What are SAS DCTs? Element-Design (DA) and Element-Performance (PA) Explained for Part 135 Operators

SAS Data Collection Tools (DCTs) are structured FAA questionnaires used by Principal Inspectors to evaluate a Part 135 Certificate Holder or Applicant against the regulations. They come in two flavors. Element-Design (ED) — also called Design Assessment (DA) — evaluates the operator’s written compliance system. Element-Performance (EP) — also called Performance Assessment (PA) — evaluates whether the operator actually performs to that documented design in practice. Both terminologies show up in FAA Order 8900.1 and in operator/inspector conversation, and they are used interchangeably.

That is the short answer. The rest of this guide explains where SAS DCTs come from, what each flavor evaluates, what an acceptable answer looks like, and what most operators get wrong the first time through. The audience is people who actually have a DCT in front of them — Directors of Operations, Chief Pilots, Directors of Safety, Compliance Managers, and applicant management teams. The goal is to leave you able to answer two questions: “is this DCT actually scoped to my operation?” and “what does a defensible answer look like?”

The SAS framework, in one paragraph

The FAA’s Safety Assurance System (SAS) is the framework the agency uses to certificate and oversee Part 121, 135, and 145 operators. SAS replaced the older Air Transportation Oversight System (ATOS) approach and is documented primarily in FAA Order 8900.1. The framework breaks an operator’s compliance picture into elements, where each element corresponds to a discrete area of regulation (for example, training programs, maintenance programs, hazardous materials handling, dispatch). For each element, two questions matter to the inspector: (1) is the operator’s design sound? and (2) is the operator actually performing to that design? Element-Design (DA) DCTs answer the first question. Element-Performance (PA) DCTs answer the second.

Element-Design (ED) · Design Assessment (DA)

An Element-Design DCT — equivalently, a Design Assessment — is the questionnaire you receive from your Principal Inspector that asks the operator to demonstrate, in writing and with citations to the manual suite, how the operation’s written procedures satisfy a specific set of regulatory requirements. It is the assessment of the design: does the paper plan hold up against the rule?

ED/DA DCTs are typically delivered as a PDF or fillable form containing dozens of structured questions. Each question reads something like:

• “Does the operator have written procedures for [specific regulatory requirement]?”
• “Are those procedures consistent with [specific 14 CFR section / AC / Order 8900.1 reference]?”
• “Where in the operator’s manual suite is that procedure documented?”

For each question, the operator is expected to provide a clear, written answer with a citation back to the specific paragraph of its manual suite where the procedure lives. “Yes — see GOM § 4.3.2” is a better answer than “Yes.” A bare “Yes” gives an inspector nothing to verify against.

Who completes it. The operator (often with a consultant’s help) completes the ED/DA DCT, then submits the package to the Principal Inspector for review. Acceptance generally comes before any meaningful field assessment kicks in.

Element-Performance (EP) · Performance Assessment (PA)

An Element-Performance DCT — equivalently, a Performance Assessment — is the FAA’s evaluation of whether the operator actually does, in practice, what its manual suite says it does. It is the assessment of performance: when you watch the operation, does it match the design that was accepted in the ED/DA phase?

EP/PA DCTs are populated through observation, not narrative answers from the operator. Inspector activities that feed an EP/PA assessment include:

• Line checks and en-route inspections
• Ramp inspections and station audits
• Records reviews (training records, maintenance records, dispatch records)
• Observation of pre-flight and post-flight crew duties
• Witnessing required briefings, weight-and-balance, hazmat acceptance, etc.

The inspector compares what they observe to what the operator’s manual suite (accepted at ED/DA time) says should be happening. A clean EP/PA result means the design and the practice match. A gap — for example, the crew doing something the manual doesn’t describe, or skipping a step the manual requires — generates follow-up questions and possibly a corrective action request.

Who completes it. The Principal Inspector, based on field observation. This is why EP/PA DCTs cannot be outsourced to a consultant: only the operator can be observed performing the operation. What a consultant can do is help the operator prepare — ensuring crew briefings, paperwork flows, and operational practices align with the documented design before the inspector arrives.

ED/DA vs. EP/PA: a quick reference

Aspect	Element-Design (ED) / Design Assessment (DA)	Element-Performance (EP) / Performance Assessment (PA)
What it evaluates	The operator’s written compliance system — manual suite design.	The operator’s actual compliance behavior — what happens in practice.
Evidence base	GOM, GMM, training manuals, hazmat manual, ERP, OpSpecs.	Line checks, ramp inspections, records reviews, station audits, observation.
Completed by	Operator (with optional consultant support), with citations to manuals.	FAA Principal Inspector, with field observations.
Sequence	Comes first — establishes the design baseline.	Follows ED/DA, validates that the design is being executed.
Typical failure mode	Citations missing, vague, or pointing to the wrong section; boilerplate answers that don’t reflect the operator’s actual scope.	Field observation does not match what the accepted manual says; crew working from outdated procedures.
Can a third party complete it for you?	Yes — consultancies commonly produce ED/DA DCT packages from the operator’s manuals.	No — only the operator can be observed. But a consultant can help prepare.

Peer groups and DCT revisions: why two operators get different questions

SAS does not hand every Part 135 operator the same questionnaire. Each DCT is issued per peer group and specialty, and carries a revision. The file name tells you all three — ED_4_3_9_135C_OP_V17 is Element-Design DCT 4.3.9, for peer group 135C, Operations specialty, revision 17. The Part 135 peer groups are:

Peer group	Who sits in it	What it changes
135B	Operators of aircraft type-certificated for 10 or more passenger seats	CAMP and GMM questions, CASS, flight attendants, Part 121-style training items
135C	Nine-or-less operations, including turbojets and multi-pilot aircraft	The largest standard set — GOM, training, AAIP or CAMP election, special authorizations
135D	Single-pilot operators (OpSpec A040), grouped with single PIC (A039) for process	A much shorter set; the compliance statement carries what a GOM would for other groups
135E	Helicopter air ambulance	Subpart L items — A021, D093, the H-series, operations control center — on top of the seat-count tier of the helicopters

Specialties split the bank again: OP (Operations) DCTs are worked by the Principal Operations Inspector, AW (Airworthiness) DCTs by the Principal Maintenance and Avionics Inspectors. And revisions matter more than most operators expect: the FAA revises DCTs as regulations and guidance change, and an answer package built against revision 15 will be read against revision 17 if that is what the inspector opens. For applicants, the FAA expects DCT answers to be current within 90 days; Delta Bravo re-checks every client's DCT set against the current bank on that cadence and shows the revision number and date in the heading of every DCT it renders.

One more 2026 change: under the FAA's readiness process (N 8900.766), a new Part 135 applicant completes the Element-Design DCTs for its own design before the certification team reviews them — the same instrument a certificate holder sees in surveillance, now part of the applicant's own package. How that fits into a build is covered in Can a Company Build Your Part 135 Certificate for You?.

What makes a DCT answer acceptable

The attributes below apply primarily to ED/DA DCTs (the ones the operator answers in writing), but the same posture pays off when the EP/PA assessment arrives. A defensible answer is:

1. Traceable. Every assertion is linked back to a specific paragraph of the operator’s manual suite. “See GOM § 4.3.2” beats “Yes.” If the regulatory requirement is non-obvious, also cite the underlying 14 CFR section or Advisory Circular.
2. Scope-correct. The answer reflects the operator’s actual OpSpecs, fleet, and operations type. Boilerplate answers that describe a generic Part 135 operation get pushed back. If you do not hold OpSpec A031, do not pretend to.
3. Honest about “Not Applicable.” Many DCT questions will not apply to a given operator. “N/A” is acceptable, but each N/A needs a documented rationale tied to a fact about the operator — typically the OpSpecs held, the aircraft type, the passenger capacity, or whether a particular program (SMS, AQP, etc.) is in place.
4. Internally consistent. Different DCTs sometimes touch the same procedure from different angles. The citations across DCTs should point to the same paragraph of the manual suite, not different paragraphs that contradict each other.
5. Written in operator voice. The deliverable goes to your inspector under your name. The voice should be the voice of your operation, not a consultant’s house style.

Where most operators struggle

Two recurring patterns we see when DCT work comes back with inspector questions:

Pattern one: scope creep on ED/DA. An operator fills out every question in the DCT as if it applies, including questions that genuinely do not apply to its operation. The DCT ends up describing a different — usually larger — operation than the one on the certificate. Inspectors notice. The fix is rigorous scoping up front: list every OpSpec held, every aircraft type, every program in place, and let those facts drive which questions get full answers and which get a documented “Not Applicable.”

Pattern two: design-vs-performance drift. The ED/DA DCT was accepted clean, but six or twelve months later when the EP/PA assessment runs, the crew is doing something different from what the manual says — usually because an informal “how we actually do it” practice grew up around an outdated procedure. The fix is twofold: keep the manual suite current as the operation evolves, and run periodic internal walk-throughs comparing what the manual says to what the crew actually does. A Manual Gap Suggested Edit Report (Delta Bravo’s consolidated amendment report) is one structured way to close that gap before the inspector finds it.

How a DCT engagement typically runs

A well-scoped DCT engagement — whether done in-house or with outside help — typically moves through four stages on the ED/DA side, plus a preparation stage for the EP/PA side:

1. Scoping. Inventory the operator’s OpSpecs, fleet, passenger capacity, crew complement, and active programs (SMS, ASAP, FOQA, AQP, CASS, NVG, HAZMAT carrier status, etc.). This drives which ED/DA questions apply and which get a documented N/A.
2. Manual cross-reference. For each in-scope ED/DA question, locate the paragraph in the operator’s manual suite that addresses it. This is where most of the labor lives.
3. Answer drafting. Write each ED/DA answer in operator voice with the manual citation embedded. Cite the underlying regulation (14 CFR, AC, 8900.1) where it helps the inspector verify.
4. Gap callout and counsel review. Before anything is rendered, the whole package is read by a blind panel of inspector-style reviewers who have not seen it being produced — a step that catches the weak citation and the stale revision a drafter stops seeing. Where the manual suite does not yet support an answer, flag the gap explicitly rather than papering over it. The operator can then choose to close the gap (a manual revision) before submission or document the gap for the inspector. A clean gap callout is far better than a fudged answer.
5. EP/PA readiness. Once the ED/DA design is accepted, walk the operation against the manual: do crew briefings match the documented script? Are records being kept in the place and form the manual specifies? Closing the gap between what was accepted on paper and what happens on the ramp is the work that turns a clean ED/DA into a clean EP/PA.

How OpSpecs and peer groups decide which questions you answer

Two operators with the same aircraft type can receive different Element-Design questionnaires. The SAS system scopes each DCT to a peer group (for Part 135: 135B, 135C, 135D or 135E) and a specialty (Operations, Maintenance, Cabin Safety, Avionics, and so on). Your Operations Specifications then further decide which questions inside that DCT are in scope. An OpSpec that authorizes hazardous materials carriage brings hazmat questions into play; the absence of that OpSpec usually supports a documented N/A, not a Yes.

Before answering, confirm three things against the file name and the first page of the DCT: the peer group matches your certificate, the specialty matches the inspector who assigned it, and the revision is the current one on the FAA Dynamic Regulatory System (DRS). Answering the wrong peer group or an older revision is one of the fastest ways to send a package back for rework. See also Preparing for an FAA SAS DCT Review.

Yes, No, N/A and GAP: the four answer outcomes

Every Element-Design question resolves to one of four outcomes. Getting the outcome right matters as much as the citation:

• Yes — the manual suite contains a procedure that satisfies the requirement, and the answer cites the specific paragraph. Prefer “Yes — see GOM § 4.3.2” over a bare Yes.
• No — the requirement applies to this operation, and the manual suite does not yet contain a supporting procedure. A No without a plan to close it invites a finding; a No paired with a dated corrective action is usually stronger.
• N/A — the requirement does not apply to this certificate because of OpSpecs, fleet, passenger capacity, cargo-only status or another documented limiter. The answer must state why it does not apply (for example, “Operator does not possess OpSpec A055” for a certificated holder, or “is not seeking” for an applicant).
• GAP — Delta Bravo’s vocabulary for a No that the manuals cannot yet support. The answer package flags the gap explicitly so the operator can close it with a manual revision (or a Manual Gap Suggested Edit Report) before submission, rather than papering over it.

Scoping mistakes — answering Yes to a question that should be N/A, or N/A to a question the OpSpecs actually authorize — are among the most common reasons an inspector returns a package. The fix is to inventory OpSpecs, fleet and programs before drafting, not after.

Applicants now complete their own Element-Design DCTs

Under FAA Notice N 8900.766 (effective January 26, 2026), an applicant must demonstrate readiness before the FAA places it on the national Applicant List. That readiness package includes the compliance statement and, by tier, the manuals — and applicants complete their own Element-Design DCTs rather than waiting for an inspector to issue them after Formal Application. The five certification phases in Order 8900.1 still describe the process; the front end now collapses Phase 1 and Phase 2 content into a single readiness filing. For the clocks, tiers and AIS Services portal, see How Long Does Part 135 Certification Take? and Can a Company Build Your Part 135 Certificate for You?.

Part 5 SMS and DCTs: related, but not the same engagement

Existing Part 135 operators authorized to conduct operations before May 28, 2024 must implement a Safety Management System that meets 14 CFR § 5.9(a) and submit a declaration of compliance no later than May 28, 2027. New applicants must have an SMS that meets Part 5 as part of certification. SMS documentation can appear in the N 8900.766 readiness package and can surface inside certain DCT elements, but building the SMS itself is a separate body of work.

Delta Bravo Aviation does not develop or sell SMS programs. For the SMS itself, Delta Bravo refers operators to vetted providers such as OmniSMS and AirTera. What Delta Bravo does complete is the Element-Design DCT package scoped to your OpSpecs and manuals — including the SMS-related questions once your SMS provider’s documentation is in place.

Sources

• 14 CFR Part 135 — Operating requirements for commuter and on-demand operations.
• FAA Order 8900.1, Volume 10 — Safety Assurance System policies and procedures (peer groups, Design Assessment and Performance Assessment). Available on the FAA Dynamic Regulatory System (DRS).
• FAA Notice N 8900.766, Determine Applicant Readiness for Certification (effective January 26, 2026).
• 14 CFR § 5.9 — Part 5 SMS compliance dates for Part 135 and § 91.147 operators.
• FAA Part 135 certification page — AIS Services transition (September 30, 2026) and the five-phase process.
• Your Operations Specifications (OpSpecs) — the operator-specific authorities that scope which DCT questions apply.

Frequently asked questions

What are SAS Data Collection Tools (DCTs)?

SAS Data Collection Tools (DCTs) are structured FAA questionnaires used by Principal Inspectors to evaluate a Part 135 Certificate Holder or Applicant against the regulations. They come in two flavors: Element-Design (ED), also called Design Assessment (DA), which evaluates the operator's written compliance system (its manual suite); and Element-Performance (EP), also called Performance Assessment (PA), which evaluates whether the operator actually performs to that documented design in practice. The operator completes ED/DA DCTs with citations to its manual suite; EP/PA DCTs are typically completed by the inspector based on field observation.

What is the difference between Element-Design (ED) and Element-Performance (EP) DCTs?

Element-Design (ED) DCTs evaluate what the operator has documented in its manual suite — the design of its compliance system. Element-Performance (EP) DCTs evaluate whether the operator actually does what it says it does — the performance of that system in the field, observed through line checks, ramp inspections, records reviews, and station audits. ED comes first conceptually; EP follows once the documented design is in place and the operation is running against it.

What is a Design Assessment (DA)? Is it the same as an Element-Design DCT?

Yes. Design Assessment (DA) is the alternate name the FAA uses for an Element-Design (ED) DCT. The terms are interchangeable — both refer to the structured questionnaire that asks an FAA Part 135 operator to demonstrate, with citations to its manual suite, how its written procedures meet specific regulatory requirements. Some inspectors and operators say ED; some say DA. They mean the same instrument.

What is a Performance Assessment (PA)? Is it the same as an Element-Performance DCT?

Yes. Performance Assessment (PA) is the alternate name for an Element-Performance (EP) DCT. Both terms describe the FAA's evaluation of how an operator's documented procedures perform in actual operations — observed during line checks, surveillance events, ramp inspections, and records reviews. EP and PA are interchangeable in FAA Order 8900.1 and in operator/inspector usage.

Who is required to complete a SAS DCT?

Any FAA Part 135 Certificate Applicant in the certification process, and any Certificate Holder during surveillance or an OpSpecs amendment, may be required to complete one or more SAS Element-Design (DA) DCTs. Element-Performance (PA) DCTs are typically completed by the FAA Principal Inspector based on observations of the operation, not by the operator. The specific DCTs assigned depend on the operator's scope: aircraft type, OpSpecs held, operations type, and the regulatory area in question.

How long does a SAS DCT take to complete?

Internally, most Part 135 operators take weeks or months to complete a single Element-Design (DA) DCT because the work requires careful cross-referencing of the manual suite against 14 CFR, Advisory Circulars, and FAA Order 8900.1. With a focused effort and a disciplined process, a DCT can be completed in a single business day. Delta Bravo Aviation specializes in this fast turnaround, priced at $20 per DCT question — same flat rate for every question, regardless of complexity.

What counts as an acceptable answer on a SAS DCT?

An acceptable Element-Design (DA) DCT answer is traceable. For each question, the operator should cite the specific paragraph in its operator manual suite where the procedure is documented (for example, 'GOM Section 4.3.2'), and where helpful, cite the underlying regulation (e.g., 14 CFR § 135.21). 'Not Applicable' is an acceptable answer when scoped properly, but each N/A must include a documented rationale tied to the operator's OpSpecs, fleet, or operations type. For Element-Performance (PA) DCTs, acceptability is judged by the inspector against observed field performance compared to the documented design.

What does an FAA inspector look for in a completed DCT?

For Element-Design (DA) DCTs, inspectors look for three things: (1) traceability — every assertion linked back to a specific manual paragraph or regulation; (2) scope-correct answers — answers that reflect the operator's actual OpSpecs, fleet, and operations type rather than boilerplate; and (3) documented rationales for any 'Not Applicable' designations. For Element-Performance (PA) DCTs, inspectors look for alignment between the documented design and what they actually observe in line checks, records reviews, and station audits. A mismatch between the manual and the practice generates follow-up questions and a longer surveillance cycle.

Where do I find the SAS DCTs and the supporting regulations?

The DCTs themselves are provided by the operator's Principal Inspector. Supporting reference material includes 14 CFR (the regulations), the relevant Advisory Circulars (AC), and FAA Order 8900.1 (Flight Standards Information Management System), which guides inspector practice and contains the SAS framework definitions and procedures for both Design Assessment and Performance Assessment.

Can a third party help complete a SAS DCT?

Yes, for Element-Design (DA) DCTs. Operators commonly engage aviation compliance consultancies to complete ED/DA DCTs on their behalf. The consultancy works from the operator's manual suite and produces a completed, citation-traceable DCT package for inspector submission. The operator remains the responsible party for accuracy, but the lift is moved off in-house staff. Element-Performance (PA) DCTs cannot be answered by a third party because they assess actual operational behavior — only the operator can be observed performing the operation.

What are the SAS peer groups for Part 135?

The FAA sorts Part 135 certificates into peer groups by configuration: 135B for operators of aircraft type-certificated for 10 or more passenger seats, 135C for nine-or-less operations including turbojets and multi-pilot aircraft, 135D for single-pilot operators (with single PIC operators grouped alongside for process purposes), and 135E for helicopter air ambulance. Each DCT is issued per peer group and specialty — Operations (OP) or Airworthiness (AW) — so two operators in different peer groups receive different question sets.

Do DCT revisions matter?

Yes. The FAA revises Data Collection Tools as regulations and guidance change, and each DCT carries a revision number. An inspector reads your answers against the current revision, so a package built against an older one can miss or misnumber questions. The FAA expects an applicant's DCT answers to be current within 90 days, and a well-run compliance program re-checks its DCT sets on that cadence and records the revision and date on every answered DCT.

What does a 'GAP' mean in a DCT answer package?

A GAP is Delta Bravo Aviation's rendering of a 'No' answer: the question applies to the operator's scope and the manual suite does not yet contain the process, procedure or statement the question asks for. It is a finding, not a failure — it identifies exactly which manual needs an amendment before the inspector reviews the package, and it feeds the Manual Gap Suggested Edit Report.

Related reading

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• DCT vs. SOC: When the FAA Wants More Than Answered DCTs
• Preparing for an FAA SAS DCT Review: What Part 135 Operators Should Expect
• OpSpecs Explained: How Operations Specifications Scope Your Certificate
• 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
• Manual Gap Suggested Edit Report — closing gaps surfaced by a DCT engagement
• Pricing — flat rates for DCT, SOC, Manual Gap Suggested Edit Report and the Builders