RVSM Authorizations
Summary
This article originally appeared in Contrails Embraer Magazine, Spring 2023.
12/17/2023 Read time: 10 min
To “self-authorize” your operation for RVSM via the ADS-B exemption, ensure your aircraft qualifies and crew is properly trained, and complete a little bit of paperwork. International operations will require a full RVSM LOA from the FSDO.
Details
RVSM in an ADS-B World
The foundational authorizations for any turbine flight department are MEL and RVSM LOAs. Now that ADS-B has become standard, unlocking RVSM operations is quicker than ever for domestic US operations.
Reduced Vertical Separation Minimum (RVSM) airspace is a worldwide standard (minus a few airspace anomalies). Instead of 2000 feet of vertical separation, RVSM operations run aircraft 1000 feet apart from FL290-FL410. It sets a Minimum standard of aircraft equipment quality and crew training, so Vertical Separation of aircraft can be Reduced; catchy name.
For decades, aircraft manufacturers have built RVSM-capable aircraft out of the box, and typically, flying in this airspace is not operationally different from lower altitudes. This has left some wondering why we have to go through the process of obtaining FAA LOA authorization to do this. I guess we are spoiled by modern technology and reliability. Flying relics are still out there, and equipment does break, so it is for your protection that access to this thinner air is quality controlled. The good news is that things are improving, and obtaining RVSM authorization on ADS-B equipped aircraft is a much more streamlined solution than in the past.
There are two routes to achieve RVSM authorization:
Obtain the RVSM LOA B046
Use the exemption for ADS-B equipped aircraft under Part 91, Appendix G, Section 9.
The first is a lengthy process of working directly with your FSDO inspector. The exemption method is cost-free and a means to quickly “self-authorize.” There are, however, necessary steps to take to do it correctly and limitations to know.
ADS-B Exemption
For a flight department that conducts international operations, you MUST have the B046 LOA. Utilizing the exemption is ONLY good within domestic US airspace. Foreign inspectors have violated operators for flying in RVSM airspace without a B046 RVSM LOA. So, for those conducting international operations or planning to do so, I recommend utilizing the exemption in the short term (domestically) while pursuing the full LOA.
Another common misunderstanding regarding the exemption is: “I have ADS-B, so I’m good to blast off into RVSM airspace.” Not so fast. Utilizing the exemption does not absolve you of compliance with all the requirements of RVSM operations. Even though you are “self-authorizing,” you are still responsible for ensuring the compliance of the pre-requisite paperwork and equipment, that crew members are adequately trained, and that the operation knows its responsibilities. This is true even for a single pilot, owner-operator flight department. You, the operator, have operational control and bear the burden of compliance, whether that single crew member is you or not.
The walkthrough below is the proper way to obtain a Part 91, Appendix G, section 9 RVSM authorization. The guide outlines the different requirements, which are all preparation for pursuing a full RVSM B046 LOA if desired. Remember that the requirements address both the aircraft and the aircraft operator in tandem.
Aircraft
Group Aircraft Status. The FAA defines an RVSM Group Aircraft as one that comes from the factory capable of RVSM. This is a requirement for the Section 9 exemption. You can locate whether the manufacturer built your aircraft to RVSM standards in either the limitations section or a supplement in your AFM.
ADS-B Equipment. Since 2020, 1090 ADS-B Out equipment has been required in the US above FL180. Hopefully, if you are in an aircraft capable of flying in RVSM airspace, you have already complied with this regulation.
ADS-B Performance. You also need to make sure your installed ADS-B equipment is working correctly. The FAA has a web portal to evaluate your performance. After a flight with at least 10 minutes of cruise (it doesn’t have to be in RVSM airspace), submit a PAPR PERFORMANCE REPORT. Shortly after, you will receive an email with the status of your ADS-B performance. No red means you pass.
Maintenance. In addition to the 24-month pitot-static and transponder maintenance inspections, there are 12 calendar month RVSM inspections for your altimetry equipment. These need to be completed before conducting your first RVSM flight.
Aircraft-Specific Requirements. The aircraft manufacturer may require specific software configurations, service bulletins, service letters, or inspections to be completed. Your AFM limitations or supplements sections should specify this.
Operator
Verify all pilots have a high-altitude endorsement.
Ensure all pilots have completed training on RVSM operations. This can be internal or outsourced. An online course is an easy option. ONE OPTION. And another.
Flight plan equipment code. The plane and pilots are ready; now, you can change your ICAO flight plan codes to include RVSM operations. In a Foreflight format, you would change your FAA Equipment code to /L, /W, or /Z. Most likely /L (if equipped with GPS). And under ICAO Equipment, add code W.
Review manufacture operational requirements. There may be aircraft-specific requirements, such as onboard supplements or software versions.
Begin conducting RVSM operations. But wait! You’re not done yet.
Monitoring
The remaining step is to complete initial monitoring and ongoing monitoring as required. RVSM monitoring is a task accomplished by the North American Approvals Registry and Monitoring Organization (NAARMO). They ensure that your system is up to snuff in the wild.
To complete initial monitoring, you must fly in RVSM airspace in level cruise for over 15 minutes. Then, you need to submit a monitoring request to NAARMO. The form with instructions can be accessed from the FAA WEBPAGE HERE. The form is a downloadable PDF link in the ADS-B Height Monitoring Section.
Four to six weeks later, your tailnumber should be added to their list, and you can see the monitoring results by downloading the massive file of all aircraft they monitor. The file you are looking for is US IGA OPERATORS WITH DOMESTIC RVSM AUTHORIZATION UNDER PART 91 SECTION 9 (ADS-B).
You do not need to wait for results to continue conducting RVSM operations. However, you should save the monitoring results for your records. Ongoing monitoring is required after two years or 1000 hours, whichever is longer. When you are due, submit the same form as the initial monitor request.
RVSM B046 LOA
Success. You’ve self-authorized, but what must you do above and beyond all this to obtain the full RVSM LOA? The answer: paperwork.
The exemption allows operators who know what they are doing to access RVSM airspace. To get the LOA, you must show the FAA that you, the operator, know what you’re doing.
Depending on the workload of your FSDO and your preparedness, this could be a process that is a couple of weeks to months long. The goal is to have your POI sit down with your application with no errors or additional information required. What you need to show is the following:
An application letter to the FAA from the operator stating your intentions to obtain a B046 RVSM LOA. This should identify the aircraft, operator, and responsible personnel for LOA management.
Copies of the aircraft airworthiness certificate and registration.
Copies of the AFM or maintenance logs showing the aircraft is a Group Aircraft or visa vis 337 forms showing the RVSM required equipment was installed.
State the means of complying with pilot training, copies of the RVSM training syllabus, and copies of training completion certificates of current crew members within the operation.
Copy of an ADS-B performance report.
Show a proper understanding of RVSM operations. Usually, an operations manual describing crew actions from pre-flight through shutdown includes an altimeter log, when/how to report altitude deviations, and a monitoring plan.
I am a fan of simplicity. I went through the above process attempting to be as minimally thorough as possible and ended up with a 40-page RVSM application packet and manual. I have learned to appreciate the value of third-party providers who can prepare these applications and manuals for your operation.
Further Reading
An excellent resource for standardized procedures is ADVISORY CIRCULAR 91-85B Authorization of Aircraft and Operators for Flight in Reduced Vertical Separation Minimum (RVSM) Airspace. Remember, even if you utilize the RVSM ADS-B exemption, you should be as knowledgeable as an operator obtaining the full RVSM LOA about operational requirements and procedures. It is always good to consult the regulation in CFR PART 91, APPENDIX G.
Aviate
All capable operators should pursue the RVSM ADS-B exemption if you do not yet have an RVSM LOA. Review the aircraft, operator, and monitoring steps above.
If you plan to fly internationally, pursue a full RVSM B046 LOA with the ADS-B exemption with your LOCAL FSDO. The exemption will give you RVSM domestic access while the LOA is processed. AVIATION MANUALS is an excellent resource for assistance.
