4-2 operators to work with their responsible Flight Standards office to obtain relief for unevaluated STC items as described in this chapter. Operators are no longer required to petition the STC or design holder for relief.
4.5 Adding Relief for Items Installed After Type Certification. STCs issued without concurrent AED evaluation may be granted relief by request from the operator to the FAA. Additional information may be found in Order 8900.1, Volume 4, Chapter 4, Section 3, MEL Re quirements for 14 CFR Parts 91K, 121, 125, 125 LODA, and 135 Operations. STCs already listed by STC number in the applicable aircraft MMEL or in an AED approval letter may be added to the operator’s MEL through the normal revision process without further evaluation. However, a principal inspector (PI) may coordinate with the AED during this process, as needed. Using the normal revision process found in Chapter 9, MEL Revi sions, of this AC, an operator may add relief for items to its MEL through any of the following solutions:
4.5.1 MMEL Specifically Lists the Relief. Where the MMEL lists the specific STC number
(e.g., ST00733SE) or identifies the specific design change nomenclature (other than STCs), an operator may add the relief to its MEL.
4.5.2 Design Change Approval Letters. Upon evaluation and approval of a design change, the AED will submit an approval letter directly to the FAA’s DRS. Operators may access these approval letters at https://drs.faa.gov/ under “MELs and AED Guidance Documents,” “STC Relief Approval Letters.” The approval letter will contain the allowed relief, including conditions and provisos, along with remarks or exceptions. Approval letters will be dated and have revision numbers. Operators may amend their MEL(s) with the relief for the STC(s) in accordance with the AED approval letter. Paper copies of the AED approval letter are also acceptable in lieu of the DRS database.
4.5.3 MEL Relief T hrough MMEL PL With GC Designation. Operators may add relief into their MEL(s) for an STC through an MMEL PL with a current GC designation. However, upon the AED evaluation of the item (if an evaluation is conducted), operators may have to amend or remove previously approved relief in their MEL(s). See Chapter 9 for additional information on GC.
4.5.4 Responsible Flig ht Standards Office’s Relief Evaluation. If the proposed relief is not covered by one of the three solutions immediately above and the MEL item is listed generically in the MMEL, the item may be evaluated by the responsible Flight Standards office. Additional information may be found in Order 8900.1, Volume 4, Chapter 4, Section 3. To add MEL relief using this method, the following points should be considered:
1. T he basic item needs to be found in the applicable aircraft’s MMEL (e.g., FMS, autopilot, passenger seat). If not, the AED must complete the evaluation.
2. The operator’s Safety Management System (SMS) (as applicable) reveals that the proposed relief does not present a hazard to the operator’s use of the relief.
4-3
3. The PIs conducting the evaluation may consult with the STC holder, AED, Original Equipment Manufacturer (OEM), and other stakeholders during their evaluation of the operator’s proposal.
4. If the item was previously evaluated by the AED and relief was not granted, the item is not eligible for evaluation by the responsible Flight Standards office.
5. If the PI believes a hazard exists with the operator’s proposal, the item is not eligible for relief.
4.6 Items Needed for Evaluation of Design Changes. Each proposed operator MEL relief item should have accompanying supporting justification before it will be considered. The information needed by the FAA allows a thorough evaluation of the risk associated with operating the aircraft with the item inoperative. The FAA may reject an item proposal if the justification information is inadequate. At a minimum, the following information should accompany all item proposals:
1. The title and number of the proposed MMEL item;
2. A brief description of the system and its intended functions;
3. A summary of the proposed MMEL relief;
4. A brief description of intent;
5. The effect of dispatching a flight with this inoperative item;
6. The operating rule(s) that requires the item to be operative, as applicable;
7. The transfer of function when the item is inoperative;
8. The next most critical failure;
9. The effect on increased flightcrew workloads (including risk mitigations);
10. The certification requirements for the item;
11. Any conflicts with Airplane Flight Manual (AFM) limitations, procedures, or Airworthiness Directives (AD);
12. If the item affects or is required to accomplish an emergency procedure;
13. The effect on aircraft capability in an emergency;
14. Maintenance (M) and Operations (O) procedures required for the proposed dispatch condition;
15. Any information that adds support to the proposal (e.g., wiring diagrams, schematic drawings, or STC documents); and
16. Any other information requested by the FAA before or during the evaluation.
5-1 CHAPTER 5. MEL MANAGEMENT PROGRAM REQUIREMENTS
5.1 General. Each operator will develop and maintain a comprehensive program for managing the repair of items listed in the FAA-approved MEL. An operator’s MEL management program is required by Operations Specification (OpSpec)/Management Specification (MSpec) D095, Minimum Equipment List (MEL) Authorization, issued by the FAA to authorize an operator to use an MEL.
5.2 MEL Management Program. The MEL management program should include at least the following:
1. A method for tracking the date and, when required, the time an item was deferred and subsequently repaired. This should include a supervisory review of:
a. The number of deferred items per aircraft; and
b. Each deferred item to determine:
• The reason for any delay in repair,
• The length of the delay, and
• The estimated date the item will be repaired.
2. A plan for managing the materials, personnel, facilities, and aircraft to ensure timely corrective action.
3. Processes to ensure parts availability.
4. A description of specific duties and responsibilities, by job title, of the personnel who manage the MEL program.
5. Procedures for controlling an extension to specified repair intervals as permitted by the operator’s OpSpec/MSpec to include the limit of the extension and the procedures for authorizing an extension.
5.3 Continuing Authorization—Single Extension. For operations conducted under part 91K, 121, 125, or 135, OpSpec/MSpec D095 authorizes an operator to use a continuing authorization-single extension to approve a single, one-time extension to the repair interval for repair category B and C items only, as specified in the FAA-approved MEL.
5.3.1 OpSpec/MSpec D095 requires each operator’s MEL management program to contain procedures for controlling extensions to item repair intervals. Procedures for the method by which the operator approves a continuing authorization-single extension will be included.
5.3.2 Under OpSpec/MSpec D095, an operator is not authorized to use a continuing authorization-single extension for repair category A or D items.
5.3.3 Under OpSpec/MSpec D095, the operator should notify its responsible Flight Standards office within 24 hours of approving a continuing authorization-single extension.
5-2 Note: The FAA may deny the use of the continuing authorization-single extension privilege if abuse is evident.
5.4 Additional Extensions. After the operator has exercised its one-time extension of a repair category B and C item, approval for additional extensions can only be obtained by submitting a request to the responsible Flight Standards office. An extension to a repair interval may not exceed the time of the original repair interval. For example, a repair category B item with a repair interval of 3 consecutive calendar days may only be extended up to an additional three consecutive calendar days. In rare cases, some additional extensions may be authorized by coordination with Safety Standards divisions.
Operators may request extensions to category A and D items by contacting their responsible Flight Standards office.
6-1 CHAPTER 6. CONDUCTING OPERATIONS UTILIZING MEL RELIEF
6.1 General. Parts 91K, 121, 125, and 135 operators’ flightcrew, operational control, and maintenance personnel need to clearly understand the regulatory requirements associated with conducting operations in accordance with their FAA-approved MEL.
6.1.1 A pplicability . MEL item relief may be applied to an MEL item newly identified as inoperative up until takeoff. Takeoff is defined as the act of beginning a flight in which an aircraft is accelerated from a state of rest to that of flight. For the purposes of MEL relief, this means the point at which power is applied to initiate the takeoff from the runway or takeoff surface.
6.1.2 O perator Regulatory Responsibility . Operators must comply with all applicable FAA requirements.
6.1.3 Ite m Failures During Push -Back, Taxi, After Gate or Ramp Departure, Prior to Takeoff.
The MEL does not allow a flight to continue “as dispatched,” as any discrepancy discovered before takeoff must be addressed by repair or deferral. The MEL allows a discrepancy to be addressed by deferral for a specified period. The aircraft should be redispatched with the item of equipment inoperative, and a revised dispatch release, if required, issued showing the deferred item. An operator’s MEL management program and general manual should include the policies and procedures required to ensure an aircraft does not take off with inoperative items until the MEL deferral process has been completed. If the MEL procedures for a specific item require a mechanic’s inspection, takeoff would be prohibited until the required inspection is completed.
6.1.4 Ite m Failures A fter Takeoff. MEL relief does not apply for item failures occurring after takeoff. After takeoff, flightcrews should handle item failures in accordance with the Airplane Flight Manual (AFM)/Rotorcraft Flight Manual (RFM) and the operator’s approved procedures and checklists. However, any item failure that occurs after takeoff must be addressed before the subsequent takeoff in accordance with § 91.213.
6.2 Operational Requirements.
6.2.1 Airworthiness. Section 91.7 prohibits operation of an aircraft that is not airworthy.
Sections 121.605 and 125.355 prohibit any person from dispatching or releasing an aircraft unless it is airworthy, and § 135.143 prohibits operating an aircraft unless the aircraft and required instruments and equipment have been approved and are in an operable condition. In all cases, the operator, pilot in command (PIC), aircraft dispatcher (part 121 domestic and flag), or person authorized to exercise operational control by the operator (part 121 supplemental) are all responsible for ensuring the aircraft is dispatched/released and operated in an airworthy condition.
6.2.2 F ulfillment of Regulatory Responsibility . Each operator should provide a process for persons authorized to exercise operational control (PIC, dispatcher, flight follower, Director of Operations (DO), Operations Control Specialist, or person authorized by the DO, as applicable) to fulfill their regulatory responsibility to ensure an aircraft is not dispatched or released unless it is airworthy.
6-2
6.2.3 Operations With Inoperative Instruments. Under the provisions of §§ 91.1115, 121.628,
125.201, and 135.179, operations with inoperative instruments or equipment may be conducted with an FAA-approved MEL and MEL management program. This may be accomplished through a maintenance control organization that is responsible for verifying airworthiness and providing MEL information to the person authorized to exercise operational control before the aircraft is entered into service.
6.3 Dispatch or Flight Release Requirements. In part 121 operations, both a dispatch and a flight release specify the conditions for origination or continuation of a particular flight.
For this reason, the MEL information should be included on the dispatch or flight release, and the flight planned to account for any limitations, such as system, flight restrictions, or performance limitations imposed by the deferral stipulations of the MEL. Examples of operational limitations include, but are not limited to:
1. Altitude restrictions.
2. Cabin pressure limitations.
3. Temperature limitations.
4. Performance capabilities.
5. Weight restrictions.
6. Fuel penalties and limitations.
7. Navigational limitations.
8. Communication limitations.
9. Weather restrictions (including ice and rain limitations).
10. Cargo loading (including locks and nets) or cargo heating limitations.
11. Flight control limitations.
12. Landing gear restrictions, including braking and steering.
13. Auto flight capabilities.
14. Electrical power limitations.
15. Extended Operations (ETOPS) limitations (when applicable).
16. Lighting restrictions.
17. Oxygen system limitations.
18. Information system limitations.
19. Auxiliary power limitations.
6.3.1 Item Failures that Occur After the Issuance of a Dispatch or Flight Release–Parts 91K, 121, 125, and 135. When a dispatch or flight release is used, operators should have policies and procedures in place for the dispatcher, person authorized to exercise operational control, and the PIC to amend the dispatch or flight release when an MEL item is deferred after the dispatch or flight release has been issued. Those procedures
6-3 should include procedures to update the flight plan to include limitations that are imposed by an MEL.
6.3.2 Ite m Failures T hat Occur After an Aircraft Departs the Gate or Ramp Area, During Push-Back, Taxi, or Prior to Takeoff. In accordance with § 91.213, each operator’s MEL management program must include procedures for the PIC to communicate with the person authorized to exercise operational control and the maintenance organization to determine which of the following actions is required:
6.3.2.1 R eturn for Repairs. If an inoperative item is not included in the MEL or the inoperative item could affect the safety of flight due to circumstances such as weather, performance, weight and balance (W&B), or fuel limitations, the aircraft must return to the gate or ramp area for repairs, in accordance with § 91.213.
6.3.2.2 Return to Accomplish Maintenance (M) and Operations (O) Procedures.
PICs, dispatchers, or persons authorized to exercise operational control may determine that an inoperative item may be deferred and the appropriate (M) or (O) procedures accomplished in accordance with the operator’s approved MEL and MEL management program.
6.3.2.3 Flightcrew Accomplishment of Certain MEL Procedures. An operator may develop, and the FAA may approve, procedures that permit flightcrew members to accomplish MEL deferrals in coordination with the operator’s dispatch and maintenance organization, without returning to the gate or ramp area prior to takeoff. These procedures will be part of the operator’s MEL management program to ensure all applicable procedures are accomplished by appropriately qualified personnel and that all conditions and limitations associated with an MEL item are satisfied.
1. Coordination between flightcrew and the maintenance organization may not involve directed troubleshooting or other forms of system fault diagnosis beyond what is specifically approved in the operator’s MEL management program procedures.
2. Only qualified maintenance personnel may perform troubleshooting or fault diagnosis necessary to determine suitable MEL relief, unless otherwise approved.
3. Any time an MEL item results in operational limitations such as those affecting aircraft performance and altitude capabilities or weight or fuel restrictions, the dispatcher or person authorized to exercise operational control will recalculate a new flight plan and issue a new or amended dispatch or flight release.
6.4 Multiple Inoperative Items or System Components. Because an inoperative component in one system can affect the operation, or limit the inoperability of a component in another system, operator’s personnel should be aware of the impact that
6-4 multiple item failures and deferrals can have on the safety of flight. This includes the consideration of possible additional item failures while an aircraft is en route.
6.5 Availability of the MEL to Operator Personnel. Parts 91K, 121, 125, and 135 require that flightcrews have direct access to the MEL at all times prior to takeoff. Indirect methods of providing access such as telephone, radio, or data link are not acceptable. The method of providing access is part of the operator’s MEL management program.
7-1 CHAPTER 7. MEL CREATION AND FORMATTING
7.1 General. When constructing an MEL, each operator should consider their particular aircraft configurations and operational procedures. An MEL is based on the MMEL for the aircraft and should include the characteristics of an MMEL. In addition to the required MEL format items, an operator’s MEL should include specific content based on the items installed on the operator’s aircraft. An operator’s MEL should incorporate the phraseology used in the MMEL, wherever appropriate, to ensure clarity and standardization.
7.2 MEL Format Outline. Operators may copy the MMEL format outline directly into their MEL. An operator may also customize their MEL format provided the format does not make the MEL in any way less restrictive than the MMEL. The MMEL format outline contains eight sections. An MEL should always include six of those sections. The operator may include additional information sections in addition to the ones listed in Chapter 2, Minimum Equipment List (MEL)—General. The following information describes the operator’s recommended MEL format:
7.2.1 V ertical Bar (Change Bar) . All change bars applicable to the previous revision of the MMEL or MEL should be removed prior to release of the next revision in a manner consistent with the operators’ manual system revision process.
7.2.2 Su b system Titles. Identify subsystem titles in column one with 1), 2), etc. For example (bullets are used in this example, but are not required):
• 28-xx Fuel Quantity Indicating System o 1) Main Tank o 2) Center Tank
7.2.3 Items That Must be Operative for All Conditions. Generally, an MEL should not include any items that must be operative for all conditions. Operators may include certain items listed as required to be operative to ensure they have not inadvertently been missed, or for fleets with varied configurations, etc.
7.2.4 W hen a n MMEL Relief Item is Deleted or Moved. When an MMEL relief item is deleted or moved, the item name and sequence number will be retained in the MMEL, with an appropriate notation in the “Remarks or Exceptions” column. The MMEL revision number of the deleted or moved relief item is included. For example:
• Relief is deleted entirely: “Deleted, Revision X.”
• Relief is combined with relief at another location: “Relief combined with ATA 31-XX, [Relief Title], Revision X.”
7-2
• Relief is moved to another Air Transport Association of America (ATA) chapter:
“Relief moved to ATA 31-XX, Revision X.”
• Relief is moved to another FAA-approved document: “Relief moved to [Document Name], Revision X.”
Note: Operators may follow the MMEL format using the MEL revision number as appropriate, may simply delete the applicable item, may list the item as required operative, or may use another method that is acceptable to the FAA.
7.2.5 N umber Installed/Number Required for Dispatch . In the “Number Installed” or “Number Required for Dispatch” column, use a number whenever possible; otherwise, use a “-” with proper qualification.
7.2.6 Single Proviso Formatting. W hen only one proviso condition exists, it should be arranged into the statement of relief.
7.2.7 Control or Switch Position. Where a control or switch position is specified, indicated by label, or special emphasis is required, use all caps instead of underlining (e.g., “ON-OFF” or “OPEN-CLOSED.”) Use of the word “position” in reference to “ON-OFF” or “OPEN-CLOSED” is often redundant and need not be included. Alternative means of emphasis may be used, consistent with the aircraft manuals and operator manual system, if approved by the Principal Operations Inspector (POI).
7.2.8 Reference to Another Item Listed in the MEL. Where a proviso refers to another item listed in the MEL, typically to require that item be operative, the item will always be referred to using the exact same title as listed. The relief item number will generally not be used to reference an item.
7.2.9 Limiting Altitudes. Wh enever possible, all limiting altitudes stated should include the words “or below” (e.g., “10,000 feet MSL or below,” “FL 310 or below”).
7.2.10 Specific Word Usage. The word “operative” should be used instead of “operable.” Delete the word “the” wherever possible.
7.2.11 Provisos. Use letter and parenthesis (e.g., a), b), etc.) to identify proviso conditions.
Delete the word “or” when it is located between proviso conditions. Each set of needed proviso conditions should be repeated as required to eliminate the use of “or.” Use a comma after all proviso conditions and prior to the last one use “, and.” Use a period after last proviso condition. For example:
a) F irst c ondition,
b) Second condition, and
c) Last condition.
7.2.12 N ote(s) . Each note applies only to the relief proviso it immediately follows and is located in the “Remarks or Exceptions” column, using all caps for the word “NOTE.” Note(s)
7-3 should be repeated, as necessary, following each applicable proviso. If there is only one note, do not number it. If there is more than one note, number each (e.g., “NOTE 1:”, “NOTE 2:”).
7.3 Prohibited Items. An MEL will not include items of the aircraft required by operating regulations (e.g., wings, flaps, rudder, etc.), nor will it include instruments and equipment required for specific operations under 14 CFR (refer to § 91.1115).
7.4 MEL Restrictions. An operator’s MEL may not be less restrictive in any way (more restrictive is acceptable) than the following:
• The MMEL from which it was developed;
• Title 14 CFR;
• The operator’s Operations Specification (OpSpec)/Management Specification (MSpec) D095, Minimum Equipment List (MEL) Authorization;
• The Airplane Flight Manual (AFM)/Rotorcraft Flight Manual (RFM) limitations and emergency procedures;
• The Supplemental Type Certificate (STC)/instructions for continued airworthiness (ICA) (as applicable); or
• Applicable Airworthiness Directives (AD).
Note: Occasionally, an AD may apply to an item that may be authorized to be inoperative under the MEL. In those cases, the operator must fully comply with the terms of the AD or an FAA-approved alternative method of compliance (AMOC) with the AD. Refer to 14 CFR part 39, §§ 39.3 and 39.19. When provisions of an AD allow operation of the aircraft on the condition that certain installed items be used or be operable, those affected items must be operable, even if the MEL provides for deferral of repair.
7.5 F leet MELs. An operator may develop a fleet MEL for multiple aircraft of the same make and model (M/M). When a fleet MEL is used, aircraft of the same M/M may have differing numbers of specific items installed. PIs may approve an operator’s use of a fleet MEL to reflect all of the items that are applicable to a specific aircraft fleet type. This is allowable provided the MMEL applies to all of the make, model, and series (M/M/S) aircraft contained in the fleet. For example, the MMEL applies to all model B747-100/200/300 aircraft.
7.5.1 I dentify Each Model and Configuration Difference. A fleet MEL should identify each aircraft model and configuration difference, when appropriate. The operator does not need to list aircraft identification numbers.
7.5.2 Modifications Within a Fleet. The aircraft manufacturer determines the configuration of the aircraft, the items installed, and the official parts listed during the initial aircraft type certification process conducted at the time of manufacture. Any subsequent installation or removal of items must be accomplished through the use of an STC or other
7-4 FAA-acceptable methods, techniques, and practices, including the use of FAA-approved technical data if the installation or item removal is a major alteration. Operators with an approved fleet MEL may continue to operate under the provisions of the current fleet MEL with new items installed in one or more fleet aircraft. However, operators may not defer repair of the new items until an appropriate revision to the fleet MEL has been approved.
7.5.3 OpSpecs/MSpecs and Manuals. The operator’s OpSpec/MSpec D095 and appropriate company manuals, such as the maintenance manual, should list aircraft M/M/S for each fleet MEL approval.