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
| Situation | Service | Fee |
|---|---|---|
| Inspector assigned DCTs for a surveillance event | DCT completion, cited to your manuals | $20 per question |
| Before a surveillance visit | Pre-surveillance SAS readiness audit; manual ↔ OpSpecs ↔ DCT triangulation | Custom quote |
| Inspector wants the whole compliance picture | Statement of Compliance package | $2,500 ($1,500 bundled) |
| Manuals do not yet support an answer | Manual Gap Suggested Edit Report + free DCT re-run | $100 per amendment |
| Adding aircraft, areas or authorizations | Manual review, OpSpec scope review and amendment project | Custom quote, typically $7,500–$35,000 |
| Full GOM, GMM or training manual rewrite | Referred to manual-development partner Black River Aerospace | Priced 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.
Ask us on LinkedIn Follow DCT Watch on LinkedInRelated
- Part 135 certification consultant — the Part 135 Certificate Builder
- Part 145 repair station certification — the Part 145 Repair Station Builder
- SAS DCT readiness — DCT completion for applicants and certificate holders
- Existing Part 135 operators — surveillance DCTs, SAS readiness, gap reports and amendments
- Pricing — every published fee
- Resources & primers
- DCT Watch — weekly FAA DCT and Order 8900.1 changes