Direct Answer
In your first 100 days as a Part 135 Chief Pilot or Director of Operations, start with a records-state audit — not a reorganization. The management positions exist to administer and prove compliance under 14 CFR §119.69, so your first job is to find out, in writing, what is actually current and provable.
A workable rhythm: days 1-30 audit and stabilize — confirm all required management positions are filled and FAA-accepted, verify every pilot is current and qualified, confirm the operations manual is the current accepted/approved version, and open a professional line to your principal operations inspector. Days 31-60: close the gaps the audit found. Days 61-100: turn those fixes into a repeatable system so the operation stays provably current after the honeymoon ends.
The qualification standard for the role lives in 14 CFR §119.71 (not the Part 121 section §119.65). For the full certificate-and-experience standard, see our required management personnel qualifications guide.
What the Role Is — Before You Run It
The Director of Operations and Chief Pilot are not internal titles the company invented — they are FAA-required management positions. The requirement lives in 14 CFR §119.69, titled “Management personnel required for operations conducted under part 135 of this chapter.” Subsection (a) requires each certificate holder — except one using only one pilot in its operations — to have qualified personnel serving as a Director of Operations, a Chief Pilot, and a Director of Maintenance. Your seat is one of those three, and the operation cannot legally run on-demand or commuter service without it filled and FAA-accepted.
Cite §119.69 for Part 135 — not §119.65
14 CFR §119.65 is the Part 121 management-personnel section. The Part 135 required positions are in §119.69, and the Part 135 qualifications are in §119.71. When you reference the DO or Chief Pilot requirement for an on-demand or commuter operator, you are in the §119.69 / §119.71 pair — a common citation error worth getting right from day one.
The rule gives you the what (a required position) and §119.71 gives you the who (the qualifications). What no regulation gives you is a start-up playbook — the recurring work of the first hundred days. That is what the rest of this article is. For the regulatory scope of each seat, see the Chief Pilot duties and the Director of Operations vs. Chief Pilot comparison.
Why Your First 100 Days Are a Certificate-Level Issue
When you sign on as a required management official, you are not just taking a job — you are putting your name on the certificate holder's compliance posture. The FAA expects the person in your seat to be able to produce, on request, the records that prove the operation is being run as authorized: current crews, a current manual, operations inside the Operations Specifications. The day you start, every gap in that picture becomes your open item, whether you created it or inherited it.
That is the case for auditing before acting. New leaders get into trouble by assuming a record exists that does not — a missing recurrent training entry, a lapsed medical no one tracked, a manual revision that never got accepted. If a principal operations inspector arrives in your first month and asks for a crewmember's qualification story, “I just started” is not an answer the certificate gets to give. A leader who has already run a records-audit preparation pass is in a fundamentally different posture than one reconstructing the operation's compliance story under a deadline.
What you are accountable for on day one
One distinction is worth fixing early. If you are the Director of Operations, your function is the overall conduct and operational direction of the operation — administering operational control, scheduling, and policy. If you are the Chief Pilot, your function is crewmember standards — training, checking, currency, standardization, and the pilot manual. In a small operator one person may hold both, where the FAA accepted that structure under §119.69(b). Either way, the first 100 days are about proving the operation is sound — and the proof is documentary. For how the seats divide, see the DO vs. Chief Pilot comparison.
The Records-State Audit You Run Day One
Before you change a single procedure, find out what you inherited. The records-state audit is a structured pass across the document sets that prove the operation is compliant. The output is not a feeling — it is a written gap list: every item that is missing, expired, or unprovable. That list becomes the work plan for the next 70 days.
Management positions and FAA acceptance
14 CFR §119.69(a)/(e)Confirm all three required positions — Director of Operations, Chief Pilot, Director of Maintenance — are filled by qualified, FAA-accepted individuals, that the manual states each position’s duties and the current names/business addresses, and that the §119.69(e) notification trail is intact (including for the seat you are filling). A position that is vacant, or filled by someone who has not been accepted, is an immediate exposure.
Crew qualification and currency packages
Pilot records · PIC/SIC currency · checksFor every pilot, verify the package is complete and current: certificate and ratings, current medical of the correct class, initial/recurrent training, proficiency or competency checks, line checks, instrument currency where required, and second-in-command currency where applicable. The question to answer is brutal and specific: could you prove, today, that the pilot flying your next trip is qualified and current for it?
Operations manual and revision status
General Operations Manual (GOM)Confirm which version of the operations manual is the current accepted/approved one, that crews are actually flying to it, and that recent operational changes (new aircraft, new authorizations, revised limitations) are reflected and processed. A manual that does not match the operation is one of the most common surveillance findings — and it lands on the management function that owns it.
Operations Specifications (OpSpecs)
OpSpecs authorizations and limitationsRead the OpSpecs and confirm the operation is conducting only the kinds of operations, in the areas, and under the limitations it is authorized for. New leaders are sometimes surprised to find the operation has drifted past — or never updated — an authorization. Map what the operator actually does against what the OpSpecs allow, and flag every mismatch.
Airworthiness and maintenance records
Coordinate with the Director of MaintenanceOperational control assumes airworthy aircraft. Coordinate with the Director of Maintenance to confirm required inspections are current, the inspection program is being followed, and airworthiness records are retrievable. You do not own airworthiness as a DO or Chief Pilot — but you cannot dispatch a flight the maintenance records cannot support, so this belongs in your day-one picture.
The FAA relationship and open items
Principal inspectors (POI / PMI / PAI)Identify your principal operations inspector and the rest of the certificate management team, confirm the operator notified them of your appointment under §119.69(e), and ask — directly — whether there are open findings, surveillance items, or letters of investigation. Inheriting an open item you did not know about is how good first 100 days go wrong. Better to surface it in week one.
If you inherited a consolidated role, the audit is bigger
At a small operator you may hold more than one management title where the FAA accepted a consolidated structure under §119.69(b). That does not shrink the audit — it means one person now owns more record sets and must meet each role's §119.71 standard. We cover the consolidated-role scenario in the one-person-multiple-roles guide.
For the underlying record framework the audit touches, see what records a Part 135 operator must keep, the pilot records the FAA requires, and the records-audit preparation checklist.
Run your day-one records audit without reconstructing it by hand
FileFlo classifies and indexes the records you inherit — management appointments, pilot training and checking, currency, certificates, medicals, and the manual — and surfaces what is expired or missing in a single view, so your first-100-days gap list builds itself. Starter at $89/mo, Professional at $299/mo. 5-day free trial, no credit card required.
The 100-Day Plan, in Three Phases
The audit gives you reality. The plan turns it into action. The phasing below is a practical rhythm, not a regulatory schedule — the only hard clock in the rule is the operator's 10-day §119.69(e) notification for a personnel change. Move faster where the audit found live exposure.
Audit and stabilize
- Complete the records-state audit and produce a written gap list (missing, expired, unprovable).
- Confirm all §119.69 positions are filled and FAA-accepted; verify the §119.69(e) notification trail, including your own appointment.
- Ground or re-qualify any pilot whose currency or qualification you cannot prove — do not assign on assumption.
- Introduce yourself to the principal operations inspector; ask about open findings, surveillance history, and expectations.
- Confirm which manual version is current/accepted and that crews are flying to it.
Close the gaps
- Work the gap list in priority order: currency and qualification first, then manual/OpSpecs mismatches, then documentation completeness.
- Schedule and document overdue training, checks, and line checks; rebuild any incomplete pilot package.
- Process manual revisions through the proper accepted/approved channel so the manual matches the operation.
- Reconcile what the operation actually does against the OpSpecs; pursue authorization changes where there is drift.
- Establish the record-keeping cadence: where records live, who updates them, how expirations are tracked.
Make it repeatable
- Turn the one-time audit into a standing currency/expiration tracking system so nothing lapses silently.
- Run a mock surveillance pass: pick a crewmember and a trip at random and try to produce the full qualification story cold.
- Document the management coordination rhythm between DO, Chief Pilot, and DOM (even if you wear more than one hat).
- Set a review cycle for the manual, OpSpecs conformance, and the management-position notification obligations.
- Close the loop with the POI: show the gaps you found and fixed — credibility compounds from there.
The one hard deadline in the plan
Most of this rhythm is discretionary, but §119.69(e)(3) is not: any change in personnel or vacancy in a required management position must be reported to the responsible Flight Standards office within 10 days. If your arrival filled a vacancy, that clock already applied. Verify it was met as part of days 1–30. See the dedicated management-vacancy notification guide.
If you are stepping in to build rather than inherit — standing up the operation or pursuing a certificate — the sequence shifts toward certification work; see how to get a Part 135 certificate and the certificate types. And because the safety-program rule is changing what management must own, factor in the Part 135 SMS 2027 deadline and the new Director of Safety position from day one.
The Records You Inherit — and Have to Keep Provable
Everything in your first 100 days reduces to one question a principal inspector can ask at any moment: show me. Below are the record sets a new Director of Operations or Chief Pilot inherits, and how a document-intelligence layer keeps them audit-ready. FileFlo does not fly, train, schedule, hire, or qualify anyone — it keeps the documentary proof the role is responsible for.
Management Appointment & FAA-Acceptance Records
14 CFR §119.69 / OpSpecsWhat it proves
The documentation that the FAA has accepted qualified individuals in each required management position, the manual statement of duties and current names/addresses, and the §119.69(e) notification trail for changes and vacancies.
How FileFlo tracks it
FileFlo stores appointment and acceptance documents with dates, tied to each individual’s qualification package, so the management chain for every required position is complete and retrievable.
Your Own Qualification Package
14 CFR §119.71(a)–(e)What it proves
The evidence that you meet the §119.71 standard for the role you hold — the appropriate pilot certificate and ratings, and the logged pilot-in-command or supervisory/operational-control experience the rule requires.
How FileFlo tracks it
FileFlo keeps certificates, ratings, and the documentary evidence supporting your qualification organized in one place — useful when the operator submits, and the FAA reviews, your management-position change.
Pilot Training & Checking Records
Crewmember training and checking (14 CFR Part 135)What it proves
Initial, transition, recurrent, and requalification training plus proficiency/competency and line checks for every crewmember — the proof a pilot is qualified and current before assignment.
How FileFlo tracks it
FileFlo classifies training and check records as document classes, tags them to each pilot, and surfaces overdue or missing items so the currency picture is live, not reconstructed.
Crew Currency & Recent-Experience Tracking
PIC/SIC currency and recent experienceWhat it proves
The live eligibility picture per pilot — recent experience, instrument currency where required, SIC currency where applicable — that determines who can legally fly a given trip.
How FileFlo tracks it
FileFlo maintains per-pilot currency records with proactive expiration alerts, so an expiring or expired item is flagged before a crewmember is mistakenly assigned.
Pilot Certificate & Medical Copies
14 CFR Part 61 / §61.23What it proves
Each pilot’s certificate and ratings and a current medical of the appropriate class. A lapsed medical can ground a pilot immediately — exactly the kind of silent gap a new leader needs surfaced.
How FileFlo tracks it
FileFlo stores certificate and medical copies, tracks medical class and expiration, and alerts before a lapse affects assignability.
Operations Manual & Revision History
General Operations Manual / OpSpecs conformanceWhat it proves
The current accepted/approved pilot-facing procedures crews must follow, plus the revision history showing the manual reflects the current operation and authorizations.
How FileFlo tracks it
FileFlo indexes the manual and its revisions so you can show which version is current and that the operation is being run to it — and to the OpSpecs.
Related guides: Part 135 pilot records · Training program recordkeeping · Single-pilot operator records · Management qualifications (§119.71)
FileFlo is the proof layer, not the operational, hiring, or training system
FileFlo is a compliance document intelligence platform — it classifies, indexes, and tracks the records a new Part 135 manager inherits, and surfaces expirations and gaps. It is not a dispatch system, a flight operations management system (FOS), a training-management system, or a crew-scheduling system, and it does not hire, recruit, place, train, or qualify people, nor give legal, career, or HR advice — the operator and the FAA do that. FileFlo keeps the documentary proof audit-ready alongside whatever operational and training systems you run.
Frequently Asked Questions
What should a new Part 135 Chief Pilot or Director of Operations do in the first 100 days?
Start with a records-state audit, not a reorganization. In a Part 135 operation the management positions exist to administer and prove compliance under 14 CFR §119.69, so the first job of a new Director of Operations or Chief Pilot is to find out, in writing, where the operation actually stands: are all required management positions filled and FAA-accepted, is every pilot current and qualified, is the operations manual the current accepted/approved version, and can you produce the records that prove it. A workable rhythm is roughly: days 1-30 audit and stabilize (records, currency, manual, the FAA relationship); days 31-60 fix the gaps the audit found; days 61-100 turn fixes into a repeatable system so the operation stays provably current. The point is to inherit reality before you change anything — most new-leader trouble comes from assuming a record exists that does not.
What does a Part 135 Director of Operations actually do?
Under 14 CFR §119.69(a), the Director of Operations is one of three required Part 135 management positions (with the Chief Pilot and Director of Maintenance) for any operator using more than one pilot. The Director of Operations is the management official responsible for the overall conduct and direction of flight operations — administering operational control on behalf of the certificate holder, scheduling, dispatch or flight-following oversight, and operational policy. The qualification standard is in §119.71(a)/(b) and centers on supervisory or managerial experience exercising operational control plus the appropriate pilot certificate. Note this is the §119.69 / §119.71 pair for Part 135 — not §119.65, which is the Part 121 section. A new DO is accountable for whether the operation is controlled, staffed, scheduled, and run within its authorizations.
Do I have to tell the FAA when a Chief Pilot or Director of Operations leaves?
Yes. Under 14 CFR §119.69(e)(3), a Part 135 certificate holder must notify the responsible Flight Standards office within 10 days of any change in personnel or any vacancy in any required management position — Director of Operations, Chief Pilot, or Director of Maintenance. §119.69(e) also requires the operator to state each position's duties, responsibilities, and authority in the manual and to list the names and business addresses of the people assigned to those positions, kept current. So when you step into one of these roles, your appointment is part of a notification trail, and if the seat you are filling was vacant, the operator already owed the FAA that notice. Continuing to operate without a qualified, FAA-accepted person in a required position is itself a compliance finding.
What is the difference between a Part 135 Director of Operations and a Chief Pilot?
They are different required positions with different focus and different qualification standards. The Director of Operations is responsible for the overall conduct and operational direction of flight operations — operational control administration, scheduling, and operational policy — with a §119.71(a)/(b) standard built around supervisory/managerial experience exercising operational control. The Chief Pilot is the management pilot responsible for crewmember standards and how flights are actually flown — training, checking, currency, standardization, and the pilot sections of the manual — with a §119.71(c)/(d) standard built around recent pilot-in-command experience. In a small operator the same person may hold both titles where the FAA has accepted that structure under §119.69(b), but each role's qualifications must be met independently and both sets of duties must still be performed.
Who is the principal operations inspector (POI) and how should a new leader work with them?
The principal operations inspector (POI) is the FAA Flight Standards inspector assigned to oversee your certificate's operations; alongside the principal maintenance inspector (PMI) and principal avionics inspector (PAI), they form your certificate management team. For a new Director of Operations or Chief Pilot, establishing a professional working relationship with the POI early is one of the highest-leverage first-100-days moves — confirm the operator already notified them of your appointment under §119.69(e), understand any open items or surveillance history, and be the management contact who can produce records when asked. The POI is not an adversary; a leader who is responsive, organized, and can show current records is in a far stronger posture than one who is reconstructing the operation's compliance story under a deadline. FileFlo keeps those records retrievable so you can answer cleanly.
What records should a new Part 135 manager audit on day one?
Run a records-state audit across the document sets that prove the operation is compliant: (1) the management appointment and FAA-acceptance documentation for all required §119.69 positions, including the §119.69(e) notification trail; (2) every pilot's qualification and currency package — certificates, current medicals, training records, proficiency/competency checks, line checks, and recent-experience tracking; (3) the operations manual and its revision history, to confirm crews are flying to the current accepted/approved version; (4) the Operations Specifications to confirm what the operator is actually authorized to do; and (5) aircraft airworthiness and required-inspection records in coordination with the Director of Maintenance. The goal is a written gap list: every item that is missing, expired, or unprovable. That list becomes your 100-day work plan.
How long does it take to be added or accepted by the FAA in a required Part 135 management position?
There is no single published clock, because the FAA must be satisfied the individual meets the applicable §119.71 qualification standard for the role and is reflected in the certificate holder's management structure — and the operator owes the §119.69(e) notification within 10 days of the change. In practice, the time depends on how cleanly the candidate's qualification package documents the §119.71 experience, how quickly the operator submits the change, and the principal inspectors' review. The practical lesson for a new leader: the cleaner and more complete your own qualification documentation (certificates, ratings, logged pilot-in-command or supervisory experience evidencing the §119.71 standard), the smoother the acceptance. FileFlo does not place or qualify you and does not give career advice — but it keeps the documentary package that supports your qualification organized and retrievable.
What is the salary range for a Part 135 Director of Operations or Chief Pilot in 2026?
Compensation varies widely by aircraft type, fleet size, region, and whether the manager also flies the line, so treat any figure as a broad, date-stamped range rather than a target. As a public-market reference, ZipRecruiter data (June 2026) shows most U.S. Part 135 Director of Operations roles between roughly $75,500 and $135,500 per year (average near $107,700), and most U.S. Chief Pilot roles between roughly $122,000 and $207,000 per year (average near $163,000, top earners near $228,000). These are external job-market ranges, not regulatory figures. FileFlo is a compliance-records tool and does not provide salary, hiring, placement, or career advice — we track the qualification and currency records the role owns.
A note on pay (a top search question for both roles)
Compensation varies widely with aircraft type, fleet size, region, and whether the manager also flies the line. As a public-market reference, ZipRecruiter (June 2026) shows most U.S. Part 135 Director of Operations roles between roughly $75,500 and $135,500 per year (average near $107,700), and most Chief Pilot roles between roughly $122,000 and $207,000 per year (average near $163,000, top earners near $228,000). Treat these as broad, date-stamped market ranges — not targets or regulatory figures. FileFlo is a compliance-records tool and does not provide salary, hiring, placement, or career advice.
Start your first 100 days knowing exactly what you inherited
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Reviewed by Chad Griffith, Founder, FileFlo — compliance document intelligence. June 15, 2026. Regulatory citations verified against Cornell LII (14 CFR §119.69 and §119.71) as of publication date; salary figures cite ZipRecruiter (June 2026) as dated ranges. This article is educational and is not legal, career, or HR advice.