What is a Compliance Statement?

So you've decided to press forward with obtaining a Part 135 Cert. Congrats. Now the work begins, and by work I mean waiting...

Whether you're applying for a Basic or Single-Pilot certification, you will need to complete a compliance statement. Compliance statements may be referred to as the Letter of Compliance (LOC), Statement of Compliance (SOC), or Compliance Statement (CS). Since gov't agencies love to change the name of things during regulation re-writes, we have FAA employees that reference the same document with different names throughout the certification process.

When I first applied for the 135 certificate a woman by the name of Ronda at the FSDO sent me a list of documents that would help me get started on my certification. The compliance statement was the most vague out of all of them, but not to worry, there's an example provided and if I just write it similar to that, I'll be all good! WRONG.

I spent HOURS and HOURS writing the CS using this format below and turns out it was time wasted. This is where the real work started...

Nearly every week I checked in with the FAA Certification Team to see if there was anything I could do while we waited to go "In-Progress". Normally, they'd say "No, we're just waiting to assign you X, Y, and Z and then we'll go from there." On this particular day, I sent an e-mail to one of the team members asking them to take a look at what I had so far so I can get a little feedback before we actually start working.

Lucky for me, one of the inspectors met with me over MS Teams and walked me through the Compliance statement and what the various cert teams will be looking for. The template he showed me and explained was vastly different from what the example showed from Advisory Circular 147-3C and 120-49B.

Side Note: Advisory Circular 120-49B has some amplifying data on Part 135 and 121 Certifications and is located at this link. It has some helpful information but is misleading, especially when talking about the Compliance Statement. More on that here in a second...but here's the link https://www.faa.gov/regulations_policies/advisory_circulars/index.cfm/go/document.information/documentID/1043339

Ultimately this is what my Compliance Statement ended up looking like. Feel free to use the layout if you care to create this document all on your own. This is currently what the FAA likes to see because it's well organized and easy to read and edit.

As you can read, the bulk of the Compliance Statement is re-stating and writing how you will comply with said regulation. If in doubt, include the regulation verbiage verbatim and explain HOW the pilot(s) or operations will comply with that reg. FAA is big on the "HOW."

In all, our Compliance Statement ended up being 342 pages, not including the company documents. With company documents and Hazmat Manual, it was complete at 434 Pages long. I want to emphasize the fact that I created just about every page of the 342 pages of the Compliance Statement, from scratch. Lots of copy/paste, lots of format painter, lots and lots of writing and revising. This isn't meant to "sell" you on buying a CS from me. It's meant to show you how much time is physically required to complete one of these certifications - it takes time, and if you have time, write on!

I'm getting word that the FAA is requiring a certain number of documents before you can even go "in-progress" with them after your name gets called. This is actually great news and one piece of feedback I passed them once we were complete. What this means is that you will potentially have the opportunity to shorten the certification timeline - IF YOU'RE READY - I repeat, if you're ready. Ready with documents at some level of 75-90% solution to the point where you can start revising and working with the FAA. That's where we come in, if you have well laid out documents, show the FAA, you could be called up must faster than in the past.

If you made it to the end, congrats. There's a lot more where that came from. I'll expound on my solutions to being fully prepared when your "name is called" in a future blog, but until then, please contact us via arrowcertsolutions@gmail.com if you need assistance with any Part 135 certification questions. We're happy to provide a free consultation call at any time.

Blue skies,

Ryan, Owner - Arrow Cert

arrowcertsolutions@gmail.com