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Are there different kinds of LODA's ?

noelf

Well Known Member
I seem to remember several years ago that if a CFI wanted to give transition training ( for compensation) in his own experimental aircraft, he had to obtain a LODA. Part of the process required him to submit a Flight Training Syllabus for the training that was to be given.

I recently requested a LODA from the FAA as suggested in these recent LODA forum threads so that I (or my RV?) would comply with the latest interpretations of the regs. But I am not a CFI and I did not submit any kind of flight training document.

Does this mean that there are different classes of LODA and that they are specified when the approved LODA is received from the FAA?

And then once the LODA is received, what do you do with it? Keep it in the plane with the other aircraft documents? Keep it in the Pilots log book? Keep it in the Airframe log book? Or, just file it away someplace for whenever the FAA wants to see if you have one?
 
I'm not a CFI either, so as I read it, the LODA that I applied for, and received about a week later, allows me to receive flight instruction for compensation in my own airplane (specifically named). The language on the LODA appears to suggest that if you apply as a CFI, you get the same letter.

Letter of Deviation Authority
Deviation Authority for Conducting Flight Training in Experimental Category Aircraft (14 CFR Section 91.319 (h))​
A. The owner (or delegate) or authorized instructor listed at the bottom of this document is authorized this Letter of Deviation Authority (LODA) in accordance with the provisions of Title 14 Code of Federal Regulations (CFR) Section 91.319(h) to the extent necessary to receive or provide aircraft-specific training in an aircraft certificated in the experimental category in accordance with the limitations and provisions of this LODA.
 
A LODA is a waiver of one or more rules. Yes, there are different ones. The one first issued a dozen or so years ago allowed an EAB owner to charge for his airplane, but only for transition training in-type. (Note the LODA holder was the airplane owner, who might or might not have been a cfi). The two new ones are for (1) an owner or his designee to receive, and pay for, instruction in the owner’s EAB. The second one allows a cfi to be paid to instruct in an EAB. In both cases no payment may be paid for the airplane, and cfi compensation is limited to the usual and customary rate. Only one of these is needed for any particular case. You can tell the difference by whether or not a specific N number is listed in the box, mid-page. Since I have both, my box says ‘Owner LODA only’ in that box.
 
I sent in my LODA paperwork last Saturday and received the approved LODA today. 4 working days. Wow!

I still don't know what to do with, but I have it.
 
Umm

Umm, I have received 3 CFI lodas and 2 owner lodas since applying. All identical except the Fsdo signature…interesting…
 
Umm, I have received 3 CFI lodas and 2 owner lodas since applying. All identical except the Fsdo signature…interesting…

Bob, nearly same for me. 3 LODAs received for giving instruction, 1 for receiving. 3 diff FSDOs. Only 1 issued both letters. Posted this in the other LODA thread, as well.
 
And then once the LODA is received, what do you do with it? Keep it in the plane with the other aircraft documents? Keep it in the Pilots log book? Keep it in the Airframe log book? Or, just file it away someplace for whenever the FAA wants to see if you have one?

A link to the LODA application / template has been posted on VAF multiple times over the past few weeks, and it contains the full LODA text.

The following is from section D - Operating Limitations:

7. This document, or an electronic copy, must be carried for all operations conducted under this authority.

https://www.faa.gov/licenses_certificates/vintage_experimental/examiners/media/LODA_Template.pdf
 
Filled out the LODA and emailed it at 09:51 and received the LODA at 11:47. that's efficient!
 
LODA

Noel,
Case 1, As I understand it, the FAA has their latest iteration, where you get the LODA as an owner. The CFI follows the virtually the same process, gets a LODA as well that is not airplane specific, and then they can give you training in your aircraft. Easy to do paperwork exercise.

Case 2, which we are in the process of doing is getting a LODA to do transition training in an RV. It requires a syllabus among other things and is much more involved.

The one question that is not clear, Different interpretations, from different FAA folks is does the CFI and the owner both have to possess the LODA in Case 1, I ASSUME so. No big deal because it is easy to do.
Terry
 
The one question that is not clear, Different interpretations, from different FAA folks is does the CFI and the owner both have to possess the LODA in Case 1, I ASSUME so. No big deal because it is easy to do.
Terry

The EAA FAQ on this topic says only one.

https://www.eaa.org/eaa/news-and-publications/eaa-news-and-aviation-news/news/07-13-2021-experimental-limited-and-primary-category-aircraft-flight-training-faqs

Only one person in the cockpit needs to have the LODA. If you are a CFI and your student holds a LODA for their aircraft, you are covered.
 
I received an LODA last summer for my RV6A (Current CFII). Im considering instructing my son in our RV for parts of his private, inst, and commercial rating (having him finish each rating at the local flight school and take checkride in a 172). He isn't the "owner" and I'm not receiving "compensation" (hes getting use of my plane and my time for free)....ie, its even costing me gas and maint! So with an LODA are we legal? (insurance a different issue) Thoughts?

Kurt
 
I received an LODA last summer for my RV6A (Current CFII). Im considering instructing my son in our RV for parts of his private, inst, and commercial rating (having him finish each rating at the local flight school and take checkride in a 172). He isn't the "owner" and I'm not receiving "compensation" (hes getting use of my plane and my time for free)....ie, its even costing me gas and maint! So with an LODA are we legal? (insurance a different issue) Thoughts?

Kurt

I don’t know.. I believe the FAA considers flight time itself as compensation.. I also have my LODA for providing instruction, and it says something to the effect that only the owner of the experimental (or their deligate) can receive instruction. My question is, how do you “Deligate” a non owner?
 
The answer (2 posts back) is ‘yes’. A delegate is someone who flies your aircraft with your permission. No compensation of any kind is allowed between delegate and owner.
Edit: just for clarification: Under this LODA your son may not pay you, as owner, anything, for being allowed to use your airplane. However, he is allowed to pay you for instruction (not to exceed your usual and customary rate).
 
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Thanks Bob. That was my thought. He isn't paying for the plane (borrowing it essentially) and isn't paying me. My assumption too is that he can be my "delegate". The FAA makes things to "easy" to figure out...lol.... Much appreciate the feedback!
 
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