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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8-1 CHAPTER 8. CONTENT OF AN OPERATOR-DEVELOPED MEL
8.1 MEL Approval Under LOA D195. The MEL approved under LOA D195 consists of two documents: the LOA and the operator-developed MEL.
8.2 MEL Content. This chapter provides detailed content requirements to ensure the operator-developed MEL meets the requirements listed in LOA D195.
1. The MEL must contain the name(s) of the operator(s), aircraft serial and registration numbers (or “Fleet”), aircraft M/M/S, and the MMEL revision number on which the MEL is based.
2. 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. An MEL may contain corrections to MMEL typos, spelling, and punctuation errors.
3. The MEL must include specific content based on the items installed on the operator’s aircraft. The aircraft operator’s MEL may omit an MMEL item if the item or configuration is not installed or if the operator elects to not take relief.
4. If an operator elects to take relief for items listed in MMEL PLs with a current CG designation, STC Relief Approval Letter, or any design change approval described in Chapter 10, the MEL must comply with the requirements of paragraph 8.5 below for those items.
5. The MEL should incorporate the phraseology used in the MMEL, wherever appropriate, to ensure clarity and standardization.
8.3 MEL Required Sections. The operator-developed MEL must contain the following sections:
8.3.1 Table of Contents. The table of contents is a list of all sections/chapters in the MEL by title and the corresponding page identification. The format may vary due to operator preference.
8.3.2 L og of Revisions. The log of revisions contains the MEL revision identification (typically a number and/or letter) and the date of the MEL 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.
8.3.3 D efinitions . Definitions of the terms used in MMELs and MELs are found in MMEL PL-25. Operators must include all applicable definitions in their MEL. Not all of the MMEL PL-25 definitions are required to be in an operator’s MEL, as some are related to format issues, specific aircraft types, and certain types of operations. Certain portions of a 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. Operators may download MMEL PLs from the “MMELs and AED Guidance Documents” section in DRS at https://drs.faa.gov.
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8.3.4 Preamble. The preamble contained in MMEL PL-36 is applicable to all § 91.213(a) MEL approvals under LOA D195. This preamble must be reproduced verbatim in the MEL.
8.3.5 C ontrol Pa ge (LEP). 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. It may also be used as a means of conveying FAA approval of the MEL. The format may vary due to operator preference. At a minimum, control pages must contain:
• The name(s) of the operator(s);
• A listing of all of the pages in the MEL (individually or the range of applicable pages for a given section/chapter), including the date of all pages and their number or revision number; and
• The MMEL revision number on which the MEL is based.
8.3.6 ATA/JASC Coded System Sections. These sections are organized by aircraft system according to the ATA/JASC coded numbering system and include individual item sequence numbers, items, repair categories, number of items installed, number of items required for dispatch, remarks or exceptions, and (M) and (O) procedures. See paragraph 8.5 below for additional information.
8.4 MEL Optional Sections. The operator-developed MEL may include the optional sections listed below. The operator may also include additional sections containing information relevant to their MEL.
8.4.1 Cover Page. The cover page format and information may be the same as the MMEL.
8.4.2 Highlights of Change Page. This page list contains a summary of the changes made by the operator in each revision.
8.5 ATA/JASC Coded System Sections. The operator-developed MEL must be organized using the MMEL ATA/JASC coded numbering system. The MEL ATA/JASC coded system sections will include a list of individual items in the aircraft, together with requirements for operation when the items are inoperative. Each coded system section will be further broken down into individual item sequence numbers.
8.5.1 ATA/JASC System Code Numbers. Operators must use the ATA or JASC coded numbering system. The ATA/JASC numbering system provides an industrywide standard for numbering aircraft systems and is relevant for all aircraft.
8.5.2 I ndividual Item Sequence Number and Items. Individual item sequence numbers are the unique identification for each item within an ATA/JASC system category. The numbering scheme may be modified to align with the aircraft operator’s specific MEL format and may differ from the MMEL. They are not required to match ATA/JASC system item numbers.
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8.5.2.1 A triple asterisk (***) below the system number in column 1 of an MMEL indicates an item that is not required by regulation has been installed on some models of a particular aircraft M/M/S. An operator may not carry the “***” symbol over to the MEL. Operators omit the symbol and use a system sequence number when the item is installed on one or more of the operator’s aircraft.
8.5.2.2 An operator is not required to list all MMEL items in their MEL; however, if a particular item is not in the operator’s MEL, then the item must be fully operative at takeoff.
8.5.2.3 Operators may add limitations and restrictions to a particular item beyond what is required by the MMEL. An operator’s MEL limitations, conditions, and restrictions must never be less restrictive than the MMEL.
8.5.2.4 Operators will typically list an MEL item exactly as it is in the MMEL. If an MMEL uses a generic term to describe a particular item, an operator may use different terminology, provided the operator’s terminology is recognizable and easily identified with the corresponding MMEL item.
8.5.2.5 When an MEL item contains multiple components, those components may be listed separately following the item in the MEL.
8.5.2.6 Operators must not list duplicate items, or items listed individually elsewhere in the MMEL. For ease of use, cross-referencing is permitted.
8.5.2.7 Individual components of an MMEL or MEL item may not be listed as NEF.
8.5.3 Repair Categories. The repair category intervals indicated by the letters A, B, C, and D in column 1 of the MMEL are not applicable to an operator-developed MEL, but operators must comply with any provisos defining a repair interval (e.g., flights, flight legs, cycles, hours, days, etc.). At an operator’s discretion, repair category interval letters (e.g., A, B, C, or D) may be omitted from the MEL. If an operator chooses to include repair categories in their MEL, they may comply with the repair category intervals as a best practice, but they are not mandatory. Inoperative equipment in all cases must be repaired, replaced, removed, or inspected by qualified maintenance personnel at the next required inspection. Refer to § 91.405(c).
8.5.4 Number of Items Installed (Number Installed). The “Number Installed” column of an MEL lists the number (quantity) of the specified item installed on the aircraft.
8.5.4.1 Variable Number Installed. A dash (-) for the number installed indicates a variable number (quantity) of the installed item. The use of a dash (-) is common in fleet MELs where aircraft of the same M/M/S have differing numbers of specific items. A dash (-) is also used for MEL items that provide relief for fault messages (e.g., Crew Alert System (CAS), engine indicating and crew alerting system (EICAS), and electronic centralized aircraft monitoring (ECAM)). Additionally, operators may use a dash (-) if it is
8-4 impractical to show the actual number of the specific items (including but not limited to light bulbs, light-emitting diodes (LED), cabin storage compartments, and cargo lining panels) installed on the aircraft.
8.5.4.2 Items Listed on the MMEL but Not Installed on the Aircraft. An operator’s MEL does not have to list MMEL items not installed on the operator’s aircraft. For number continuity in an MEL, operators may choose to:
1. Simply omit the item from the MEL altogether. The option to either renumber the subsequent individual items or maintain the original MMEL sequence numbering is at the operator’s discretion.
2. List the item in the MEL and then show the “Number Installed” as zero (0). In this case, the “Number Required for Dispatch” would also be zero (0), and the remark “Not Installed” noted under “Remarks or Exceptions.” Additionally, in this case, the repair category designators would be omitted.
8.5.5 Number Required for Dispatch. The “Number Required for Dispatch” column of an MEL reflects the minimum number (quantity) of items required for flight, provided the conditions specified in the “Remarks or Exceptions” are met. The number of items required for dispatch in an MEL may differ from what is required in the MMEL under the following conditions:
1. The item is listed in the MMEL as optional and is not installed on the aircraft. In this c ase, a zero (0) may be shown as the number required, the “Number Installed” shown as zero (0), and the remark “Not Installed” noted under “Remarks or Exceptions.”
Note: An operator’s MEL does not have to list MMEL items not installed on the operator’s aircraft.
2. The “Number Required for Dispatch” is followed by a dash (-) in the MMEL. Where the MMEL shows a variable number (-) required for dispatch, the MEL may reflect the actual number required for dispatch or an alternate means of configuration control approved by the Administrator. An aircraft operator’s MEL may contain a dash (-) where the number required is based on the conditions of flight, such as adequate cockpit lighting. Fleet configuration differences (where applicable) and the dispatch requirements must be specified in the “Remarks or Exceptions” section.
3. The number required for dispatch in the MEL is not less restrictive than the MMEL.
8.5.6 Remarks or Exceptions. The “Remarks or Exceptions” column includes provisos, notes, “as required by 14 CFR” requirements and/or limitations, and (M) and (O) symbols.
Some MMEL “Remarks or Exceptions” are intentionally general to accommodate a variety of operators and operating rules. An MEL must expand upon these general MMEL “Remarks or Exceptions,” as required to adequately and safely address an operator’s particular operations and operating rules. See the examples in paragraph 8.6 below.