Per 14 CFR §135.243, a person may not serve as pilot in command of an aircraft under 14 CFR Part 135 unless that person meets the certificate, rating, and recent flight experience requirements §135.243 specifies — and the OpSpecs paragraphs and Letters of Authorization (LOAs) that issue Reduced Vertical Separation Minimum (RVSM) and Required Navigation Performance (RNP) operating privileges layer additional currency, training, and equipment requirements on top of that §135.243 baseline. The 2019 amendment to 14 CFR §91.180 eliminated the per-aircraft RVSM authorization requirement for US-registered aircraft equipped with qualifying ADS-B Out — but the §91.180 RVSM equipment standards, the AC 91-85B-aligned monitoring program, and the recurrent height-keeping monitoring records still apply. International RVSM operations under 14 CFR Part 91 Subpart H and aircraft that do not meet the §91.180 ADS-B equipment criteria still require the full RVSM authorization process — including the OpSpecs paragraph, the maintenance program documentation, and the height-keeping monitoring records under FAA AC 91-85B. RNP authorizations under FAA AC 90-105 — RNP APCH, RNP AR APCH, RNP 4, RNP 2, Advanced RNP — are issued per OpSpecs paragraph (commonly C063, C384, C055) with per-procedure operational conditions, aircraft equipment configuration, and per-PIC training records. Per 14 CFR §135.21, the General Operations Manual must reflect every active OpSpecs authorization and the underlying LOAs — and civil penalties under 49 U.S.C. § 46301 reach $37,377 per violation in 2026 (inflation-adjusted annually under the Federal Civil Penalties Inflation Adjustment Act).
The authorization-tracking layer is the spine of every 14 CFR Part 135 surveillance visit that touches RVSM or RNP operations. The Principal Operations Inspector requests the current OpSpecs index, walks each active paragraph against the underlying LOA, cross-references the RVSM monitoring records under FAA AC 91-85B against the §91.180 equipment configuration and the §91.411 altimeter system tests, cross-references the RNP training records under FAA AC 90-105 against the OpSpecs paragraph and per-PIC currency, and traces every §135.243 PIC qualification against the OpSpecs-paragraph-specific currency requirements — not just the §135.243 baseline. The most common authorization-layer finding is not a deficient initial authorization — it is an LOA, an RVSM monitoring record, an RNP training record, or a PIC-specific currency that lapsed without anyone noticing, because the OpSpecs paragraphs, the LOAs, the monitoring records, and the training records were tracked in four different systems and nobody owned the cross-reference.
The platforms ranked below split between the authorization-tracking layer and adjacent layers of the Part 135 stack. Per-tail maintenance platforms (CAMP Systems, Veryon/Traxxall, Flightdocs) feed §91.411 + §91.413 + RVSM-specific component recurrence on the equipment side but are not purpose-built for OpSpecs-paragraph-to-LOA-to-RNP-training-record cross-referencing. Operator-rating platforms (ARGUS PRO, Wyvern) provide third-party operator rating and §135.243 baseline PIC currency but do not natively inventory LOAs, RVSM monitoring records under AC 91-85B, or RNP training records under AC 90-105. Document-side compliance platforms (FileFlo) inventory every OpSpecs paragraph, LOA, RVSM monitoring record, RNP training record, and §135.243 PIC qualification in a single index — tying each authorization back to the OpSpecs paragraph that issued it under FAA Order 8900.1 Vol. 3 Ch. 18.
Primary regulations cited in this guide: 14 CFR §135.243 (PIC qualifications), 14 CFR §135.21 (Manual requirements), 14 CFR Part 135 (Commuter and on-demand operations), 14 CFR §91.180 (RVSM airspace operations), 14 CFR Part 91 Subpart H (Foreign aircraft + international operations), and 49 U.S.C. § 46301 (FAA civil penalties). Operational citations: FAA Advisory Circular AC 91-85B (Authorization of Aircraft and Operators for Flight in RVSM Airspace) for RVSM equipment, monitoring, and operational compliance; FAA Advisory Circular AC 90-105 (Approval Guidance for RNP Operations) for RNP operational approval and PIC training; FAA Order 8900.1 Volume 3 Chapter 18 (Operations Specifications) for the OpSpecs paragraph framework and LOA issuance; FAA Order 2150.3C (Compliance and Enforcement Program) for the Enforcement Decision Process.
Authorization-layer findings cascade across every operational record created against the lapsed LOA or training record
Per FAA Order 8900.1 Vol. 3 Ch. 18, OpSpecs paragraphs, LOAs, RVSM monitoring records, RNP training records, and §135.243 PIC qualifications form a single chain. A POI surveillance finding under FAA AC 91-85B (RVSM monitoring lapsed), FAA AC 90-105 (RNP training out of recurrent window), or §135.243 (PIC currency not matched to OpSpecs-paragraph-specific requirements) is usually downstream of an LOA that quietly expired, an OpSpecs paragraph that was superseded, or a per-PIC training record that was completed but never indexed against the OpSpecs paragraph. The certificate-side downstream findings stack up — but the authorization-layer root cause is what drives the Enforcement Decision Process under 49 U.S.C. § 46301. Authorization-tracking software that enforces the OpSpecs-paragraph-to-LOA-to-monitoring-record-to-training-record-to-PIC-currency chain structurally is the only defense that scales across multiple LOA renewal cycles.
The 7 Best Part 135 LOA + RVSM + RNP Authorization Tracking Platforms
Ranked by OpSpecs paragraph inventory, LOA expiration calendar, FAA AC 91-85B RVSM monitoring records, FAA AC 90-105 RNP training records, §135.243 PIC qualifications cross-reference, and the authorization-binder completeness an FAA Principal Operations Inspector requests during surveillance.
FileFlo
Top Pick — Best for Part 135 LOA + RVSM + RNP Authorization Tracking + OpSpecs-Paragraph Tie-BackBest For
Part 135 charter, air taxi, on-demand, and commuter operators (1-50 aircraft) that need an OpSpecs-paragraph-to-LOA-to-monitoring-record-to-PIC-training-record index across RVSM, RNP, Class II nav, and special-mission authorizations — without per-LOA or per-authorization pricing
Key Feature
AI document classification — upload any FAA-issued LOA, OpSpecs revision, RVSM monitoring record, RNP training certificate, or §135.243 PIC qualification record and FileFlo files it against the correct OpSpecs paragraph, authorization layer, and currency window automatically
Part 135 Focus
OpSpecs paragraph inventory, LOA inventory, RVSM monitoring records (FAA AC 91-85B), RNP training records (FAA AC 90-105), §135.243 PIC qualifications, §91.180 RVSM equipment documentation, §91.411 altimeter system tests, §91.413 ATC transponder tests, OpSpecs-paragraph-to-LOA-to-record cross-reference, recurrent-currency calendar, one-click POI authorization binder
Strengths
- AI document parsing — every uploaded LOA, OpSpecs revision, RVSM monitoring record, or RNP training certificate classified against the correct OpSpecs paragraph and authorization layer
- OpSpecs paragraph inventory — every issued paragraph (A003, A025, B033, B046, B073, C051, C063, C055, C384, D085) tracked against the current FAA-issued version under FAA Order 8900.1 Vol. 3 Ch. 18
- LOA inventory — every Letter of Authorization tracked against the OpSpecs paragraph that referenced it with effective date, expiration, and renewal window
- RVSM monitoring records under FAA AC 91-85B — initial and recurrent monitoring records cross-referenced against the §91.180 equipment configuration and the §91.411 altimeter system tests
- RNP training records under FAA AC 90-105 — per-PIC per-procedure training records cross-referenced against the OpSpecs paragraph and aircraft equipment configuration
- §135.243 PIC qualifications cross-referenced against OpSpecs-paragraph-specific currency requirements — not just the §135.243 baseline
- Recurrent-currency calendar — surfaces every LOA expiration, RVSM monitoring window, RNP training renewal, and §91.411/§91.413 inspection deadline before the next dispatch
- One-click POI authorization binder — produces a complete EDP-defensible packet of OpSpecs + LOAs + RVSM + RNP + §135.243 records in under 60 seconds
- $299/mo flat regardless of LOA count or authorization count — no per-LOA or per-authorization fees
- 5-day free trial, no credit card required, no annual contract
Limitations
- Not an aviation-specialist authoring platform — does not include built-in regulatory text libraries for drafting new OpSpecs amendment requests (pair with Web Manuals or Comply365 if you need authoring tooling)
- Not a flight planning or RNP procedure database — does not store FAA AeroNav procedure plates or Jeppesen NavData (pair with ForeFlight or Jeppesen for procedure-side workflow)
- Not a per-tail aviation maintenance tracking system — does not forecast §91.411 altimeter tests or RVSM-specific component recurrence (pair with CAMP, Veryon, or Flightdocs for per-tail maintenance forecasting)
Our take: FileFlo is the purpose-built answer to the Part 135 authorization-tracking problem: it inventories every OpSpecs paragraph, every LOA, every RVSM monitoring record under FAA AC 91-85B, every RNP training record under FAA AC 90-105, and every §135.243 PIC qualification in a single index — and ties each one back to the OpSpecs paragraph that issued it under FAA Order 8900.1 Vol. 3 Ch. 18. For Part 135 charter and on-demand operators whose primary authorization-side risk is an LOA expiration, an RVSM monitoring window, or an RNP recurrent training renewal that fell through the gap between the GOM, the GMM, and the per-tail maintenance system — not authoring tooling or per-tail maintenance forecasting — FileFlo fills the authorization-currency-and-cross-reference gap at a flat rate that scales from a single-tail air taxi to a 50-aircraft on-demand fleet.
CAMP Systems
Best for Per-Tail RVSM Maintenance Tracking (Aircraft-Side)Best For
Part 135 operators whose primary authorization-side need is per-aircraft RVSM equipment configuration tracking, §91.411 altimeter system test forecasting, and §91.413 ATC transponder test forecasting — not OpSpecs-paragraph-to-LOA-to-training-record cross-referencing
Key Feature
Decades-deep per-tail maintenance program documentation feeding §91.411 altimeter system tests, §91.413 ATC transponder tests, and RVSM-specific component recurrence on the aircraft-equipment side of the authorization stack
Part 135 Focus
Per-tail §91.411 + §91.413 + RVSM maintenance program tracking; secondary §135.443 airworthiness release; not purpose-built for OpSpecs paragraph inventory, LOA inventory, RVSM monitoring records under AC 91-85B, or RNP training records under AC 90-105
Strengths
- Industry-leading per-tail maintenance records database covering §91.411 altimeter system tests, §91.413 ATC transponder tests, and RVSM-specific component recurrence
- Strong §135.443 airworthiness release support feeding the maintenance side of every RVSM dispatch
- Deep integration with FAA AD and SB notification feeds for §91.417 aircraft record completeness
- Established vendor relationships across Part 135 charter and corporate flight departments
Limitations
- Per-aircraft pricing — costly for the authorization-tracking layer that scales with LOA count and PIC count, not tail count
- Not purpose-built for OpSpecs paragraph inventory or LOA inventory across the operator certificate
- RNP training records under FAA AC 90-105 are not natively tracked — the per-PIC per-procedure currency layer lives outside the platform
- Sales-led pricing — requires a sales engagement to evaluate
- Annual contracts standard; multi-week onboarding
- No 5-day free trial
Our take: CAMP Systems is the per-tail maintenance records incumbent feeding §91.411 + §91.413 + RVSM-specific maintenance tracking. For per-aircraft equipment-side tracking under the RVSM authorization, CAMP is strong. For the OpSpecs-paragraph-to-LOA-to-RNP-training-record cross-referencing an FAA POI requests during surveillance, CAMP is the wrong layer of the stack.
Veryon (Traxxall)
Best Post-Merger RVSM Maintenance SuiteBest For
Part 135 operators that want consolidated per-tail RVSM-side maintenance records and limited flight ops after the 2024 Traxxall + Continuum CMP rebrand
Key Feature
Combined per-tail RVSM maintenance records and limited flight ops platform after Traxxall + Continuum CMP consolidation
Part 135 Focus
Per-tail RVSM maintenance records + parts modules feeding §91.411 + §91.413 + §135.443 recurrence; per-aircraft architecture similar to CAMP; not purpose-built for OpSpecs paragraph inventory, LOA inventory, or RNP training records under AC 90-105
Strengths
- Post-2024 merger consolidated Traxxall + Continuum CMP into a single RVSM-side maintenance records suite
- Cloud-first architecture with modern UI compared to legacy on-prem maintenance systems
- Strong international footprint (EASA + FAA dual-environment) for operators with cross-border charter under 14 CFR Part 91 Subpart H
- Limited flight ops modules feed into the §91.411 + §91.413 recurrent inspection workflow
Limitations
- Per-aircraft pricing — same structural mismatch as CAMP for the authorization-tracking layer that scales with LOA count and PIC count
- Post-merger integration period creates feature-roadmap uncertainty on the GOM-side authorization layer
- Sales-led pricing — no published rates
- No purpose-built OpSpecs paragraph inventory, LOA inventory, or RNP training records under FAA AC 90-105
- Annual contracts standard; no 5-day free trial
Our take: Veryon is the rebranded post-2024 result of the Traxxall + Continuum CMP merger. For per-tail RVSM maintenance records and the maintenance-side §91.411 + §91.413 recurrence forecasting, Veryon is competitive. For the OpSpecs-paragraph-to-LOA-to-RNP-training-record audit trail an FAA POI requests during surveillance, Veryon is not purpose-built.
Flightdocs
Best Cloud-First RVSM Maintenance RecordsBest For
Part 91 corporate flight departments and Part 135 charter operators that want a cloud-first per-tail RVSM-side maintenance records platform — OpSpecs paragraph and LOA tracking is secondary
Key Feature
Cloud-native per-tail maintenance records with strong mobile experience for technicians and pilots feeding the §91.411 + §91.413 + RVSM-specific recurrence workflow
Part 135 Focus
Per-tail RVSM maintenance records; secondary work order and parts modules feeding §91.411 + §91.413 + §135.443; not purpose-built for OpSpecs paragraph inventory, LOA inventory, or RNP training records under AC 90-105
Strengths
- Cloud-first, mobile-friendly UI ahead of legacy maintenance records systems
- Mobile §135.65 mechanical irregularity entry from the flight line feeds the maintenance log workflow
- Modern API stack for integration with charter operations and dispatch platforms
- Per-tail subscription with predictable scaling for fleet operators
Limitations
- Primary value is per-tail RVSM maintenance records, not OpSpecs paragraph inventory or LOA inventory
- Per-aircraft pricing — structural mismatch for the authorization layer that scales with LOA count and PIC count
- No purpose-built RNP training records under FAA AC 90-105
- No OpSpecs-paragraph-to-LOA cross-reference
- Sales-led pricing; no 5-day free trial
Our take: Flightdocs is the modern cloud-first alternative to CAMP for per-tail RVSM-side maintenance records. For operators whose primary records-side pain is the OpSpecs-paragraph-to-LOA-to-RNP-training-record cross-referencing layer, Flightdocs is not the right tool. Pair it with FileFlo for the certificate-side authorization audit trail.
ARGUS PRO
Best Operator Rating + PIC Currency LayerBest For
Part 135 charter operators that want third-party operator rating, PIC currency tracking under §135.243, and structured safety audit reporting on top of the certificate — with OpSpecs and LOA tracking stored elsewhere
Key Feature
Third-party operator rating (Platinum/Gold/Silver) plus PIC currency dashboard under §135.243 with structured safety audit framework
Part 135 Focus
Operator rating and PIC currency tracking under §135.243 with structured safety audit framework; secondary record storage; not purpose-built for OpSpecs paragraph inventory, LOA inventory, RVSM monitoring records under AC 91-85B, or RNP training records under AC 90-105
Strengths
- Recognized operator rating that broker partners and corporate flight departments accept as third-party validation
- PIC currency dashboard under §135.243 with structured recurrence reminders
- Structured safety audit framework helps operators surface §135.21 GOM and authorization-layer gaps
- Established vendor across mid-size and larger Part 135 charter operators
Limitations
- Per-operator annual subscription — material baseline cost separate from authorization-tracking software
- Operator-rating focus, not OpSpecs paragraph inventory or LOA inventory
- RVSM monitoring records under FAA AC 91-85B and RNP training records under FAA AC 90-105 are not natively tracked
- Sales-led pricing — annual contracts standard
- No 5-day flat-rate free trial — demo-only evaluation
Our take: ARGUS PRO is the operator-rating and §135.243 PIC currency incumbent. For third-party operator validation and structured safety audit framework, ARGUS PRO is a strong fit. For the OpSpecs-paragraph-to-LOA-to-RNP-training-record cross-reference an FAA POI requests during surveillance, ARGUS PRO is not purpose-built — pair it with FileFlo for the certificate-side authorization audit trail.
Wyvern
Best Safety Audit + Wingman PIC CurrencyBest For
Part 135 charter operators that want Wingman PIC currency tracking under §135.243 and Wyvern Wingman safety audit framework alongside operator rating — with OpSpecs and LOA tracking stored elsewhere
Key Feature
Wyvern Wingman PIC currency dashboard under §135.243 plus Wingman safety audit framework with operator rating
Part 135 Focus
PIC currency under §135.243 and structured safety audit framework; secondary record storage; not purpose-built for OpSpecs paragraph inventory, LOA inventory, RVSM monitoring records under AC 91-85B, or RNP training records under AC 90-105
Strengths
- Wyvern Wingman recognized as a third-party operator-rating standard alongside ARGUS PRO
- Wingman PIC currency dashboard helps surface §135.243 baseline currency drift
- Structured safety audit framework aligns to FAA Part 5 SMS framework for operators on the SMS path
- Established vendor across mid-size and larger Part 135 charter operators
Limitations
- Per-operator annual subscription — material baseline cost separate from authorization-tracking software
- Operator-rating focus, not OpSpecs paragraph inventory or LOA inventory
- RVSM monitoring records under FAA AC 91-85B and RNP training records under FAA AC 90-105 are not natively tracked
- Sales-led pricing — annual contracts standard
- No 5-day flat-rate free trial — demo-only evaluation
Our take: Wyvern is the Wingman operator-rating incumbent alongside ARGUS PRO. For Wingman PIC currency and safety audit framework, Wyvern is competitive. For the OpSpecs-paragraph-to-LOA-to-RNP-training-record cross-reference an FAA POI requests during surveillance, Wyvern is not purpose-built — pair it with FileFlo for the certificate-side authorization audit trail.
Paper / Word / Network Drive
The Status Quo Most Part 135 Operators Are QuittingBest For
Very small single-tail Part 135 operators with a single-pilot owner-operator structure, a stable OpSpecs envelope, no RVSM or RNP authorizations, and no recent LOA renewals
Key Feature
No software vendor relationship; full local control over the OpSpecs file and LOA folder
Part 135 Focus
Whatever the director of operations or chief pilot builds in Word and a network drive — vulnerable to LOA expirations that surface only when the FAA POI asks, RVSM monitoring records that drift outside the recurrence window, RNP training records that lapse, and OpSpecs-paragraph-to-LOA cross-references that exist only in the chief pilot's head
Strengths
- Zero software cost
- No vendor lock-in
- Familiar to long-tenured directors of operations and chief pilots
- Works for a single-tail air taxi with one PIC, no RVSM or RNP authorizations, and a stable OpSpecs envelope
Limitations
- No structural OpSpecs paragraph inventory — paragraphs and effective dates live in a Word document and a PDF folder
- No LOA inventory — every Letter of Authorization is in a shared drive folder with no expiration tracking
- RVSM monitoring records under FAA AC 91-85B are tracked by hand in a spreadsheet — recurrence dates miss by weeks
- RNP training records under FAA AC 90-105 are tracked per-PIC in scattered training folders with no central recurrence calendar
- §135.243 PIC qualifications and the OpSpecs-paragraph-specific currency requirements are cross-referenced manually by the chief pilot
- No audit trail of who touched what authorization when — fails the OpSpecs-paragraph-to-LOA-to-record intent under FAA Order 8900.1 Vol. 3 Ch. 18
- Building an EDP-defensible authorization binder by hand takes days, not seconds
- Hidden labor cost: a director of operations spending 4+ hours/week on LOA + authorization currency tracking costs more annually than the software
Our take: Paper, Word documents, and network drives are the status quo most Part 135 operators are actively quitting in 2026. The hidden labor cost of manual LOA + RVSM + RNP authorization tracking plus the asymmetric downside of a single FAA Enforcement Decision Process (EDP) finding — up to $37,377/violation under 49 U.S.C. § 46301, with OpSpecs amendment or certificate suspension exposure for systemic findings — makes the status quo more expensive than a flat-rate authorization platform within the first surveillance cycle.
Side-by-Side Comparison
All 7 platforms across the criteria that matter most for Part 135 LOA + RVSM + RNP authorization tracking: LOA management, RVSM compliance tracking under FAA AC 91-85B, RNP authorization under FAA AC 90-105, OpSpecs authorization code management, pricing, and free trial.
| Criteria | FileFlo | CAMP | Veryon | Flightdocs | ARGUS | Wyvern | Paper |
|---|---|---|---|---|---|---|---|
| LOA Mgmt | ✅ Inventory + expiration calendar | ❌ | ❌ | ❌ | ⚠️ Operator rating only | ⚠️ Operator rating only | ❌ Shared drive folder |
| RVSM Compliance Tracking | ✅ AC 91-85B monitoring + §91.411 cross-ref | ⚠️ §91.411/§91.413 only | ⚠️ §91.411/§91.413 only | ⚠️ §91.411/§91.413 only | ❌ | ❌ | ❌ Spreadsheet |
| RNP Authorization | ✅ AC 90-105 training + OpSpecs tie-back | ❌ | ❌ | ❌ | ❌ | ❌ | ❌ Per-PIC folders |
| OpSpecs Auth Code Mgmt | ✅ Paragraph-to-LOA-to-record index | ❌ | ❌ | ❌ | ⚠️ Operator rating only | ⚠️ Operator rating only | ❌ Word doc |
| Pricing | $299/mo flat | ~$50–$500/aircraft | Per-aircraft | Per-aircraft | $4,000–$15,000+/year | $5,000–$20,000+/year | $0 + hidden labor |
| Free Trial | ✅ 5 days | ❌ Demo only | ❌ Demo only | ❌ Demo available | ❌ Demo only | ❌ Demo only | N/A |
⚠️ = partial or limited support. ❓ = unknown / not published. Data based on vendor documentation as of May 2026 and post-2024 Veryon merger context.
How to Choose the Right Part 135 LOA + RVSM + RNP Authorization Tracking Platform
Letter of Authorization (LOA) Workflow
A Letter of Authorization (LOA) is an FAA-issued document that authorizes a specific operational capability — RVSM, RNP, Class II navigation, special operating conditions, MEL deviations, helicopter air ambulance operations, or other specialty authorizations — typically referenced inside the relevant OpSpecs paragraph. Per 14 CFR §135.21, the General Operations Manual must reference every active LOA and reflect the operational conditions the LOA carries. The LOA workflow that surfaces most often during 14 CFR Part 135 surveillance is the LOA that expired silently because the operator tracked OpSpecs paragraphs in one system and LOAs in a shared drive folder — and the OpSpecs paragraph remained current but the underlying LOA lapsed. Authorization-tracking software must inventory every LOA against the OpSpecs paragraph that referenced it under FAA Order 8900.1 Vol. 3 Ch. 18, surface the expiration window before it arrives, and tie the LOA renewal back to the OpSpecs paragraph and the underlying operational currency records (RVSM monitoring under FAA AC 91-85B, RNP training under FAA AC 90-105) so the entire authorization chain renews on the same cadence.
RVSM Operations Post-2019 Rule Change
The January 2019 amendment to 14 CFR §91.180 eliminated the per-aircraft RVSM authorization requirement for US-registered aircraft equipped with qualifying ADS-B Out under §91.225 and meeting the §91.180 RVSM equipment standards — but did not eliminate the operator-side compliance program. Aircraft that meet the §91.180 ADS-B equipment criteria can now operate in domestic RVSM airspace without an OpSpec or LOA-level RVSM authorization, but the operator must still maintain the RVSM equipment configuration documentation, the §91.411 altimeter system tests every 24 calendar months, the §91.413 ATC transponder tests every 24 calendar months, the RVSM-specific component recurrence tracking, the height-keeping monitoring records under FAA AC 91-85B, and the per-PIC training records the operator's OpSpecs paragraph requires. Aircraft operating in international RVSM airspace under 14 CFR Part 91 Subpart H or aircraft that do not meet the §91.180 ADS-B equipment criteria still require the full RVSM authorization process including an OpSpecs paragraph and the underlying LOA. The most common 2026-era 14 CFR Part 135 RVSM surveillance finding is an operator that interpreted the 2019 rule change as "RVSM is no longer regulated" rather than "RVSM authorization is auto-issued conditional on §91.180 equipment compliance" — and let the AC 91-85B monitoring program documentation lapse. Authorization-tracking software must inventory the §91.180 equipment configuration, the §91.411 + §91.413 inspection currency, the AC 91-85B monitoring records, and the per-PIC RVSM training on parallel cadences so any single lapse surfaces before the next RVSM dispatch.
RNP Authorization + Required Navigation Performance
Required Navigation Performance (RNP) authorizations under FAA AC 90-105 cover the per-procedure operational approval framework for RNP APCH (RNP approach with LNAV/VNAV minimums), RNP AR APCH (authorization-required approach with the tightest RNP values), RNP 4 (oceanic), RNP 2 (en route), and Advanced RNP — each issued by OpSpecs paragraph (commonly C063 RNP APCH, C384 RNP AR APCH, C055 RNP 4, and related paragraphs) with per-procedure operational conditions, aircraft equipment configuration requirements, and per-PIC training requirements. The most common RNP authorization finding during 14 CFR Part 135 surveillance is a PIC operating an RNP AR APCH whose general instrument currency under 14 CFR §135.243 is intact, but whose RNP AR-specific training under FAA AC 90-105 was completed outside the recurrent window — or an RNP authorization issued under an OpSpecs paragraph that has since been superseded by a current paragraph with different operational conditions. Authorization-tracking software must inventory every active RNP authorization, the underlying aircraft equipment configuration (FMS, GPS WAAS receivers, autopilot integration), the per-PIC training record under AC 90-105, and the OpSpecs paragraph that issued the authorization — and surface drift across that chain before the next RNP dispatch.
OpSpecs Auth Code Cross-Reference
Operations Specifications (OpSpecs) — issued by the FAA under FAA Order 8900.1 Vol. 3 Ch. 18 — are the operator-specific authorizations, limitations, and standard procedures the FAA approves for each Part 135 certificate. OpSpecs are issued in paragraphs with standard naming conventions (A-series for general authorizations like A003 Authorizations and Limitations and A025 Aircraft Authorizations, B-series for operating limitations and approach authorizations like B033 IFR Approach Authorizations, B046 Special PIC Qualifications, and B073 RVSM Authorization where issued, C-series for navigation authorizations like C051 Class I Navigation, C055 RNP 4, C063 RNP APCH, and C384 RNP AR APCH, D-series for maintenance authorizations like D085 Airworthiness Release, and many more). Every OpSpecs paragraph must cross-reference the underlying LOA where one exists, the underlying operational currency records (RVSM monitoring under FAA AC 91-85B, RNP training under FAA AC 90-105), and the §135.243 PIC qualifications that match the paragraph-specific currency requirements. The most common OpSpecs-side finding during 14 CFR Part 135 surveillance is a paragraph that is current on the FAA side but whose underlying LOA expired or whose underlying training record lapsed because the operator tracked OpSpecs and the underlying records in separate systems. Authorization-tracking software must inventory every OpSpecs paragraph, every LOA, every monitoring record, every training record, and every §135.243 PIC qualification in a single cross-reference index — so a single OpSpecs amendment automatically surfaces every downstream record that needs renewal on the same cadence.
EDP Defense and POI Authorization Binder
The FAA Enforcement Decision Process (FAA Order 2150.3C) is the administrative framework under which POI surveillance findings are investigated, dispositioned, and resolved — typically through compliance action, civil penalty, OpSpecs amendment, or certificate action. Authorization-layer findings — flying an RVSM segment under an AC 91-85B monitoring record that exceeded recurrence, operating an RNP procedure under an AC 90-105 training record outside the recurrent window, holding an OpSpecs paragraph whose underlying LOA has lapsed, or operating under §135.243 PIC qualifications that do not match the OpSpecs-paragraph-specific currency requirements — are among the most consequential entries in EDP cases against Part 135 operators because each authorization-layer lapse implicates every operational record created against it. Civil penalties under 49 U.S.C. § 46301 reach $37,377 per violation in 2026. The most cost-effective structural defense is authorization-tracking software that inventories every OpSpecs paragraph, every LOA, every RVSM monitoring record under FAA AC 91-85B, every RNP training record under FAA AC 90-105, and every §135.243 PIC qualification — and surfaces drift the moment any lapse approaches. FileFlo's one-click POI authorization binder packages the OpSpecs paragraph + LOA + RVSM monitoring + RNP training + §135.243 PIC qualification records — plus the cross-reference index — for any time window into a single export the POI can review during a surveillance visit. The cost of reconstructing the authorization-layer audit trail the morning of the POI visit plus the asymmetric downside of a civil penalty makes the records-side software pay for itself within the first LOA renewal cycle.
Part 135 LOAs, RVSM monitoring, and RNP training records — inventoried, cross-referenced, and surfaced before they lapse
FileFlo inventories every OpSpecs paragraph, every LOA, every RVSM monitoring record under FAA AC 91-85B, every RNP training record under FAA AC 90-105, and every §135.243 PIC qualification in a single cross-reference index — and surfaces drift the moment any of them approaches lapse. AI document classification routes every uploaded LOA, training certificate, or monitoring record to the correct OpSpecs paragraph automatically. $299/month flat, no contract, no per-LOA fees.
Frequently Asked Questions
What is Part 135 LOA + RVSM + RNP authorization tracking software?
Part 135 LOA + RVSM + RNP authorization tracking software helps FAA-certificated air taxi, charter, on-demand, and commuter operators inventory, version, and prove currency of three interlocking layers of FAA authorization: the OpSpecs paragraphs and Letters of Authorization (LOAs) the operator holds under 14 CFR §135.243 and FAA Order 8900.1 Vol. 3 Ch. 18, the Reduced Vertical Separation Minimum (RVSM) authorization under 14 CFR §91.180 and 14 CFR Part 91 Subpart H with the monitoring and maintenance program FAA AC 91-85B requires, and the Required Navigation Performance (RNP) authorization under FAA AC 90-105 with the per-procedure operational approval, training records, and equipment configuration documentation an FAA Principal Operations Inspector requests during surveillance. The best platforms tie each authorization back to the specific OpSpecs paragraph that issued it, surface expiration or recurrent-currency dates the moment they approach, and produce an EDP-defensible authorization binder on demand — closing the most common Part 135 surveillance finding in the authorization layer: an operator flying under an OpSpecs authorization whose underlying LOA, RVSM monitoring record, or RNP training record has lapsed without anyone noticing.
What is the difference between OpSpecs, LOA, and authorization in 14 CFR Part 135?
Operations Specifications (OpSpecs) are the operator-specific authorizations, limitations, and standard procedures the FAA approves for each Part 135 certificate under FAA Order 8900.1 Vol. 3 Ch. 18. OpSpecs are issued in paragraphs (A001 General, A003 Authorizations and Limitations, A025 Aircraft Authorizations, B033 IFR Approach Authorizations, B046 Special PIC Qualifications, C051 Class I Navigation, D085 Airworthiness Release, and many more). A Letter of Authorization (LOA) is a separate FAA-issued document that authorizes a specific operational capability — RVSM, RNP, Class II navigation, special operating conditions, MEL deviations — and is typically referenced inside the relevant OpSpecs paragraph. The distinction matters during 14 CFR Part 135 surveillance because an OpSpecs paragraph can issue an authorization, an LOA can carry the specific operational conditions, and the operator-side proof of currency (RVSM monitoring records, RNP training records, PIC qualifications under 14 CFR §135.243) must match both. Compliance software must inventory OpSpecs paragraphs, LOAs, and operator-side currency evidence in a single index, surface drift the moment any of the three lapses, and tie each LOA renewal back to the OpSpecs paragraph that referenced it.
What does §135.243 require for PIC qualifications in 14 CFR Part 135?
Per 14 CFR §135.243, a person may not serve as pilot in command of an aircraft under Part 135 unless that person meets the certificate, rating, and recent flight experience requirements specified in §135.243(a), (b), and (c) — including the airline transport pilot certificate requirement for certain operations and the commercial pilot certificate with appropriate category, class, and instrument rating requirements for others. The §135.243 PIC qualifications interact directly with the LOA and OpSpecs authorization layer because an RVSM, RNP, or special-mission OpSpecs paragraph typically requires the PIC to hold specific currency or training on top of the §135.243 baseline. A common Part 135 surveillance finding is a PIC operating an RVSM segment whose §135.243 currency is intact but whose RVSM-specific operational training under FAA AC 91-85B was completed outside the recurrent window, or a PIC operating an RNP procedure whose §135.243 instrument currency is intact but whose RNP-specific training under FAA AC 90-105 was never documented. Compliance software must cross-reference §135.243 PIC qualifications against the LOA-specific and OpSpecs-paragraph-specific currency requirements, not just the §135.243 baseline.
How did the 2019 RVSM rule change affect Part 135 operators?
Per the 14 CFR §91.180 amendment effective January 22, 2019, the FAA eliminated the requirement for US-registered aircraft equipped with qualifying ADS-B Out and meeting the §91.180 RVSM equipment standards to obtain an individual RVSM authorization for operations in RVSM airspace. Aircraft that meet the §91.180 equipment criteria are now eligible to operate in RVSM airspace without an OpSpec or LOA-level RVSM authorization — but the operator must still maintain the RVSM maintenance program, equipment configuration documentation, and operational currency the FAA AC 91-85B-aligned monitoring framework requires. Operators of aircraft that do not meet the §91.180 ADS-B equipment criteria — older airframes, aircraft with non-compliant ADS-B installations, or aircraft operating in international RVSM airspace per 14 CFR Part 91 Subpart H — still need the full RVSM authorization process including the OpSpecs paragraph, RVSM maintenance program documentation, height-keeping monitoring records, and PIC training records. The most common 2026-era 14 CFR Part 135 surveillance finding is an operator that read the 2019 rule change as "RVSM is no longer regulated" rather than "RVSM authorization is auto-issued conditional on §91.180 equipment compliance," and let the RVSM maintenance program documentation lapse.
What does FAA AC 91-85B require for RVSM authorization in 14 CFR Part 135?
FAA Advisory Circular AC 91-85B (Authorization of Aircraft and Operators for Flight in Reduced Vertical Separation Minimum Airspace) provides FAA-acceptable means of compliance for the §91.180 RVSM equipment, maintenance, and operational requirements. The AC 91-85B framework addresses: RVSM equipment standards (altimetry, autopilot altitude-hold, altitude alerter, ADS-B Out for the auto-eligible criteria), RVSM maintenance program documentation (recurrent inspections, altimeter system tests under 14 CFR §91.411 every 24 calendar months, RVSM-specific component reliability tracking), height-keeping monitoring (initial monitoring under an approved Regional Monitoring Agency, recurrent monitoring as the RMA assigns), PIC training and currency (initial RVSM training and recurrent training per OpSpecs paragraph B046 or B073 conditions), and the RVSM operating manual content that lives inside or alongside the §135.21 General Operations Manual. The most common AC 91-85B finding is an RVSM monitoring record that exceeds the RMA-assigned recurrence interval, or a §91.411 altimeter system test that lapsed because the GMM-side inspection schedule and the GOM-side OpSpecs authorization were tracked in different systems. Compliance software must index every RVSM authorization against the underlying monitoring record, §91.411 test record, and PIC training record so any lapse surfaces before the next RVSM dispatch.
What does FAA AC 90-105 require for RNP authorization in 14 CFR Part 135?
FAA Advisory Circular AC 90-105 (Approval Guidance for RNP Operations and Barometric Vertical Navigation Operations in the U.S. National Airspace System and in Oceanic and Remote Continental Airspace) provides the operational approval framework for Required Navigation Performance procedures including RNP APCH (approach), RNP AR APCH (authorization required approach), RNP 4 (oceanic), RNP 2 (en route), and Advanced RNP. Each RNP authorization is issued by OpSpecs paragraph (commonly C063 RNP APCH, C384 RNP AR APCH, C055 RNP 4, and related paragraphs) with the per-procedure operational conditions, aircraft equipment configuration, PIC training requirements, and recurrent training intervals AC 90-105 specifies. The most common RNP authorization finding during Part 135 surveillance is a PIC operating an RNP AR APCH whose general instrument currency is intact but whose RNP AR-specific training under AC 90-105 was completed outside the recurrent window, or an RNP authorization that was issued under an old OpSpecs paragraph that has since been superseded by a current paragraph with different operational conditions. Compliance software must inventory every active RNP authorization, the underlying aircraft equipment configuration, the per-PIC training record under AC 90-105, and the OpSpecs paragraph that issued the authorization — and surface any drift across that chain before the next RNP dispatch.
How much does Part 135 LOA + RVSM + RNP authorization tracking software cost?
Pricing splits across the same three categories as broader Part 135 compliance tooling. Aviation-specialist manual + authorization platforms (Web Manuals, Comply365, ARGUS) handle multi-authorization tracking and revision control for Part 135 + 145 + 121 operators — priced per-manual or per-operator under sales-led annual contracts, typically $5,000–$30,000+/year. Per-tail maintenance platforms (CAMP Systems, Veryon/Traxxall, Flightdocs) include RVSM-related §91.411 + §91.413 inspection tracking on the GMM side but are not purpose-built for OpSpecs-paragraph-to-LOA-to-training-record cross-referencing on the GOM side — per-aircraft pricing $30–$500/tail/month. Charter operations platforms (Wyvern, ARGUS PRO) provide operator ratings and PIC currency tracking with limited LOA inventorying. Document-side compliance platforms (FileFlo) inventory every OpSpecs paragraph, LOA, RVSM monitoring record, RNP training record, and §135.243 PIC qualification in a single index, tie each authorization back to the OpSpecs paragraph that issued it, surface expiration and recurrent-currency dates, and produce an EDP-defensible authorization binder on demand — $299/month flat for unlimited pilots, mechanics, manuals, aircraft, LOAs, and authorizations. Most Part 135 operators need software from at least two categories, and the LOA + authorization tracking layer is the one that most directly drives surveillance findings in the authorization-currency dimension.
What FAA civil penalty applies to LOA + RVSM + RNP authorization violations under 14 CFR Part 135?
Under 49 U.S.C. § 46301(a)(1), the FAA may impose civil penalties up to $37,377 per violation for most Part 135 regulatory violations as of the 2026 inflation-adjusted schedule (penalties adjusted annually under the Federal Civil Penalties Inflation Adjustment Act). Authorization-side findings — flying an RVSM segment without the FAA AC 91-85B-aligned monitoring record current, operating an RNP procedure without the AC 90-105 PIC training record current, holding an OpSpecs paragraph whose underlying LOA has lapsed, or operating under §135.243 PIC qualifications that do not match the OpSpecs-paragraph-specific currency requirements — are among the most consequential entries in EDP cases against Part 135 operators because the authorization layer interacts with every operational record created against it: a single RVSM dispatch with a lapsed monitoring record implicates the dispatch authorization, the §135.79 flight locating record, the PIC qualification record, and the §135.63 record retention chain. Repeat or systemic findings in the authorization layer can result in compliance action, OpSpecs amendment, or certificate suspension exposure for charter operators with patterned findings. The authorization binder — OpSpecs paragraph + LOA + RVSM monitoring record + RNP training record + §135.243 PIC qualification — is the spine of every 14 CFR Part 135 surveillance visit that touches RVSM or RNP operations.
Stop reconstructing the OpSpecs-to-LOA-to-monitoring-record chain the morning of the POI surveillance visit
FileFlo holds the OpSpecs paragraph inventory, LOA expiration calendar, RVSM monitoring records under FAA AC 91-85B, RNP training records under FAA AC 90-105, and §135.243 PIC qualifications cross-reference across every renewal cycle — all for $299/month flat, no contract, no per-LOA fees, no per-authorization fees.
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