LOAs · October 31, 2026 · 6 min read · By BizJetDocs

The FAA streamlined Part 91 LOA application: what it is and who qualifies

How the Streamlined Part 91 Operational Approval works: the nine LOAs it covers, the ASOC, TSOC and PSOC, expiry dates, and what you submit.

Short answer: the Streamlined Part 91 Operational Approval Application lets a Part 91 operator request a bundle of common LOAs in one application, using three FAA-accepted statements (one for the aircraft, one for training, one for procedures) instead of proving each requirement from scratch. You qualify LOA by LOA: the aircraft needs a signed, unexpired Aircraft Statement of Capability (ASOC) covering the operation, at least one complete crew needs training from a course on a signed Training Statement of Compliance (TSOC), and your manual needs a signed Procedures Statement of Compliance (PSOC) where the LOA calls for one. The inspector guidance is FAA Order 8900.1, Volume 3, Chapter 18, Section 15.

Which LOAs can be bundled

Table 3-18-15A of that section lists the LOAs available in the streamlined application:

• A056 Data Link Communications (FANS or ATN)
• B036 Oceanic RNP Operations (only RNP 2, 4 and 10 using multiple long-range navigation systems)
• B039 Operations in North Atlantic High Level Airspace
• B046 Operations in RVSM Airspace
• C048 Enhanced Flight Vision System operations (only to 100 feet above touchdown zone elevation)
• C052 Straight-in non-precision, APV and Category I minima (only GNSS approaches with LNAV, LP, LNAV/VNAV or LPV minima)
• C063 RNAV and RNP terminal operations (only RNP 1 and RNAV 1)
• C073 VNAV approaches using MDA as a DA
• D195 Minimum Equipment List

Anything outside that list, or anything the inspector cannot verify through the streamlined documents, goes through the normal process. Paragraph 3-18-15-11 says that if eligibility for any requested LOA cannot be verified, that LOA should not be issued and the request should be reviewed outside the streamlined process.

Why it is faster

Paragraph 3-18-15-5A gives three reasons: applicants may request multiple LOAs in one application, verification of aircraft capability, crew training and procedures is simplified, and "policy division concurrence is not required to issue streamlined LOAs." That last point matters for B036. Under the normal B036 guidance in 8900.1, Volume 3, Chapter 18, Section 4, an initial B036 needs concurrence from the Flight Operations Group (AFS-410), and the same guidance notes that streamlined applications do not.

The three statements, and when they expire

These come from paragraphs 3-18-15-5B and 3-18-15-7A through 7C. Inspectors "should not process an application submitted with an unsigned or expired" ASOC, TSOC or PSOC. The 90-day ASOC window is the one that catches people: request it when the rest of the package is close to ready.

Some details from the same paragraphs:

• An ASOC may list capabilities that depend on optional equipment. In that case the applicant provides the documentation the ASOC asks for, such as maintenance records of the installation.
• Training records must show a completion date after the course compliance date listed on the TSOC.
• Training records from an active Part 135 certificate holder can be used if training was completed within the last 2 years and the inspector can confirm the certificate holder holds the equivalent OpSpec.

What the inspector checks for each LOA

Table 3-18-15B lists the actions by LOA. In summary:

• A056: aircraft capability, training, flight planning review, procedures, and verification that the operator and communication service providers are on the PBCS Global Charter membership list.
• B036: aircraft capability, flight planning review, training and procedures.
• B039: an issued and active B036 (or all B036 requirements met in the same application), flight planning review, training and procedures.
• B046: aircraft capability, training and procedures.
• D195: MEL compliance verification.

Adding an aircraft to an issued and active A056, B036, B046, C048, C063 or C073 drops some items, as marked in the table.

The sample flight plan

For A056, B036 and B039, paragraph 3-18-15-9 has the inspector review a sample operational flight plan for an oceanic flight. The equipment codes in Item 10 and the PBN/, NAV/, DAT/ and SUR/ codes in Item 18 must match the Flight Plan Code section of the ASOC. For B036 and B039 the fuel allocation must include taxi, trip, contingency (no less than 5 percent of trip fuel), destination alternate and final reserve (at least 30 minutes), and the plan must contain equal time point calculations for engine-out, depressurization and medical scenarios showing positive fuel at the en route alternates. A flight planning provider format that does not show these is a common reason to go back and fix the sample.

The MEL

D195 is the LOA that authorizes operation under an MEL for purposes of 14 CFR 91.213(a). For D195, paragraph 3-18-15-7E has the inspector verify "an operator-developed MEL" and "a signed letter attesting that the MEL conforms to the content in" AC 91-67. Two notes in the same paragraph limit this: inspectors should not use the streamlined guidance to issue D195 if the operator currently holds D095 for the same aircraft, and operators cannot use the streamlined process to request D095 at all. See D195 vs D095.

Who qualifies

In practice you qualify when:

1. Your aircraft make, model and series has an ASOC that covers the operations you want, and your aircraft has any optional equipment the ASOC requires.
2. At least one complete crew has completed courses listed on a current TSOC for each requested LOA.
3. Your operations manual carries a current PSOC for the LOAs that need procedures.
4. For D195, you have an operator-developed MEL that conforms to AC 91-67 and you do not already hold D095 for that aircraft.

If one LOA in your request does not meet these, the rest can still be issued; that one is handled outside the streamlined process.

Timing around a purchase

Paragraph 3-18-15-7 says inspectors "should attempt to issue LOAs as close as possible to the date the operator takes operational control of the aircraft," and paragraph 3-18-15-11 says they should begin processing and preparing draft LOAs in anticipation of that date. Tell your office the expected closing or delivery date in the application.

What you submit and who submits it

Paragraph 3-18-15-3A says streamlined applications should be entered into the Safety Assurance System (SAS), either by the applicant through the SAS External Portal or by FAA personnel. The operator, or a third party acting for an operator who keeps operational control (8900.1, Volume 3, Chapter 2, Section 2), submits the application to the Flight Standards office responsible for the operator's principal base of operations.

We prepare the application package: request letters, the LOA tables built from your ASOC, and a checklist of the training records, PSOC-bearing manual and flight plan sample to attach. If you order the D195 MEL with it, we prepare the conforming MEL and its attestation letter too. You sign and submit. The FAA alone decides whether each LOA is issued and when.

Frequently asked questions

Can I get D095 through the streamlined application?

No. 8900.1, Volume 3, Chapter 18, Section 15, says operators cannot use the streamlined process to request MEL approval under LOA D095; that request goes in a separate application under AC 91-67, Chapter 6.

How long is an ASOC good for?

Ninety days after the manufacturer's signature, unless the ASOC says otherwise. TSOCs and PSOCs run 24 months from the provider's signature.

Do all my pilots need the training before I apply?

The guidance asks the inspector to verify that at least one complete crew operating the aircraft has training completion documents from a course on a TSOC for each requested LOA.

Have it prepared

The streamlined application package is $1,725 and an aircraft-specific D195 MEL is from $550. The Part 91 Turbine Starter combines the streamlined application, the MEL and B046 for from $2,550. Details and the document format are below.

Sources

Primary sources, as retrieved when this article was last updated. Check the current text before you rely on it.

• FAA Order 8900.1, Volume 3, Chapter 18, Section 15, Streamlined Part 91 Operational Approvals (CHG 973)
• FAA Order 8900.1, Volume 3, Chapter 2, Section 2, Responsibility for Part 91 LOAs (CHG 976)
• FAA Order 8900.1, Volume 3, Chapter 18, Section 4, Part B Operations Specifications (CHG 1067)
• AC 91-67A, Minimum Equipment Requirements for General Aviation Operations Under 14 CFR Part 91
• 14 CFR 91.213, Inoperative instruments and equipment

Informational only. Not legal advice, not FAA guidance and not a promise of FAA approval or of any FAA timeline. The operator submits its own application; only the FAA approves, accepts or issues an authorization.