Direct Answer
Operations Specifications (OpSpecs) are the FAA-issued document that defines the exact envelope of operations your Part 135 certificate authorizes — the operator-specific authorizations, limitations, and procedures the regulations require be spelled out for your certificate.
Under 14 CFR §119.7, OpSpecs must contain the authorizations, limitations, and certain procedures under which each kind of operation is conducted, and certain procedures under which each class and size of aircraft is operated. They are issued together with the certificate under 14 CFR §119.5, and §119.5 prohibits operating without — or in violation of — appropriate operations specifications.
OpSpecs are organized into a standardized A/B/C/D paragraph structure, must be kept at your principal base and mirrored in your operating manual under 14 CFR §119.43, and can be amended by either the FAA or the operator under 14 CFR §119.51. Because they change far more often than the certificate itself, keeping the current version on file — and your manual excerpts in sync — is an ongoing document-control problem.
The Certificate Sets the Door; the OpSpecs Set the Lines
A common misconception among new Part 135 operators is that the air carrier certificate (or operating certificate) is the document that says what they can do. It is not. The certificate establishes that you are authorized to conduct commercial air operations; your operations specifications establish which operations, with which aircraft, in which areas, and under what conditions. Per 14 CFR §119.5, no person may operate as a direct air carrier or commercial operator without — or in violation of — both an appropriate certificate and appropriate operations specifications. The two are issued together and read together.
The reason this matters for recordkeeping is that the regulations themselves do not tell you everything you need to know to operate legally. Part 135 sets the universal floor — minimum equipment, crew qualifications, recordkeeping obligations. But the operator-specific details — that you may fly RNP approaches, that you are authorized for a particular area, that this exact aircraft registration is on your certificate, that you may or may not carry hazardous materials — live in your OpSpecs. The FAA built this two-layer system deliberately: it lets the agency tailor authorizations to each operator and adjust them quickly, without re-issuing the certificate every time something changes.
Are OpSpecs part of the certificate? Per 14 CFR §119.7(b), no — with one exception: the paragraphs that identify the kinds of operations authorized are treated as part of the certificate. Everything else is binding but technically separate, which is precisely what allows the FAA to amend most OpSpecs paragraphs through the lighter-weight process in §119.51 rather than a full certificate action. The result, for the operator, is a living document that changes more often than almost any other in the compliance file.
"Not part of the certificate" does not mean "optional"
The §119.7(b) statement that OpSpecs are not part of the certificate is frequently misread as making them advisory. It does not. 14 CFR §119.5(g) prohibits operating in violation of the operations specifications, and §119.5(j) prohibits operating in a geographic area unless your OpSpecs specifically authorize it. The "not part of the certificate" language is about amendment procedure, not enforceability — an OpSpecs deviation is a violation with the same penalty exposure as any other Part 119/135 breach.
For the broader picture of what a Part 135 certificate obligates you to keep, start with what records a Part 135 operator must keep, and for the related question of who must hold authority over each flight, see what operational control means in Part 135.
The A/B/C/D Paragraph Structure
The CFR tells you what must be in your OpSpecs; it does not prescribe the lettered-paragraph format. That structure is an FAA administrative convention — described in FAA Order 8900.1 and managed through the agency\'s Web-based Operations Safety System (WebOPSS) — that organizes the §119.49 contents into a standardized, machine-generated template so that every operator\'s OpSpecs are laid out the same way and every inspector knows where to look.
A note on paragraph numbers
The specific paragraph numbers below (A001, B036, C063, D085, and so on) and their exact contents are governed by current FAA guidance and your individual issuance — and the FAA revises the standardized paragraph templates over time. Treat the descriptions here as an orientation to how the series are organized, not as an authoritative list. Always confirm the meaning and currency of any paragraph against your own OpSpecs and your Principal Operations Inspector.
A-series — General authorizations and operator profile
The A-series establishes who you are and what, in broad terms, you are authorized to do. Representative paragraphs include A001 (issuance and applicability of the OpSpecs), A003 (the certificate holder's name, certificate number, and business names), and A004 (a summary of the authorized kinds of operations). The A-series paragraphs that identify the kinds of operations authorized are the ones §119.7(b) treats as part of the certificate itself.
B-series — En route authorizations and limitations
The B-series covers how you operate between airports: en route navigation authorizations and limitations, area-of-operation authorizations, and special navigation capabilities such as Reduced Vertical Separation Minimum (RVSM) and the en route portions of Required Navigation Performance (RNP). Operators that fly oceanic, remote, or special-navigation routes carry the bulk of their special authorizations in this series, frequently with an underlying Letter of Authorization referenced in the paragraph.
C-series — Airport and terminal-area authorizations
The C-series covers operations at and around airports: terminal-area procedures, instrument approach authorizations (including lower-than-standard minimums, Category II/III where authorized, and RNP approach procedures), and airport-specific authorizations and limitations. This is the series most directly tied to your pilots' approach training and instrument currency records.
D-series — Aircraft maintenance and airworthiness
The D-series covers the maintenance and continuous-airworthiness side of the certificate: the approved aircraft inspection program or continuous-airworthiness maintenance program, airworthiness-release authorizations, and maintenance-related authorizations and limitations. This is where the §119.49 inspection-program and time-limitation contents are organized, and the series that links your OpSpecs to your maintenance records.
E-series and beyond — Specialized authorizations
Higher letter series cover additional specialized areas — for example, weight-and-balance control authorizations and other operation-specific authorizations the FAA standardizes as new paragraph templates. Most small Part 135 on-demand operators hold a relatively compact set of OpSpecs concentrated in the A through D series; larger and more complex operators accumulate more paragraphs as their authorized envelope grows.
The practical takeaway is that your OpSpecs are not a single document you read once at certification — they are a structured set of authorizations, each tied to a different part of your operation and each capable of being amended independently. When the FAA adds an RNP authorization, it issues a new or revised C-series paragraph. When you add an aircraft type, the A- and D-series paragraphs change. Each revision produces a new effective date, and the operator must be able to show the current version of every paragraph on demand.
Keeping OpSpecs Current: The Amendment Process
Because OpSpecs are not (mostly) part of the certificate, the FAA can change them through the streamlined amendment process in 14 CFR §119.51. Either side can start the process, and the timelines differ depending on who initiates and why.
FAA-initiated amendments
The FAA may amend your OpSpecs when the Administrator determines that safety in air commerce and the public interest require it. When the FAA initiates a change, the responsible Flight Standards office must:
- Notify you in writing of the proposed amendment.
- Give you a reasonable period — not less than 7 days — to submit written information, views, and arguments.
- Notify you of adoption, partial adoption, or withdrawal of the amendment.
- Make the amendment effective not less than 30 days after you receive notice — unless you petition for reconsideration or the FAA finds an emergency requiring immediate effect.
Operator-initiated amendments
You may apply to amend your own OpSpecs — to add an aircraft, a kind of operation, or a new authorization. The FAA grants the amendment if it determines that safety and the public interest allow it. The application timing depends on the change:
- At least 90 days before the intended effective date for major changes — mergers, acquisitions of operating authority, changes requiring extensive evaluation, or adding aircraft types or kinds of operations not already authorized.
- At least 15 days before the intended effective date in all other cases — unless the FAA approves a shorter period.
- Once approved, the amendment is effective on the date the Administrator approves it.
Petition for reconsideration
If the FAA denies your amendment request, or initiates an amendment you disagree with, you may petition for reconsideration within 30 days of receiving the notice. Filing the petition suspends the effectiveness of the amendment — unless the FAA has found that an emergency exists requiring the amendment to be effective immediately in the interest of safety in air commerce. This is the one place in the OpSpecs process where the operator has a formal mechanism to pause a change, and the 30-day clock is unforgiving.
The duty to maintain and distribute — §119.43
Issuance is only half the obligation. Per 14 CFR §119.43, every certificate holder has three standing duties around its OpSpecs:
Maintain a complete and separate set
You must keep a complete and separate set of your operations specifications at your principal base of operations — the authoritative master copy.
Mirror them in your operating manual
You must insert pertinent excerpts of the OpSpecs (or appropriate references) into your operating manual, clearly identify each excerpt as part of the operations specifications, and state that compliance with each is mandatory. When an OpSpecs paragraph is amended, the corresponding manual excerpt is now out of date — and that mismatch is itself a finding.
Keep your people informed
You must keep each employee and other person used in your operations informed of the OpSpecs provisions that apply to that person's duties and responsibilities. A pilot, mechanic, or dispatcher operating against a superseded provision is a §119.43(c) gap.
The version-drift trap
The most common OpSpecs finding during surveillance is not operating outside the envelope — it is a version mismatch. The FAA issues an amended paragraph; the master copy at the principal base is updated; but the excerpt in the General Operations Manual, the copy the chief pilot circulated, or the reference the dispatcher works from still reflects the old version. Under §119.43(b)–(c), the operator must keep the manual excerpts and its people current — so an amendment that was correctly accepted can still produce a finding weeks later if the downstream documents were never reconciled. This is a document-control problem, and it is exactly the kind of drift that surfaces in a Part 135 surveillance audit.
Is your current OpSpecs revision on file — and your manual in sync?
FileFlo classifies and version-tracks every OpSpecs revision, LOA, and the operating-manual excerpts that must mirror them under §119.43 — flagging the excerpt that just went stale and producing a one-click authorization binder for POI surveillance. Starter at $89/mo, Professional at $299/mo. 5-day free trial, no credit card required.
The OpSpecs Record an Inspector Expects to Be Current
During a Part 135 surveillance visit, the Principal Operations Inspector typically starts with the current OpSpecs index and works outward — confirming that the master set matches what WebOPSS shows, that the manual excerpts match the master set, and that the operation actually conducted falls inside the authorized envelope. The documents below are the spine of that review. None of them is a flight operations or maintenance-tracking system — they are the record that proves your authorization status, and keeping that record complete and current is a document-management discipline.
Current OpSpecs Master Set
14 CFR §119.43(a) / §119.7What it proves
The complete and separate set of operations specifications maintained at your principal base. Every paragraph must reflect its current FAA-issued revision and effective date. A master set with a superseded paragraph — or a missing one — is the first thing surveillance turns up, because the inspector can compare it directly against the agency's own WebOPSS record.
How FileFlo tracks it
FileFlo classifies each OpSpecs revision as a versioned document, retains the full revision history with effective dates, and produces a one-click current-OpSpecs inventory for surveillance.
Operating Manual Excerpts (GOM/GMM)
14 CFR §119.43(b)What it proves
The pertinent OpSpecs excerpts (or references) inserted into your General Operations Manual and General Maintenance Manual, each clearly identified as part of the OpSpecs with mandatory-compliance language. When a paragraph is amended, the matching manual excerpt is immediately out of date until reconciled — a §119.43(b) version-drift finding.
How FileFlo tracks it
FileFlo links each manual excerpt to the OpSpecs paragraph it mirrors, so when a revision is uploaded the now-stale excerpt is flagged for update before it becomes a finding.
Letters of Authorization (LOAs)
Referenced within OpSpecs paragraphsWhat it proves
Many special authorizations — RVSM, RNP, Class II navigation, and others — are carried in an LOA referenced inside the corresponding OpSpecs paragraph. The OpSpecs paragraph points to the LOA; the LOA carries the detailed operating conditions and, frequently, an expiration or recurrent-currency requirement. An OpSpecs paragraph whose underlying LOA has lapsed is an authorization that looks current but is not.
How FileFlo tracks it
FileFlo inventories every LOA against the OpSpecs paragraph that references it, with effective date, expiration, and renewal-window alerts surfaced before the next operation that depends on it.
Underlying Authorization Evidence
§135.293 / §135.297 / §91.411 / §91.413What it proves
Each authorization implies ongoing proof that you still meet its conditions — pilot training and instrument-currency records behind an approach authorization, altimeter and transponder inspection records behind a navigation authorization, hazmat training behind a hazmat-carriage authorization. The OpSpecs paragraph is the authorization; these records are the evidence it remains valid.
How FileFlo tracks it
FileFlo cross-references each authorization to its supporting records — surfacing a lapsed currency or inspection before it undermines the authorization that depends on it.
Grants of Exemption / Deviation
14 CFR §119.49 (deviations and exemptions)What it proves
Where your OpSpecs authorize a deviation or exemption from a Part 135 requirement, the underlying FAA grant of exemption is a document you must be able to produce alongside the OpSpecs paragraph that references it. The paragraph alone does not prove the relief — the grant does.
How FileFlo tracks it
FileFlo stores each grant of exemption with the OpSpecs paragraph it supports, its effective period, and any renewal deadline, so the deviation and its authority are retrievable together.
Related reading: What records a Part 135 operator must keep · Required management personnel qualifications · Part 135 training-program recordkeeping · Part 135 maintenance recordkeeping (CAMP)
FileFlo is the proof layer, not the operational layer
FileFlo is a compliance document intelligence platform — it classifies, indexes, version-tracks, and surfaces expirations on the documents that prove your authorization status. It does not amend OpSpecs, interact with WebOPSS, run dispatch or flight operations, or maintain your aircraft. Your director of operations and your Principal Operations Inspector own the amendment process; FileFlo keeps the resulting record — the OpSpecs revisions, the LOAs, the manual excerpts, and the underlying evidence — complete, current, and audit-ready. That separation of concerns is deliberate: the record that proves your authorizations must be maintained independently from the systems that exercise them.
Frequently Asked Questions
What are Operations Specifications (OpSpecs) in 14 CFR Part 135?
Operations Specifications (OpSpecs) are the FAA-issued document that defines the exact envelope of operations a Part 135 certificate holder is authorized to conduct. Per 14 CFR §119.7, OpSpecs contain the authorizations, limitations, and certain procedures under which each kind of operation is conducted, plus certain procedures under which each class and size of aircraft is operated. They are issued together with the air carrier or operating certificate under 14 CFR §119.5 and identify your principal base of operations, the kinds and areas of operations authorized, the specific aircraft you may operate, any deviations or exemptions the FAA has granted, your hazardous-materials authorization or prohibition, and (for on-demand operators) the registration markings of each aircraft inspected under an approved aircraft inspection program, plus the time limitations for inspections and overhauls of aircraft maintained under an airworthiness maintenance program required by §135.411(a)(2). In practice, OpSpecs are the operator-specific rulebook the FAA holds you to: the regulations in Part 135 set the floor, and your OpSpecs tell you exactly which of those operations you are allowed to perform and under what conditions.
Are OpSpecs part of the FAA certificate?
Mostly no. 14 CFR §119.7(b) states that operations specifications are not a part of the certificate itself — with one important exception: the OpSpecs paragraphs that identify the kinds of operations authorized are treated as part of the certificate. The practical effect of this distinction is procedural. Because most OpSpecs paragraphs are not part of the certificate, the FAA can amend them under the streamlined process in 14 CFR §119.51 without going through a certificate-action proceeding — which is why OpSpecs can change far more often than the certificate does. But operating outside your OpSpecs is still a violation: 14 CFR §119.5(g) prohibits operating in violation of the appropriate operations specifications, and §119.5(j) prohibits operating in a geographic area unless your OpSpecs specifically authorize it. So OpSpecs sit in a hybrid position — not the certificate, but binding with the same force.
What does the A/B/C/D paragraph structure of OpSpecs mean?
The A/B/C/D structure is an FAA administrative convention (described in FAA Order 8900.1 and managed in the FAA's automated OpSpecs system — formerly WebOPSS, now part of the Safety Assurance System), not a numbered subsection of the CFR. The CFR — 14 CFR §119.49 — lists what OpSpecs must contain; the letter-prefix paragraph system is how the FAA organizes those contents into a standardized template. Broadly: the A-series covers general authorizations and the operator profile (A001 issuance and applicability, A003 aircraft authorization, A004 summary of special authorizations and limitations); the B-series covers en route authorizations and limitations (navigation, RVSM, RNP, areas of operation, special navigation); the C-series covers airport authorizations and terminal-area / approach operations; and the D-series covers aircraft maintenance, the airworthiness inspection program, and continuous-airworthiness items. Higher letter series (E for weight and balance, and beyond) cover additional specialized authorizations. The precise paragraph numbers and what each contains are governed by current FAA guidance and your individual issuance — always confirm against your own OpSpecs and your Principal Operations Inspector rather than a generic template.
How do OpSpecs get amended, and who can initiate the change?
Under 14 CFR §119.51, either the FAA or the certificate holder may initiate an amendment. When the FAA initiates a change, the responsible Flight Standards office notifies the certificate holder in writing, gives a reasonable period — but not less than 7 days — to submit written information or argument, and then makes the amendment effective not less than 30 days after the certificate holder receives notice (unless the holder petitions for reconsideration, or an emergency exists requiring it to be effective immediately). When the certificate holder requests an amendment, the application must be filed at least 90 days before the intended effective date (unless the FAA approves a shorter filing period) for major changes — mergers, acquisitions of airline operational assets that require an additional showing of safety (such as proving tests), changes in the kind of operation as defined in §110.2, resumption of operations following a suspension of operations as a result of bankruptcy actions, or the initial introduction of aircraft not before proven for use in air carrier or commercial operator operations — and at least 15 days before the intended date in all other cases. A certificate holder may petition for reconsideration of a denied or FAA-initiated amendment within 30 days of receiving the notice, and that petition suspends the effectiveness of the amendment unless the FAA has found an emergency requiring immediate effect.
Where must a certificate holder keep its OpSpecs, and who must know them?
Per 14 CFR §119.43, each certificate holder must maintain a complete and separate set of its operations specifications at its principal base of operations. The certificate holder must also insert pertinent excerpts of the OpSpecs (or appropriate references to them) into its operating manual, clearly identify each such excerpt as part of the operations specifications, and state that compliance with each is mandatory. Critically, §119.43(c) requires the certificate holder to keep each of its employees and other persons used in its operations informed of the provisions of the OpSpecs that apply to that person's duties and responsibilities. That last requirement is where document management becomes a compliance function: a pilot flying a route, a mechanic releasing an aircraft, and a dispatcher planning a leg each need access to the current OpSpecs provisions that govern their job — and an out-of-date excerpt in a manual is itself a finding.
What happens if you operate outside your OpSpecs?
Operating outside your OpSpecs envelope is a certificate violation independent of any other regulation you may have broken. 14 CFR §119.5(l) prohibits operating an aircraft under Part 119/121/135 in violation of the operating certificate or appropriate operations specifications, and §119.5(j) prohibits operating in a geographic area that your OpSpecs do not specifically authorize. Common deviations include flying a route or into an area your OpSpecs do not cover, operating an aircraft type or registration not listed in your aircraft authorization paragraph, conducting an approach or navigation operation (RVSM, RNP, Category II/III) without the corresponding authorization paragraph and any required Letter of Authorization, or carrying hazardous materials when your OpSpecs prohibit it. Because OpSpecs deviations are documented against a known, FAA-issued envelope, they are among the most straightforward findings for an inspector to establish during surveillance — and civil penalties under 49 U.S.C. § 46301 reach $75,000 per violation in 2026 (adjusted annually under the Federal Civil Penalties Inflation Adjustment Act).
How are OpSpecs different from a Letter of Authorization (LOA)?
OpSpecs are the comprehensive, paragraph-structured authorization document issued to every Part 135 certificate holder under 14 CFR §119.7, covering the full envelope of operations. A Letter of Authorization (LOA) is a separate, narrower FAA-issued document that authorizes a specific operational capability — and the two are frequently linked, with an OpSpecs paragraph referencing the underlying LOA that carries the detailed operating conditions. For Part 135 certificate holders, most special authorizations live in the OpSpecs paragraph system. The category distinction matters because Part 91 operators (who hold no certificate and therefore no OpSpecs) receive their special authorizations purely as LOAs or, for management specifications under Part 91 Subpart K, as MSpecs. For tracking purposes the rule is the same regardless of the label: every authorization has an issuing document, an effective scope, and — for many — an expiration or recurrent-currency requirement, and the operator must be able to prove all three are current.
Does FileFlo file or amend OpSpecs with the FAA?
No. FileFlo is a compliance document intelligence platform — it classifies, indexes, version-tracks, and surfaces expirations on the documents that prove your authorization status, including OpSpecs revisions, LOAs, and the operating-manual excerpts that must mirror your OpSpecs under 14 CFR §119.43. It does not interact with the FAA's OpSpecs system (formerly WebOPSS, now part of the Safety Assurance System), submit amendment requests, or communicate with your Principal Operations Inspector — those are functions of your director of operations and the FAA. FileFlo sits alongside that process: when a new OpSpecs revision is issued, you upload it and FileFlo files it against the correct authorization, flags any operating-manual excerpt that is now out of date, and keeps the version history an inspector will ask for during surveillance. The amendment is the FAA's and your DO's job; keeping the resulting record complete, current, and audit-ready is the document problem FileFlo solves.
Keep your OpSpecs envelope provable — every revision, every excerpt, every LOA
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Reviewed by Chad Griffith, Founder, FileFlo — compliance document intelligence. Last reviewed June 9, 2026. Regulatory citations verified against the Cornell Legal Information Institute eCFR (14 CFR §§119.5, 119.7, 119.43, 119.49, 119.51) as of publication date. The A/B/C/D paragraph descriptions are an orientation to FAA Order 8900.1 / WebOPSS conventions, not an authoritative paragraph list — confirm against your own OpSpecs and your Principal Operations Inspector.