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• Diversion and alternate airport options;
• Additional crew workload caused by inoperative items;
• Crew fatigue; and
• Other human factor considerations.
5.2 Documentation of Deferred Items. A means of recording discrepancies and corrective actions must be in the aircraft and available to the PIC when operating under the provisions of § 91.213(a). Additionally, when an instrument or equipment item is discovered to be inoperative, an entry must be made in the aircraft maintenance records.
Since some operators do not carry aircraft logbooks in the aircraft, a discrepancy record or log is an acceptable alternative. When an operator uses this type of discrepancy log in lieu of the aircraft maintenance records, the operator must retain the log as a part of the aircraft’s records, per § 91.417(b). If the operator elects to use the aircraft maintenance record to log inoperative items, that portion of the record must be available to the pilot during all operations.
5.3 Placarding. Each inoperative item must be placarded (e.g., marked as “inoperative”) to inform and remind the flightcrew and maintenance personnel of the item’s condition. To the extent practical, placards will be securely affixed to a location adjacent to the control or indicator for the item affected. The placard is not required to be in a particular form, but will be legible and visible to the flightcrew; may not obscure other controls or indicators; and should not interfere with aircraft operation. Unless otherwise specified
(e.g., in an MEL proviso), placard wording and location will be determined by the aircraft operator.
5.4 Performing (M) and (O) Procedures. The presence of either (M) or (O) symbols (as explained below) in the “Remarks or Exceptions” column of the MEL indicate a specific (M) or (O) procedure is required to be accomplished. In addition to carrying the documents that comprise the MEL onboard the aircraft, the operator must have accessible any applicable technical manuals needed to accomplish (M) and (O) procedures when operating under the provisions of § 91.213(a).
5.4.1 (M) Procedures. T he (M) symbol indicates a specific maintenance procedure that must be accomplished prior to operation with the listed item inoperative. Normally, (M) procedures are accomplished by qualified maintenance personnel; however, other personnel may be qualified and authorized to perform certain functions. Procedures requiring specialized knowledge or skill, or requiring the use of tools or test equipment, should be accomplished by maintenance personnel. The satisfactory accomplishment of all (M) procedures, regardless of who performs them, is the responsibility of the aircraft operator. Appropriate procedures are required as a part of the aircraft operator’s MEL.
5.4.2 (O) Procedures. Th e (O) symbol indicates a specific operations procedure that must be accomplished prior to operation with the listed item inoperative. Normally, these procedures are accomplished by the flightcrew; however, other personnel may be qualified and authorized to perform certain functions. These procedures may be required for flight planning purposes, or they may require action by the flightcrew. Additionally,
5-3 MEL items affecting the aircraft W&B and cargo loading may require procedures for additional personnel, such as those involved with aircraft load control. The satisfactory accomplishment of all (O) procedures, regardless of who performs them, is the responsibility of the aircraft operator. Appropriate procedures are required as a part of the aircraft operator’s MEL.
5.5 Repair of Deferred Instruments or Equipment Items. The MEL is intended to permit operations with inoperative items for the minimum period of time necessary until repairs can be accomplished. It is important repairs be accomplished at the earliest opportunity in order to return the aircraft to its design level of safety and reliability.
5.5.1 Accomplishing Repair, Replacement, Removal, or Inspection of Deferred Items. The repair category intervals indicated by the letters A, B, C, and D in column 1 of the MMEL are not applicable to an MEL approved under the provisions of § 91.213(a), but operators must comply with any provisos defining a repair interval (e.g., flights, flight legs, cycles, hours, days, etc.). The operator must have any inoperative items, which are permitted to be inoperative, either repaired, replaced, removed, or inspected within the proviso-defined repair interval period or at the next required aircraft inspection, whichever comes first. If an operator chooses to defer maintenance on an inoperative item beyond a required aircraft inspection, certificated maintenance personnel must inspect the item for conformance with the requirements of the MEL and § 43.11(b).
• The person performing the required inspection must give the aircraft owner or lessee a signed and dated list of all discrepancies not repaired.
• The person performing the required inspection must ensure each inoperative item that remains inoperative is placarded appropriately.
Figure 5-1. PIC Decision Sequence Figure 5-1 illustrates the sequence of events involved in using an MEL to operate an aircraft with inoperative items. This chart is not required to be part of the operator's MEL.
Instrument or equipment item is discovered to be inoperative before takeoff.
Make entry in the aircraft maintenance records.
Does the MEL allow the item to be deferred? If NO, repair item before takeoff.
If YES, review all applicable MEL procedures, conditions, or limitations for that item.
Is the operator able to comply with and perform all applicable MEL procedures, If NO, repair item before takeoff.
conditions, or limitations?
If YES, conduct safety risk analysis.
Are the aircraft and crew capable of safely conducting the proposed operation under anticipated flight If NO, repair item before takeoff.
conditions with inoperative items?
If YES, perform applicable MEL procedures, placard item appropriately, and return aircraft to service.
• The PIC must ensure all applicable (M) and/or (O) procedures are performed and must comply with applicable conditions or limitations listed in the "Remarks or Exceptions" column of the MEL.
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6-1 CHAPTER 6. APPLICATION FOR MEL LETTER OF AUTHORIZATION (LOA)
6.1 Application for an MEL Approval Issued Under LOA D095. An operator applying for an MEL approval issued under LOA D095 must submit a signed, written request for issuance of LOA D095 to the responsible Flight Standards office having jurisdiction over the area in which the operator’s principal base of operations is located. An electronic signature, or a signed and scanned request transmitted via email is acceptable. The operator’s request must contain the information described in Figure 6-1, Sample LOA D095 Request Letter. Except for reapplication after cancellation, rescission, or revocation, the operator is not required to submit the procedures document to the FAA.
See Chapter 7 for detailed information on the procedures document content.
6.2 Application for an MEL Approval Issued Under LOA D195. An operator applying for an MEL approval issued under LOA D195 must submit a signed, written request for issuance of LOA D195, along with a copy of the operator-developed MEL (an electronic copy is preferred), to the responsible Flight Standards office having jurisdiction over the area in which the operator’s principal base of operations is located. An electronic signature, or a signed and scanned request transmitted via email is acceptable. The operator’s request must contain the information described in Figure 6-2, Sample LOA D195 Request Letter for an Operator-Developed MEL That Conforms to the Content Described in AC 91-67. Operators who conduct international operations and currently hold an LOA D095 should state so in their request letter. See Chapter 8 for detailed information on operator-developed MEL content.
6.3 R equest for Approval of an MEL That Does Not Conform to This AC. An operator may request approval of an operator-developed MEL that does not conform to the content described in this AC. If an operator-developed MEL does not conform to the content described in this AC, the operator should:
1. Submit a signed, written request to the responsible Flight Standards office for approval of an MEL that does not conform to this AC (see Figure 6-3, Sample MEL Approval Request Letter for an Operator-Developed MEL That Does Not Conform to the Content Described in AC 91-67);
2. E xplain in their request letter how their MEL meets the requirements of § 91.213(a) ;
3. Provide a copy of the operator-developed MEL (an electronic copy is preferred) with the request; and
4. Be advised that approval of the MEL may be delayed.
6.4 Oversight. The FAA may request to review a procedures document or operator-developed MEL during normal surveillance activity. If the FAA determines the MEL does not comply with the conditions and limitations of the operator’s MEL LOA, the FAA may rescind the LOA.
6-2 Figure 6-1. Sample LOA D095 Request Letter To: Responsible Flight Standards Office I request issuance of a Letter of Authorization (LOA) D095 under the provisions of Title 14 of the Code of Federal Regulations (14 CFR) part 91, § 91.213 to [complete legal name of operator] for the aircraft listed below.
I attest that I have a copy of the [state the make, model, series (M/M/S) Master Minimum Equipment List (MMEL), revision number (e.g., Gulfstream Aerospace GVII-G500/G600 MMEL, revision 3)] and have developed a procedures document for the listed aircraft. The procedures document conforms to the content described in Advisory Circular (AC) 91-67, and contains:
1. The name of the operator, aircraft serial and registration numbers (or “Fleet”), aircraft M/M/S, and the MMEL revision number;
2. Maintenance (M) and Operations (O) procedures that correspond with the (M) and (O) provisos listed in the MMEL;
3. A list of applicable MMEL items that contain the statement “as required by 14 CFR;”
4. Definitions, per current MMEL Policy Letter (PL)-25; and
5. A preamble, per current MMEL PL-36.
Principal base of operations address of the operator:
[Mailing address of the operator, if different from the principal address]:
Responsible Person’s full name, email address, and/or telephone number [part 91 only]:
Aircraft serial number:
Aircraft registration number:
Aircraft M/M/S:
[List information for additional aircraft, if applicable] Sincerely, [Signature] [Full name of the person legally authorized to make the request on behalf of the operator]
6-3 Figure 6-2. Sample LOA D195 Request Letter for an Operator-Developed MEL That Conforms to the Content Described in AC 91-67 To: Responsible Flight Standards Office I request issuance of a Letter of Authorization (LOA) D195 under the provisions of Title 14 of the Code of Federal Regulations (14 CFR) part 91, § 91.213 to [complete legal name of operator] for the aircraft listed below.
I attest that the attached minimum equipment list (MEL) conforms to the content described in Advisory Circular (AC) 91-67, is based on the [state the make, model, series (M/M/S) Master Minimum Equipment List (MMEL), revision number (e.g., Gulfstream Aerospace GVII-G500/G600 MMEL, revision 3)], is not less restrictive than the MMEL, and contains:
1. The name of the operator, aircraft serial and registration numbers (or “Fleet”), aircraft M/M/S, and the MMEL revision number on which the MEL is based;
2. A table of contents;
3. A log of revisions;
4. Definitions, per current MMEL Policy Letter (PL)-25;
5. A preamble, per current MMEL PL-36;
6. Control page(s);
7. Air Transport Association of America (ATA) [or Joint Aircraft System/Component (JASC)] coded system sections;
8. Maintenance (M) and Operations (O) procedures that correspond with the (M) and (O) provisos listed in the MMEL; and
9. Applicable MMEL items that contain the statement “as required by 14 CFR.”
Principal base of operations address of the operator:
[Mailing address of the operator, if different from the principal address]:
Responsible Person’s full name, email address, and/or telephone number [part 91 only]:
Aircraft serial number:
Aircraft registration number:
Aircraft M/M/S:
[List information for additional aircraft, if applicable] Sincerely, [Signature] [Full name of the person legally authorized to make the request on behalf of the operator]
6-4 Figure 6-3. Sample LOA D195 Request Letter for an Operator-Developed MEL That Does Not Conform to the Content Described in AC 91-67 To: Responsible Flight Standards Office I request review and approval of a Title 14 of the Code of Federal Regulations (14 CFR) part 91 minimum equipment list (MEL) that does not conform to the content described in Advisory Circular (AC) 91-67. Upon review and approval, I request issuance of Letter of Authorization (LOA) D195 under the provisions of part 91, § 91.213 to [complete legal name of operator] for the aircraft listed below.
[Explain how the MEL conforms to the requirements of § 91.213(a)] I have attached the proposed MEL for your review and approval.
Principal base of operations address of the operator:
[Mailing address of the operator, if different from the principal address] Responsible Person’s full name, email address, and/or telephone number [part 91 only]:
Aircraft serial number:
Aircraft registration number:
Aircraft make, model, and series (M/M/S):
[List information for additional aircraft, if applicable] Sincerely, [Signature] [Full name of the person legally authorized to make the request on behalf of the operator]
7-1 CHAPTER 7. CONTENT OF A PROCEDURES DOCUMENT
7.1 MEL Approval Under LOA D095. The MEL approved under LOA D095 consists of three documents: the LOA, the aircraft M/M/S-specific MMEL, and the procedures document.
Note: Operators may include MMEL PLs with a current GC designation, STC Relief Approval Letters, or any design change approval described in Chapter 10, as an attachment to the MMEL.
7.2 Procedures Document Content. Thi s chapter provides information to ensure the procedures document meets the requirements listed in LOA D095.
1. The procedures document must contain the name of the operator, aircraft serial and registration numbers (or “Fleet”), aircraft M/M/S, and the MMEL revision number on which the MEL is based.
2. The procedures document must include specific content based on the items installed on the operator’s aircraft. The procedures document may omit an MMEL item if the item or configuration is not installed or if the operator elects to not take relief. If the operator does not take relief for an installed item, the procedures document will clearly state that no MEL relief is provided for that item, and it must be operative for takeoff.
3. A procedures document should incorporate the phraseology used in the MMEL, wherever appropriate, to ensure clarity and standardization.
7.3 Procedures Document Required Sections. The procedures document must contain the following sections:
7.3.1 (M) and (O) Procedures. T he presence of either (M) or (O) symbols in the MMEL “Remarks or Exceptions” column indicates specific (M) or (O) procedures are required to be accomplished prior to operation when the item is inoperative. The procedures document must contain (M) and (O) procedures corresponding to the (M) and (O) provisos, if present, listed in the MMEL for all installed equipment for which the operator desires MEL relief. The procedures document’s (M) and (O) procedures:
1. Must meet the intent of the (M) and (O) provisos in the MMEL, if provisos are pr esent.
2. Must never be less restrictive than the (M) and (O) provisos in the MMEL.
3. May be either manufacturer’s (M) and (O) procedures or operator-developed (M) and (O) procedures.
Note: It is recommended, although not required, that operators use the Original Equipment Manufacturer’s (OEM) document (e.g., maintenance operational placarding procedures (MOPP), dispatch deviation guide (DDG), MEL procedures manual (MPM), etc.) as the required (M) and (O) procedures element.
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4. May be developed from the manufacturer’s (M) and (O) procedures or the guidance provided in the manufacturer’s AFM, RFM, or Aircraft Maintenance Manual (AMM), manufacturer’s recommendations, engineering specifications, or other appropriate sources. Operators are not required to copy the manufacturer’s recommended (M) and (O) procedures verbatim in their procedures document. When a manufacturer-recommended procedure exists, the operator may use it as published or develop equivalent procedures for their procedures document.
5. Must comply with all 14 CFR requirements and must not deviate from the AFM/RFM limitations, emergency procedures, or ADs, all of which take precedence over the MEL.
6. Must specify suitable conditions and limitations in the form of placards, maintenance procedures, crew operating procedures, and other restrictions, which must be accomplished by the operator to ensure an ALoS is maintained.
7. May reference a procedure in an FAA-approved or FAA-accepted manual. The manual reference must be preceded by a specific instruction defining the action required and direct the use of that manual to include specific enough information
(e.g., chapter, section, task, or paragraph references) for the user to find the proper procedure.
7.3.2 As Required by 14 CFR. A n operator must develop a list of all MMEL items containing the statement “as required by 14 CFR” or any similar statement, based on the items installed on the operator’s aircraft for which the operator desires MEL relief. The procedures document will: (1) list the specific 14 CFR part and section (e.g., 14 CFR part 91, § 91.209) (and the operator must ensure the applicable 14 CFR section is accessible on board the aircraft), or (2) specify the requirements and/or limitations to conduct the flight in accordance with the appropriate 14 CFR regulations. MMEL PL-25 contains a list of regulatory references according to the ATA chapter number. This list is not all-inclusive.
Note: The term “14 CFR” has replaced “F ederal aviation regulations (FAR)” as the current reference to Federal regulations pertaining to aviation. Many MMELs and MELs still contain the acronym “FAR” and should be updated to “14 CFR” as they are revised.
7.3.3 Definitions. M MEL and MEL definitions are contained in MMEL PL-25. Operators must include all applicable definitions in their procedures document. Not all of the MMEL definitions are required to be in a procedures document, as some are related to format issues, specific aircraft types, and certain types of operations. Certain portions of an MMEL definition may be edited or are not required, but the intent of the definition must be the same and must not be less restrictive than the definition in MMEL PL-25.
Alternatively, operators may insert the entire MMEL PL-25 in the procedures document.
Operators may download MMEL PLs from the “MMELs and AED Guidance Documents” section in DRS at https://drs.faa.gov.
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7.3.4 Preamble. The preamble contained in MMEL PL-36 is applicable to all § 91.213(a) MEL approvals under LOA D095. This preamble must be reproduced verbatim in the procedures document and include the aircraft type.
7.4 Procedures Document Optional Sections. An o perator may include the optional sections listed below. The operator may also include additional sections containing information relevant to their MEL.
7.4.1 Cover Page. The cover page format and information may be the same as the MMEL. The cover page content and format may vary due to operator preference.
7.4.2 Table of Contents. The table of contents is a list of all the sections/chapters in the procedures document by title and the corresponding page identification. The format may vary due to operator preference.
7.4.3 Log of Revisions. The log of revisions contains the revision identification (typically a number and/or letter) and the date of the revision. At the operator’s discretion, it may also contain a list of the revised pages, a block for the initials of the person posting the change, and additional enhancements for use by the operator. The format may vary due to operator preference.
7.4.4 Control Page (List of Effective Pages (LE P)). Control pages are used for tracking the status of the MEL and include a record of the revision status or the date of each page of the operator’s MEL. The format may vary due to operator preference.
7.4.5 Highlights of Change Page. This page list contains a summary of the changes made by the operator in each revision.
7.5 Example “As Required by 14 CFR” and (M) and (O) Procedures. F igures 7-1(a) through 7-3(b) are examples of MMEL and corresponding procedures document “as required by 14 CFR” and (M) and (O) procedures. These are examples only and are not intended to be used or depicted as actual MMEL or procedures document procedures.
Figure 7-1(a). Example MMEL “As Required by 14 CFR” Statement
7-4 Figure 7-1(b). Example Procedures Document “As Required by 14 CFR” Regulatory Reference or Requirement/Limitation 33-33-07: 14 CFR Reference: 14 CFR 91.205(c)(4) and 91.205(d)(1).
[And ensure the applicable 14 CFR section is accessible on board the aircraft.] Or 33-33-07: The landing light must be operative for night flight operations if the aircraft is being operated for hire.
Note: Illustrated in the examples above, the procedures document will: (1) list the specific 14 CFR part and section (and the operator must ensure the applicable 14 CFR section is accessible on board the aircraft), or (2) specify the requirements and/or limitations to conduct the flight in accordance with the appropriate 14 CFR regulations.
Figure 7-2(a). Example 1 MMEL Maintenance (M) and Operations (O) Symbols and Provisos F ig ure 7-2(b). Example 1 Procedures Document Maintenance (M) and Operations (O) Procedures 78-30-01:
Maintenance (M) Procedure Lock affected thrust reverser in the forward thrust position in accordance with AMM 78-30-12.
Operations (O) Procedure Refer to AFM Performance Section, Thrust Reverser inoperative for applicable takeoff and landing penalties.
Note: AMM 78-30-12 and the AFM in the above example are FAA-approved or FAA-accepted manuals.
Figure 7-3(a). Example 2 MMEL Maintenance (M) Symbol and Proviso
TABLE KEY
1. REPAIR CATEGORY AIRCRAFT:
2. NO. INSTALLED (insert aircraft make and model)
3. NO. REQUIRED FOR DISPATCH
4. REMARKS OR EXCEPTIONS
28. FUEL Sequence No. Item 2 4 Change Bar 28-21-25 XBP Crossfeed Valve 2 (M) One or more may be inoperative in dosed position provided:
a) All Booster Pumps are operative,
b) Affected XBP Crossfeed Valve is secured in closed position, and
c) Repairs are made within 3 consecutive calendar-days.
Figure 7-3(b). Example 2 Procedures Document Maintenance (M) Procedure 28-21-25:
Maintenance (M) Procedure CROSSFEED VALVE IN CLOSED POSITION:
1. Open the door 170AB.
2. Check that the inoperative XBP crossfeed valve (400QS/410QS) is in close position ("C").
NOTE: If not, set the valve to close ("C") using the lever.
3. Disconnect the electrical connector.
4. Close the door 170AB.
NOTE: Place inoperative placard near MDU.
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