AC 91-85A

Historical

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

A newer version is currentThis is a historical version. AC 91-85B Ed Update is the version in force, approved March 21, 2025.
Approved
July 21, 2016
Last reviewed
August 2, 2024
Cancels
AC91-85
Cancelled by
AC91-85B
Family
AC 91-85 · 4 versions
Revision
A
14 CFR parts
43, 91, 121, 125, 129, 135, 145

Guidance, not mandatory unless a rule or AD requires it. DRS record last changed November 21, 2025.

Show pages 5–16

3-7 current version of this chart can be found on the FAA’s RVSM Web page in the Monitoring Requirements and Procedures section.

Note: An Operator that is unable to meet the minimum height monitoring requirements within the specified time frame should contact the responsible CHDO/CMO/FSDO/IFO prior to exceeding the specified time frame. (See paragraph 3.6.4, Note 1.)

3.6.4.4 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 Global Positioning System (GPS)-based monitoring unit (GMU) onboard 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, Airplanes Geometric Height Monitoring Elements (AGHME) (requires Mode-S equipment); or

• Approved ground-based height measuring systems in other regions

(e.g., Europe or Japan).

3. An RVSM-authorized aircraft equipped and operating with Automatic Dependent Surveillance-Broadcast (ADS-B) Out avionics meeting the performance requirements of § 91.227 at an RVSM altitude where ADS-B height monitoring is provided.

Note: The height monitoring requirements are globally harmonized and the ICAO Regional Monitoring Agency for North America is the North American Approvals Registry and Monitoring Organization (NAARMO). The NAARMO coordinates RVSM monitoring results with the more than 30 other ICAO Regional Monitoring agencies throughout the world.

3.6.4.5 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.

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3. For North American Operators, the database can be accessed from the FAA RVSM Web site under the section RVSM Documentation or on the FAA’s NAARMO website at:

https://www.faa.gov/air_traffic/separation_standards/naarmo/rvsm _approvals/.

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

1. Number and identification (registration number/serial number) of airplanes to be monitored.

2. Expected time frame for completion of monitoring requirements.

3. Expected method for monitoring.

3.6.5 Can Non-RVSM Aircraft Be Accommodated in RVSM Airspace? Operators must be authorized and aircraft must be certified to fly in designated RVSM airspace with limited exceptions.

3.6.5.1 In Domestic U.S., Alaska Offshore Airspace, the following aircraft can be accommodated on a workload-permitted basis. The vertical separation standard applied between aircraft not approved for RVSM and all other aircraft must be 2,000 ft:

1. Department of Defense (DOD) aircraft.

2. Flights conducted for aircraft certification and development purposes.

3. Active air ambulance flights utilizing a “MEDEVAC” call sign.

4. Aircraft climbing/descending through RVSM flight levels (FL) (without intermediate level off) to/from FLs above RVSM airspace.

5. Foreign State (government) aircraft.

3.6.5.2 In addition to the accommodation categories listed in paragraph 3.6.5.1, in U.S.-controlled oceanic airspace, the following aircraft can be accommodated on a workload-permitted basis:

1. Aircraft being initially delivered to the State of Registry or Operator.

2. Aircraft that was formerly RVSM-approved but has experienced an equipment failure and is being flown to a maintenance facility for repair in order to meet RVSM requirements and/or obtain approval.

3. Aircraft being utilized for mercy or humanitarian purposes.

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3.6.5.3 An aircraft or Operator not authorized for RVSM operations or an Operator/aircraft without operable RVSM equipment is referred to as non-RVSM. If either the Operator or the aircraft or both have not received RVSM authorization, the Operator or dispatcher must not file the RVSM equipment code in the flight plan. The pilot of non-RVSM aircraft must inform the controller of the lack of RVSM approval in accordance with the direction provided in the FAA Aeronautical Information Manual (AIM), paragraph 4-6-8, Pilot/Controller Phraseology.

3.6.5.4 The procedures for accommodation of non-RVSM aircraft in RVSM airspace for operations in Domestic U.S., Alaska Offshore Airspace and the San Juan Flight Information Region (FIR) are contained in the FAA Aeronautical Information Manual (AIM), Section 6, paragraph 4-6-10. For operations within oceanic airspace, see the U.S. Aeronautical Information Publication (AIP), Enroute, Section 7.

4-1 CHAPTER 4. SUBMITTING AN APPLICATION FOR RVSM AUTHORIZATION.

4.1 What is the First Step an Applicant May Consider Taking When Applying for an RVSM Authorization?

4.1.1 Should an Applicant Request a Preapplication Meeting? The regulations do not require an applicant participate in a preapplication meeting. However, an applicant may wish to request a preapplication meeting if the applicant is unfamiliar with the application process, seeks additional information with respect to RVSM authorizations, or has other questions concerning how to move forward with the application process.

4.1.2 Where Should an Applicant Request a Preapplication Meeting? An applicant who wishes to request a preapplication meeting should make initial contact with the FAA office as follows.

1. Parts 91K, 121, 125 (A125 LODA holders), and 135 Operators should notify the jurisdictional CHDO, CMO, or FSDO of its intent to obtain authorization for RVSM operations. (See FAA Order 8900.1, Volume 3, Chapter 2, Section 2, paragraph 3-55.)

2. In accordance with FAA Order 8900.1, Volume 3, Chapter 2, Section 2, part 91 Operators apply for an RVSM LOA to the FSDO with a service area covering the Operator’s primary business address. If your primary business address is not in the United States, apply to the responsible IFO’s geographic Area of Responsibility (AOR) on the following Web site:

http://www.faa.gov/about/office_org/field_offices/ifo/. Once on the Web site, click on the service area under each IFO for additional information.

4.2 What are the Applicable Steps and Information Required to Seek an RVSM Authorization? Prior to making a request for service, each applicant should review the information provided in Chapter 3 as well as the RVSM decision Matrix in Figure 4-1 to determine if the applicant should apply procedures for Authorization Group I, Authorization Group II, or Authorization Group III. Each of these groups is summarized in paragraph 4.2, with the RVSM-Decision Matrix (Figure 4-1) provided for detailed examples and information for the application process.

Note: The written request discussed in paragraphs 4.2.1.2, 4.2.2.2, and 4.2.3.2 is your letter to the CHDO requesting service. Using the RVSM Decision Matrix in Figure 4-1, you should identify the specific RVSM Authorization Group for your request. Include sufficient administrative information to allow the FAA inspector to make the necessary form field entries when creating the authorization document. For part 91 LOAs, samples of the needed administrative information is located on the FAA Web site, http://www.faa.gov/air_traffic/separation_standards/rvsm/documentation. Scroll down to the “Getting Started” section and locate the appropriate document titled Information Sheet for Part 91 RVSM Letter of Authorization (LOA). Use of the information sheet will help you organize required information needed for authorization. Providing sufficient information to the CHDO can assist in

4-2 streamlining the application process and help prevent processing delays while the inspector waits for the needed information to be submitted.

4.2.1 What are the General Steps an Applicant will take when its Application Falls Within RVSM Authorization Group I, RVSM Authorization Amendments?

4.2.1.1 Prior to making a request for service for an authorization amendment, each existing authorization holder should make a positive determination none of the previously accepted RVSM Authorization Elements are changing.

4.2.1.2 That authorization holder should then submit a written request to the responsible FSDO, CHDO, or IFO that:

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

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

and

3. Requests the issuance of an amendment to the existing RVSM authorization acknowledging the administrative change being made.

4.2.1.3 The authorization holder should also provide such further information as the FSDO, CHDO, or IFO may request in order to efficiently process the request.

4.2.2 What are the General Steps an Applicant will take when its Application Falls Within RVSM Authorization Group II, RVSM Authorization Based on One or More Existing RVSM Authorization Elements?

4.2.2.1 The applicant should make a positive determination the existing or new proposed RVSM Operator is seeking an RVSM authorization utilizing at least one previously approved/accepted RVSM Authorization Element.

4.2.2.2 Submit a written request to the responsible FSDO, CHDO, or IFO that:

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

2. Further specifically states 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;

3. Provides such additional information as necessary to evidence compliance with new or different RVSM-Knowledgeable Pilots

4-3 requirements (or to be able to gain such approvals) and any of the other RVSM Authorization Elements listed in Chapter 3; and

4. Asks for the issuance of an RVSM authorization applying to the operation of the aircraft by that proposed RVSM Operator.

4.2.2.3 Provide such further information as the FSDO, CHDO, or IFO may request in order to efficiently process the request.

4.2.3 What are the General Steps an Applicant will take when its Application Falls Within RVSM Authorization Group III, RVSM Authorization Not Based on One or More Existing RVSM Authorization Elements?

4.2.3.1 In the event a proposed new or existing approved RVSM Operator seeks the issuance of an RVSM authorization not based on any existing RVSM Authorization Element, then neither Authorization Group I nor II above will apply.

4.2.3.2 The applicant should submit a written request to the responsible FSDO, CHDO, or IFO with sufficient evidence to show its ability to comply with each of the RVSM Authorization Elements in Chapter 3, and the FSDO, CHDO, or IFO should process the request as a new and unique request by reviewing all of the materials provided by the applicant to ensure each of the RVSM Authorization Elements have been met.

4.2.3.3 The applicant should also provide such further information as the FSDO, CHDO, or IFO may request in order to efficiently process the request.

4.2.4 The RVSM Matrix. A detailed description of Figure 4-1 is provided in paragraph 2.4.

Figure 4-1. 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.

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RVSM DECISION MATRIX

4. Removal of an RVSM-Compliant Aircraft from an existing RVSM authorization having multiple RVSM-Compliant Aircraft listed.

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 none of the previously accepted RVSM Authorization Elements are changing.

2. That authorization holder should then submit a written request to the responsible FSDO, CHDO, or IFO that:

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

b. Further affirmatively states none of the previously accepted RVSM Authorization Elements forming 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 acknowledging the administrative changes being made.

3. If the nature of the requested amendment is to change the primary business address from one FSDO, CHDO, or IFO service area to another, it must notify, in writing, the losing (previously responsible) FSDO, CHDO, or IFO of the new physical location and mailing address within 30 calendar-days following relocation. The losing FSDO, CHDO, or IFO will then request the WebOPSS Help Desk move the Operator's database to the responsible receiving FSDO, CHDO, or IFO. The losing FSDO, CHDO, or IFO will also notify the receiving FSDO, CHDO, or IFO of the change. The receiving FSDO, CHDO, or IFO will then update and reissue the Operator's A001 template to reflect the new address, and the receiving FSDO, CHDO, or IFO becomes the responsible FSDO, CHDO, or IFO for processing new LOAs for that Operator.

4. The authorization holder should also provide such further information as the FSDO, CHDO, or IFO may request in order to efficiently process the request.

I. C. Applicable Procedures the Responsible FSDO, CHDO, or IFO Will Follow Upon a Request for an Administrative Change to an Existing RVSM Authorization

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

2. Re-issue the amended RVSM authorization identical to the initial RVSM authorization in all respects other than reflecting the new amended information; and

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

4. If an existing RVSM authorization holder has made a written affirmation none of the underlying previously accepted RVSM Authorization Elements has changed or will change, and there is no other information provided to the FSDO raising any questions or concerns with respect to the on-going validity or applicability of those RVSM Authorization Elements, then, subject to paragraph 2.4.4, the FSDO, CHDO, or IFO should issue the requested amendment without further inspections being required.

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RVSM DECISION MATRIX 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 seeking the issuance of an RVSM authorization for an aircraft already an RVSM-Compliant Aircraft or where the new RVSM Operator will be utilizing 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 Contact Person 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, for example, 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, together with a previously accepted RVSM-Knowledgeable Pilots requirements. Examples of this type of situation may include:

a. An Operator takes delivery of a newly-manufactured aircraft type certified as RVSM-compliant.

b. An approved RVSM aircraft is being operated under an RVSM authorization issued to a part 135 air carrier, and the underlying owner or a separate lessee will occasionally use that specific aircraft while it is maintained under part 135 air carrier’s Maintenance Program and/or the same RVSM-Knowledgeable Pilots requirements.

c. A group of underlying owners or lessees use an RVSM-Compliant Aircraft, each maintaining their own operational control of that aircraft pursuant to a dry lease, while also utilizing the same previously accepted RVSM-Knowledgeable Pilots requirements.

3. An existing or new 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.

II. B. Applicable Steps and Information Required from RVSM Authorization Applicant

1. Make a positive determination that the existing or new proposed RVSM Operator is seeking an RVSM authorization utilizing at least one previous RVSM Authorization Element (i.e., an existing RVSM-Compliant Aircraft and/or RVSM-Knowledgeable Pilots requirements).

2. Submit a written request to the responsible FSDO, CHDO, or IFO that:

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

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RVSM DECISION MATRIX

b. Further specifically states 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 applying to the operation of the aircraft by that proposed RVSM Operator.

3. Provide such further information as the FSDO, CHDO, or IFO may request in order to efficiently process the request.

II. C. Applicable Procedures to be Followed by the Responsible FSDO, CHDO, or IFO

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

2. To the extent the RVSM applicant has provided written documentation evidencing 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 not 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 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 FSDO, CHDO, or IFO raising any questions or concerns with respect to the on-going 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 2.4.4, the FSDO, CHDO, or IFO should issue the requested amendment without further inspections being required.

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 not based on any existing RVSM Authorization Element, then neither Authorization Group I nor II above will apply, the applicant should submit sufficient evidence to show its ability to comply with each of the RVSM Authorization Elements, and the FSDO, CHDO, or IFO should process the request as a new and unique request by reviewing all of the materials provided by the applicant to ensure each of the RVSM Authorization Elements have been met.

5-1 CHAPTER 5. FAA REVIEW AND EVALUATION OF RVSM APPLICATIONS.

5.1 What is the General Process the FAA will Follow Upon Submission of the Request for an RVSM Authorization or Amended Authorization? Once application is made, the FAA will begin the process of review and evaluation of the documentation submitted.

When the FAA determines the airworthiness and operational requirements of the application are met, the FAA will proceed with issuing the authorization.

5.2 What are the Applicable Forms of the RVSM Authorization Documents?

5.2.1 Parts 121, 125, and 135 Operators. Authorization for parts 121, 125, and 135 Operators to operate in RVSM airspace should be granted through the issuance of an OpSpec paragraph from Part B (En Route Authorizations, Limitations, and Procedures) and Part D (Aircraft Authorization). Each aircraft for which the Operator is granted authority should be listed in the OpSpecs. Authorization to conduct RVSM operations in an RVSM area of operations new to the Operator should be granted by adding the Part B RVSM OpSpecs paragraph number to the appropriate area of operations in the Part B paragraph:

Authorized Areas of En Route Operation Limitations and Procedures.

5.2.2 Part 129 Operators. The operational authorization of RVSM for part 129 is provided by the State of the Operator. OpSpec A003 is used to confirm that the foreign air carrier has operational approval. The State of the Operator must have regulation and supporting guidance documents for the issuance of RVSM. The following are examples of guidance documents the FAA considers to be consistent with ICAO standards on RVSM.

5.2.2.1 The current edition of this advisory circular (AC) (91 85, Authorization of Aircraft and Operators for Flight in Reduces Vertical Separation Minimum Airspace); and Joint Aviation Authority (JAA) Temporary Guidance TGL-6.

Note: For part 129 Operators, inspector guidance for paragraph A003 is contained in FAA Order 8900.1, Volume 12, Chapter 2, Section 3.

5.2.3 Part 91K Operators. Part 91K Operators’ authorization to operate in RVSM airspace should be granted through the issuance of an MSpecs paragraph from Part B and Part D.

Each aircraft for which the Operator is granted authority should be listed in MSpecs.

Authorization to conduct RVSM operations in an RVSM area of operations new to the Operator should be granted by adding the Part B RVSM MSpecs paragraph number to the appropriate area of operations in the Part B paragraph.

5.2.4 Parts 91 and 125 (LODA Holder) Operators. Part 91 Operators and part 125 Operators holding a LODA should be issued a LOA when the initial authorization process has been completed.

Note: LODA is a formal authorization issued by the FAA CHDO, authorizing a deviation from specified sections of part 125 and identified in WebOPSS (125M database) as an A125 LODA operator.

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5.2.5 LOA Exemptions. Operators issued OpSpecs are not required to obtain an LOA for those operations conducted under part 91 provided that:

1. The aircraft is operated under the Operator name listed on the OpSpecs.

2. The flight is conducted in an area of operations listed in the OpSpecs.

3. The aircraft is operated under the conditions under which the OpSpecs were granted (e.g., if the Operator holds 121 or 135 OpSpecs, then the pilots used for the part 91 operation must have received part 121 or 135 training.)

4. Each part 91 operation, not associated with a certificated operator, will need a LOA to operate in RVSM airspace.

5.3 What are the Conditions That Would Require the Removal of an RVSM Authorization?

Note: Examples of reasons for amendment, revocation, or restriction of RVSM authorization include, but are not limited to, the reasons listed in part 91 appendix G, section 7.

5.3.1 Height-Keeping Errors. The incidence of height-keeping errors tolerated in an RVSM environment is very small. It is incumbent upon each operator to take immediate action to rectify the conditions causing the error. The operator should also report the event to the FAA within 72 hours with initial analysis of causal factors and measures to prevent further events. The FAA should determine the requirement for follow-up reports. Errors which should be reported and investigated are: Total Vertical Error (TVE) equal to or greater than ±300 ft (±90 m), ASE equal to or greater than ±245 ft (±75 m), and assigned altitude deviation (AAD) equal to or greater than ±300 ft (±90 m).

5.3.2 Error Categories. Height-keeping errors fall into two broad categories: 1) errors caused by malfunction of aircraft equipment, and 2) operational errors. An operator who commits one or more error(s) of either variety may be required to forfeit authority for RVSM operations. If a problem is identified related to one specific aircraft type, then RVSM authority may be removed for the operator for that specific type.

5.3.3 Effective, Timely Response. The operator should make an effective, timely response to each height-keeping error. The FAA may consider removing RVSM operational authorization if the operator response to a height-keeping error is not effective or timely.

The FAA should also consider the operator’s past performance record in determining the action to take. If an operator shows a history of operational and/or airworthiness errors, then authorization may be removed until the root causes of these errors are shown to be eliminated and RVSM programs and procedures are shown to be effective. The FAA will review each situation on a case-by-case basis.

5.3.4 Review Relevant OpSpec/MSpec/LOA Paragraphs. Operators may also consider reviewing all relevant paragraphs of their respective OpSpec, MSpec, or LOA

(e.g., A001) for other reasons which may affect RVSM authorizations.

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5.4 What Happens if I Change RVSM Equipment After Operational Authorization has been Granted? Any change to an RVSM Critical Component or RVSM System as defined in the initial application must be reported to the responsible office for evaluation.

The responsible office will determine if the aircraft is RVSM compliant.