8900.1 CHG 750



Indicates new/changed information.

Section 8  Qualification Requirements Issuance of Certain Part 91 LOAs to Operators of U.S.-Registered Aircraft Based Outside of the United States

Source Basis:

    Section 91.180, Operations Within Airspace Designated as Reduced Vertical Separation Minimum Airspace.

    Section 91.609, Flight Data Recorders and Cockpit Voice Recorders.

    Section 91.703, Operations of Civil Aircraft of U.S. Registry Outside of the United States.

    Section 91.706, Operations Within Airspace Designed as Reduced Vertical Separation Minimum Airspace.


8.1    General.

8.1.1    Purpose. This section provides policy and guidance for the qualification of Federal Aviation Administration (FAA) International Field Office (IFO) principal inspectors (PI) to issue certain Title 14 of the Code of Federal Regulations (14 CFR) part 91 Letters of Authorization (LOA). When qualified, the PI, without additional concurrence, is authorized to issue certain LOAs to operators of U.S-registered aircraft based outside of the United States. See Volume 3, Chapter 18, Sections 3 and 4 for additional LOA policy.

8.1.2    Scope. This section applies to all IFO managers and PIs.

8.1.3    Safety Assurance System (SAS) Activity Recording (AR) Codes.

    Operations: 1402, 1404, 1406, 1408.

    Maintenance: 3431, 3432, 3433, 3434.

    Avionics: 5431, 5432, 5433, 5434.

8.2    Definitions. See Volume 12, Chapter 1, Section 1, Definitions, Abbreviations, and Acronyms, for information associated with this section.

8.3    Background. Volume 3, Chapter 1, Section 1 requires that PIs upload certain part 91 LOA applications to the Operations Approval Portal System (OAPS) for additional concurrence prior to issue. However, both the International Program Division (AFS-50) and the Flight Technologies and Procedures Division (AFS-400) concur that if an IFO PI meets the appropriate qualifications, the IFO PI may issue certain part 91 LOAs without the additional concurrence requirement. The specific part 91 LOAs associated with this policy are as follows:

    A056, Data Link Communications;

    B036, Oceanic and Remote Continental Navigation Using Multiple Long-Range Navigation Systems (LRNS);

    B039, Operations in North Atlantic High Level Airspace (NAT HLA); and

    B054, Oceanic RNP 10 Operations Using a Single Long-Range Navigation System.

8.4    Requirements. All IFO PIs (i.e., Operations, Maintenance, and Avionics specialties) should take the Oceanic and International Operations Course 21000088 and participate in telecons and other remote meetings established to keep up with the current state, issues, and updates to those LOAs. The LOAs listed in paragraph 8.3 may be issued by an IFO PI without additional concurrence through OAPS if the PI has received specific on-the-job training (OJT) from one of the following:

a)    The assigned IFO OJT instructor; or

b)    Personnel assigned to AFS-400 and specifically trained on the LOAs listed in paragraph 8.3.

8.4.1    OJT. IFO PIs have extensive experience in conducting oversight of foreign persons and operators of U.S.-registered aircraft. However, the IFO manager and assigned IFO OJT manager must ensure that PI OJT is adequate to support the issuance of the aforementioned part 91 LOAs. At a minimum, the IFO PI OJT program will include:

a)    Three OJT Levels. All OJT must be documented in a SAS activity record per FAA Order 3140.20, Flight Standards Service National Training Program, as amended.

b)    Specific Emphasis Items. The training must use General Aviation (GA) Job Task Analysis (JTA) O4.3.34 and include specific emphasis items unique to part 91 LOAs, and specifically identify the training associated with the part 91 LOAs listed in paragraph 8.3.

8.4.2    LOA Processing. With the documented appropriate training, the following actions may be taken if in receipt of an application for one of the part 91 LOAs listed in paragraph 8.3:

a)    IFO PIs who are qualified per paragraph 8.4 and receive a part 91 LOA application outside of OAPS do not need to upload those applications to OAPS nor need additional concurrence prior to issuance.

b)    IFO PIs who are qualified per paragraph 8.4 and receive an LOA application via OAPS will process the application via OAPS, but will not require additional concurrence.

c)    IFO PIs not qualified per paragraph 8.4 will process the LOAs with the standard policy in Volume 3, Chapter 1, Section 1.

8.5    Questions and Assistance. For questions or assistance regarding the issuance of these LOAs, contact the Flight Operations Group (AFS-410). AFS-410 contacts are listed in the “Operation Specification (OpSpec) Contact List” on AFS-400’s web page at https://www.faa.gov/about/office_org/headquarters_offices/avs/offices/afx/afs/afs400/media/OpSpec_Contact_List.pdf.