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MEL / AML lists

Peter wrote:

but unless you do the aircraft becomes unairworthy if basically anything is u/s.

Is there a reference for this?

Sorry, I was being too brief… What I meant to say was that if anything becomes u/s then the aircraft becomes unairworthy until maintenance staff has determined that the defect doesn’t affect safe flight. But if there is a MEL, the pilot can determine that using the MEL.

The reference is in part-M.

M.A.403 Aircraft defects
(a) Any aircraft defect that hazards seriously the flight safety shall be rectified before further flight.
(b) Only the authorised certifying staff, according to points M.A.801(b)1, M.A.801(b)2, M.A.801(c), M.A.801(d) or Annex II (Part-145) can decide, using M.A.401 maintenance data, whether an aircraft defect hazards seriously the flight safety and therefore decide when and which rectification action shall be taken before further flight and which defect rectification can be deferred. However, this does not apply when the MEL is used by the pilot or by the authorised certifying staff.

Surprisingly, the exact wording implies that if pilot/owner maintenance is permitted on the aircraft, a pilot/owner can’t determine that it is safe to fly with a defect even if it is a defect that the pilot/owner may fix (e.g. a broken light bulb).

ESKC (Uppsala/Sundbro), Sweden

What I meant to say was that if anything becomes u/s then the aircraft becomes unairworthy until maintenance staff has determined that the defect doesn’t affect safe flight.

In practice that means if something packs up, the school operating it just gets an engineer to stick an INOP sticker on it. That’s how it was always done here in the UK. The stickers are not done by the school.

If you want to go the MEL route, is that possible on a simple SEP, and who approves the MEL? If it needs an STC, that is a Major mod under any regime, and probably not commercially viable (as an STC) for someone to do to make money out of it. And any change to the POH is a Major mod too.

Administrator
Shoreham EGKA, United Kingdom

Peter wrote:

If you want to go the MEL route, is that possible on a simple SEP, and who approves the MEL? If it needs an STC, that is a Major mod under any regime, and probably not commercially viable (as an STC) for someone to do to make money out of it. And any change to the POH is a Major mod too.

I assume you would only do it if a MMEL exists. It is effectively an STC under FAA rules. Not an STC which becomes a Mod.

It is more an issue for twins and turbines tbh.

Last Edited by JasonC at 05 May 21:47
EGTK Oxford

Peter wrote:

If you want to go the MEL route, is that possible on a simple SEP, and who approves the MEL?

Yes, it is possible. As I wrote above, the MEL does not need approval, but it has to be based on a MMEL. Here is the EASA MMEL for the Cessna 172R/S. local copy PDF

ESKC (Uppsala/Sundbro), Sweden

I was digging around the MEL topic recently and came across AC91-67 local copy.

That is for an N-reg, FWIW. It is incredibly complicated. It is no wonder that almost nobody seems to understand this, in light GA private flight context.

In practice, the POH prevails and if it says something is required (for day VFR, which is the minimum level) then you cannot fly without it (except on a ferry permit).

An implication that something is required is enough, too. Somebody asked on one US site if you can fly without an alternator and it was found that not only is that a required item (in the POH but not in an obvious place) but also the preflight checklist states that the voltage indicator must be in the green and obviously that will never be the case without an alternator…

Administrator
Shoreham EGKA, United Kingdom

The FAA can issue a D095 authorisation to use an MMEL as an MEL. But in Europe for aircraft required to have an MEL ie those turbine or jets, this is not regarded as acceptable. In that case you need a D195 specific MEL for your airframe.

To get that you must apply to a FSDO or IFO.

EGTK Oxford

Hello,

NCO.IDE.A.105 Minimum equipment for flight

A flight shall not be commenced when any of the aeroplane instruments, items of equipment or functions required for the intended flight are inoperative or missing, unless:
(a) the aeroplane is operated in accordance with the MEL, if established; or
(b) the aeroplane is subject to a permit to fly issued in accordance with the applicable airworthiness requirements.

I am not sure to really understand the point of this regulation item :
- Is “required for the intended for the flight” relative to “any of the aeroplane instruments, items of equipment or functions” or to “functions” only?
- I can’t see how a MEL if established could authorise to fly with something inoperative that is required for the intended flight? Any example?

Thank you
Thomas

LFPE

The above post got duplicated from another thread, and there was another good question:

Can one fly a plane under GA NCO on DAY VFR with a landing light reported inoperative on the plane logbook without a maintenance response or release and without a MEL established?

and I think the answer is along the lines of my post above i.e. it depends on whether the landing light is listed as standard equipment etc. If e.g. it appears only in the “night VFR” section then you don’t need it working for a day VFR flight.

Administrator
Shoreham EGKA, United Kingdom

I think I can add some interesting things to the discussion, but I would appreciate if someone knowledgeable could confirm my understanding of MELs in Part-NCO:

Legal basis:
- ED Decision 2014/005/R, its annex or, consolidated and simpler, the Easy Access Rules for Generic Master Minimum Equipment Lists CS-GEN-MMEL
- NCO.GEN.155 and AMC2 NCO.GEN.155

NCO.GEN.155 states that under Part-NCO you may establish an MEL and you shall notify it and all revisions of it to the authority (in Switzerland we can just send an e-mail with the PDF). This is to be read in contrast to NCC and CAT, where the wording is very similar but the word “approved” is replaced by “notified” in NCO. The CAA does not even have a legal basis to “approve” an MEL under NCO.
The ED Decision’s executive summary states the following:
“[…] Moreover, in accordance with the additional requirements for air operations for commercial purposes laid down in Annex IV to Article 8 of the Basic Regulation, an operator must establish a Minimum Equipment List (MEL) or equivalent document based on the Master Minimum Equipment List (MMEL).
This requirement for commercial operations has been transposed in the Implementing Rules for Air Operations, namely in Part ORO. The possibility of establishing an MEL on a voluntary basis for non-commercial operations of other-than-complex motor-powered aeroplanes has been also foreseen in the Implementing Rules for Air Operations in Part-NCO.
Following these considerations, the Agency introduces with this Decision the CS-GENERIC-MMEL for other-than-complex motor-powered aeroplanes with the aim of assisting the type certificate holder in developing the Master Minimum Equipment List (MMEL).
Clearly, this CS-GEN-MMEL is a template intended for type certificate holders to establish their MMEL. However, the second paragraph is referencing NCO.GEN.155 and following the third paragraph this use case in NCO was a consideration when developing this CS-GEN-MMEL as a template.

AMC2 NCO.GEN.155 states that the standard format for MELs should be used (according MMEL and IATA 100/2200 Specification numbering system for MEL items) or be clear and unambiguous. So, in many cases NCO aircraft do not have an MEL and the CS-GEN-MMEL might be overkill and I could simply write an A5 paper that states: “HB-ABC, Cessna 172, Serial #12345 / Landing light INOP → Flying at night prohibited” and then I would be legal to fly with an INOP landing light. Of course I couldn’t list anything that is required by type design (oil pressure gauge etc.) or the equipment rules in NCO.IDE.

Am I completely wrong?
…why can’t EASA just use a clear language, like: “This generic MMEL may be used by any NCO operator to develop their MEL or equivalent document.”

Edit: What TomTom says is also my interpretation. A landing light ist not equipment required for the intended flight, if I fly during daytime. So it may be INOP anyways.

Last Edited by ArcticChiller at 19 Apr 08:14

Peter wrote:

and I think the answer is along the lines of my post above i.e. it depends on whether the landing light is listed as standard equipment etc. If e.g. it appears only in the “night VFR” section then you don’t need it working for a day VFR flight.

Yes Peter, but if you consider Part M M.A.403 b) ; without a MEL you would need a certifying staff assessing whether the landing light defect rectification can be deferred or not.
But AFAIK a pilot is not supposed to know and use Part M regulation to go flying???

ArcticChiller wrote:

Edit: What TomTom says is also my interpretation. A landing light ist not equipment required for the intended flight, if I fly during daytime. So it may be INOP anyways.

Then if you can fly a plane with a landing light U/S without a MEL, what is point of having a MEL?

All this is really ambiguous for such not unusual situations…

LFPE
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