Certificate holders · Part 135

For Existing Part 135 Operators: SAS Readiness, DCTs, Gap Reports and Amendments

You already hold the certificate. What lands on your desk now is surveillance: DCTs your principal inspectors assign, OpSpec amendments as the operation grows, and manual revisions that never quite catch up. Delta Bravo Aviation does that documentation work for a published fee, with every answer cited to your own manuals.

The short answer

What does Delta Bravo do for certificate holders? Answers assigned DCTs at $20 per question, runs pre-surveillance SAS readiness audits, prepares Statements of Compliance ($2,500), drafts manual amendments in a Manual Gap Suggested Edit Report ($100 each), and scopes manual reviews and OpSpec amendment projects (typically $7,500–$35,000).

What about the Part 5 SMS deadline? Part 135 operators authorized before May 28, 2024 must have an SMS meeting Part 5 implemented, and a declaration of compliance filed, by May 28, 2027 (14 CFR § 5.9(a)). Delta Bravo does not develop SMS programs; we refer operators to vetted SMS providers we recommend, such as OmniSMS and AirTera.

Who does the work? The principal, a sitting Part 119 Director of Operations — no junior hand-offs.

What we do for certificate holders

SituationServiceFee
Inspector assigned DCTs for a surveillance eventDCT completion, cited to your manuals$20 per question
Before a surveillance visitPre-surveillance SAS readiness audit; manual ↔ OpSpecs ↔ DCT triangulationCustom quote
Inspector wants the whole compliance pictureStatement of Compliance package$2,500 ($1,500 bundled)
Manuals do not yet support an answerManual Gap Suggested Edit Report + free DCT re-run$100 per amendment
Adding aircraft, areas or authorizationsManual review, OpSpec scope review and amendment projectCustom quote, typically $7,500–$35,000
Full GOM, GMM or training manual rewriteReferred to manual-development partner Black River AerospacePriced by the partner

Design versus performance

Surveillance looks at two things: whether the written program satisfies the rule (design) and whether the operation does what the program says (performance). Strong manuals with weak records still produce findings. The primer Preparing for an FAA SAS DCT Review lists what to stage and the six reasons answers get sent back.

Part 5 SMS: the May 28, 2027 deadline

The FAA’s 2024 Safety Management Systems rule extended 14 CFR Part 5 to every Part 135 operator. Operators authorized before May 28, 2024 must develop and implement an SMS that meets Part 5 and submit a declaration of compliance to their Flight Standards office no later than May 28, 2027 (14 CFR § 5.9(a); FAA Notice N 8900.737, Appendix B). The declaration comes at the end of the work, not the start: the SMS has to be implemented before it is signed. New applicants must have a compliant SMS as part of certification (§ 5.9(b)).

Delta Bravo Aviation does not develop or sell SMS programs. For the SMS itself, we refer operators to vetted SMS providers we recommend, such as OmniSMS and AirTera.

Frequently asked questions

Can someone help me answer the DCTs my inspector assigned?

Yes. Delta Bravo Aviation answers assigned DCTs at $20 per question with citations to your own manuals, scoped to your OpSpecs and peer group, with a blind inspector-style review before delivery.

How do I prepare for an FAA surveillance event?

Stage your current manual suite, OpSpecs, a question-to-paragraph cross-reference and the current revision of each DCT in scope. Delta Bravo Aviation runs pre-surveillance SAS readiness audits that triangulate manuals, OpSpecs and DCT answers, quoted individually.

Who helps with a Part 135 OpSpec amendment?

Delta Bravo Aviation scopes manual reviews, OpSpec reviews and amendment projects individually, typically $7,500 to $35,000, including the manual, OpSpecs and DCT changes the amendment drives.

When do existing Part 135 operators have to comply with Part 5 SMS?

Operators authorized to conduct Part 135 operations before May 28, 2024 must develop and implement an SMS that meets 14 CFR Part 5 and submit a declaration of compliance to the FAA no later than May 28, 2027 (14 CFR § 5.9(a)).

Does Delta Bravo Aviation build SMS programs?

No. Delta Bravo Aviation does not develop or sell SMS programs. It refers operators to vetted SMS providers it recommends, such as OmniSMS and AirTera.

Questions first? Ask us on LinkedIn

Not ready for a call? Message Delta Bravo Aviation on LinkedIn and Daniel Buehner will answer, or follow DCT Watch for the weekly FAA DCT and Order 8900.1 changes.

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About the author

Daniel Buehner is Founder and Principal of Delta Bravo Aviation, LLC. He spent 27 years in aviation across ramp service, USAF aircraft maintenance, Lockheed Martin test engineering, airline and charter flight decks, and Part 135 leadership seats including Chief Pilot, Director of Safety, and Director of Operations — a seat he still holds at an FAA-certificated air carrier. He has built and stood up multiple Part 135 certificates and logged more than 3,000 hours in Gulfstream aircraft. Delta Bravo Aviation is an SDVOSB-certified aviation compliance consultancy based in Kennesaw, GA. Read full bio →