A Change in FAA Interpretation of FARs Results in New Inspection and Maintenance Requirements for Large Ag Aircraft; NAAA Offering Webinar March 26th to Clarify New Requirements
A new FAA interpretation has resulted in the AT-802/802A being classified as a “large aircraft” with respect to §FAR 91.409 and has resulted in Air Tractor being required to revise their AT-802/802A Owner’s Manual to remove language pertaining to Annual Inspections. The issue stems from a long-held assumption that the annual inspection requirement in §91.409(a) applied to the AT-802/AT-802A just as it did for all other ag aircraft. This assumption was held for over 30 years by aircraft manufacturers, operators, mechanics, and FAA inspectors. However, the FAA has now determined that §FAR 1.1 classifies AT-802 and AT-802A aircraft as Large Aircraft, making the assumption incorrect.
Large aircraft as defined by §FAR 1.1 are any aircraft with a maximum certificated takeoff weight of more than 12,500 lb. With a maximum takeoff weight of 16,000 lb both the AT-802 and AT-802A are classified as large aircraft. As such, §91.409(e), §91.409(f)(3) and §91.409(f)(4) become applicable. These sections require that an AT-802 or AT-802A operator either follow Air Tractor’s inspection program as detailed in the AT-802/AT-802A Owner’s Manual or create their own inspection program which must be approved by the FAA.
This change in interpretation of the regulations required Air Tractor to change the inspection section of the AT-802/AT-802A Owner’s Manual. The 12/12/24 version of the manual has been updated to reflect this, as detailed in Air Tractor’s Service Information Letter No. 802-0118. Under the new FAA interpretation, the older version of the Owner’s Manual would have required the hour-based time inspections to be performed at the specified intervals instead of as part of an annual inspection; this is because they are part of the manufacturer’s recommended inspection program.
In recognition that AT-802 / AT-802A’s have been successfully maintained with an annual inspection program since 1993, Air Tractor reworded the Owner’s Manual to “suggest performing all of the inspections at the specified intervals” and that Air Tractor “recommends that all of the 12-month, 100-hour, 200-hour and 300-hour inspections be performed at least once every 12 months.” The “recommended” action of performing the inspections at least once every 12 months fulfills the requirements of §91.409(e), §91.409(f)(3).
This new interpretation of FAA’s rules is not limited to the AT-802/802A – it affects all ag aircraft with a maximum certificated takeoff weight over 12,500 lb. There is, however, no change to inspection and maintenance requirements for ag aircraft at or under 12,500 lb maximum certificated takeoff weight and those aircraft can be maintained using the current Annual Inspection programs in place. Nor does this change add any requirements regarding engine or propeller TBO.
The FAA has verbally stated that there will a phase-in period to allow for proper education and give operators and mechanics time to get aircraft logbooks into accordance with the latest guidelines. The FAA Flight Standards policy office has not made any comments or threats that any aircraft will be grounded as a result of their new interpretation. Air Tractor has been informed that the FAA has drafted an Information for Operators (InFO) letter that will be sent out to clarify their intent. This letter has not yet been published or shared with anyone in industry.
To help AT-802/802A operators understand these changes, NAAA will be hosting a webinar on March 26, 2025, at 3:00 PM CDT. Panelists will include representatives from Air Tractor and the FAA who will discuss the new interpretation, the updates to the manual, and what it all means for inspections moving forward. Click here to register for the webinar.
