> ## Documentation Index
> Fetch the complete documentation index at: https://docs.planeconnection.com/llms.txt
> Use this file to discover all available pages before exploring further.
# Part 135 Peer Groups and Exemptions
> How PlaneConnection adapts to different Part 135 operator sizes and which Part 5 requirements apply to each peer group.
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.
This page is for safety managers and accountable executives who need to understand how Part 5
requirements scale to their operation's size. It is especially important for single-pilot
operators (135D) who benefit from significant exemptions. For the full regulatory text, see [FAA
14 CFR Part 5 Overview](/en/explanation/faa-part-5). For implementation timelines, see [SMS
Compliance Timeline](/en/explanation/compliance-timeline).
## 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.
## Peer Groups in PlaneConnection
| Peer Group | Size | Typical Operations | DCT Elements |
| :--------: | --------------- | ------------------------------------------------------------ | :--------------------------: |
| **135D** | Sole individual | Single pilot performing all functions; no employees | EP only (\~19 elements) |
| **135C** | Small | Small Part 135 operators with limited staff | EP + ED (\~25 elements) |
| **135B** | Medium | Mid-size Part 135 operators with multiple aircraft and crew | EP + ED + SP (\~31 elements) |
| **135E** | Large | Large commuter operators with complex, multi-base operations | EP + ED + SP (\~31 elements) |
Your peer group is configured in **Settings > Organization > Operator Profile**. If your organization grows or restructures, update the peer group to ensure your compliance tracking reflects the correct set of applicable requirements.
## 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.
### 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.
### Exempted sections
Single-pilot sole-individual operators are exempt from the following Part 5 sections, all of which presuppose an organization with multiple people:
| Section | Requirement | Reason for Exemption |
| ---------- | ----------------------------------------------- | ------------------------------------------ |
| 5.21(a)(4) | Employee safety reporting mechanisms | No employees to report. |
| 5.21(a)(5) | Coordination across the organization | Single person -- no coordination needed. |
| 5.21(c) | Communication of safety policy to all employees | No employees to communicate to. |
| 5.23(a)(2) | Safety management personnel designation | Single person fills all roles. |
| 5.23(a)(3) | Management representative | Single person is the entire management. |
| 5.25(b)(3) | SMS implementation team | Single person implements the SMS. |
| 5.25(c) | Designation of required personnel | Single person performs all functions. |
| 5.27(a) | Emergency response coordination | Limited scope for a single person. |
| 5.27(b) | Emergency response planning | Limited scope for a single person. |
| 5.71(a)(7) | Employee safety concern processes | No employees to raise concerns. |
| 5.93 | Safety communication | No one to communicate with. |
| 5.97(d) | Communication records | No organizational communication to record. |
### 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.
The exemptions are meaningful but they do not eliminate the need for an SMS. A 135D operator still
needs a functioning risk management process, documented procedures, and evidence of ongoing safety
activity. The FAA will validate your SMS through surveillance, and they will expect to see real
engagement with safety processes proportional to your operation.
### 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.
## The Critical Distinction: Single-Pilot With Employees
**Single-pilot with employees is not the same as a single-pilot sole individual.** If you have any
employees -- a mechanic, a dispatcher, an administrative assistant, a part-time bookkeeper, or
anyone else performing functions related to your operation -- you are NOT a 135D sole-individual
operator. All Part 5 requirements apply in full, with no exemptions. Select the appropriate peer
group (135C, 135B, or 135E) based on your organizational size and complexity.
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.
## 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.
| Peer Group | DCT Assessment Scope | Typical Element Count |
| :--------: | -------------------- | :-------------------: |
| **135C** | EP + ED | \~25 elements |
| **135B** | EP + ED + SP | \~31 elements |
| **135E** | EP + ED + SP | \~31 elements |
### DCT element types
| Type | Code | What It Assesses |
| -------------------------- | :--: | ---------------------------------------------------------------------------------------------------------------------------- |
| **Existing Processes** | EP | Whether operational safety processes are in place and functioning. |
| **Existing Documentation** | ED | Whether those processes are formally documented in your SMS manual and procedures. |
| **Special Emphasis** | SP | Advanced effectiveness indicators beyond basic compliance -- proactive risk management, data trending, predictive analytics. |
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.
## How PlaneConnection Auto-Adapts
PlaneConnection reads the peer group from your workspace's organization settings and adjusts the interface automatically:
| Feature | 135D | 135C | 135B / 135E |
| --------------------------------- | -------------- | ---------------- | --------------------- |
| Compliance element count | \~19 (EP only) | \~25 (EP + ED) | \~31 (EP + ED + SP) |
| DCT assessment tabs | EP only | EP + ED | EP + ED + SP |
| Executive Dashboard DCT readiness | 1 bar (EP) | 2 bars (EP + ED) | 3 bars (EP + ED + SP) |
| Exempt sections visibility | Marked N/A | Fully visible | Fully visible |
| Safety committee features | Hidden | Visible | Visible |
| Multi-user training assignment | Hidden | Visible | Visible |
| My Safety as primary view | Yes | No | No |
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.
## 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**.
When in doubt, select the peer group that reflects your current operational complexity. It is
better to comply with a slightly broader set of requirements than to claim exemptions that do not
apply. Your FAA principal inspector can provide guidance on the appropriate peer group
classification.
## Related
The regulation that defines SMS requirements and single-pilot exemptions.
Key dates and the recommended implementation approach.
Monitor your compliance posture with peer-group-filtered elements.
Run a self-assessment scoped to your peer group.