IATA Aircraft Lease Guidance

Guidance Material and Best Practices for Aircraft Leases
Unlike EASA, the FAA makes use of the wording “alterations” and their regulatory requirements are similar to
repairs. Alterations are classified as major or minor. A major alteration is an alteration not listed in the aircraft,
aircraft engine, or propeller specifications:
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That might appreciably affect weight, balance, structural strength, performance, power plant operation,
flight characteristics, or other qualities affecting airworthiness or
That is not done according to accepted practices or cannot be done by elementary operations
A minor alteration is an alteration other than a major alteration. The assessment is based on the scope and
complexity of the modification, and the experience and capability of the maintenance provider which in some
instances is also the operator. The responsibility for determining whether a modification is major or minor
rests with operators and holders of an inspection or maintenance authorization.
Major alterations must be accomplished in accordance with technical data approved by the FAA. A DER may
approve major alterations, if specifically authorized, however this DER-approved data may not be adequate to
cover every aspect of the alteration. Data such as manual supplements are not in the scope of the DER and
need additional approval. Providing the approval for the modification, the DER must submit a copy of the FAA
Form 8110-3 and the approved data to the owner/operator or repair station that requested the approval.
The FAA issues an STC for a major modification when it provides approval to the applicant to modify an
aircraft from its original design. This STC approves not only the modification, but also that modification’s
effect on the original design.
A third way to approve a major modification is by an Organization Designation Authorization (ODA). The ODA
must document these data approvals on FAA Form 8100-9, which is considered approved data for the
purpose of returning the altered product to service.
3. Modification File
There are separate requirements for TC-related modifications and modifications approved by means of an
STC. Consequently, two separate summary listings and compliance files are needed, one in which SBs and
EOs are listed and a second in which STCs are listed. In addition, a summary listing and compliance file
should be created for engines and APU. The compliance files are required to provide evidence of the
modifications performed, at which revision status these modifications were embodied and compliance data of
the components installed, which is the evidence to prove that the modification is performed in accordance
with approved data.
Setup
The modification file should contain the following sections:
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Modification status listing containing:
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o
Reference number and revision number
Modification description
98 4 th Edition 2017