the OPSS will issue those applicable authorizations. After an operator has the new type of automated LOA in hand, it stays in effect as long as the information contained in the LOA remains valid.