NBAA International Operations Committee Sets Streamlined LOA Process
Jens Hennig, vice president, operations for the General Aviation Manufacturers Association (GAMA), outlined a streamlined Letters of Authorization (LOA) process that has been recently approved by the FAA. The new process is aimed at brand-new aircraft due to be operated under Part 91 only, for now. It will turn what has been a months-long process into one that just takes a few days. Of course, we’ve heard about this before, but Hennig newly revealed the FAA approval and that it has been tested successfully. To understand the new process, one needs to understand the problems with the old ways.
As the system now stands, an operator who purchases a brand-new aircraft needs to assemble hundreds of pages of documents that the FAA has already seen. These are typically aircraft, personnel training and procedural documents, such as the Aircraft Flight Manual and the Company Operations Manual. Hennig called this the “arts and crafts part of the LOA process.” The operator submits them and then the FAA checks them, page by page. Even if the operator already has approval for the identical aircraft and crew, the process is repeated. This has been a long-standing complaint from operators, manufacturers and the FAA.
An Implementation Working Group was convened in early 2020, led mainly by the FAA and Gulfstream Aerospace Corp., and attended by many aircraft manufacturers, training vendors and manual services. Their solution replaces the hundreds of pages of documentation with three one-page documents.
The first document is an Aircraft Statement of Capability (ASOC), which is provided by the aircraft manufacturer. The ASOC lists the capabilities needed for the various LOAs and verifies that these capabilities have already been FAA approved in the original type certificate.
The second document is a Training Statement of Compliance (TSOC), which is provided by training vendors. The TSOC lists the training accomplished by the operator’s pilots, mechanics, and other personnel needed to qualify for the applicable LOAs. The training vendor also attests that their training programs have been FAA approved.
The final document is a Procedural (Manual) Statement of Compliance, which is provided by a manuals vendor. The PSOC lists the various manuals produced for the operator and states that these manuals have been completed through an FAA-approved process.
The envisioned process requires the operator to obtain the ASOC, TSOC, and PSOC from its chosen companies and submit these to the FAA. The FAA inspector no longer must check hundreds of pages of documents, but only that the three documents are valid. The LOA can be approved in days. The new process has just completed beta testing with two aircraft manufacturers, two training centers and several manuals vendors. Several Flight Standards District Offices were included in the testing. The results are being studied now and the new process is on track for deployment by next February.