NAAA is once again hearing reports of operators being contacted by FAA inspectors demanding they fulfill various requirements related to 14 CFR Part 119 for operations specifications (OpSpecs). NAAA is aware of the issue and has been in contact with the FAA, which is currently working on a fix for the problem. Below are a few key reminders if the FAA contacts you making requests not backed up by the FARs. For a full description of the issue, please read this article from the Winter 2020 issue of Agricultural Aviation.

• There are no OpSpecs for 14 CFR Part 137 operations.
• A Letter of Authorization (LOA) for Part 137 operations is not required by 14 CFR Part 137 either.
• It is requested in the spirit of cooperation for national security reasons that Part 137 operations complete an A003 LOA to facilitate tracking the nations agricultural aircraft fleet (response to 9/11 terrorist attacks).
• Part 137 operations are not required to have new aircraft or aircraft brought in from other operations to help during a pest outbreak inspected before putting them on an A003 form or putting them into service.
• If you have an aircraft you need to use for work but are being told by an inspector you can’t fly it or add it to your A003 form until it has been inspected, do not wait. Inform the inspector of their error using these points and the article and fly the aircraft. 
• Part 137 operations do not have to provide a copy of any aircraft lease to an inspector.

NAAA will inform members when the FAA has updated its guidance to deal with this confusion. If you are having trouble with your local FSDO, please contact Scott Bretthauer, who can assist with contacting FAA headquarters to clear up the situation.