LOAs · October 31, 2026 · 7 min read · By BizJetDocs

How to get Part 91 LOAs for oceanic and international flying: A056, B036, B039 and B046

Which Part 91 LOAs an oceanic trip needs (A056, B036, B039, B046), what each one authorizes, what the FSDO checks, and what you submit.

Short answer: for a typical business jet crossing an ocean, a Part 91 operator usually applies for four Letters of Authorization (LOAs): A056 for data link, B036 to file oceanic RNP capability, B039 to enter North Atlantic High Level Airspace, and B046 for RVSM where the operation needs a specific RVSM authorization. FAA Advisory Circular (AC) 91-70D Change 1, Table B-1, lists each of these and what it is required for. The LOAs are issued to the operator, not to the airplane, and you apply to the Flight Standards office that covers your principal base of operations.

This article walks through what each LOA does, what the FAA looks at, and the order that tends to work.

What each LOA authorizes

AC 91-70D Change 1, Appendix B, Table B-1 ("Title 14 CFR Part 91 LOAs for Oceanic and/or Remote Areas") summarizes the Part 91 LOAs for oceanic flying:

B036: oceanic RNP

B036 is the one most operators misunderstand. AC 91-70D Change 1, paragraph B.1.1.1, says that while LOA B036 "is not required for 14 CFR part 91 to fly in oceanic airspace, it is required to indicate oceanic RNP capability (i.e., RNP 2 (oceanic/remote), RNP 4, or RNP 10) on ATC flight plans." The same paragraph warns that without RNP capability "you may not be cleared on optimal routes and/or altitudes," and the FAA recommends Part 91 operators obtain B036 for all oceanic operations. Paragraph B.1.1.2 adds that some oceanic areas require a minimum of RNP 10, naming NAT HLA and Central East Pacific routes at FL 290 through FL 410.

FAA Order 8900.1, Volume 3, Chapter 18, Section 4 (the B036 guidance) says the aircraft must be eligible for at least RNP 10 and that applicants should provide manufacturer-prepared, FAA-approved documentation, such as the aircraft flight manual, attesting to that eligibility. It also says the operator must show flightcrew operating procedures covering typical oceanic, remote continental and RNP normal and contingency procedures, plus training on them. AC 91-70 is named as the primary source of those procedures.

A detail that trips up applications: the same guidance says a single flight management computer receiving inputs from two independent sources is still only one long-range navigation system. B036 multiple-LRNS authorization needs at least two independent "electronic navigation units."

B039: NAT HLA

The B039 guidance in 8900.1, Volume 3, Chapter 18, Section 4, says "FAA authorization is a prerequisite for operations within NAT HLA," and that a Part 91 LOA B039 "normally will also be issued only if LOA B036 has also been issued." It also documents an exception: a Part 91 B039 issued without oceanic RNP authorization is valid only for the Iceland-Greenland Corridor. Training must cover NAT HLA material in addition to general oceanic training, including responses to partial or complete loss of long-range navigation capability. We cover NAT HLA in detail in NAT HLA requirements for Part 91 operators.

A056: data link

The A056 guidance in 8900.1, Volume 3, Chapter 18, Section 3, says Part 91 operators do not need operational authorization to use data link in U.S. domestic airspace, but "for data link operations in oceanic and remote continental airspace and/or foreign countries requiring specific data link approval, LOA A056 applies." The operator provides a statement of compliance for the data link system, documentation of the installed equipment and the recorder installation, data link procedures in line with AC 90-117, MEL entries for the communication equipment, a sample flight plan, a performance monitoring process and a problem reporting procedure.

B046: RVSM

Under 14 CFR 91.706, no person may operate a U.S.-registered civil aircraft in RVSM airspace unless the operator and aircraft meet Part 91 Appendix G and the operator is authorized. Appendix G, Section 9 authorizes operation for qualifying ADS-B Out equipped aircraft without a separate application, but the B046 guidance in 8900.1 says an operator still applies when the aircraft lacks qualified ADS-B Out, when the FAA cannot monitor its height-keeping, or when it will fly in foreign airspace where the State requires a specific RVSM authorization. Details are in RVSM authorization for Part 91 operators.

The rules that apply once you leave the United States

14 CFR 91.703(a) requires a person operating a U.S.-registered civil aircraft outside the United States to comply with ICAO Annex 2 over the high seas, with the flight rules of a foreign country when within it, and with Part 91 to the extent it is not inconsistent with those, and to comply with § 91.706 in RVSM airspace. The LOAs above are how the FAA documents that your aircraft, crew and procedures meet the specific airspace requirements on the way.

Who the LOA belongs to

8900.1, Volume 3, Chapter 2, Section 2, paragraph 3-2-2-5I, says "an LOA is issued to the person exercising operational control and not to a specific aircraft." The responsible office is the Flight Standards office whose service area covers the operator's principal base of operations, which is "the location where operational control decisions are made," not a P.O. box or a virtual office. The same section says LOAs are nontransferable. If the aircraft is dry leased to several operators, each lessee needs its own LOAs.

Checklist before you apply

• Confirm who holds operational control and use that legal name on every page.
• Confirm the principal base of operations address and the responsible Flight Standards office.
• Collect AFM or AFM supplement pages showing RNP, data link and RVSM eligibility for the exact aircraft.
• Confirm two independent long-range navigation systems for B036, or plan for the single-LRNS limits.
• Get training records for at least one complete crew covering oceanic, NAT HLA, RVSM and data link.
• Write or update the oceanic and international procedures your crews will fly.
• Make sure the MEL addresses navigation, communication and RVSM equipment.
• Prepare a sample operational flight plan for a typical oceanic route.
• Decide whether the streamlined application fits your aircraft (see below).

The streamlined option

If your aircraft has an FAA-accepted Aircraft Statement of Capability, many Part 91 operators bundle these LOAs in one Streamlined Part 91 Operational Approval Application. 8900.1, Volume 3, Chapter 18, Section 15, Table 3-18-15A lists A056, B036, B039 and B046 among the LOAs available in that process, and B036 issued through it does not require the policy division concurrence otherwise needed. See the FAA streamlined LOA application.

What you submit and who submits it

The operator submits the application to its responsible Flight Standards office, signed by the person authorized to act for the operator. 8900.1, Volume 3, Chapter 2, Section 2, paragraph 3-2-2-5H, allows third parties such as a management company or consultant to submit an application on behalf of an operator who retains operational control.

We prepare the package for you: the LOA request letters, the aircraft and equipment tables, the supporting compliance cross-references, and step-by-step instructions for submitting through your office's preferred channel. With the International Operations Manual, the oceanic and international procedures come from the same set. You review, sign and submit. Only the FAA decides whether to issue an LOA and how long its review takes.

Frequently asked questions

Do I need B036 just to fly over the ocean under Part 91?

Not to fly there. AC 91-70D Change 1 says B036 is not required for Part 91 to fly in oceanic airspace, but it is required to show oceanic RNP capability on the flight plan, and some areas, such as NAT HLA, require at least RNP 10.

Can I use the seller's LOAs after I buy the airplane?

No. The FAA issues LOAs to the operator, not the aircraft, and 8900.1 says LOAs are nontransferable. The new operator applies in its own name. See which authorizations don't transfer.

Is there a short-term option for a single trip?

AC 91-70D Change 1, Table B-1, lists LOA D098, Short-Term Operations in Airspace Requiring Specific Approval, as available for oceanic or remote airspace, RVSM airspace and NAT HLA.

Have it prepared

The individual LOA packages are A056 ($875), B036 ($1,175), B039 ($775) and B046 ($775). The International Operations Package bundles the IOPM with A056, B036 and B046 for $3,650. Prices, contents and the document format are shown below.

Sources

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

• AC 91-70D Change 1, Oceanic and Remote Continental Airspace Operations (10/19/2026)
• FAA Order 8900.1, Volume 3, Chapter 18, Section 4, Part B Operations Specifications (CHG 1067)
• FAA Order 8900.1, Volume 3, Chapter 18, Section 3, Part A Operations Specifications (CHG 1068)
• FAA Order 8900.1, Volume 3, Chapter 2, Section 2, Responsibility for Part 91 LOAs (CHG 976)
• 14 CFR 91.703, Operations of civil aircraft of U.S. registry outside of the United States
• 14 CFR 91.706, Operations within RVSM airspace
• 14 CFR Part 91, Appendix G, Operations in RVSM Airspace

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.