Part 91 LOA Basics

What is an LOA and When You Need One

For many Part 91 operators, the most confusing part of compliance is not flying the aircraft. It is understanding what the FAA requires before a specific operation can be conducted legally and efficiently.

A Letter of Authorization (LOA) is an FAA approval that allows a Part 91 operator to conduct certain operations that require more than simply having a capable aircraft or qualified crew. In the FAA’s streamlined Part 91 process, operators may request multiple LOAs through one application, supported by documents such as an Aircraft Statement of Capability (ASOC), Training Statement of Compliance (TSOC), and when applicable a Procedures Statement of Compliance (PSOC).

What Is a Part 91 LOA?

An LOA is the FAA’s formal authorization for a specific type of operation. That means capability alone is not enough. Your aircraft may be equipped for a mission, and your pilots may be trained for it, but if the FAA requires an LOA for that operation, the authorization still has to be in place.

That is the practical difference between being technically capable and being operationally authorized.

Why LOAs Matter

LOAs matter because they affect real-world operational capability.

Without the right authorization, an operator may lose access to efficient altitudes, face limitations when equipment becomes inoperative, or discover too late that a planned mission cannot be flown as expected. Your website already frames this correctly: the issue is not just paperwork, but avoiding delays, wasted time, and regulatory headaches while preserving operational utility.

What the FAA Reviews

The FAA evaluates whether the aircraft, training, and procedures support the requested authorization. The application consists of three main components:

ASOC (Aircraft Statement of Capability): for aircraft equipment

TSOC (Training Statement of Capability): for aircrew training compliance

PSOC (Procedure Statement of Capability): for procedural manual(s) compliance

This is why LOA issuance is not just a form-submission exercise. The authorization has to line up with the aircraft, mission, documents, and intended operation.

Common Part 91 LOA Problems

Most LOA problems are not dramatic. They are usually avoidable gaps, such as:

- Assuming aircraft capability equals approval

- Incomplete supporting documents

- Outdated training records

- Weak procedures alignment

- Misunderstanding how deferred maintenance authority works

- Waiting until a trip or discrepancy exposes the gap

These are the kinds of problems that turn compliance into delay.

Bottom Line

The Part 91 LOA application process is the FAA’s way of authorizing specific operations that require more than assumption. When handled correctly, LOAs protect capability, reduce friction, and support cleaner operations. When handled poorly, they create delays, uncertainty, and avoidable rework.

For many operators, the first step is simply determining which LOAs actually apply to your operation.

There are dozens of available Authorizations, which can make the process overwhelming and confusing.

Our FREE Part 91 LOA Playbook greatly simplifies the complexity.

Below is a comprehensive list of the dozens of available Authorizations from the FAA. Those highlighted in bold blue are the most common for most Part 91 operations.

Part A

001

004

005

007

011

049

056

115

320

321

353

510

511

512

520

529

532

534

Part B

036

039

046

050

054

057

501

548

Part C

052

059

060

063

073

081

358

381

384

Part D

095

098

195

Part J

501

550

501

502

503

504

505

506

507

508

.....1.

...-2.

Issuance and Applicability

Summary of Authorizations

Exemptions, Deviations and Waivers

Agent for Service

Carry-On Baggage Program

Commercial Air Tour Operations Authorization and Antidrug and Alcohol Misuse Prevention Program Registration

Data Link Communications

Deviation Authority for Conducting Flight Training in Experimental Category Aircraft (14 CFR Section 91.319(h))

Special Federal Aviation Regulation (SFAR) No. 77 Grant of Exemption

Special Federal Aviation Regulation (SFAR) No. 77 Authorization-Erbil International Airport (ORER) and Sulaymaniyah International Airport (ORSU)

In-Trail Procedures (ITP) using ADS-B In

Special Flight Authorization (SFA) for Ferry Flights

Special Flight Authorization (SFA) for Sales Demonstration Flights

Special Flight Authorization (SFA) for Training Flights

Special Federal Aviation Regulation (SFAR) No. 77 Approval

Special Authorization for Emergency Operations to Support Regional Disaster Recovery

Special Federal Aviation Regulation (SFAR) No. 112 Approval for Operations Authorized by Another U.S. Government Agency

Special Federal Aviation Regulation (SFAR) No. 87 Approval for Operations Authorized by Another U.S. Government Agency

Oceanic and Remote Continental Navigation Using Multiple Long-Range Navigation Systems (LRNS)

Operations in North Atlantic High-Level Airspace (NAT HLA)

Operations in Reduced Vertical Separation Minimum (RVSM) Airspace

Special Authorizations for Certain Areas of Operations

Oceanic and Remote Airspace Navigation Using a Single Long-Range Navigation System (S-LRNS)

National Parks Air Tour Management Operations Under 14 CFR Part 136

FAA/Industry Training Standards (FITS) Courses

Air Tour Operations Below 1,500 Feet AGL in the State of Hawaii

Straight-In Non-Precision, APV, and Category I Precision Approach and Landing Minima - All Airports

Category II Instrument Approach and Landing Operations

Category III Instrument Approach and Landing Operations

Area Navigation (RNAV) and Required Navigation Performance (RNP) Terminal Operations

Vertical Navigation (VNAV) Instrument Approach Procedures (IAP) Using Minimum Descent Altitude (MDA) as a Decision Altitude (DA)/Decision Height (DH)

Special Non 14 CPR Part 97 Instrument Approach or Departure Procedures

Special Restrictions for “RNP-like” Foreign RNAV Terminal Instrument Procedures with RNP Lines of Minima

Special Non 14 CPR Part 97 Terminal Instrument Procedures, Regional Authorization

Required Navigation Performance (RNP) Procedures With Authorization Required (AR)

MMEL Used as an MEL 97 Aging Aircraft Programs

Flight in Special Areas of Operation For Short-Term Operations

Minimum Equipment List (MEL)

Parachute Operations Over or Into a Congested Area or Open-Air Assembly of Persons

Banner Towing Operations

Certificate of Authorization U.S. Operator NAFTA SAS in Mexico

Certificate of Authorization U.S. Operator NAFTA SAS in Canada

Letter of Registration U.S. Operator Firefighting and/or Forest Fire Management NAFTA SAS in Mexico

Letter of Registration U.S. Operator Firefighting and/or Forest Fire Management NAFTA SAS in Canada

Certificate of Authorization Mexican Operator NAFTA SAS in U.S.

Letter of Registration Mexican Operator Firefighting and/or Forest Fire Management NAFTA SAS in U.S.

Certificate of Authorization Canadian Operator NAFTA SAS in U.S.

Letter of Registration Canadian Operator Firefighting and/or Forest Fire Management NAFTA SAS in U.S.

Continued Use of Level l Flight Training Devices (FTD)

Flight Training Devices (FTD), Levels 2, 3, and 5

The LOAs that almost all Part 91 Operators need are:

B046 – Operations in RVSM (Reduced Vertical Separation Minimum) Airspace

D195 – Operator-developed MEL (Minimum Equipment List)

Allstate Aviation Solutions
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