International ops · October 31, 2026 · 6 min read · By BizJetDocs

RVSM authorization for Part 91 operators: when you need LOA B046 and what maintenance the FAA expects

When Part 91 operators need an RVSM LOA B046 despite ADS-B Out, what AC 91-85B asks for, the Responsible Person, and RVSM maintenance duties.

Short answer: an RVSM-compliant aircraft with a qualified ADS-B Out system can fly in U.S. RVSM airspace under 14 CFR Part 91, Appendix G, Section 9 without applying for anything. You still need an RVSM authorization, issued to a Part 91 operator as LOA B046, when the aircraft lacks qualified ADS-B Out, when it does not fly where the FAA can monitor its height-keeping, or when you will fly RVSM in a foreign country that requires a specific approval. Maintenance is the operator's job in both cases: AC 91-85B, paragraph 2.4, says the operator "must ensure that it complies with the appropriate instructions for continued airworthiness (ICA)."

The rules

Two sections apply. 14 CFR 91.180 covers RVSM airspace generally, and 91.706 covers U.S.-registered aircraft operating outside the United States. Both say no person may operate in RVSM airspace unless the operator and aircraft comply with Appendix G and the operator is authorized. Appendix G, Section 8, says RVSM may be applied in all ICAO flight information regions, and the B046 guidance in FAA Order 8900.1, Volume 3, Chapter 18, Section 4, tells operators to expect RVSM procedures whenever they operate between FL 290 and FL 410 inclusive.

Section 9: authorized without applying

Appendix G, Section 9 authorizes RVSM operation when the aircraft has two independent altitude measurement systems, an automatic altitude control system meeting the tolerance in Section 9(a)(2), an altitude alert system, a TCAS II meeting TSO-C119b (Version 7.0) or later if TCAS II is installed, and an ADS-B Out system that meets § 91.227, with its height-keeping performance monitored. Under Section 9(b) the altimetry system error must not exceed 200 feet.

AC 91-85B, Chapter 4, explains how that works in practice:

• Operators under Section 9 "are not required to apply for authorizations" (para 4.1.1).
• The aircraft's initial RVSM operation must be in airspace where the FAA collects enough ADS-B data to evaluate it (para 4.3.5.1). That includes the first RVSM flight of a new aircraft, the first after an alteration affecting RVSM, and the first after a return to RVSM status.
• The aircraft must have been monitored within the previous 24 months and found compliant (para 4.3.5.2).
• The FAA tracks aircraft for monitoring by serial number, so a transfer of ownership or a registration change of a properly maintained aircraft does not affect its Section 9 status (para 4.3.5.1).
• If monitoring requirements are not met, the operator must file as non-RVSM until the issue is resolved (para 4.4.1).

When you need B046

The B046 guidance in 8900.1 says an operator must still apply for an RVSM authorization when:

1. its aircraft are not equipped with qualified ADS-B Out systems;
2. it does not operate in RVSM airspace where the FAA can successfully monitor the aircraft's height-keeping performance; or
3. it intends to conduct RVSM operations in foreign airspace where the State authority requires a specific RVSM operational authorization.

The same guidance notes that ICAO Annex 6, until amended, requires a specific approval for RVSM operations by all aircraft operating outside U.S.-controlled airspace. AC 91-70D Change 1, Table B-1, summarizes B046 as "required to operate outside FAA-controlled RVSM airspace." For a flight department that goes overseas, B046 is the normal answer.

What the application contains

Appendix G, Section 3(c), requires evidence that the operator can operate and maintain each aircraft for which it applies and that each pilot has adequate RVSM knowledge. AC 91-85B, Chapter 5, turns this into two elements: an RVSM-compliant aircraft and RVSM-knowledgeable pilots (para 5.2).

The aircraft. Paragraph 2.2.2: the limitations section of the AFM or AFM supplement should show the aircraft has been determined capable of meeting Appendix G performance. Paragraph 5.5.1: if the aircraft was manufactured RVSM-compliant, the airworthiness certificate date is usually the compliance date; if it was brought into compliance by service bulletin, STC or similar, include the maintenance record return-to-service entry.

The pilots. For a Part 91 applicant, paragraph 5.5.2.1 lists acceptable evidence: Part 142 training center certificates, certificates of completion of a course on RVSM policy and procedures, or the operator's in-house training program. Paragraph 3.2 lists fifteen subjects to cover, including flight planning, contingency procedures, MEL, TCAS and severe turbulence.

The operator. Paragraph 5.6.1 says the applicant should be "the person exercising operational control of the aircraft." Paragraph 5.7 says a Part 91 application must designate a Responsible Person who has legal authority to sign for the operator and adequate RVSM knowledge, and may designate a separate RVSM point of contact.

Other items (para 5.8.6): RVSM items in your MEL, any operating history of altitude-keeping problems, and participation in altitude-keeping performance monitoring under Appendix E of the AC.

Pick the right authorization group

AC 91-85B, paragraph 5.3, sorts requests into three groups, which decides how much evidence you send:

• Group I, administrative amendment: change of business address, Responsible Person, registration markings, or removal of one aircraft from a multi-aircraft LOA.
• Group II, new authorization using existing approved elements: for example, a new operator using an existing RVSM-compliant aircraft, or a change in the legal entity where everything else stays the same.
• Group III, everything new: evidence for every element.

State the group in your written request (para 5.8.2 note) and include enough administrative information for the inspector to fill in the LOA.

RVSM maintenance

Part 91 operators often ask whether they need a separate approved RVSM maintenance program. The Group I examples in AC 91-85B, Appendix F, include "removal of wording describing use of an RVSM-Approved Maintenance Program for operators otherwise not having a requirement for an approved maintenance program." What the AC does require is in paragraphs 2.3 and 2.4: maintain the altimetry and altitude-keeping configuration shown to provide RVSM performance, comply with the ICA, and evaluate every alteration for its effect on altitude-keeping. Paragraph 2.4.1: "Operators must determine aircraft RVSM eligibility after each alteration or modification." Appendix G, Section 6, separately requires reporting altitude-keeping errors of 300 feet total vertical error, 245 feet altimetry system error, or 300 feet assigned altitude deviation.

Checklist

• AFM or AFMS page showing RVSM capability, or the return-to-service entry for the RVSM modification.
• Current ICA for the RVSM-critical systems and a way to show you follow them.
• Height-monitoring result within the last 24 months.
• Training certificates for each pilot.
• RVSM procedures, usually in your international operations manual.
• MEL items for RVSM equipment.
• The correct legal operator and a designated Responsible Person.

What you submit and who submits it

The operator submits a written request to the Flight Standards office covering its principal business address (AC 91-85B, para 5.8.1.1), signed by the Responsible Person. B046 is also available in the streamlined LOA application.

We prepare the B046 request with the aircraft eligibility evidence, the RVSM procedures and pilot-knowledge records list, and the authorization-group statement, plus instructions for submitting. You review, sign and submit. The FAA decides on the authorization and its timing.

Frequently asked questions

My jet has ADS-B Out. Do I need B046 for a trip to Europe?

If the foreign State requires a specific RVSM approval, yes. The 8900.1 guidance lists foreign airspace requiring specific approval as a reason to apply even when Section 9 would otherwise cover you.

Does B046 move with the aircraft when it is sold?

No. It is issued to the operator. AC 91-85B treats a new operator of an existing compliant aircraft as a Group II request.

Is an RVSM maintenance program approval required for Part 91?

AC 91-85B requires compliance with the ICA and configuration control, and treats removal of approved-program wording for operators without an approved maintenance program requirement as an administrative change.

Have it prepared

The RVSM authorization package is $775, and an RVSM continued-airworthiness statement is $800. B046 is also part of the Part 91 Turbine Starter at from $2,550. See the format below.

Sources

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

• 14 CFR Part 91, Appendix G, Operations in RVSM Airspace
• 14 CFR 91.180, Operations within RVSM airspace
• 14 CFR 91.706, Operations within RVSM airspace (U.S. aircraft outside the United States)
• AC 91-85B (editorial update), Authorization of Aircraft and Operators for Flight in RVSM Airspace
• FAA Order 8900.1, Volume 3, Chapter 18, Section 4, Part B Operations Specifications (CHG 1067)
• AC 91-70D Change 1, Oceanic and Remote Continental Airspace Operations (10/19/2026)

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.