Legal Interpretations

Legal interpretations of the aviation statutes and Title 14 of the Code of Federal Regulations are issued by the Office of the Chief Counsel in FAA headquarters and by the various regional counsels’ offices in the nine FAA regions. The interpretations are typically issued in response to inquiries from the aviation community or from one of the FAA’s own field offices, such as a Flight Standards District Office (FSDO), Aircraft Certification Office (ACO), and Manufacturing Inspection District Office (MIDO) or through an FAA regional operating division. Interpretations are generally made available on the FAA chief counsel’s website.

Recently Issued Interpretations of Interest to ARSA Members (Updated 5/6/2016)

Legal Interpretation: Interpretation of 14 C.F.R. § 91.409(b)
Issued 05/04/2016
Regulation/Order #: 14 C.F.R. § 91.409(b)

This legal interpretation responds to a question asking whether an aircraft would be considered “club owned” and whether such aircraft would be subject to the 100-hour inspection requirement in 14 C.P.R.§ 91.409(b).

Legal Interpretation: Clarification regarding connecting aircraft maintenance records required by 14 CFR 91.417(a)(2), documenting compliance with airworthiness directives under 14 CFR 91.417(a)(2)(v), removing unauthorized comments in an aircraft’s maintenance records under 14 CFR part 43, and documenting completion of 100-hour inspection required by 14 CFR 91.409(b)
Issued 05/04/2016
Regulation/Order #: 14 C.F.R. § 91.409(b)

This legal interpretation responds to four questions regarding: (1) whether you may connect an error in an aircraft’s records involving incorrect total time or time since overhaul by marking out the error and including a single entry with connected times; (2) whether an individual may rely on a “blanket AD compliance” statement to show compliance with all applicable airworthiness directives; (3) an appropriate means to remove comments in an aircraft’s records made by an individual who is not authorized to make maintenance record entries; and (4) whether “100 hr” inspection sign offs may be made only in the aircraft logbook or must also be made in the engine and propeller logbooks.

Legal Interpretation: Tasks That Must be Recorded in an Aircraft’s Maintenance Record, and Names That Must Appear in those Maintenance Records Under 14 C.F.R. § 43.9(a)
Issued 05/04/2016
Regulation/Order #: 14 C.F.R. § 91.417(a)(2), 14 CFR 91.417(a)(2)(v), 14 CFR part 43, and 14 CFR 91.409(b).

This legal interpretation responds to a question asking whether request for an interpretation of 14 C.F.R. § 43.9(a), to clarify the circumstances under which a person must make an entry in the maintenance record of an aircraft, and under what circumstances must a person’s name be included in the record when the task he or she performed is minor or in the nature of assisting the person who approves the aircraft for return to service.