Detailed compliance checklist for FAA Part 121 and Part 135 combined operations. Operators running both scheduled airline services (Part 121) and charter/commercial flights (Part 135) must comply with overlapping and distinct regulatory requirements.
FAA PART 121 & 135 COMPLIANCE CHECKLIST
(For Dual Operators: Scheduled Airline & Charter Operations)
1️ CERTIFICATION & OPERATIONS (Part 119)
✔ Obtain an Air Carrier Certificate for both Part 121 & Part 135 operations
✔ Maintain separate Operations Specifications (Ops Specs) for each
✔ Designate key management personnel approved by FAA:
- Director of Operations
- Chief Pilot
- Director of Maintenance
- Safety Manager (if applicable)
✔ Establish an FAA-compliant Safety Management System (SMS)
✔ Comply with minimum equipment requirements (MEL/CDL programs)
2️ FLIGHT CREW REQUIREMENTS
Pilot Hiring & Training
✔ Part 121:
- Minimum ATP (Airline Transport Pilot) Certificate required
- 1,500 flight hours minimum
- Two-pilot operations required (Captain & First Officer)
✔ Part 135 (On-Demand Charter/Commuter):
- ATP required for turbine aircraft
- Commercial Pilot License (CPL) + IFR Rating
- Minimum 1,200 flight hours for IFR operations
✔ Training & Recurrent Checks:
- Part 121: Annual simulator-based Line-Oriented Flight Training (LOFT)
- Part 135: Training every 12 months, 6 months for IFR ops
✔ Duty Time & Rest Rules (FAR 117 for Part 121, FAR 135.267 for Part 135)
3️ FLIGHT DISPATCH & OPERATIONAL CONTROL
✔ Part 121:
- FAA-certified Flight Dispatchers required
- Weight & balance planning for each flight
- Minimum Fuel Requirements: Alternate fuel planning for flag/destination alternates
✔ Part 135:
- Dispatchers not required, but flight control must be documented and maintained
- PIC responsible for flight planning
- More flexible fuel and alternate requirements
✔ Operations Manual (GOM/OPSpecs):
- Must cover weather planning, alternate airports, IFR/VFR criteria
- Differences between 121 & 135 must be clearly documented
4️ AIRCRAFT MAINTENANCE & AIRWORTHINESS (PART 145)
✔ Develop a Continuous Airworthiness Maintenance Program (CAMP) for Part 121 aircraft
✔ Part 135 operators may use FAA Part 91.409 inspections instead of CAMP
✔ All aircraft must comply with:
- Airworthiness Directives (ADs)
- Service Bulletins (SBs) & modifications
- Minimum Equipment List (MEL) adherence
- Deferred defect tracking & correction
✔ Establish contracts with FAA Part 145 Repair Stations for heavy maintenance
✔ Recordkeeping: - 121: Retain logs for at least 5 years
- 135: Retain logs for at least 2 years
5️ CABIN SAFETY & EMERGENCY EQUIPMENT
✔ Flight Attendant Requirements:
- Part 121: Required for aircraft with 10+ passenger seats
- Part 135: Not required unless more than 19 seats
✔ Safety Equipment:
- Life vests, rafts, and ELT for overwater operations
- Fire extinguishers, oxygen masks, and emergency lighting
✔ Emergency Exit Operations & Training
✔ Crew Resource Management (CRM) Training
6️ RECORDKEEPING & DOCUMENTATION
✔ Flight Records & Logs
- 121: Retain for 5 years
- 135: Retain for 1–2 years
✔ Pilot Training Records
✔ Aircraft Maintenance Logs & AD/SB Compliance
✔ Operational Control & Dispatch Records
7️ AUDITS & REGULATORY OVERSIGHT
✔ Scheduled FAA Inspections & Conformity Checks
✔ Internal SMS Safety Audits
✔ Compliance with Drug & Alcohol Testing Programs (DOT 49 CFR Part 40)
✔ Emergency Response Plan (ERP) & Security Compliance (TSA Programs if required)
Summary: Key Differences in Compliance Between Part 121 & 135
| Requirement | Part 121 (Airline Ops) | Part 135 (Charter/Commuter) |
| Pilot Requirements | ATP, 1,500+ hours | ATP or Commercial (non-turbine), 1,200+ hours |
| Flight Dispatch | FAA-licensed dispatchers required | PIC responsible for flight planning |
| Duty & Rest Rules | FAR 117 limitations | FAR 135.267 (more flexible) |
| Maintenance Program | CAMP required | May follow Part 91.409 inspections |
| Cabin Crew | Required for 10+ seats | Only required for 19+ seats |
| Operational Control | Fully regulated & documented | More flexible |
This checklist ensures compliance with both Part 121 & Part 135 regulations for operators managing a mixed fleet.