OpSpecs Explained: How Operations Specifications Scope Your Part 135 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.

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	Paragraphs that most often decide a Part 135 certificate's scope
Part A	General	A001 (issuance and applicability), A003 (aircraft authorized), A004/A055 (hazmat will-carry / will-not-carry), A005 (exemptions and deviations), A006 (management personnel), A007 (designated persons), A010 (weather sources), A015 (autopilot in lieu of SIC), A025 (electronic records and signatures), A031 (contract training), A039 (single PIC) and A040 (single-pilot), A046 (single-engine IFR with passengers), A057 (eligible on-demand), A062 (SIC professional development), A449 (drug and alcohol program)
Part B	En route authorizations, limitations and procedures	Areas of operation (B050 and the specific-area paragraphs for Canada, Mexico, the Caribbean, the North Atlantic, the Pacific and Europe), Class I and Class II navigation (B034, B036), NAT HLA (B039), RVSM (B046)
Part C	Airplane terminal instrument procedures and airport authorizations and limitations	Airports authorized (C070), special airports, EFVS (C048), RNAV/RNP approaches (C052, C063), CAT II and CAT III (C059, C060), lower-than-standard takeoff minimums (C079), terminal VFR for turbojets (C077)
Part D	Aircraft maintenance	Approved Aircraft Inspection Program (D073), CAMP and the inspection program references, short-term escalation (D076), parts pool (D083), aircraft listing (D085 — an aircraft may not sit on two certificate holders' D085 at once), minimum equipment list (D095)
Part E	Weight and balance control	Weight-and-balance program authorizations where issued; most Part 135 operators carry their W&B program in the A096–A099 series instead
Part H	Helicopter terminal instrument procedures and authorizations	Helicopter IFR, offshore and special procedures; the helicopter air ambulance set under Subpart L (A021, A050, D093 and the H-series paragraphs)
Part P	Powered-lift operations	The newest series, issued to operators of powered-lift aircraft under 14 CFR Part 194 (for example P049); its paragraphs mirror the airplane and helicopter authorizations for the new category

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.

Amendment lead times: what § 119.51 requires

Because an OpSpec change is a compliance project, the regulation builds in notice. Under 14 CFR § 119.51, a certificate holder requesting an amendment must file at least 15 days before the proposed effective date in most cases — and at least 90 days before for mergers, acquisitions of operational assets that require an additional showing of safety (proving tests, for instance), changes in the kind of operation as defined in § 110.2, resumption of operations after a bankruptcy suspension, or the initial introduction of an aircraft type not previously proven in air carrier or commercial operator service. An amendment becomes effective on the Administrator's approval. Changes to the certificate itself — a new category or class of aircraft, added areas, air ambulance or scheduled authority — run through § 119.41 and are treated by the FAA as an abbreviated certification with their own Data Collection Tools.

Those lead times are why Delta Bravo's Part 135 Certificate Builder plans the OpSpec set for day one and the amendment schedule for the 12/24/36-month growth plan at the same time: an authorization the business will need in month 18 is filed in month 15 with its manual content and DCT answers already drafted, rather than discovered in month 18 and waited on through month 21.

What this means in practice

For a Director of Operations, Chief Pilot, or compliance manager, three takeaways matter:

1. 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.
2. 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.
3. Treat amendments as compliance projects with lead times. Expanding scope means updating manuals, answering DCTs and filing 15 or 90 days ahead under § 119.51. Plan for that work on the growth plan's calendar rather than discovering it mid-request.

Sources

• 14 CFR §§ 119.5, 119.41, 119.51; 14 CFR § 110.2; 14 CFR Part 194 (powered-lift operations).
• FAA Order 8900.1, Volume 3, Chapter 18 (Operations Specifications), Sections 3–6 (Parts A through H) and the powered-lift paragraphs; Volume 3, Chapter 18, Section 13 (adding and removing aircraft).
• FAA Advisory Circular AC 120-49B, Certification of Air Carriers (changes in scope treated as abbreviated certifications).

How OpSpecs drive DCT scoping

Every Element-Design answer that is in scope because of an OpSpec — and every N/A that is justified because an OpSpec is absent — starts with an accurate OpSpec inventory. Before a DCT engagement begins, confirm the current OpsSpecs print matches what the FAA shows for the certificate, including pending amendments. An amendment that adds or removes an authorization (for example, hazmat, RVSM, or a new area of operation) changes which DCT questions apply on the next revision cycle. For how that interacts with Element-Design vs. Element-Performance, see What are SAS DCTs?.

Frequently asked questions

What are Operations Specifications (OpSpecs)?

Operations Specifications (OpSpecs) are the legally binding document, issued by the FAA, that defines exactly what an air carrier or operator is authorized to do under its certificate. While 14 CFR Part 135 sets the general rules for all on-demand and commuter operators, the OpSpecs tailor those rules to the individual operator — listing the specific authorizations, limitations, aircraft, areas of operation, and conditions that apply to that certificate holder. OpSpecs carry the force of regulation for the operator they are issued to.

How are OpSpecs organized?

OpSpecs are organized into lettered parts, each covering a category of authorization. Part A covers general authorizations and definitions; Part B covers en route authorizations and limitations; Part C covers airport authorizations and limitations; Part D covers maintenance; and additional parts cover other areas. Within each part, individual paragraphs are numbered — for example, A001 identifies the certificate holder and the regulations under which it operates, A003 lists ratings and authorizations, and C-series paragraphs address specific airport and approach authorizations.

Why do OpSpecs matter for completing a DCT?

OpSpecs determine which regulations actually apply to an operator and how. A DCT question about a particular authorization is only relevant if the operator holds that authorization in its OpSpecs. Conversely, a requirement tied to an authorization the operator does not hold is legitimately not-applicable. Because the OpSpecs define the operator's true scope — fleet, areas of operation, special authorizations, and limitations — every DCT answer must be scoped against them. Answering a DCT without applying the operator's OpSpecs produces answers that are either over-inclusive or simply wrong.

What is the difference between Part 135 regulations and OpSpecs?

14 CFR Part 135 is the body of federal regulation that applies generally to all on-demand and commuter air carriers. OpSpecs are the operator-specific document that applies Part 135 to one certificate holder — granting particular authorizations, imposing particular limitations, and listing the specific aircraft and areas of operation. Think of Part 135 as the rulebook for the whole league and OpSpecs as the contract that says exactly what one team is allowed to do.

How does an operator change its OpSpecs?

An operator requests an OpSpec amendment through its FAA Principal Inspector or certificate management team. The operator typically must demonstrate that it can comply with the requirements attached to the new authorization — often by updating its manual suite and answering the relevant Data Collection Tools, and sometimes by providing a broader compliance demonstration. The inspector reviews the request, and if the operator's design and procedures support it, the amended OpSpecs are issued. Adding a new aircraft type, a new area of operation, or a special authorization are all OpSpec amendments.

What does OpSpec paragraph A001 contain?

A001 is the foundational paragraph of the Operations Specifications. It identifies the certificate holder by legal name, lists the certificate number, and states the regulations under which the operator is authorized to conduct operations. It establishes the basic identity and regulatory basis of the certificate, which is why it is typically the first paragraph reviewed in any examination of an operator's authorized scope.

Can a consultant help interpret OpSpecs when completing compliance work?

Yes. Reading OpSpecs correctly is central to compliance work. A consultancy completing DCTs or building a Statement of Compliance must apply the operator's exact authorizations and limitations so that each answer reflects the operator's true scope. Delta Bravo Aviation scopes every DCT and SOC engagement to the operator's OpSpecs, fleet, and operations type — so a requirement that does not apply is documented as not-applicable with a rationale, and a requirement that does apply is answered with a citation to the operator's manuals.

What are the lettered parts of Part 135 Operations Specifications?

Part A covers general authorizations (A001 issuance, A003 aircraft, A005 deviations, A006 management personnel, A025 electronic records, A039/A040 single PIC and single-pilot, A449 drug and alcohol, among others); Part B covers en route authorizations such as areas of operation, Class II navigation, NAT HLA and RVSM; Part C covers airplane terminal instrument procedures and airport authorizations such as EFVS, RNP, CAT II/III and lower-than-standard takeoff minimums; Part D covers maintenance, including the AAIP, aircraft listing (D085) and MEL (D095); Part E covers weight and balance where issued; Part H covers helicopter procedures and the helicopter air ambulance set; and the new Part P series is issued to powered-lift operators under 14 CFR Part 194.

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
• Can a Company Build Your Part 135 Certificate for You? What a Complete 2026 Application Contains
• DCT Completion service — what's included, scope, deliverable format
• Pricing — flat rates for DCT, SOC, Manual Gap Suggested Edit Report and the Builders