Avionics News October 2015 - 10

In this monthly column, Ric Peri of the AEA's Washington, D.C., office, informs members of the latest regulatory updates.

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A EA V I C E P R ES I D E N T O F G OV E R N M E N T & I N D U ST RY A F FA I RS

BACK TO BASICS:

Alterations
D

espite nearly a decade of training, distributing
thousands of the Aircraft Electronics Association's
"Evaluating Alterations" training CDs, and
thousands of individuals participating in the AEA
online training courses, the industry is still plagued
by discussions of alterations. Maybe, like the basic
regulations, this is a routine topic that needs to be
discussed from time to time. Deciding major or minor
is the responsibility of the installer - a responsibility
that is challenging for legacy equipment and nearly
impossible for new integrated technologies. To help with
the process, and to review the regulations, the AEA will
conduct updated training on evaluating alterations at this
month's AEA East Regional Meeting in Tampa, Florida,
Oct. 12-13.
In my humble opinion, the regulations and guidance
for determining major and minor are quite clear; however,
industry still seems to have disagreements with the
regulators on the topic. The most recent disagreement is
a fairly common argument. Occasionally, an inspector
will argue that the alteration isn't listed in the aircraft
specifications; therefore, it must be major. Or the inspector
argues the modification is not on part of the type design;
therefore, it must be major. Both of these approaches are
simply wrong!
The Merriam-Webster dictionary defines an alteration
as "the act, process, or result of changing or altering
something."
If I was returning the aircraft to its current type design,
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avionics news

october

2015

it would be a repair. If I am changing the aircraft "from" its
type design, it is an alteration. The regulations, then, define an
alteration as major and minor (i.e. two levels of alteration).

Remember, the FAA regulations define
a minor alteration as follows: Minor
alteration means an alteration other
than a major alteration.
Part 1 of the regulations defines a major alteration as follows:
"Major alteration means an alteration not listed
in the aircraft, aircraft engine, or propeller
specifications - (1) That might appreciably affect
weight, balance, structural strength, performance,
powerplant operation, flight characteristics, or
other qualities affecting airworthiness; or (2) That
is not done according to accepted practices or
cannot be done by elementary operations."
Confusion stems from alterations that "might appreciably
affect weight, balance, structural strength, performance,
powerplant operation, flight characteristics, or other
qualities affecting airworthiness."
The first question is always, "What is appreciable?"
Since the regulations are silent on defining appreciable,
we turn again to the dictionary. Merriam-Webster defines
appreciable as "capable of being perceived or measured."

Table of Contents for the Digital Edition of Avionics News October 2015