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Moving Up — Managing Your Transition

Real-World Flying

To MEL or Not to MEL

by Stan Smith
n this issue, I want to discuss the what an MEL is and how it is used. operator for a specific aircraft (or

I benefits and requirements for


aircraft operators who are con-
sidering applying to the FAA for a
Then I’ll talk about the muddy
waters that cause confusion, fol-
lowed by the benefits of having your
group of like aircraft).
The MEL may permit the operator
to take off with various pieces of
Letter of Authorization (LOA) to own MEL. equipment inoperable because those
operate their aircraft using a pieces of equipment are not deemed
Minimum Equipment List (MEL). First, understand that the option critical to the proposed flight and do
of operating without an MEL is an not present a safety risk. While
The decision for Part 91 operators
alternative which is not available to pilots often think of the MEL as a
to operate with an MEL is one that
often raises more questions than Part 135/121 operators. They must “ticket” to depart, technically the
answers. As an advocate of operating fly with an approved MEL. While MEL permits the operator to “defer”
with an MEL, I expected to lay out many Part 91 operators see this maintenance until a specific future
my argument, do some research, relief as a benefit, I would suggest date or number of flight hours.
and present the definitive answer as that most operational procedures Typically the airplane may be flown
to why you should (or must) apply adopted or required by commercial for three, 10 or 120 days with an
for the MEL LOA. operators make sense from an oper- item deferred, or a given number of
ational, regulatory and safety aspect. flight hours.
But, like many things in the avia-
What is a Minimum Equipment List? The MEL lists many pieces of
tion regulatory world, the more you
equipment on the airplane. As such,
ask the more muddied the waters By definition the MEL is “a list of it is usually specific to that airplane’s
become: black and white turns into items, equipment and instruments configuration. The MEL is usually
grey and the simple answer becomes that may be inoperative on a specific developed using a Master Minimum
more complex. aircraft under stated conditions.” Equipment List (MMEL) normally
But, let me start with the basics of The LOA is issued to a specific provided by the aircraft manufacturer

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Moving Up — Managing Your Transition
and then tailored to the specific air- integrated or separate “O & M” sec- instruments or equipment installed
plane or utilized with the under- tion or guide that details the require- unless the following conditions are
standing (as specified in the LOA) ments of specified items. Normally met:” (from here I will edit and para-
that the applicable (installed) equip- “O” items are performed by pilots phrase the conditions pertinent to
ment is relevant. The exact format and “M” items by an A&P, but this is this discussion)
and equipment listed will be not always the case.
reviewed and sometimes dictated by 1. You have an approved MEL on
the Flight Standards District Office Finally you will make an entry board and the operation is conducted
(FSDO) issuing the LOA. into your “Discrepancy Log.” The within the limitations of the MEL, or;
discrepancy log could be a separate
How is the MEL used? 2. The flight is conducted in a
section of your maintenance log-
nonturbine-powered airplane for
book or (more typically of Part 91
There are several steps to actually which a Master Minimum Equipment
operators who don’t their entire
using the MEL. While at first this List (MMEL) has not been devel-
maintenance logbook on the air-
may seem cumbersome after you oped, or a nonturbine-powered
plane) included in your MEL binder.
practice the process a time or two, it small airplane (less than or equal to
The Discrepancy Log entry should
is really quite easy. The sequence 12,500 pounds) for which an MMEL
be formatted to drive you through
and logic makes sense if you realize has been developed, and;
much of the rest of the process to
that, in the FAA’s eyes, you are being include placarding the inoperative a. The equipment is not basic
permitted to operate an airplane item and determining the item cate- VFR-required equipment, and;
that otherwise should be grounded gory (how long the repairs can be
(the FAA considers an approved deferred). b. The equipment is not required
MEL to be an STC). for the phase of flight (i.e., night
The aircraft can now be flown IFR) according to the Kinds of
The first step is to identify the dis-
until the “repair due date” expires, Operation Equipment List (KOEL),
crepancy. If repair is not practical
but it should certainly be repaired as and;
you will look for the affected equip-
soon as reasonably possible. It is also
ment in the MEL. If the equipment is c. The equipment is not required
the responsibility of the operator/PIC
not listed, then you may not defer according to 91.205 (Instrument
to consider multiple discrepancies
the repair and you must have it fixed and Equipment Requirements,
and how they may combine to pres-
before flight. etc.),
ent an unsafe condition.
If the affected equipment is listed d. Required by an AD, and;
in the MEL then you must deter- The preflight process must include
mine if you meet the “required num- a review of any deferred discrepan- Any inoperative equipment falling
ber” of items required for dispatch. cies by the PIC prior to flight. This is under item 2 above must be
For example, on a CJ2 there are two of critical importance when multiple removed, the cockpit control plac-
Fuel Flow Indicating Systems but pilots fly the same airplane. A subse- arded, documented and a new
only one is required per my MEL. quent pilot could easily violate an weight and balance calculated, or
“O” procedure (like flying at night deactivated and placarded (by main-
Next you must review if there are without landing lights) that was not tenance if required), and the pilot
any “remarks or exceptions” listed a factor for the previous pilot or over (or certified maintenance person)
in the MEL under that item. These fly the repair due date. must determine if the condition
may be general remarks like “as does not present a hazard.
required by FAR” or in the case of
Why Are the Waters Muddy?
my inoperative Fuel Flow Indicator Nothing in item 2 provides relief
Earlier I mentioned the confusion for a turbine-powered airplane. If
“One (1) may be inoperative,” or the as to the need for an MEL. First I
remarks may fall into two more spe- you fly a turbine aircraft you must
must put this discussion into the have an MEL (to operate with inop-
cific categories, “O” or “M.” context of the light twin and turbine erative equipment). Nothing in Item
operators because that is where 2 provides relief for an airplane
An “O” designation means that a
things get complicated (at least for more than 12,500 pounds, turbine
specific “operational” procedure or
me). or otherwise.
constraint must be followed. For
example, landing lights may be inop- Many Part 91operators ask if they If you operate a conventional twin
erative during day operations but need an MEL. The easy answer is, under 12,500 pounds, then you may
not at night. yes. But easy isn’t good enough, so operate under the guidelines of item
let’s elaborate. 2 (be sure you read the actual FAR).
An “M” designation means that a
specific “Maintenance” procedure According to FAR 91.213 (a) But my question is what benefit
must be followed such as deactivat- “Except as provided in paragraph do you have over the pilot with the
ing a system or collaring a circuit (d) of this section, no person may same airplane who has an MEL? I
breaker. Your MEL may have an take off an aircraft with inoperative think little to none. If fact you take

46 • TWIN & TURBINE AUGUST 2004


Moving Up — Managing Your Transition
on much more responsibility with Minimums (DRVSM) takes affect in
much less guidance. January 2005. While it is not specif-
One thing that confuses many ically required (by regulation) that
operators is the inclusion of the operators flying in DRVSM airspace
Kinds of Operation Equipment List (above FL280) use an MEL, they
(KOEL) in the Airplane Flight must have an LOA to operate in
Manual (AFM). For Part 23 (Normal RVSM. Since much of the RVSM cer-
Category) airplanes, the inclusion of tification process deals with the air-
the KOEL in the AFM is an FAA plane’s altitude-keeping equipment Stan Smith is
requirement placed on the manufac- many FSDOs are wanting an MEL the director of
turer during the certification along with the RVSM LOA. flight operations
for Guardian Jet,
process. It is also a reference source What Are the Benefits? LLC. Smith has
in developing the MMEL. While more than 19
referring to the KOEL is one step in The benefits of an MEL are sever- years of flight
the process for the pilot using item 2 al. While the process to attain your experience en-compassing corpo-
above, the KOEL is not an MEL and MEL LOA may be cumbersome and rate, military and airline flying. An
can not be used as one. However, time consuming, once you have it, ATP, CFII, MEI, FE, and C-5
there is always the exception: Instructor Pilot in the USAF
your operation is much more adapt-
Reserve, he holds type ratings in the
If your AFM addresses certain able to equipment failures. This is CE-525, CE-550, EMB-120, SA-227
operations with equipment inopera- especially true when you are away and B-737. Smith directs the
tive, you will find that item listed in from home or a maintenance facility Guardian Standards Program,
the KOEL, and there should be a and trying to make schedule. It which provides Initial Operating
note which refers you to the proce- allows you the ability to rapidly dis- Experience (IOE) and Recurrent
patch with inoperative equipment. Standards Flights as part of a wide
dure required for dispatch. For range of consulting and oversight
example, the Citation CJ2 AFM per- Also the MEL spells out your solu- services to the light jet owner. To
mits me to dispatch with the anti- tion. You don’t have to research the learn more about the Guardian
skid inoperative. The KOEL refers legality of trying to fly this after- Standards Program and other ways
me to the Abnormal Section of the to enhance your ownership experi-
noon. You have planned ahead! ence, contact Smith at
AFM where there is a specific proce- (How many times do we talk about
dure that includes items like pro- (203) 458-2500 or
that in aviation?) www.GuardianJet.com.
hibiting no-flap takeoffs, turning off
the anti-skid switch, and increasing The answer and solution become
the runway required by a factor of “black and white”. Perhaps the
1.6. In this instance, I can dispatch greatest benefit is that in its effort to
with an inoperative anti-skid and no ensure your airplane is safe to fly, it
MEL. protects you as the PIC while
You can also expect to see more demonstrating your commitment to
emphasis on MELs as the Domestic a safe and legal operation.
T &T
Reduced Vertical Separation

AUGUST 2004 TWIN & TURBINE • 47