FAA Moves Part 137 Inspection Requirements into Part 91; Few Practical Changes for Ag Operators
On November 10, the FAA published a Final Rule that reorganizes several aircraft maintenance and inspection regulations, including the inspection requirements for Part 137 operations over congested areas. The rule takes effect January 11, 2027. The FAA adopted the Part 91 and Part 137 changes as proposed in January 2024.
The bottom line for ag operators:
- 100-hour inspections for congested-area operations are unchanged. They have only moved from Part 137 to Part 91.
- Inspection requirements for large aircraft (over 12,500 lb) are unchanged.
- Single-engine turbine aircraft that are not large may now use a manufacturer inspection program instead of annual or 100-hour inspections. This is optional.
1. Congested-area inspections: same requirement, new location
The 100-hour/annual inspection requirement for operations over congested areas, formerly §137.53(c)(1), now appears in §91.409(b) alongside the other 100-hour requirements for aircraft operated for hire. A progressive inspection program remains an accepted alternative. §137.53(c) now contains only the existing jettison requirement, which is unchanged. Pilot requirements and congested-area plan requirements (§§137.51 and 137.53(b)) are also unchanged.
2. Large aircraft: no change
Ag airplanes over 12,500 lb, such as the AT-802 and Thrush 710, must still be inspected under an inspection program selected under §91.409(f), typically the manufacturer’s recommended program. That requirement is now found in §91.409(e)(1). The FAA removed the duplicate reference in §137.53(c)(1)(ii).
3. Single-engine turbine aircraft at 12,500 lb or less: a new option
Owners of these aircraft may now elect to use a manufacturer-recommended inspection program, or an owner-developed program approved by the FAA, instead of annual, 100-hour or progressive inspections. The choice is entirely voluntary, and existing inspection methods remain valid. Given typical ag utilization, most operators will likely find the annual inspection remains the simpler option.
Also in the rule: Part 145 repair stations no longer have to keep “current” revisions of every manual listed in §145.109(d). This may modestly lower costs for independent engine shops that serve the ag fleet. The rule does not address OEM manual pricing, which NAAA continues to monitor.