Part 91 LOAs
Summary
This article first appeared in Contrails Phenom magazine, July 2026.
7/1/2026 Read time: 10 min
Letters of Authorization (LOAs) are the FAA’s way of saying you (the operator) have demonstrated your ability to handle advanced operations. It is the way the FAA ensures you have, or will complete, training beyond what is required for basic airmen certification, and that you have the procedures in place for these operations.
For Part 91 turbine operators, LOAs unlock the ability to use a Minimum Equipment List (MEL) for deferrals, access RVSM airspace, navigate oceanic complexities, and improve your ability to access airports through advanced approaches.
You may get by without any, depending on your operation, but for newish aircraft, LOAs are quicker and simpler to get than ever before.
A good way to think of them is in three buckets: core, enroute/oceanic, and approach/airport. Most of the complexity comes from international operations. Core LOAs form the everyday foundation, while enroute and oceanic ones open the door to reliable long-range trips. Approach LOAs give you more options at destination airports.
Details
Core LOAs
MEL LOA (D095 or D195): technically optional, but very useful for turbine aircraft.
Turbine-powered aircraft cannot use the simple KOEL exception in 91.213. You need an approved MEL to defer inoperative equipment. Without it, when you experience inoperative equipment, you are grounded until it's fixed. Unless you live in a world where stuff only breaks when you are airborne, you’re going to want an MEL.
The D095 uses the published Master Minimum Equipment List (MMEL). This is simpler and faster to get because you adopt this generic MEL for your aircraft type as your own. You can look up MMEL’s for your aircraft here.
The D195 is a custom MEL specific to your serial number. Since it is customized, it requires a little more review. When flying internationally, you’ll want the D195 MEL, as foreign (EASA) inspectors consider a D095 a ramp inspection finding (RIP/SAFA).
This is a point of disagreement between the FAA and EASA. While the FAA thinks a D095 works fine, EASA’s reasoning is due to formatting and technicalities:
An MMEL is designed for a type, not a specific serial number, and may not address equipment installed on a particular aircraft.
MMELs list items "as required by CFR 14” that may be unfamiliar and need to be made explicit.
After receiving a D095 MEL, the operator needs to develop M&O procedures, but ramp checks reveal that this is not always being done.
Generic MMELs do not address the specific kinds of operations conducted, special approvals and authorizations, or the operating environment of MEL holders.
More MEL info can be found here.
RVSM LOA (B046): Required to fly 1,000-foot vertical separation between FL290–FL410 almost worldwide.
Similar to MELs, there are two different RVSM authorizations. The full-fledged B046 LOA and a Part 91 Appendix G Section 9 exemption. International operations require the actual LOA.
ADS-B equipped group aircraft can “self-authorize” via the exemption. However, there are still hoops to jump through before blasting off into RVSM airspace, and this is only good for US domestic operations.
For a rundown of the ADS-B exemption process and more RVSM info, navigate here.
Enroute / Oceanic LOAs: Crossing Borders and Oceans
These LOAs unlock Oceanic airspace, specifically the North Atlantic, as well as international SIDs & STARs.
A056 Data Link Communication (CPDLC for Oceanic Ops)
B036 Oceanic and Remote Continental Navigation Using Multiple Long-Range Navigation Systems (RNP 2/4/10 for Oceanic Ops)
B039 Operations in North Atlantic High Level Airspace (NAT HLA Oceanic Ops)
C063 Area Navigation (RNAV) and Required Navigation Performance (RNP) Terminal Operations (RNAV 1 & RNP 1 SIDs and STARs, international)
Data Link Communications are required via the Datalink Mandate (DLM) in the North Atlantic High Level Airspace (NAT HLA) from FL285 to FL420. Unless you fly through the Greenland - Iceland DLM exemption area, you’ll need it. If you’re equipped, you’ll want it anyway. It is way better to communicate via CPDLC than HF radios. RCP 240 and RSP 180 performance specs are required for the most efficient PBCS tracks in the NAT HLA. A whole lot of articles on this can be found on the International side of the site.
Aircraft need to be FANS 1/A equipped for A056. FANS 1/A = CPDLC + ADS-C. This LOA is separate from Domestic CPDLC, which requires no LOA, just an application to get started. More Datalink info here.
B036 Required Navigation Performance (RNP) 2/4/10 is your GPS capability, sprinkled with IRS redundancy if equipped. Dual WAAS GPS will most likely qualify you for all three specs. Oceanic airspace requires RNP 10; the NAT HLA requires RNP 4 to access the PBCS tracks; and a couple of routes off the coast of France require RNP 2.
Yet another North Atlantic requirement, B039, is an LOA specific to NAT HLA ops due to its unique procedures and congestion.
C063 is an RNAV 1/ RNP 1 spec, which is what SIDs and STARs are built on. The difference between RNAV and RNP is that RNP requires performance monitoring and alerting (which a WAAS GPS already provides). In the US, we keep the RNAV term to leave room for navigation systems capable of RNAV 1 without being RNP. Internationally, all are RNP.
Flying domestically, no authorization is needed to fly SIDs and STARs; training is covered with an instrument rating. Internationally, LOA C063 is required to access GPS-based SIDs and STARs.
Approach / Airport LOAs: Expanding Your Options
All of these LOAs are optional.
C048 Enhanced Flight Vision System (EFVS) (lower approach minimums if EVS equipped)
C052 Approach Procedures with Vertical Guidance (LNAV/VNAV and LPV approaches to DA, needed for international ops)
C073 Vertical Navigation (VNAV) Instrument Approach Procedures (IAP) Using Minimum Descent Altitude (MDA) as a Decision Altitude (DA)/Decision Height (DH) (Using MDA as DA, US only)
If HUD/EVS equipped, C048 can help you reach lower approach minimums - either to 100 ft above touchdown or all the way to the ground through rollout. The former is authorized without an LOA in the US, but you need it internationally (not all foreign countries allow it). Touchdown and rollout ops obviously have a higher entry bar and require an LOA in the US.
C052 lets you fly an LPV or LNAV/VNAV GPS approach to DA minimums, like an ILS. This is another one of those international differences. No LOA is required domestically, but you’ll want it for international ops.
Closely related, C073 lets you fly a GPS approach with vertical guidance down to an MDA, but you treat the MDA like a DA, and buy you another 30-50 ft depending on the airframe. Without the LOA, you can still fly like this. It’s good Continuous Descent Final Approach (CDFA) technique and avoids diving and driving. However, you have to add 30-50 ft to your mins (called your Derived Decision Altitude, DDA) so you don’t go below MDA in a go-around.
With the LOA, you can go all the way down to your MDA and use it as your DA, but caution, it's up to you to make sure your approach path is surveyed clear of obstacles below MDA (if that runway is also served by an approach to a DA, then it’s surveyed, sans NOTAMs).
LOAs used to be a huge hassle and waiting game. Thanks to some FAA improvements, at one of my operations we successfully crossed the Atlantic, with all required LOAs in hand, within 5 days of closing on a new aircraft type. The trip would not have been possible under the old processes.
The Streamlined Process
In 2022, the FAA rolled out the Streamlined Part 91 Operational Approval (SLOA) process. Instead of submitting separate, custom applications for each authorization, eligible operators can now bundle any of the nine LOAs above into a single package using standardized Aircraft, Training, and Procedures Statements of Compliance (ASOC/TSOC/PSOC).
If your aircraft comes out of the box capable of these LOA performance specs, a simple AFM page confirms compliance; however, not all OEMs participate. Partner with a pre-vetted training and manual provider, complete the relatively simple PDF application guide, and voila - your application is ready for review. Experienced operators adding a new type could be flying an Atlantic trip within a week of closing, thanks to this streamlined process.
The streamlined process has drastically reduced the lengthy back-and-forth with the FAA from 6-12+ weeks to days if you have your ducks in order, but there are some caveats: The FAA still needs to make sure you understand what you are doing, especially if this is your first go at these LOAs.
Not all aircraft qualify, and you still need a manual (or at least clear procedures), properly trained crew, and someone who knows how to package the application correctly. Many operators use third-party services to prepare the package so the POI gets a clean submission the first time.
Other LOAs and Authorizations
The above nine LOAs are the most common, but there are a few more available for Part 91 operators, such as:
B030 (IFR Remote Continental/Alaska - training certification only)
C060 (Cat II/III ILS approaches)
C078 (lower takeoff minima for international operations, coming soon for Part 91)
C081 (custom-built and flown instrument procedures)
C384 (RNP AR approaches).
Beyond formal LOAs, consider Domestic CPDLC (application process, no LOA) and Europe's ATN CPDLC (same). Honeywell-equipped aircraft can subscribe to AR RNP or visual approaches.
A good place to start is to partner with a procedure/manual provider. They can walk you through the intricacies of your department and help build the LOA application package. Look into the other options as desired. And don’t forget, once you’re approved, update your ICAO flight plan codes!
LOAs are not one-and-done. They require ongoing compliance, recurrent training, and record-keeping as your operation grows. For owner-operators and professional flight departments alike, they deliver real advantages in flexibility, safety, and access—without the old bureaucratic headaches when you use the streamlined path.
In my experience, getting these squared away early pays off the moment you need to defer equipment or clear oceanic tracks efficiently.
This overview gives you a solid foundation. For deeper dives into specific LOAs, keep reading.
Aviate
Contact a manual provider for a bundled package quote.
Gather AFM docs and training outlines using the FAA guide.
Submit a clean package through your FAA POI (or have the manual provider do it for you).
Complete required training and update manuals.
Update ICAO codes.
Schedule recurrent training and conduct regular compliance checks.
