ADS-B Deviation Authorization Preflight Tool (ADAPT)

In April 2019, the FAA published a “Statement of Policy for Authorizations to Operators of Aircraft that are Not Equipped with Automatic Dependent Surveillance-Broadcast Out Equipment” that outlined the FAA’s policy for issuing an ATC authorization to persons seeking to operate aircraft not equipped with ADS-B Out equipment in ADS-B rule airspace. The regulatory text in 14 CFR § 91.225(g) details the rule’s allowance for a deviation, and the FAA’s statement of policy explained how it plans to implement that regulation and how pilots could make an application. Specifically, Section 91.225(g) addresses two aircraft equipage types that may not meet the ADS-B Out requirements: Aircraft with inoperative ADS-B Out equipment, 91.225(g)(1), and aircraft that are not equipped with ADS-B Out equipment, 91.225(g)(2).

The FAA noted that the ADS-B Deviation Authorization Preflight Tool (ADAPT) is the only approved method for making a preflight request for an ATC authorization in accordance with 14 CFR § 91.225(g)(2). This web tool streamlines the application process and removes the burden on the pilot who otherwise might have to coordinate with many ATC facilities to access rule airspace. Pilots cannot make any airspace access request related to Section 91.225(g)(2) over the phone or in flight–all requests must go through ADAPT–and all official FAA approvals will be transmitted via email. Controllers who interact with pilots over the radio will not be responsible for determining whether aircraft not equipped with ADS-B Out are properly authorized to operate in ADS–B Out rule airspace.

ADAPT Basics

Below are the guidelines for the ADAPT website:

• Aircraft operators that need to make an application for an ATC authorized deviation pursuant to 14 CFR 91.225(g) must use ADAPT.
• This web tool is available for use by all civil aircraft operators, including those flying into Class A airspace, but is intended for general aviation Part 91 operators flying aircraft not equipped with ADS-B Out or that have an inoperable ADS-B system.
• An operable transponder with operational altitude encoding (i.e., Mode C) is required to make an ADAPT request.
• Pilots will need to submit their flight details (step-by-step instructions below) via the web-based Flight Information Entry Form so that their route can be checked to determine availability of an alternative surveillance source (i.e., radar availability). Entering your flight’s details into the Flight Information Entry Form does not constitute filing a flight plan with ATC.
• After completing the Flight Information Entry Form, pilots must then fill out the Deviation Request form. Pilots do not have an ATC authorization until they receive an email stating they have been approved; the approval email is considered the FAA official approval.
• Pilots must submit their ADAPT application at least 1 hour prior to and no more than 24 hours from the proposed time of departure.
• If departure is not made within 2 hours of the proposed departure time, the ATC authorized deviation is automatically canceled. ADAPT can be used for international flights and by non-U.S. registered aircraft; however, any approval is only valid for U.S. airspace. 
• Aircraft on the FAA’s ADS-B No Services Aircraft List (NSAL) are not eligible to use ADAPT.
• Do not put your transaction number or any notes about receiving an authorized deviation on your flight plan for ATC. It is not necessary to tell ATC that you have received an authorized deviation.
• Occasionally the ADAPT website will be unavailable due to maintenance. Official notification of an outage will be listed on the FAA’s Operational Information System website. The ability to request an ATC authorization will not be possible when the website is down.

Additional guidance and an FAA tutorial video on using ADAPT can be found on their website, and an extensive Frequently Asked Questions (FAQ) list is available on the ADAPT help page.

Approval or Denial

ADAPT is designed to automate the approval process as much as feasible. Most requests fit within a few limited categories such that the FAA can automatically approve these requests, with some limitations. For example, the FAA may grant an ATC authorization to fly in ADS-B airspace for a pilot to have ADS-B installed or repaired; however, authorizations will be tracked by tail number and the FAA is likely to limit the number of approvals issued for one aircraft that chooses this category multiple times. Any operator planning to routinely need access to ADS-B rule airspace is expected to equip with ADS-B.

The FAA will not include any unique comments or rationale in its approval or denial email to the applicant due to legal limitations. Requests for ATC authorization may be denied for a variety of reasons such as ATC workload or a radar outage. Additionally, the FAA is unlikely to approve an ATC authorization if the destination or departure airport is a capacity-constrained airport, which includes:

• Boston Logan International Airport (BOS)
• Charlotte Douglas International Airport (CLT)
• Chicago O’Hare International Airport (ORD)
• Dallas/Fort Worth International Airport (DFW)
• Hartsfield-Jackson Atlanta International Airport (ATL)
• John F. Kennedy International Airport (JFK)
• LaGuardia Airport (LGA)
• Los Angeles International Airport (LAX)
• McCarran International Airport (LAS)
• Newark Liberty International Airport (EWR)
• Philadelphia International Airport (PHL)
• Ronald Reagan Washington National Airport (DCA)
• San Diego International Airport (SAN)
• San Francisco International Airport (SFO)
• Seattle-Tacoma International Airport (SEA)

Some operator requests reside beyond the bounds of automated approval thresholds and will need to be manually reviewed. These requests (which upon submission will be identified as pending) are automatically forwarded to an FAA air traffic representative for processing; however, FAA will only staff this position 16 hours per day, 7 days per week (6 a.m. to 10 p.m. Eastern time). If FAA personnel do not respond to a request because of other priority duties, at least 30 minutes prior to the applicant’s proposed time of departure, the applicant will automatically be emailed a denied response.

The controllers that pilots interact with over the radio will not be aware of the status of your request or, in the case of an approval, permission to access ADS-B required airspace. These controllers will continue to provide air traffic services to all aircraft operating within their airspace, including those aircraft that have not equipped with ADS-B Out and have not obtained proper authorizations under 14 CFR 91.225(g). It is the responsibility of the pilot to ensure he or she has proper approvals before entering this specific airspace, and pilots should not consider an ATC clearance into that airspace as a replacement for an approval via ADAPT.

Common reasons for denial:

• The proposed departure time is within 1 hour of ADAPT ATC authorization request submission.
• Flight is to/from a capacity-constrained airport during a busy time period.
• Aircraft does not have an operable transponder with operational encoding capability.
• Aircraft is on the NSAL.
• The number of requests for that aircraft exceeds the FAA’s number of permissible approvals for a given amount of time (e.g., that month).
• Radar outage along route of flight (i.e., unavailability of alternate surveillance).
• ATC workload, such as proximity to VIP TFR or special activity.  

ADAPT Best Practices

Pilots who need to use ADAPT can increase their chances for approval following several best practices:

• Submit the ADAPT request early. As the FAA may need to manually review your request, allow enough time such that this can be accomplished. Pilots flying in Hawaii, Alaska, and the west coast should consider submitting requests as soon as possible.  
• Consider your time of departure. You will receive a denial if the application is made less than 1 hour before the proposed departure time. When submitting a request, ensure you are submitting at least 1 hour before the proposed departure time. The authorization is valid for up to two hours after your proposed departure time, as submitted on the Flight Information Entry form. Pilots should carefully consider this limitation and, should weather, passengers, or some other factor lead to a foreseeable delay, consider submitting more than one ATC authorization request. The ATC authorization is valid beginning at the proposed departure time, so departures prior to that time are not permissible. All requests made on the same UTC day count as one authorization, so there is no penalty in submitting more than one request for that day, such as for multi-leg flights or to create a wider departure window if bad weather threatens.  
• Plan to fly during off-hours into or from capacity-constrained airports. The FAA is unlikely to approve an ATC authorization at a capacity-constrained airport unless it is outside of peak hours, typically 0600-2200 local time.
• Choose the appropriate “Reason for Request.” Each request will be tracked by the FAA so pilots should always choose the best drop-down option for that flight, or be specific in the comments box, which is only reviewed if “other” is selected as the reason for an ATC authorization request.
• ATC authorization denial. If you are denied, you can first attempt to resubmit your request by choosing “other” under “Reason for Request” within the Deviation Request portal. You should provide a clear rationale in the comments box why you believe your flight should be approved. If you are still denied, you can submit a question to the FAA air traffic representative; however, a response may be delayed and email is the only means of communication. Calling ATC is not permitted and all interactions will have to occur via email. Depending on why your request was denied, you may also resubmit your request with a different proposed time, route, or altitude. 

Below is a short overview of submitting a request via ADAPT. A full user guide is available from the FAA.

Step 1: Flight Information Entry Form

The first step is to access ADAPT and fill out the Flight Information Entry form, which appears similar to the recently discontinued domestic flight plan format. Clicking each field will open a box explaining how to fill out that section. The route of flight entered should be similar to what you intend to fly, although the route entered does not have to not match routes or reroutes provided by ATC; changes are expected.

Field 11 is where the specific ADS-B information is selected. Most pilots will select either “unequipped” or “inoperative” for the “ADS-B Position Source TSO” and “ADS-B Link TSO.” You can leave “Mask Angle” and “Baro-Aiding equipment installed” unchanged; they are not relevant, and the selection will not affect ADAPT.

Then click “Check Availability” to see if alternative surveillance is available for your flight. The “Transaction Number” does not need to be recorded and it is not an authorization.

After clicking “Check Availability” the page will automatically scroll down to show a “Request an Authorized Deviation for this flight” link, which should be clicked as it is the next step.

Step 2: Deviation Request

The applicant will complete the additional fields in the Deviation Request form. It is important that the email address provided is accurate and accessible, because the official approval will only be emailed to this address. Pilots should confirm receipt of the approval email before conducting that flight.

The “Reason for Request” includes several options, presented below with a short explanation of what each means.

• ADS-B Equipment Installation – This flight is associated with equipping with ADS-B. (Note pilots do not need to request authorization via ADAPT for a first flight after installing ADS-B)
• ADS-B Equipment Repair – This flight is associated with repairing the ADS-B system.
• Insufficient GPS – General aviation aircraft use WAAS GPS as the position source for the ADS-B system, so general aviation pilots will generally not need to select this option (WAAS GPS units conduct performance monitoring and can alert the pilot to position errors; RAIM checks are not required).
• Ferry Aircraft – Normally associated with a ferry permit/special flight permit.
• Fringe Operation – See discussion on fringe operations and who qualifies.
• Crop Duster – An operation that relates to agricultural aircraft operations (“Flight Classification” should be entered as Part 91 for all crop duster operations).
• Antique – This includes non-electrical aircraft; a transponder with altitude encoding is required.
• Other – Any other type of request not listed; details must be listed in comments box. For example, special operations that are not routine, like medical transportation or humanitarian flights, might need access to ADS-B rule airspace. But any reason can be submitted so long as it is representative of that flight. Pilot proficiency or currency flights may be considered routine flights by the FAA so are likely to require ADS-B and unlikely to be approved in ADAPT. Most revenue generating flights are also unlikely to be approved.

All other fields can be filled out as applicable to the flight. Comments entered as part of the application process are not reviewed by the FAA during the approval process when the flight is automatically approved and manual review is not required. Finally, the applicant can submit the request and await the FAA’s response, which is discussed in the next step.

Step 3: Status of the Request

One of three options will appear after submitting the deviation request: approved, denied, or pending. The status of the request will be provided. If you are approved, you must ensure you have received an approval email because it serves as the official record. Retain this email. A pending response means manual review will be necessary and it may take longer to receive a response.

A denial indicates that flight cannot be completed as requested. The FAA will not provide a specific reason for the denial because of legal limitations. The pilot can revise the flight and resubmit. AOPA advises pilots who are denied that they can adjust their flight, as they feel is necessary, and select “other” under “Reason for Request.” Selecting “other” ensures the flight will have a manual review and that the accompanying comment submitted by the pilot will be read.

For inquiries about the process or if you have any questions, see ADAPT contacts.

Fringe Airport Policy

One of the “reason for request” drop-down options in ADAPT is “fringe operation.” A fringe operation is a flight that will take place at a fringe airport, which is defined in FAA Order JO 7210.3 as “…an airport that is approximately 25 NMs or farther from the Class B airspace primary airport and is not served by a scheduled air carrier; or an airport outside the Mode C veil at which aircraft operations in the traffic pattern routinely enter the Mode C veil.” JO 7210.3 further stipulates that fringe operations must: “(a) not adversely impact other operations receiving radar service in the area; (b) must take place below 2,500 feet AGL; (c) remain clear of traffic flows; and (d) are to be conducted in the airport traffic pattern and via the most direct routing out of the Mode C veil, consistent with existing traffic and noise abatement procedures.” The FAA will likely approve fringe operations that follow these guidelines and are submitted via ADAPT. ADAPT is best used for infrequent operations.

For long-term authorizations for fringe operations in aircraft not equipped with ADS-B Out, such as for based aircraft, the ATC facility responsible for that airspace can be contacted to enter into a Letter of Agreement (LOA). An LOA will replace the need to conduct per-flight requests in ADAPT. This is one of the few cases where the local ATC facility is contacted directly. AOPA can assist with contact information, see ADAPT contacts.

Inoperative ADS-B System

Pilots can submit an ATC authorization request via ADAPT for operations of an aircraft with an inoperative ADS-B system, per 14 CFR 91.225(g)(1), by selecting “ADS-B equipment repair” as the reason for the request. The regulation allows pilots to fly to the airport of ultimate destination, including any intermediate stops, or to proceed to a place where suitable repairs can be made, or both. Although the regulation states the request may be made at any time, ADAPT requires at least a 1-hour lead time.

ADAPT is only used for flights with an inoperable ADS-B system that will transit ADS-B required airspace. There is no requirement to seek an FAA authorization prior to flying an aircraft with an inoperable ADS-B system if that flight will not transit ADS-B required airspace (see AC 90-114, “Automatic Dependent Surveillance-Broadcast Operations”). ADAPT requires that the aircraft have an operating transponder with altitude encoding.

A failure of the ADS-B system in flight will be handled by ATC and does not require the operator to make any request via ADAPT for that flight, including after the failure has occurred. 

Inoperative Transponder or Aircraft Not Equipped with Transponder

ADAPT will automatically deny any applicant who does not have an operable transponder with altitude encoding. Pilots who have a transponder failure must call the ATC facility with responsibility for that airspace to request an ATC authorization in accordance with 14 CFR 91.215(d). AOPA can assist with contact information, see ADAPT contacts.

Pilots desiring access to ADS-B required airspace flying an aircraft that does not have a transponder with altitude encoding capability at all, such as a non-electrical aircraft, antique aircraft, or agricultural aircraft, cannot use ADAPT and instead must call the ATC facility with responsibility for that airspace in order to gain access. Long-term requests for ATC authorization are to be made to the ATC facility responsible for that airspace. Pilots can request to enter into a Letter of Agreement (LOA). An LOA will replace the need to conduct per-flight requests via ADAPT. AOPA can assist with contact information, see ADAPT contacts.

For questions on an ATC authorization request, use this FAA air traffic email. This email is not staffed 24/7 and there may be delays in a response.

Feedback on the ADAPT interface can be directed to the FAA feedback form.

Any questions on using ADAPT can be directed at AOPA’s Pilot Information Center.

Updated May 20, 2020