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Resolving EASA's Minimum Equipment List Concerns

NBAA is working with EASA, the FAA and ICAO to provide clearer guidance to Part 91 operators conducting international operations with a D095 LOA.

Nov. 27, 2017

Part 91 operators with Letter of Authorization (LOA) D095 to use a minimum equipment list (MEL) need to be diligent when conducting international operations, particularly in Europe, as the European Aviation Safety Agency (EASA) puts extra focus on three separate areas, especially during safety assessment of foreign aircraft (SAFA) ramp inspections.

First, operators must be sure they are in compliance with their current LOA, which consists of four parts:

  1. The aircraft-specific LOA
  2. The MEL procedures document, containing maintenance and operations procedures developed by the operator
  3. The master minimum equipment list (MMEL) preamble
  4. The MMEL itself, developed by the aircraft manufacturer and the FAA together, makes up a Part 91 MEL acceptable to EASA.

“Part 91 operators need to be sure all four parts of the MEL are kept on the aircraft and that the maintenance and operations procedures are operator-specific,” said Doug Carr, NBAA’s vice president of regulatory and international affairs. “Pilots must be trained on and familiar with the MEL procedures. They should be able to clearly explain to a SAFA inspector how their company’s procedures work.”

Second, operators must ensure the MEL reflects any equipment installed on the aircraft via a supplemental type certificate (STC).

Depending on the age of the aircraft, the MMEL may not include every STC issued on a particular airframe.

Finally, ICAO Annex 6 Part 2, 2.5 requires operators to have “appropriate maintenance procedures to ensure continued airworthiness” of all installed communication, navigation and surveillance equipment, which includes being listed on the MEL. These performance-based standards from ICAO require additional operator consideration for the effect of inoperative equipment when flying in performance-based airspace.

Part 91 operators need to be sure all four parts of the MEL are kept on the aircraft and that the maintenance and operations procedures are operator-specific.
– DOUG CARR Vice President of Regulatory and International Affairs, NBAA

These last two focus areas highlight how different states apply the ICAO standards. What may be allowed in the U.S. could be grounds for safety actions in other parts of the world.

As other states adopt the principles of EASA’s SAFA program into their national safety oversight programs, operators could face similar MEL scrutiny when flying beyond Europe.

Part 91 operators may consider other options for complying with EASA and ICAO standards, including requesting FAA approval of an aircraft-specific D195 LOA MEL, but obtaining and maintaining that approval requires considerably more work on the operator’s part, as well as additional oversight from the FAA.

“The best way to ensure a successful outcome in a SAFA inspection is to be prepared,” said Carr.

Learn more about European ramp inspections at www.nbaa.org/ramp-inspections.

INDUSTRY CHALLENGE

Using a D095 letter of authorization regarding MEL items to fly internationally, especially to countries that abide by ICAO standards, requires special attention.

NBAA RESPONSE

NBAA is working with EASA, the FAA and ICAO to provide clearer guidance to Part 91 operators conducting international operations with a D095 LOA.

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This article originally appeared in the November/December 2017 issue of Business Aviation Insider. Download the magazine app for iOS and Android tablets and smartphones.