International ops · · 6 min read · By BizJetDocs
NAT HLA operations: what Part 91 operators need before crossing the North Atlantic
What a Part 91 operator needs for North Atlantic High Level Airspace: LOA B039 on top of B036, RNP 10, training, the single-LRNS corridor and HF rules.
Short answer: to fly in North Atlantic High Level Airspace (NAT HLA), a Part 91 operator needs LOA B039, and normally also B036, because the FAA issues a Part 91 B039 "normally ... only if LOA B036 has also been issued" (FAA Order 8900.1, Volume 3, Chapter 18, Section 4). The aircraft must have RNP 10 or better capability, the crews need NAT HLA training on top of general oceanic training, and the operator's procedures must cover loss of long-range navigation. Without oceanic RNP authorization, a Part 91 B039 is valid only in the Iceland-Greenland Corridor.
What NAT HLA is
The B039 guidance, citing ICAO Doc 7030, describes NAT HLA as the airspace between FL 285 and FL 420 within the oceanic control areas of Bodo Oceanic, Gander Oceanic, New York Oceanic East north of 27° N, Reykjavik, Santa Maria and Shanwick, excluding the Shannon and Brest Ocean Transition Areas. It was formerly called NAT minimum navigation performance specifications (MNPS) airspace. The same guidance says "FAA authorization is a prerequisite for operations within NAT HLA," and AC 91-70D Change 1, paragraph A.2.49, says operators "must obtain approval from their State of Registry to operate within NAT HLA."
What the FAA requires
Navigation performance
8900.1, Volume 4, Chapter 1, Section 5, paragraph 4-98B: "RNP 10 or better capability is required to fly in NAT HLA. Such approvals are issued via OpSpec/MSpec/LOA B036." AC 91-70D Change 1, paragraph B.1.1.2, lists NAT HLA among oceanic areas requiring a minimum of RNP 10. B036 multiple-LRNS authorization needs at least two independent long-range navigation systems; a single flight management computer fed by several sensors counts as one (8900.1, Volume 3, Chapter 18, Section 4, B036 guidance).
B039 itself
Part 91 LOA B039 has two tables. Following the guidance in 8900.1, Volume 3, Chapter 18, Section 4, inspectors list each aircraft by registration number in one of them:
- Iceland-Greenland Corridor only: aircraft with only a single LRNS, aircraft not authorized oceanic RNP in B036, or aircraft that do not meet the NAT HLA long-range communication or data link equipage requirements in ICAO NAT Doc 007.
- Within and outside the Corridor: aircraft authorized oceanic RNP in B036 and meeting the NAT HLA communication and data link equipage requirements in NAT Doc 007.
A "Remarks" column lets the inspector clarify authorizations by make, model and series. The guidance also tells inspectors not to add nonstandard text about communication equipment, because the overwater rules, ICAO Annex 2, Doc 7030 and NAT Doc 007 already set those limits.
Training and procedures
The B039 guidance says operators "must document the training provided to flightcrew members, dispatchers, flight followers, and other operational control personnel to properly plan and operate flights within NAT HLA," in addition to general oceanic training, and that training and procedures "must address responses to a partial or complete loss of long-range navigation capability." It lists the references the training must draw on: AC 91-70, ICAO Doc 4444 paragraph 15.2 (special procedures for in-flight contingencies in oceanic airspace), ICAO Doc 7030, ICAO NAT OPS Bulletins and ICAO NAT Doc 007.
AC 91-70D Change 1 adds operational details that belong in your procedures, for example that in NAT HLA without CPDLC or ADS-C in use, crews must report to ATC both when leaving and when reaching a new flight level, and that a current track message is needed even on a random route or above NAT HLA (Appendix D, paragraph D.2.1.5).
Communications
14 CFR 91.511(a) requires two transmitters and two independent receivers, among other equipment, for Part 91 subpart F airplanes flying more than 30 minutes or 100 nautical miles from shore. Section 91.511(d) says that when both VHF and HF are required for the route and the airplane has two VHF transmitters and receivers, only one HF transmitter and one HF receiver are required. The B039 guidance points out that, whether or not 91.511 applies to an operator, ICAO Annex 2 requires "a continuous air-ground voice communications watch on the appropriate communication channel" with ATC throughout the flight. Over the high seas, 14 CFR 91.703(a)(1) makes Annex 2 binding on U.S.-registered aircraft.
The single-LRNS corridor
The B036 guidance explains that Part 91 LOA B036 does not authorize the Iceland-Greenland Corridor for single-LRNS operation. Instead, Part 91 subpart F operators rely on 91.511(f), which allows a single long-range navigation system in a defined area west of a line through 67° W and 60° W (covering the Gulf of Mexico, the Caribbean and part of the western Atlantic) when no more than a 30-minute gap in VHF communications is expected. NAT HLA entry still requires B039.
Keeping the authorization
8900.1, Volume 4, Chapter 1, Section 5, paragraph 4-98D, says each gross navigation error (10 nautical miles or more) must be fully investigated, the cause identified and effective action taken. An operator that fails to act faces suspension of NAT HLA authorization.
Checklist
- B036 issued or requested in the same application, with RNP 10 or better shown in the AFM or AFMS.
- Two independent long-range navigation systems, or a plan limited to the Corridor.
- NAT Doc 007 communication and data link equipage checked for each aircraft.
- HF and VHF fit checked against 91.511.
- NAT HLA training records for at least one complete crew, on top of oceanic training.
- Procedures for loss of navigation capability, contingencies, SLOP and level-change reporting, usually in your international operations manual.
- A sample operational flight plan with fuel allocation and equal time points.
- A056 if you will use CPDLC and ADS-C.
The streamlined route
8900.1, Volume 3, Chapter 18, Section 15, lists B039 in the streamlined Part 91 application. The inspector "should not issue LOA B039 unless the operator has an issued and active LOA B036 or has met all the requirements for LOA B036 in the streamlined application," and reviews the flight plan, training and procedures. See the FAA streamlined LOA application and Part 91 LOAs for international flying.
What you submit and who submits it
The operator with operational control applies to the Flight Standards office responsible for its principal base of operations, usually in one application with B036 and often A056 and B046. We prepare the B039 request with its aircraft tables, the B036 request it normally depends on, the NAT HLA procedures and training cross-references in the International Operations Manual, and the submission instructions. You review, sign and submit. The FAA decides whether and when to issue the LOAs.
Frequently asked questions
Can I get B039 without B036?
Yes, but under the 8900.1 guidance a Part 91 B039 issued without oceanic RNP authorization is valid only for the Iceland-Greenland Corridor.
Is one HF radio enough?
For Part 91 subpart F airplanes, 91.511(d) allows one HF transmitter and receiver when the airplane has two VHF transmitters and two VHF receivers and both VHF and HF are required. Annex 2's continuous listening watch still applies.
What happens after a gross navigation error?
The FAA is notified by the NAT Central Monitoring Agency, and the operator must investigate and correct the cause. Inadequate action can lead to suspension of NAT HLA authorization.
Have it prepared
The NAT HLA LOA B039 package is $775. The B036 oceanic LOA package it normally sits on is $1,175, the A056 data link package $875, and the International Operations Manual $1,475. The International Operations Package bundles B036, A056, B046 and the manual for $3,650, and the large-cabin LOA program includes B039 for $8,050. See the format below.
Have it prepared for you
We prepare the documents and the submission instructions; you review, sign and submit them to the FAA. Published flat fees, no hourly billing.
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 4, Part B Operations Specifications (CHG 1067)
- FAA Order 8900.1, Volume 4, Chapter 1, Section 5, Special Navigation Areas of Operation (CHG 738)
- AC 91-70D Change 1, Oceanic and Remote Continental Airspace Operations (10/19/2026)
- FAA Order 8900.1, Volume 3, Chapter 18, Section 15, Streamlined Part 91 Operational Approvals (CHG 973)
- 14 CFR 91.511, Communication and navigation equipment for overwater operations
- 14 CFR 91.703, Operations of civil aircraft of U.S. registry outside of the United States
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.
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