Before work begins
Record official URL, document identity, current status, retrieval time, and observed change information.
RESOURCES AND REGULATORY UPDATES
Useful only if the source is current.
Each regulatory note identifies its official source and shows when it was last reviewed by Neil Schnaak. These notes are informational only, are not legal advice, and do not replace advice about your operation’s specific circumstances.
Regulatory note
Informational only; not legal advice.
Part 5 applicability and the May 28, 2027 deadline
Part 135 operators and §91.147 LOA holders authorized before May 28, 2024 must develop and implement a Part 5 SMS and submit the required declaration by May 28, 2027. Newer applicants face Part 5 SMS requirements through their authorization process.
A qualifying single-pilot organization may receive reduced treatment under §5.9(e), but it is not categorically exempt from SMS.
- Primary source
- 14 CFR §5.9, current eCFR text (opens in a new tab)
- Official-source retrieval date
- Last reviewed
SOURCE RECEIPT STANDARD
Every consequential engagement records the evidence.
Before substantive drafting
Confirm the applicable source set and route uncertain meaning to Neil instead of guessing.
Before delivery
Repeat the check, record changes, assess impact, and capture Neil's final interpretation and approval.
Planned source lane
FAA DRS and other official FAA sources are consulted as current external authority. Indexed extracts, change flags, and AI-assisted summaries support retrieval and review but do not become authority by themselves.