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

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 review. 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.

Where the references live

If you want to read further, these are the primary sources behind everything above:

• 14 CFR Part 135 — the regulation governing on-demand and commuter operations. This is the substantive law your manual suite must satisfy.
• FAA Order 8900.1, Volume 10 — Safety Assurance System policies and procedures, including the SAS framework definitions and the DCT process. Both Design Assessment and Performance Assessment terminology appear here.
• Advisory Circulars in the 120-series (e.g., AC 120-92 on SMS, AC 120-66 on ASAP, AC 120-90 on LOA programs) — non-regulatory guidance the FAA expects operators to consider.
• Your Operations Specifications (OpSpecs) — the operator-specific authorities and limitations that determine which DCT questions apply.

Related reading

• DCT Completion service — what’s included, scope, deliverable format
• Statement of Compliance — when an inspector wants more than answered DCTs
• Manual Gap Suggested Edit Report — closing gaps surfaced by a DCT engagement
• Pricing — flat rates for DCT, SOC, and Manual Gap Suggested Edit Report
• About Delta Bravo Aviation and Daniel Buehner