OpSpecs Explained: How Operations Specifications Scope Your Certificate and Drive DCT Answers
If 14 CFR Part 135 is the rulebook for the whole league, your Operations Specifications are the contract that says exactly what your team is allowed to do. OpSpecs are where the general regulation becomes operator-specific — and that is precisely why they govern how every Data Collection Tool must be answered. Get the OpSpecs reading wrong, and even a perfectly cited DCT answer can be wrong.
The short answer
What are OpSpecs? The FAA-issued, legally binding document defining what your specific certificate is authorized to do.
Why do they matter for DCTs? They define your true scope — so they decide which requirements apply and which are legitimately not-applicable.
The rule of thumb: never answer a DCT without reading it against the operator’s current OpSpecs first.
What OpSpecs are
Operations Specifications — universally shortened to “OpSpecs” — are a document the FAA issues to each certificate holder that spells out exactly what that operator is authorized to do. Part 135 establishes the regulations that apply to on-demand and commuter operators generally. The OpSpecs take those regulations and tailor them to one operator: which aircraft, which areas of operation, which special authorizations, and under which limitations.
Critically, OpSpecs are not guidance or suggestion — they carry the force of regulation for the operator they are issued to. Operating outside your OpSpecs is operating outside your authority. That binding quality is why they sit at the center of every compliance question.
How OpSpecs are organized
OpSpecs follow a standardized structure of lettered parts, each addressing a category of authorization. Within each part, individual numbered paragraphs grant specific authorizations or impose specific limitations.
| Part | Covers | Examples of what lives here |
|---|---|---|
| Part A | General | A001 (certificate holder identity and regulatory basis), A003 (ratings and authorizations), definitions, and general conditions |
| Part B | En route | Area of operation authorizations, navigation and en route limitations |
| Part C | Airports | Airport authorizations and limitations, approach and landing minimums authorizations |
| Part D | Maintenance | Maintenance program authorizations, inspection program references |
| Further parts | Specialized areas | Training, weight and balance, and other authorization categories as applicable |
The paragraph that anchors everything is A001. It names the certificate holder, states the certificate number, and identifies the regulations under which the operator conducts business. When anyone — an inspector, a consultant, or you — sits down to understand an operator’s authorized scope, A001 is where the reading starts.
OpSpecs vs. Part 135: the league and the contract
The relationship is worth making concrete, because conflating the two is the root of many compliance errors:
- 14 CFR Part 135 is the body of federal regulation. It applies to every on-demand and commuter operator. It is general by design.
- OpSpecs apply Part 135 to a single operator. They grant the specific authorizations that operator has demonstrated it can hold, and they impose the limitations that operator must respect.
Two operators can both be “Part 135 certificate holders” and yet have radically different obligations — because their OpSpecs authorize different things. One may hold single-pilot authority and VFR-only operations; another may hold a full fleet of turbine aircraft, international authorizations, and low-visibility approach authority. Same rulebook, very different contracts.
Why OpSpecs decide how a DCT is answered
This is the heart of why operators completing compliance work cannot skip the OpSpecs. A Data Collection Tool asks whether the operator meets a regulatory requirement — but whether that requirement even applies, and how, depends on the operator’s authorizations.
Consider the logic:
- If the operator holds an authorization, the DCT questions tied to that authorization are live, and each must be answered with a citation to where the operator’s manuals document compliance.
- If the operator does not hold an authorization, the questions tied to it are legitimately not-applicable — but only if that N/A is documented with a rationale grounded in the OpSpecs (“the operator does not hold this authorization per OpSpec paragraph X, therefore this requirement does not apply”).
Answer a DCT without applying the OpSpecs and you get one of two failures: over-inclusion, where you scramble to document compliance with requirements you were never subject to, or error, where you claim an authorization the operator does not actually hold. Both undermine credibility at the desk. This is why our DCT and SOC work always begins with the OpSpecs — they are the lens through which every answer is scoped.
For how that scoping plays out in an actual review, see Preparing for an FAA SAS DCT Review. For when an inspector wants the whole regulatory picture rather than element-level answers, see DCT vs. SOC.
OpSpec amendments: adding to your scope
OpSpecs are not static. When an operator wants to expand what it can do — add a new aircraft type, add an area of operation, gain a special authorization — it requests an OpSpec amendment through its FAA Principal Inspector or certificate management team.
An amendment is rarely a simple paperwork change. The operator generally must demonstrate it can comply with the requirements attached to the new authorization. In practice that means updating the manual suite to document the new procedures, answering the Data Collection Tools relevant to the change, and sometimes providing a broader compliance demonstration when the amendment touches multiple regulatory areas at once. The inspector reviews the demonstration, and if the operator’s design and procedures support the request, the amended OpSpecs are issued.
In other words: a meaningful change to your OpSpecs usually triggers DCT work. The two are tightly linked, which is why operators planning to expand scope benefit from getting the compliance documentation in order before they file the amendment request.
What this means in practice
For a Director of Operations, Chief Pilot, or compliance manager, three takeaways matter:
- Keep your OpSpecs current and accessible. They are the reference point for every compliance conversation. An out-of-date understanding of your own authorizations leads to wrong answers.
- Scope every DCT against them. Before answering, confirm which authorizations are live. The OpSpecs tell you which questions are real and which are documented not-applicable.
- Treat amendments as compliance projects. Expanding scope means updating manuals and answering DCTs. Plan for that work rather than discovering it mid-request.
Related reading
- What are SAS DCTs? Element-Design (DA) and Element-Performance (PA) Explained
- Preparing for an FAA SAS DCT Review: What Part 135 Operators Should Expect
- DCT vs. SOC: When the FAA Wants More Than Answered DCTs
- DCT Completion service — what’s included, scope, deliverable format
- Pricing — flat rates for DCT, SOC, and Manual Gap Suggested Edit Report