Part 135 CertificationsWhat You Need To Know
Part 135 Certification
A Few Notes About Experience
Part 135 Certification: Within our group we have ex-FAA POI, Part 125 & 135 operator in turbojet operations and vast years of certifications at all levels from smallest to largest of Part 135 charter operations.
Unfortunately, all of the above means little. Each certification is a bit different, depending upon the office and the region and those are both commonly in flux creating a known lack of standards.
What is a standard, mostly, is that the better the material, the BETTER IT LOOKS, the faster and easier and less costly it will be. It is true, appearances mean a lot, but it does also mean that you came to the FAA prepared and have done enough research to find someone that has the experience and the range of Part 135 manuals to get you through faster–hopefully.
Be prepared financially and emotionally, for a minimum of 3 months on smaller operations and up to 6-8 months on larger ones, which is partially why we get paid up front because that is more than we can string out. If you have owners and investors, let them know, be frank, and move along because when you are done, with an air carrier certificate, you have something of value, and personally you have value as someone that moved this through.
Getting Started – We send you a worksheet for the overall 135 certification and if using a GMM, another, detailed, GMM worksheet.
What You Need – The GOM, the GMM if operating a 10 or more passenger aircraft, the Statement of Compliance, the Training Program, plus Maneuvers Manual, an MEL for ME airplanes and whatever airspace approval manuals you need for this operating name. This is a LOT of manuals and forms and application documents to go with it all.
Manuals You Need for Part 135
1st Be Prepared
Part 135 Certification – Above everything else, you need to drive and direct the certification. Come with draft manuals in hand with knowledge of the process because if you do not, then some inspector, well-meaning as they might be, becomes the director of your certification. Their real job is just to ensure you have the material to manage the operation, not to create it for you.
We recommend you show up at the Preapplication PASI Meeting with draft manuals, right there, showing you are ready to move ahead NOW. After that, in over 15-years of doing this on all sides of the table have only seen a couple of formal application meetings as they are not needed if you are ready. Half the time the FAA will take what you have to move along, but then other times will ask you to go back, go over what was discussed and SEND the manuals back to them.
Part 135 Certification –
Some Manual Overkill
Yes, to a point, the Nacellepubs compliance manuals are a bit of an overkill in some areas. But realistically there is not a 5% difference between a Baron flying in IFR operations and a Global Express in worldwide operations. Both are high-level, compliance-driven, professionally flown operations. And the difference between that and or fleet of wide-bodied Boeing Part 125s is very, very little also.
And frankly, for a Part 135 Certification, the larger jet operations are a lot easier to get approved just because the manuals touch on every level of professional flight operations–which should be the same for an operator with a Baron, a PC-12, King Air or Global Express.
New DCTs Could Be Showstoppers
These are new from the FAA – and we think are improper
Data Collection Tools
From the last months of 2017, these are over 680+ questions with mandatory manual references – many being totally incomprehensible – to be addressed and then evaluated by a local inspector, whom could be only (and now often are), small airplane flight school pilots with zero Part 135 experience and no turbine time – whom are now designated to evaluate and make totally subjective determination on extremely complex procedures from operators with global turbojet operations.
This has to be recalled like the overreaching and ill-considered SMS demands were. There is no way, none at all, that these inspectors can be tasked for this. Also, these are largely Part 121 legacy airline-level questions that often require a lawyer and HR manager to address. We have SE airplane and helicopter guys being demanded to address things like their Airworthiness Release program! There are no A/W releases on anything with less than 10-passenger seats.
These are largely off-the-grid demands from someone in FAA HQ with, in our view, absolutely zero qualification to interject this demand which is way, way, way beyond the requirement for manuals and a Statement of Compliance.
Yes, we have most of them approved, but they are insanely complex, timely, and costly. Worse, because they are locally evaluated by someone possibly with zero qualification to do so, does not mean that other operators have to have hundreds and hundreds of changes to satisfy their local inspectors.
This is not an inspector overreach issue – they do not want to spend weeks just to go through some small operator manuals and reject changes – it is about hugely overreaching from someone in FAA HQ – and it needs to be killed by Congressional pressure.
This lowers aviation safety at every level – not that we could not use a couple new BMWs at the office and an avionics upgrade to the King Air 350 on the ramp.
FAA Manual Review
Try to have them put in writing things they question, as there is nothing lacking the manuals and then we can help answer the concerns.
At all times, try to AVOID having a sit-down with the FAA to “walk through” your manuals. This might seem like a good and fast idea, but it can get you digging a hole sitting right there with the FAA inspectors that you may regret. In writing you have time to consider a response, not uttering something off the top of your head that you may regret saying or promising to do.
Never Over Promise
You want to get favorable action, in a timely manner, but be very, very careful about over promising that you can do something or get something done in the background that you cannot do or do on a timely manner.
Never Mislead. NEVER. If you do not know something, defer it (good reason to respond to FAA in writing requests, not sitting at their table). If you screwed up, let them know. Throwing yourself on the sword has some goodwill advantages.
Turbojet Proving Flights
Part 135 Certification – This is the high ticket part of the certification.
Actually, it is validation flights now. It was a past rule of 25-hours and then give-ins of 25-45% reductions if you played nice. Now what a FSDO wants is not actually known and is mostly driven by the regional offices, so there is only the wizard behind the curtain and little you can do about it . . but the better prepared the less time spent. We have plans for you to develop YOUR PLAN, but, again, the better prepared and presented the better and shorter.
Frankly, proving runs prove nothing at all. If it is testing procedures that all could be done sitting at a conference table with operations and maintenance management and the FAA and playing scenarios. Just so you know . .