AC 91-85B

editorial update

Advisory circular · Authorization of Aircraft and Operators for Flight in Reduced Vertical Separation Minimum (RVSM) Airspace

Approved
March 21, 2025
Last reviewed
March 21, 2025
This change
Editorial update to AC 91-85B.
Cancels
AC91-85B
Family
AC 91-85 · 4 versions
Revision
B
14 CFR parts
91, 121, 125, 135
14 CFR sections
§ 91.180§ 91.706

Guidance, not mandatory unless a rule or AD requires it. DRS record last changed June 25, 2026.

Show pages 61–72

Appendix E E-1 APPENDIX E. RVSM ALTITUDE-KEEPING PERFORMANCE MONITORING WHEN

OPERATING WITH AN RVSM OPSPEC, MSPEC, OR LOA E.1 Introduction. This appendix explains how an operator can meet the requirements for altitude-keeping performance monitoring when operating under the provisions of 14 CFR part 91 appendix G, section 3 w hen issued an OpSpec, MSpec, or LOA.

Note: If the operator’s aircraft is equipped with a qualified ADS-B OUT system and wishes to conduct operations under the provisions of part 91 appendix G, section 9, see Chapter 4, Authorizations for Operators of RVSM Aircraft Equipped With a Qualified ADS-B OUT System.

E.1.1 All Oper ators Wishing to Conduct Operations in RVSM-Designated Airspace Are Required to Participate in RVSM Height-Monitoring.

E.1.1.1 Part 91 appendix G, section 3 stipulates how the operator, in a manner prescribed by the Administrator, must provide evidence that “[i]t is capable to operate and maintain each aircraft or aircraft Group for which it applies for approval to operate in RVSM airspace.” Height-monitoring is the method prescribed to verify ASE remains within required performance limits.

E.1.2 When Do I Have to Get My Airplanes Monitored? U.S.-registered operators are required to conduct initial height-monitoring within 6 months of the authorization date of issue and must conduct height-monitoring every 2 years, or within intervals of 1,000 flight-hours, whichever period is longer.

1. Monitoring is not required prior to being granted operational approval.

2.

Evidence of previous successful monitoring of an airplane may be used to meet the monitoring requirements.

3. When calculating the 1,000-hour provision of the Minimum Monitoring Requirement (MMR), the calculation of the flight time should be from the last satisfactory height-monitoring date on record.

E.1.3 How Many Ai rplanes Need to Be Monitored?

1. An operator with multiple airplanes may not need to have all airplanes monitored. For height-monitoring, only a sampling of airframes of each airplane type need to be monitored.

2. To determine the number of airframes each operator is required to have monitored, use the RVSM Minimum Monitoring Requirement (MMR) chart.

(Refer to the RVSM Documentation web page at https://www.faa.gov/air_traffic/separation_standards/rvsm/documentation/.)

Note: An operator that is unable to meet the minimum height-monitoring requirements within the specified timeframe should contact the appropriate Flight Standards office prior to exceeding the specified timeframe.

Appendix E E-2 E.1.4 How Do I Get My Airplanes Monitored?

1. An operator may choose to fly with a trained technician from an FAA-approved RVSM monitoring support provider utilizing a GMU on board the airplanes.

2. An operator may fly an airplane through an established ground-based height-measuring system. Currently, ground-based systems exist in:

• North America, AGHME (requires Mode S equipment); or approved ground-based height-measuring systems in other regions (e.g., Europe or Japan).

• An RVSM-authorized aircraft equipped and operating with ADS-B OUT avionics meeting the performance requirements of part 91, § 91.227 at an RVSM altitude where ADS-B height-monitoring is provided.

E.1.5 How Can I Verify If My Airplanes Were Monitored in the Last 2 Years?

1. An operator that has a valid RVSM authorization can check the RVSM Approvals database to determine if their last valid monitoring occurred within the last 2 years.

2. The following methods satisfy monitoring requirements:

• Entry of successful AGHME or other approved ground-based monitoring system result in the U.S. RVSM Approvals database.

• A report of a successful monitoring supplied by an FAA-approved, GPS-based provider.

• Evidence provided through another ICAO-sponsored regional monitoring agency, such as EUROCONTROL.

Note: For North American operators, the database can be accessed from the FAA RVSM website under the RVSM Documentation section or on the FAA’s North American Approvals Registry and Monitoring Organization (NAARMO) website at https://www.faa.gov/air_traffic/separation_standards/naarmo/rvsm_approvals/.

E.1.6 RVSM Height-Monitoring Plan. Operators, upon application, should submit a monitoring plan including:

• Number and identification (registration number/serial number) of airplanes to be mon itored.

• Expected timeframe for completion of monitoring requirements.

• Expected method for monitoring.

Appendix F F-1 APPENDIX F. DECISION MATRIX WHEN APPLYING FOR AN RVSM OPSPEC,

MSPEC, OR LOA F.1 Introduction. The RVSM Authorization Matrix (or simply the “Matrix”) is a tool created to assist operators and the FAA in determining the typical documentation needed for application and which RVSM Authorization Elements approval action the applicant is seeking.

Table F-1. RVSM Decision Matrix

RVSM DECISION MATRIX AUTHORIZATION GROUP I:

RVSM AUTHORIZATION AMENDMENTS

• The following changes are considered to be administrative in nature only.

• This Group only applies in circumstances where a previously authorized RVSM operator and each of the previously accepted RVSM Authorization Elements are remaining the same.

I. A. Examples of Requested Action/Nature of Change

1. Change in the primary business address of an RVSM-Compliant Aircraft and/or RVSM authorization holder.

2. Change in an existing RVSM operator’s designated Responsible Person (or RVSM-Authorized Representative or RVSM-Point of Contact (POC)).

3. Change in the registration markings of an RVSM-Compliant Aircraft being operated by an existing RVSM authorization holder.

4. Removal of wording describing use of an RVSM-Approved Maintenance Program for operators otherwise not having a requirement for an approved maintenance program.

5. Removal of an RVSM-Compliant Aircraft from an existing RVSM authorization that has multiple RVSM-Compliant Aircraft listed.

Appendix F F-2 I. B. Applicable Steps and Information Required From RVSM Authorization Holder

1. Prior to making a request for service for an authorization amendment, each existing authorization holder should make a positive determination as to which portions of the previously accepted RVSM Authorization Elements the authorization holder is requesting to change.

2. That authorization holder should then submit a written request to the appropriate Flight Standards office that:

a. States which of the applicable administrative changes are occurring;

b. Further affirmatively states that none of the previously accepted RVSM Authorization Elements that formed the basis for the initial issuance of the affected RVSM authorization have changed or are changing; and

c. Requests the issuance of an amendment to the existing RVSM authorization that acknowledges the administrative change being made.

3. If the nature of the requested amendment is to change the primary business address from one service area to another, he or she must notify, in writing, the losing (previously responsible) FAA office of the new physical location and mailing address within 30 calendar-days following relocation. The losing office must request that the Web-based Operations Safety System (WebOPSS) Help Desk move the operator’s database to the appropriate receiving FAA office. The losing office must also notify the receiving office of the change. The receiving office should then update and reissue the operator’s A001 template to reflect the new address, and the receiving office becomes the appropriate Flight Standards office for processing new letters of authorization (LOA) for that operator.

4. The authorization holder should also provide such further information as requested by the FAA to efficiently process the request.

I. C. Applicable Procedures to Be Followed by the Appropriate Flight Standards Office

1. Review the request and supporting documentation received from the RVSM authorization applicant to determine if it appears that an amended RVSM authorization is warranted.

2. Reissue the amended RVSM authorization that is identical to the initial RVSM authorization in all respects other than reflecting the new amended information.

3. If the nature of the requested amendment is to change the primary business address from one service area to another, see the additional applicable guidance in FAA Order 8900.1, Volume 3, Chapter 2, Section 2, Responsibility for Part 91 Letters of Authorization (LOA).

4. I f an existing RVSM authorization holder has made a written affirmation that none of the underlying previously accepted RVSM Authorization Elements have changed or will change, and there is no other information provided to the FAA raising any questions or concerns with respect to the ongoing validity or applicability of those RVSM Authorization Elements, then, subject to paragraph 5.3.4 o f this AC, the appropriate Flight Standards office should issue the requested amendment without further inspections being required.

Appendix F F-3 AUTHORIZATION GROUP II:

RVSM AUTHORIZATION BASED ON

ONE OR MORE EXISTING APPROVED RVSM AUTHORIZATION ELEMENTS

• The following RVSM authorizations are new authorizations.

• This Group will normally apply to a new or proposed RVSM operator that is seeking the issuance of an RVSM authorization for an aircraft that is already an RVSM-Compliant Aircraft and/or previously accepted RVSM-Knowledgeable Pilots requirements with respect to its operations of that specific aircraft.

II. A. Examples of Requested Action/Nature of Change

1. There is a change in the legal status or identity of the business entity that is the Approved RVSM operator, but the Responsible Person, RVSM-Authorized Representative, and/or RVSM-POC and each of the Approved RVSM Authorization Elements are remaining the same.

a. One example of this situation may occur where an operator is converted from an S corporation to a limited liability company under applicable state law, but no other changes are occurring.

b. Another example may occur where the ownership and operation of an aircraft is transferred from one company to a legal affiliate, but there are no other changes occurring.

2. A new proposed RVSM operator will be using an existing RVSM-Compliant Aircraft and/or previously accepted RVSM-Knowledgeable Pilots requirements. Examples of this type of situation may include:

a. An operator takes delivery of a newly manufactured aircraft that is type-certified as RVSM-compliant.

b. An Approved RVSM Aircraft is being operated under an RVSM authorization issued to a Title 14 of the Code of Federal Regulations (14 CFR) part 135 ai r carrier, and the underlying owner or a separate lessee will occasionally use that specific aircraft and/or the same RVSM-Knowledgeable Pilots requirements.

c. A group of underlying owners or lessees use a n RVSM-Compliant Aircraft, each maintaining their own operational control of that aircraft pursuant to a dry lease and/or the same RVSM-Knowledgeable Pilots requirements.

3. An existing or newly proposed Approved RVSM operator seeks an RVSM authorization and will be utilizing one or more existing Approved RVSM Authorization Elements.

a. An example may be where an existing RVSM operator seeks to add a new proposed RVSM-Compliant Aircraft to an existing RVSM authorization where that operator will continue to use previously accepted RVSM-Knowledgeable Pilots requirements.

Appendix F F-4 II. B. Applicable Steps and Information Required From RVSM Authorization Applicant

1. Make a positive determination that the existing or newly proposed RVSM operator is seeking an RVSM authorization that will utilize at least one previously Approved RVSM Authorization Element (i.e., an existing RVSM-Compliant Aircraft and/or RVSM-Knowledgeable Pilots requirements).

2. Submit a written request to the appropriate Flight Standards office that:

a. Provides complete documentation of an RVSM compliance program, including written information evidencing that the specific aircraft meets the requirements of an RVSM-Compliant Aircraft;

b. Further specifically states that previously accepted RVSM-Knowledgeable Pilots requirements will be used with respect to the operation of the proposed Approved RVSM Aircraft in RVSM airspace, as applicable;

c. Provides such additional information as necessary to evidence compliance with new or different RVSM-Knowledgeable Pilots requirements (or to be able to gain such approvals); and

d. Asks for the issuance of an RVSM authorization that applies to the operation of the aircraft by that proposed RVSM operator.

3. Provide such further information requested by the FAA to efficiently process the request.

II. C. Applicable Procedures to Be Followed by the Appropriate Flight Standards Office

1. Review the request and supporting documentation received from the RVSM authorization applicant to determine if it appears that the requested RVSM authorization is warranted.

2. To the extent the RVSM applicant has provided written documentation evidencing that the operator will be using a previously accepted RVSM Authorization Element, and accept that RVSM Authorization Element as a valid basis for the issuance of the new RVSM authorization, and to the extent the applicant has presented a proposed RVSM Authorization Element that has not been previously reviewed and accepted, conduct such additional review and research with respect to that RVSM Authorization Element only as is required to issue the new RVSM authorization.

3. If an RVSM applicant has made a written affirmation that one or more of the underlying previously accepted RVSM Authorization Elements have not changed or will not change, there is no other information provided to the FAA raising any questions or concerns with respect to the ongoing validity or applicability of those RVSM Authorization Elements, and the applicant has otherwise presented sufficient evidence of compliance with the requirements of the remaining RVSM Authorization Elements, then, subject to paragraph 5.3.4, the appropriate Flight Standards office should issue the requested amendment without further inspections being required.

Appendix F F-5 AUTHORIZATION GROUP III:

RVSM AUTHORIZATION NOT BASED ON

ONE OR MORE EXISTING RVSM AUTHORIZATION ELEMENTS In the event a proposed new or existing approved RVSM operator seeks the issuance of an RVSM authorization that will not be based on any existing RVSM Authorization Element, then neither Authorization Group I nor II above will apply. The proposed approved RVSM operator should submit sufficient evidence to show his or her ability to comply with each of the RVSM Authorization Elements, and the appropriate Flight Standards office should process the request as a new and unique request by reviewing all of the materials provided by the applicant to ensure that each of the RVSM Authorization Elements have been met.

Advisory Circular Feedback Form If you find an error in this AC, have recommendations for improving it, or have suggestions for new items/subjects to be added, you may let us know by contacting the Flight Technologies and Procedures Division at 9-AWA-AFS400-Coord@faa.gov or the Flight Standards Directives Management Officer at 9-AWA-AFB-120-Directives@faa.gov.

Subject: AC 91-85B, Authorization of Aircraft and Operators for Flight in Reduced Vertical Separation Minimum (RVSM) Airspace Date: _____________________ Please check all appropriate line items:

An err or (pro ce dural or typographical) has been noted in paragraph ____________ on page _______.

Recommend paragraph _____________ on page __________ be changed as follows:

______________________________________________________________________ ______________________________________________________________________ In a future change to this AC, please cover the following subject:

(Briefly describe what you want added.)

______________________________________________________________________ ______________________________________________________________________ Other comments:

______________________________________________________________________ ______________________________________________________________________ I would like to discuss the above. Please contact me.

Submitted by: Date: ______________________