For example, the replacement of a building roof is considered a major repair if it allows the building to be used beyond its normal operating life. Or, the engine in a forklift is replaced, thereby extending the lifespan of the equipment. As mentioned in 43.3 (a) above, Appendix A to Part 43 also provides us with a list of what is considered a major alteration or major repair.
After the discontinuance, the first annual inspection under § 91.409(a) is due within 12 calendar months after the last complete inspection of the aircraft under the progressive inspection. The 100-hour inspection under § 91.409(b) is due within 100 hours after that complete inspection. A complete inspection of the aircraft, for the purpose of determining when the annual and 100-hour inspections are due, requires a detailed inspection of the aircraft and all its components in accordance with the progressive inspection. A routine inspection of the aircraft and a detailed inspection of several components is not considered to be a complete inspection. Considering the difficulty we all face now in obtaining approved data either from the FAA or from manufacturers, many are tempted, when on the fence, to subjectively decide that the repair or alteration is minor and does not need a 337 or approved data.
CFR § 43.7 – Persons authorized to approve aircraft, airframes, aircraft engines, propellers, appliances, or component parts for return to service after maintenance, preventive maintenance, rebuilding, or alteration.
Back when this old rule was written, approved data for repairs was rare and the common practice was to use AC 43.13-1A as data to support the repair. You may be surprised to find out that you can still use AC 43.13-1B (revised about five years ago) as approved data for major repairs. These types of approvals are called “field approvals” and are not so widely used anymore. You would still need to record the Major Repair and reference the approved data on an FAA Form 337. A supplemental type certificate (STC) is a national aviation authority-approved major modification or repair to an existing type certified aircraft, engine or propeller.
Purchasing a Property
Repairs and maintenance expense is the cost incurred to ensure that an asset continues to operate. This may involve bringing performance levels up to their original level from when an asset was originally acquired, or merely maintaining the current performance level of an asset.
Because of the subjectivity introduced here, it is far better to err on the safe side and execute the 337 when in doubt. That sounds simple enough but there is another big difference between a major repair/alteration and a minor repair/alteration.
Major Repairs
This list is a part of the regulations that is outdated and difficult at times to apply to a particular situation. I will not include all of the descriptions here but please take the time to pull out your Regulation Book and take a gander at the list. There is a good decision tree for determing a major or minor repair in Appendix 1 of AC titled Maintenance and Alteration Data. You can download a copy of AC from the “Advisory Circular” section of this website.
More definitions of Minor repairs
Examples of such non-qualifying repairs, according to the IRS, include painting walls, fixing leaks, or replacing broken hardware. It’s an age-old question among us maintenance technicians, one that is yet to receive a clear, understandable answer from the FAA. At that time I was not interested in trying to find the answer in the regulations, I expected the chief inspector to be able to provide me with a quick response so that I could move on and get to the next task at hand (hoping the whole time for a minor repair). The distinction between a major alteration and a minor alteration and the major repair and a minor repair is clouded by outdated regulations and guidance material. It seems to be a common practice for some mechanics to file a 337 form “just in case” in order to avoid any interpretation issues, but I would strongly advise against that approach.
- This one exception to the requirement to use an FAA Form 337 applies to major repairs only.
- It is critically important though, to understand the limitations behind this exception.
Personal tools
This one exception to the requirement to use an FAA Form 337 applies to major repairs only. That being said, if the entity performing the work is a repair station certificated under Part 145 it may elect to provide the aircraft owner or operator a signed copy of the work order in place of the Form 337. It is critically important though, to understand the limitations behind this exception. Regardless of how the major repair is approved for return to service, whether it be by use of the Form 337 or a signed copy of the work order, the work must be performed in accordance with approved data. When you look at the list you will find it obviously has not been revised significantly since its inception April 23, 1964.
Fund University Capital Improvements – This fund is for appropriated capital improvement projects, including extraordinary repairs, funded from State General Fund dollars. Costs charged to this fund will be assigned to the Capital Improvement appropriations line on the OMB Appropriation Status reports. Assume, for example, a person purchases a home for $650,000 and spends $50,000 to renovate the kitchen and add a bathroom. After 10 years of owning and living in the home, the homeowner, who is single and files taxes as such, ends up selling the property for a price of $975,000. If no capital improvements had been made, the taxable amount for the capital gain would be $75,000 ($975,000 sale price – $650,000 purchase price – $250,000 capital gains exclusion).
If the repair you are performing could be construed as major by the FAA or a future purchaser of the aircraft, figure out how to get the approved data. The manufacturer may only rebuild or alter the aircraft unless they are certificated as a repair station as well.
By definition, the FAA should reject any 337 form that does not constitute a major alteration and they sometimes do. In addition, the act of passing the judgment on to the FAA actually weakens the authority of the A&P’s and IA’s in the field. But, most importantly to an owner, stuffing your logbooks full of unnecessary 337 forms can mislead a future buyer regarding the amount and depth of work that has been done to the aircraft in the past. Maintenance and other costs to maintain an asset in its normal state are considered repairs. Costs to replace an existing asset or asset portion with an improved or superior asset, usually at a cost materially in excess of the replace item, are considered capitalizable improvements.
Clearly, a repair station must use approved data for major repairs even when it elects to approve for return to service in accordance with 14 CFR Part 43 Appendix B (b). The frequency and detail of the progressive inspection shall provide for the complete inspection of the aircraft within each 12 calendar months and be consistent with the manufacturer’s recommendations, field service experience, and the kind of operation in which the aircraft is engaged. The progressive inspection schedule must ensure that the aircraft, at all times, will be airworthy and will conform to all applicable FAA aircraft specifications, type certificate data sheets, airworthiness directives, and other approved data. If the progressive inspection is discontinued, the owner or operator shall immediately notify the responsible Flight Standards office, in writing, of the discontinuance.
In the United States issuance of such certificates is under the purview of the Federal Aviation Administration (FAA). In the last article, we explored“mysterious modifications” that seem to regularly appear on aircraft and how to evaluate their legality.
This time, let’s dive head-first into the deep end with a discussion about major vs. minor alterations and how to make some sense of the federal aviation regulations (FARs) when it comes time to modify an aircraft. This is a complex and often controversial topic, so we will have to cover it in parts. That said, if you stick with me, you will either gain great appreciation for the world your IA lives in, or at the very least, give you a headache trying. The 100-hour limitation may be exceeded by not more than 10 hours while en route to reach a place where the inspection can be done. The excess time used to reach a place where the inspection can be done must be included in computing the next 100 hours of time in service.
What is major repair maintenance?
First, you must determine if the repair is a Major Repair. The FAA’s definition of a Major Repair is a repair: (1) That, if improperly done, might appreciably affect weight, balance, structural strength, performance, powerplant operation, flight characteristics, or other qualities affecting airworthiness; or.
First of all, we need to understand the difference between a repair and an alteration. So it is obvious to see that repairs and alterations make up the majority of what maintenance is performed on aircraft every day. Knowing the regulations and the differences between major and minor repairs and alterations also determines whether or not a record of the maintenance performed has to be done. However, repairs that are part of a larger project, such as replacing all of a home’s windows, do qualify as capital improvements. Renovations that are necessary to keep a home in good condition are not included if they do not add value to the asset.