Experimental Aircraft: Letters of Deviation Authority (LODA)

Forms and Documents

Forms and supporting documents for this ICR

Document	Type	Status	Availability
2026-03491.pdf	Supplementary Document	Uploaded 2026-04-29	Available
2120-0812 5-4-26 v2.docx	Supporting Statement A	Uploaded 2026-05-04	Available
Statutory Authority for LODA ICR.docx	Supplementary Document	Uploaded 2023-02-27	Available

IC Document Collections

Information collection document groups

IC ID	Collection	Type	Status	Form
258635	91.319 Experimental LODA Reporting and Recordkeeping	Instruction	Unchanged

ICR Details

OMB Control No: 2120-0812	ICR Reference No: 202604-2120-004
Status: Received in OIRA	Previous ICR Reference No: 202302-2120-006
Agency/Subagency: DOT/FAA	Agency Tracking No:
Title: Experimental Aircraft: Letters of Deviation Authority (LODA)
Type of Information Collection: Extension without change of a currently approved collection	Common Form ICR:  No
Type of Review Request: Regular	Date Submitted to OIRA: 05/27/2026

table that charts list comparision

	Requested	Previously Approved
Expiration Date	36 Months From Approved	06/30/2026
Responses	20	20
Time Burden (Hours)	380	380
Cost Burden (Dollars)	0	0

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Abstract: In 2004, the FAA established a Letter of Deviation Authority (LODA) process for operators who advertise or “hold out” their experimental aircraft for use in training, testing or checking in exchange for compensation. See 69 Fed. Reg. 44771 (July 27, 2004). To obtain a LODA, the operator must submit an application to the FAA that includes airworthiness and maintenance records, and an aircraft-specific training outline at least 60 days in advance of the first training operation. The FAA uses this collection of information to ensure that operators of an aircraft with an experimental airworthiness certificate who broadly offer their aircraft for training, testing or checking follow appropriate safety precautions. Application is made to the FAA electronically by email, fax, in-person delivery, or mail, to the responsible FAA Flight Standards District Office. This requirement applies to the registered aircraft owner seeking to conduct operations through deviation authority, or their agent. Importantly, the LODA requirement in this information collection does not apply to owners (and those affiliated with owners) of experimental aircraft who receive training, testing or checking in their own aircraft. On July 12, 2021, in response to a court ruling, the FAA issued a “Notification of Policy for Flight Training in Certain Aircraft” in the Federal Register (86 FR 36493) that established a shortened, email LODA requirement for owners of experimental aircraft who receive training, testing or checking in their own aircraft. However, the National Defense Authorization Act (NDAA) of 2023 eliminated this requirement. The FAA no longer requires owners of experimental aircraft to apply for a LODA to receive training, testing or checking in their own aircraft.

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Authorizing Statute(s): US Code: 49 USC 44711 Name of Law: Prohibitions and exemption
   US Code: 49 USC 44701 Name of Law: General Requirements
  

Citations for New Statutory Requirements: None

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Associated Rulemaking Information
RIN:	Stage of Rulemaking:	Federal Register Citation:	Date:
	Not associated with rulemaking

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Federal Register Notices & Comments
60-day Notice:	Federal Register Citation:	Citation Date:
	91 FR 8569	02/23/2026
30-day Notice:	Federal Register Citation:	Citation Date:
	91 FR 29248	05/19/2026
Did the Agency receive public comments on this ICR? No

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Number of Information Collection (IC) in this ICR: 1

table that charts list of burden

IC Title	Form No.	Form Name
91.319 Experimental LODA Reporting and Recordkeeping

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ICR Summary of Burden

table that charts list of burden

	Total Request	Previously Approved	Change Due to New Statute	Change Due to Agency Discretion	Change Due to Adjustment in Estimate	Change Due to Potential Violation of the PRA
Annual Number of Responses	20	20	0	0	0	0
Annual Time Burden (Hours)	380	380	0	0	0	0
Annual Cost Burden (Dollars)	0	0	0	0	0	0

Burden increases because of Program Change due to Agency Discretion: No

Burden Increase Due to:

Burden decreases because of Program Change due to Agency Discretion: No

Burden Reduction Due to:

Short Statement:

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Annual Cost to Federal Government: $11,018

Does this IC contain surveys, censuses, or employ statistical methods? No

Does this ICR request any personally identifiable information (see OMB Circular No. A-130 for an explanation of this term)? Please consult with your agency's privacy program when making this determination.     No

Does this ICR include a form that requires a Privacy Act Statement (see 5 U.S.C. §552a(e)(3))? Please consult with your agency's privacy program when making this determination.     No

Is this ICR related to the Affordable Care Act [Pub. L. 111-148 & 111-152]? No

Is this ICR related to the Dodd-Frank Wall Street Reform and Consumer Protection Act, [Pub. L. 111-203]? No

Is this ICR related to the American Recovery and Reinvestment Act of 2009 (ARRA)? No

Is this ICR related to the Pandemic Response? No

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Common Form ICR:  No

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On behalf of this Federal agency, I certify that the collection of information encompassed by this request complies with 5 CFR 1320.9 and the related provisions of 5 CFR 1320.8(b)(3).

The following is a summary of the topics, regarding the proposed collection of information, that the certification covers:

(a) It is necessary for the proper performance of agency functions;

(b) It avoids unnecessary duplication;

(c) It reduces burden on small entities;

(d) It uses plain, coherent, and unambiguous language that is understandable to respondents;

(e) Its implementation will be consistent and compatible with current reporting and recordkeeping practices;

(f) It indicates the retention periods for recordkeeping requirements;

(g) It informs respondents of the information called for under 5 CFR 1320.8 (b)(3) about:

(i) Why the information is being collected;

(ii) Use of information;

(iii) Burden estimate;

(iv) Nature of response (voluntary, required for a benefit, or mandatory);

(v) Nature and extent of confidentiality; and

(vi) Need to display currently valid OMB control number;

(h) It was developed by an office that has planned and allocated resources for the efficient and effective management and use of the information to be collected.

(i) It uses effective and efficient statistical survey methodology (if applicable); and

(j) It makes appropriate use of information technology.

If you are unable to certify compliance with any of these provisions, identify the item by leaving the box unchecked and explain the reason in the Supporting Statement.

Certification Date: 05/27/2026

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