The FAA has issued a notice directed at Part 135 operators concerning the use of runway obstacle analysis (ROA) products — the third-party performance tools that on-demand and commuter operators rely upon to ensure aircraft can meet required obstacle clearance margins during takeoff and, in some cases, approach and landing operations. Under 14 CFR Part 135, turbine-powered aircraft operators are obligated to demonstrate that their aircraft can clear all obstacles in the departure environment by prescribed margins, and many operators fulfill this obligation through vendor-supplied analysis products rather than constructing their own obstacle evaluation in-house. The FAA's notice signals renewed regulatory attention to how these products are developed, validated, and applied operationally, and likely addresses concerns about data currency, methodology transparency, or the qualifications of vendors providing such analysis.
The practical stakes for Part 135 operators are significant. Runway obstacle analysis is not a routine paperwork exercise — it directly governs which runways, weights, and conditions are operationally permissible for a given aircraft on a given day. When operators accept a vendor's obstacle analysis product without scrutiny of its underlying data sources, update cycles, or terrain and obstacle database integrity, they may unknowingly be operating outside actual performance margins. The FAA has historically raised concerns about operators treating third-party ROA products as self-evidently compliant without verifying that the vendor's methodology aligns with the applicable aircraft flight manual (AFM) performance data and accounts for all relevant obstacles within the required assessment corridor. This notice likely serves as a reminder — or a direct corrective action — that acceptance of an ROA product does not transfer regulatory accountability away from the certificate holder.
For directors of operations, chief pilots, and flight operations managers at Part 135 certificate holders, this notice carries immediate compliance implications. Operators should audit their current ROA vendor relationships to confirm that contracts specify data currency standards, that airport and obstacle databases are updated at regular intervals consistent with FAA and ICAO charting cycles, and that the vendor's analytical methodology has been validated against the specific aircraft types in the fleet. Part 91K fractional operators and even large-cabin Part 91 operators conducting international operations under performance-based departure procedures may find it prudent to apply similar scrutiny even where not strictly required, as the underlying safety rationale is identical.
This notice fits within a broader FAA effort over the past several years to tighten accountability around performance-based operations in business aviation. The agency has increasingly scrutinized the gap between what operators believe their performance products are computing and what those products actually deliver, particularly following accident investigations in which departure obstacle clearance was a contributing factor. NBAA's publication of the notice reflects the association's ongoing role as the primary conduit between the FAA and the business aviation community on operational compliance matters, and operators should treat NBAA's distribution as a signal to treat the underlying FAA guidance as high-priority reading rather than routine regulatory housekeeping.