Part 135 Peer Groups and Exemptions

The FAA classifies Part 135 operators into peer groups based on the size and complexity of their operations. This classification determines which elements of 14 CFR Part 5 apply, how the Design and Compliance Tool (DCT) self-assessment is structured, and how much of the SMS infrastructure an operator is expected to maintain. PlaneConnection uses your peer group setting to automatically adapt the compliance interface, filtering out inapplicable requirements and surfacing only what your organization needs.

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Why Peer Groups Exist

Part 5 was designed to be scalable. The FAA recognized that a single-pilot charter operator with one aircraft and a 50-aircraft commuter airline with hundreds of employees cannot reasonably implement the same SMS infrastructure. Peer groups are the mechanism for this scalability. Advisory Circular 120-92D provides guidance on adapting SMS to different operator sizes. PlaneConnection implements this guidance by associating each workspace with a peer group and adjusting the compliance, DCT, and dashboard experiences accordingly.

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Peer Groups in PlaneConnection

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135D: Sole Individual Operators

The most significant adaptation applies to 135D operators — single-pilot organizations where one individual performs all functions related to safe aircraft operation, with no employees of any kind.

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What 14 CFR 5.9(e) defines

Per Section 5.9(e), a “single-pilot organization” is one where a single pilot is the sole individual performing all necessary functions in the conduct and execution related to, or in direct support of, the safe operation of the aircraft. This means the pilot personally handles flight operations, maintenance coordination, record keeping, and all other operational duties.

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Exempted sections

Single-pilot sole-individual operators are exempt from the following Part 5 sections, all of which presuppose an organization with multiple people:

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What still applies

Even with these exemptions, 135D operators must still develop and implement an SMS that addresses their operation, submit a Declaration of Compliance by May 28, 2027, maintain a safety policy with core elements (objectives and code of ethics), perform Safety Risk Management (identifying hazards, assessing risk, and implementing controls), conduct self-audits as part of Safety Assurance, and maintain documentation and records for all SMS activities.

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How PlaneConnection adapts for 135D

When your workspace is configured as a 135D peer group, PlaneConnection adapts the interface to match the sole-individual context. The My Safety dashboard becomes the primary view, serving as the natural home screen with action items, training, and quick-submit buttons. The compliance tracker filters to Existing Processes (EP) elements only, hiding ED and SP elements that are not applicable, and exempted sections display a “Not Applicable” badge instead of requiring evidence. DCT self-assessments show only EP questions, and the radial readiness indicator on the Executive Dashboard shows a single EP bar. Organizational features like safety committee scheduling, multi-user training assignment, and team communication are suppressed entirely, since they serve no purpose for a single individual.

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The Critical Distinction: Single-Pilot With Employees

This distinction is the most common source of confusion in Part 5 implementation. The exemptions exist specifically because certain requirements (like employee reporting mechanisms and organizational communication) are logically impossible for a one-person operation. The moment a second person is involved in any capacity, those requirements become applicable.

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135C, 135B, and 135E: Full Compliance

Operators in the 135C, 135B, and 135E peer groups must comply with all Part 5 requirements. The differences between these groups affect how the DCT assessment is structured, not which regulatory requirements apply.

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DCT element types

For 135C operators, the DCT focuses on EP and ED elements, reflecting the expectation that smaller operations demonstrate functioning processes and adequate documentation. For 135B and 135E operators, SP elements are added, assessing whether the SMS has matured beyond compliance into proactive safety management.

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How PlaneConnection Auto-Adapts

PlaneConnection reads the peer group from your workspace’s organization settings and adjusts the interface automatically: No manual configuration is needed beyond setting the correct peer group. If your peer group changes — for example, if you hire your first employee and move from 135D to 135C — update the setting in Settings > Organization > Operator Profile and the interface adjusts immediately.

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Choosing Your Peer Group

The peer group selection depends primarily on organizational size and complexity. A sole individual performing all functions with no employees of any kind belongs in 135D. Small operations with fewer than 10 operational personnel and a simple route structure typically fit 135C. Mid-size operations with 10 to 50 personnel, multiple aircraft types, and moderate route complexity align with 135B. Large or complex operations with 50+ personnel, multiple bases, and complex fleets belong in 135E.

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