Back to blog

FAA Hangar Use Policy: Aeronautical vs Non-Aeronautical

T

The Hangar Direct Team

hangardirect.com

complianceFAAairport operations

The FAA's hangar use policy sounds simple, hangars are for aeronautical things, until the specific requests land on your desk. Here is how the line actually gets drawn.


A tenant wants to store a classic car in the back of their hangar next to the airplane. Another wants to run a small business out of theirs. A third has an aircraft project that has not flown in years and may never fly again. Every airport manager at a federally obligated field has fielded some version of these questions, and the honest answer to all of them is the same: it depends, and the FAA has opinions.

The framework for those opinions is the FAA's hangar use policy. It was published in the Federal Register on June 15, 2016 and took effect on July 1, 2017, after years of confusion about what a hangar at a federally funded airport can be used for. It is one of those rules that sounds simple, hangars are for aeronautical things, until you get into the specific requests that land on your desk. Here is how the line actually gets drawn, and what you need to document to stay on the right side of it.

This is a general explainer, not legal advice. Your FAA Airports District Office and your airport attorney are the authorities on any specific situation.


Why the Policy Exists at All

If your airport has accepted Airport Improvement Program funding, you agreed to a set of grant assurances, and several of them come down to a promise that the airport, and the land under it, will be used for aviation. Federal money built or improved those hangars for aeronautical purposes, and the FAA wants them serving that purpose rather than quietly becoming storage units or strip-mall retail.

The hangar use policy is how the FAA translates that promise into rules about what can happen inside a specific building. It is not the FAA being fussy about your neighbor's boat. It is the mechanism that keeps federally funded aviation infrastructure available for aviation, which is the deal you signed when you took the grant.


What Counts as Aeronautical Use

The core permitted use is what you would expect: storing aircraft and the things that go with operating and maintaining them. A hangar housing a based aircraft, along with the equipment, tools, parts, and materials tied to that aircraft, is squarely aeronautical.

The 2016 policy also settled a long-running question in owners' favor. Building an aircraft counts as aeronautical use. Specifically, the non-commercial construction of an amateur-built or kit aircraft is an aeronautical activity, even though nothing is flying yet, as long as there is real progress toward an aircraft. That mattered to a lot of homebuilders who had spent years worried their projects put them out of compliance.

So aeronautical use is broader than "a finished airplane sits here." It includes the aircraft, the gear to keep it flying, and the work of building or maintaining it.


Where the Gray Area Lives

The policy also gives you some breathing room, which is where most of the real questions come from. Non-aeronautical items are allowed in a hangar, within limits.

A tenant can generally keep non-aeronautical belongings in their hangar as long as two conditions hold: the items do not interfere with the aeronautical use of the space, and the space is not needed for an aeronautical purpose. In plain terms, the car parked in the corner next to the airplane is usually fine. The car parked in a hangar with no airplane in it, while pilots sit on your waitlist, is not.

That is the balance the policy strikes. Incidental, non-interfering, secondary non-aeronautical use tends to be acceptable. The moment non-aeronautical use displaces aviation, either by crowding out the aircraft or by occupying space that aeronautical demand needs, you have crossed the line.


What Clearly Crosses the Line

Some uses are not gray at all. A hangar used entirely for non-aeronautical purposes, no aircraft, just storage or a business, is a problem unless the FAA has approved an interim non-aeronautical use. The policy gives sponsors two paths for that. Where there is genuinely no aeronautical demand, a sponsor can seek blanket approval to allow month-to-month non-aeronautical leases, so the space frees up the moment aviation demand returns. For a longer arrangement, a sponsor can get individual prior approval for an interim non-aeronautical lease, generally in the three-to-five-year range. Either way, the space has to be charged at non-aeronautical fair-market rent, not the aeronautical rate.

The aircraft that has not flown in years is a genuinely tricky case. A stalled project or a long restoration can still be aeronautical if there is real progress toward flight. A derelict airframe that is functionally just taking up a hangar, with a waitlist of flyable aircraft waiting for space, starts to look like non-aeronautical storage wearing an airplane costume. This is exactly the kind of call the FAA expects you to be able to justify.


The Part That Actually Protects You: Documentation

Here is what ties the hangar use policy back to your day-to-day work. When the FAA reviews compliance, whether in a scheduled inspection or in response to a complaint, the question is not just whether your hangars are used correctly. It is whether you can show it.

That means being able to produce, for your field, evidence that hangars are serving aeronautical purposes, a record of any approved non-aeronautical use and the terms attached to it, documentation of vacancy so you can show non-aeronautical use is not displacing aviation demand, and the ability to demonstrate you can reclaim space for aeronautical use when needed. If you granted an interim non-aeronautical use, the approval and the reasoning need to be in the file, not in someone's memory.

Airports that keep clean, current records of what each hangar holds and how each space is used can answer these questions in an afternoon. Airports that cannot are the ones that turn a routine review into a scramble, or worse, into a finding.


Keeping It Manageable

None of this requires policing your tenants' every belonging. It requires knowing what is in your hangars, tracking use against what each space is obligated for, and keeping the paperwork for any exception. Do those three things and the hangar use policy stops being a source of anxiety and becomes a set of rules you can administer.

Keeping that record current across a whole field is part of what we built the Hangar Direct platform to handle, so hangar assignments, aircraft, and compliance documentation live in one place you can export when a reviewer asks. But the underlying discipline is what matters most: know what is in your hangars, keep aviation first, and document the exceptions. That is the whole policy, in practice.

Get your hangar use records reviewer-ready

Want help getting your hangar use records into a form you could hand an FAA reviewer tomorrow? Book a walkthrough and we will show you what that looks like.

Book a walkthrough