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VOLUME 4  AIRCRAFT equipment and operational authorizations


Section 7  MEL Approval Process for 14 CFR 91K, 121, 135, and 129 Operators

4-796   GENERAL. This section contains specific direction, guidance, and procedures to be used by aviation safety inspectors (ASI) when evaluating and approving MELs. The operator’s MEL is developed by the operator from the appropriate Master Minimum Equipment List (MMEL), then approved by the Federal Aviation Administration (FAA). The FAA approval process for an MEL follows the general process for approval or acceptance described in Volume 4, Chapter 4, Section 6. This section contains an expansion of the FAA approval process for the MEL.

4-797   MEL ACCEPTABILITY. The general criteria for MEL acceptability are as follows:

A.  Equally or More Restrictive. The operator’s MEL must not be less restrictive than the MMEL, Title 14 of the Code of Federal Regulations (14 CFR), the operations specifications/ management specifications (OpSpecs/MSpecs), the Approved Flight Manual (AFM) limitations, certification maintenance procedures, or Airworthiness Directives (AD).

B.  Appropriate. The MEL must be appropriate to the individual aircraft make and model.

C.  Specific. The operator’s operations (“O”) and maintenance (“M”) procedures must be specific to the aircraft and the operations conducted.

D.  Applicability. An MEL should be applicable for the regulation under which the operator is certificated.

4-798   INITIAL PHASE OF MEL APPROVAL. In this phase of the MEL approval process, the operator should consult with the principal operations inspector (POI) regarding requirements for either developing an MEL or for revising an existing MEL. The POI will consult with and seek the participation of the principal maintenance inspector (PMI) and the principal avionics inspector (PAI) during the entire approval process. During the review of the “O” and “M” procedures, the POI, PMI, and PAI may consult with the Flight Operations Evaluations Board (FOEB) chairman as necessary concerning specific procedures. When the FOEB chairman determines that additional engineering support is necessary, the FOEB chairman will contact the appropriate Aircraft Certification Office (ACO) and provide that information to the POI.

A.  Operator Familiarization. In phase one of the MEL approval process, the POI should determine the scope of the task, based on the operator’s experience with MELs. POIs should adapt the discussion to fit the operator’s needs and experience, and should provide advice and guidance to the operator as necessary. POIs must clearly explain to the operator that MEL document preparation is solely the operator’s responsibility.

B.  Required Document Submittal. POIs should advise the operator that, for an MEL to be approved, they must submit the following documents:

·    The proposed MEL or MEL changes;

·    Necessary “O” and “M” procedures, which may be based on the aircraft manufacturer’s recommended procedures, Supplemental Type Certificate (STC) modifier’s procedures, or equivalent operator procedures;

·    A description of the MEL management program and its procedures as required by OpSpec/MSpec D095, unless an MEL management program is already in place; and

·    Any required guidance material developed by the operator, such as training material, guidance, and deferral procedures for both maintenance and operations personnel.

NOTE: Several manufacturers have produced manuals of recommended procedures for operating with inoperative equipment. The Lockheed and McDonnell Douglas MEL Procedures Manuals, and the Boeing dispatch deviation guide (DDG), are examples of these manuals. Title 14 CFR parts 23 and 27 manufacturers normally do not publish procedures manuals. When a manufacturer’s recommended procedures exist, operators may use them or may develop alternate procedures. When contract services are used to develop the operator’s MEL along with acceptable “O” and “M” procedures, the principal inspectors should review the “O” and “M” procedures in light of the type of operations being conducted and should ensure the acceptability of the procedures. The principal inspectors should ensure that the developed MEL procedures can be adequately implemented by the operator.

C.  Materials Provided to the Operator. Copies of all current MMELs are accessible to all interested parties directly from www.opspecs.com. If the FSDO furnishes the MMEL to the operator on computer disk, the MMEL should be in standard ASCII (DOS text) format or Microsoft Word. This allows the operator to use different word processing packages and different types of computers when editing the document. The POI should provide the operator with one of the following:

·    The MMEL Web site (www.opspecs.com) for direct access to the MMEL and related information (preferred);

·    A computer disk containing the appropriate MMEL (computer disk to be provided by the operator); or

·    A hard copy of the MMEL document and appropriate guidance material (as a last resort).

D.  Document Form. The operator may submit MEL draft documents to the FAA either on hard copy (printed on paper) or on computer disk, as mutually agreed upon between the operator and the POI. The operator and the POI should discuss the techniques that will be used for revising and editing the proposed document. It is important that the operator understand that when the process is complete, the final proposed MEL must be submitted on paper unless otherwise approved by the Administrator.

E.  MEL Format. The MMEL format has been standardized to facilitate the development, revision, and approval of both master and operator documents. While the master document contains eight total sections, six of these sections are considered basic for MEL development and should be included in each operator’s MEL. Refer to this volume for a detailed list of each MMEL section and whether or not it should be included in the operator’s MEL.

F.  Generic Single-Engine MMELs. A generic MMEL for single-engine aircraft was developed and published by the FAA. This MMEL is applicable to all single engine airplanes and helicopters for which a specific MMEL has not been issued. When an operator is approved to use this generic MMEL, and a specific MMEL for the individual aircraft type is subsequently issued, the operator’s MEL must be revised within the specified time frame to conform to the specific MMEL.

G.  Required Document Submittal. PIs should advise the operator that for an MEL to be approved, the following documents must be submitted:

1)   Current equipment list for each make, model, series aircraft that is to be included in the MEL or revisions.
2)   The proposed MEL or MEL changes.
3)   Necessary “O” and “M” procedures, which may be based on the aircraft manufacturer’s recommended procedures, STC modifier’s procedures, or equivalent operator procedures.
4)   For part 121 purposes, a document or the portions of its § 121.133 required manuals for each group of personnel (§ 121.135(b)) that includes its comprehensive program for managing the repair of items listed in the proposed or revised MEL, as appropriate.
5)   For part 121 purposes, any other parts of its manual that includes duties, responsibilities, authority, policies, procedures, instructions, or information for crewmembers, ground, maintenance, and management personnel with regard to handling of MEL items covering §§ 121.133, 121.563, 121.701, and 121.709.
6)   For part 121 purposes, a description in its § 121.367 required inspection program and its program covering MEL items that ensures that:
a)   The maintenance performed by it, or by other persons, is performed in accordance with the requirements of their manual.
b)   Competent personnel are provided for the proper performance of that maintenance.
c)   Each aircraft released to service is airworthy and has been properly maintained for their operation.

4-799   FINAL PHASE OF MEL APPROVAL PROCESS. The final phase begins when the operator formally submits the proposed MEL or MEL changes to the POI. The POI should initially review the operator’s submittal to verify that it is complete, contains the required elements, as listed in paragraph 4-799 B 6) of this section, and is detailed enough to permit a thorough evaluation of the MEL.

A.  Unacceptable Submittal. If the POI finds the proposed MEL package to be incomplete or unacceptable at this time or at any other juncture in the approval process, the POI should contact the operator. A sample letter is provided in Figure 4-49. If a mutually acceptable correction cannot be immediately agreed upon, the entire package must be immediately returned to the operator, or its representative, along with an explanation of the problems found within the documents.

B.  Acceptable Submittal. If the POI finds the proposed MEL package to be complete and to contain the required information in an acceptable format, the detailed analysis begins. During this analysis, the POI should coordinate with the PMI and the PAI to perform a detailed examination of the proposed MEL document and other supporting documents and procedures. If the operator does not currently have an MEL program, its MEL management program must also be reviewed for acceptability. Inspectors should examine the technical content and quality of the proposed MEL document and other supporting documents and procedures as follows.

1)   Timely Review. POIs should promptly address all deficiencies and notify the operator of any discrepancies or outstanding issues. The POI and the operator may informally coordinate by telephone to clarify minor discrepancies or misunderstandings.
2)   Reference Material. Inspectors should use the MMEL as the primary reference document when reviewing and approving the MEL. In addition, inspectors should use the following references:

·    Related 14 CFR,

·    Appropriate advisory circulars (AC),

·    AFM,

·    Operator’s OpSpecs/MSpecs,

·    Operator’s manuals, and

·    MMEL policy letters.

3)   Coordination with Technical Groups. During this phase, the POI may wish to coordinate with the appropriate Aircraft Evaluation Group (AEG) for guidance. Inspectors should refer to volume 8, chapter 2, section 2 of this order for information on the technical guidance available through the AEG.
4)   Document Deficiencies. Refer to paragraph 4-799A of this section.
5)   Change in Schedule. If certain MMEL items must be addressed within a specific time frame, the POI should notify the operator of this requirement as soon as possible. If the operator is unable to meet these schedule requirements, the POI should negotiate a new schedule with the operator.
6)   MEL Evaluation. Inspectors should compare the operator’s MEL changes against the corresponding items in the current MMEL for the specific aircraft type. In addition, inspectors should verify that the operator’s MEL contains the following required items:
a)   Cover Page (Optional). The MEL cover page contains the operator’s name and the make and model of the aircraft to which the MEL applies.
b)   Table of Contents (Required). The table of contents contains a list of all of the pages in the MEL by title and the corresponding page identification (usually a page number).
c)   Log of Revisions (Required). The log contains the revision identification (usually a number) and date of the revision. 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.
d)   Preamble and Definitions (Required). The standard MMEL preamble and definitions section must be reproduced word-for-word in each MEL, without modification, except as specified in Flight Standards Policy Letters 25, 34, and 70.
e)   Control Page (Required). The control page is used for keeping track of the status of the MEL and includes 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.

1.   Minimum Contents. At a minimum, the control page must contain the following:

·    The operator’s name;

·    A listing of all of the pages in the MEL (including the date of each page and its number or revision number);

·    The MMEL revision number on which the MEL is based; and.

·    A signature block containing space for signature of the POI (only if this page is used as a means of conveying FAA approval of the MEL).

2.   Optional Contents. The operator may include additional information on the control page to provide flexibility and additional approval functions.

3.   Highlights of Change Page (Optional). This page contains a synopsis of the changes made by the operator in each revision.

f)   Additional Items. The operator may include additional information sections in excess of the six FAA sections.
7)   Individual Air Transport Association of America (ATA) System Page Evaluation. These pages contain a list of individual items of equipment in the aircraft together with provisions for the operation of the aircraft when the items are inoperative. The reviewing inspector should examine the individual ATA system pages, ensuring that the MEL is at least as restrictive as the MMEL and that operator’s procedures are adequate and appropriate. The inspector should also examine the material contained on these pages for conflict with 14 CFR, with the AFM emergency procedures and limitations, and with the operator’s OpSpecs/MSpecs. The following elements are included:
a)   The ATA Numbering System. Operators should use the standard ATA numbering system, similar to the manner used in the MMEL, for numbering individual pages in this section. An example of this numbering system would be the communications page; the first page would be 23-1; the second page would be 23-2.
b)   Individual Items of Equipment. The MMEL contains listed items of installed equipment that may be inoperative.

1.   MMEL Items Not Listed on the Operator’s MEL. If items listed on the MMEL are not listed on the MEL there is no relief.

2.   MMEL Items Listed on the Operator’s MEL. Each piece of equipment that is installed on the aircraft and that is contained in the MMEL, for which the operator seeks relief and that is appropriate for its operation, should be listed on the appropriate page of the operator’s MEL within the associated ATA system. The operator may be more restrictive than permitted by the MMEL by not listing certain items in its MEL. Each item title on the operator’s MEL will generally be entered exactly as it is shown on the MMEL. Exceptions include the following:

a.   When the MMEL uses a generic term to address equipment that serves a similar function but various operators use different names for that equipment; or

b.   When the MMEL lists functions rather than individual pieces of equipment within that category (Examples include “Navigation Equipment” or “Communications Equipment.” In such cases, the MEL must contain a list of the individual equipment or systems within that category that are actually installed on the aircraft, such as “VHF Communications Transceivers.” When items of this type consist of several components of a system, the item may be listed as a complete system, such as “VOR Navigation System,” consisting of a VOR navigation receiver and its associated indicator. The inspector should ensure that the operator has not listed inappropriate items or items that are listed individually elsewhere in the MMEL. However, the POI is authorized to approve generic MMEL relief for navigation or communication equipment that is appropriate such as instrument landing system (ILS), VHF omni‑directional range station (VOR), very high frequency (VHF), high frequency (HF) and global positioning system (GPS).)

3.   Items Listed on the MMEL but Not Installed on the Operator’s Aircraft. The POI may follow several acceptable methods of dealing with an item of equipment being listed on the MMEL but not installed on the operator’s aircraft. One method is to simply omit the item from the MEL altogether, renumbering individual items within an ATA category as necessary to provide proper continuity. (It should be noted that individual item numbers on a page are not necessarily ATA code numbers, but are simply sequential item numbers within an ATA category.) Another method is to list the item as shown on the MMEL, and to show the Number Installed as zero. In this case, the “Number Required for Dispatch” would also be zero, and the remark “Not Installed” may be noted under “Remarks and Exceptions”; repair category designators should be omitted.

4.   Triple Asterisk Symbol (***). The triple asterisk symbol is used in an MMEL to indicate that an item is not installed on some models of the aircraft. Operators should not produce or use this symbol in the MEL.

5.   Repair Category. Each item of equipment listed in the operator’s MEL, except for Administrative Control Items and Passenger Convenience Items, must include the repair category designator for that item as shown on the MMEL. These designators, categorized as “A,” “B,” “C,” or “D,” indicate the maximum time that an item may remain inoperative before repair is made. The actual repair categories corresponding to these letters are provided in the “Notes and Definitions” section of the MMEL. The operator may choose to adopt a more restrictive repair category than the one shown on the MMEL, but may not relax the requirement. Components or subsystems of items categorized in the MMEL, such as items of communications or navigation equipment that are not listed individually in the MMEL, must retain the repair category shown on the MMEL when listed as separate items on the MEL.

6.   Passenger Convenience Items. Passenger convenience items relate to the convenience, comfort, and entertainment of passengers and must never affect the airworthiness of the aircraft. These items do not carry a specific repair category; however, the operator should make repairs to convenience items within a reasonable time frame. Normally, the operator lists these items individually in ATA chapters 25 and 38. Passenger convenience items may be included elsewhere in the MEL if clearly identified as passenger convenience items. POIs should review the proposed MEL to decide which passenger convenience items are components of an item appearing in the MMEL. When listing passenger convenience items on the MEL, the operator must list each item for which the operator wishes relief. The operator may make a list of passenger convenience items that, once it is acceptable to the POI, is held at the certificate-holding district office (CHDO). Passenger convenience items also apply to cargo airplanes, as appropriate.

7.   Administrative Control Items. “Administrative control item” means an item listed by the operator in the MEL for tracking and informational purposes. It may be added to an operator’s MEL by approval of the POI, provided no relief is granted, or provided conditions and limitations are contained in an approved document (such as Structural Repair Manual or AD). If relief other than that granted by an approved document is sought for an administrative control item, the operator must submit a request to the Administrator. If the request results in review and approval by the FOEB, the item becomes an MMEL item rather than an administrative control item. Examples of items that could be considered administrative control items are cockpit procedure cards, medical kits, and life vests. These items should appear in the appropriate ATA chapter and would not have a repair category. When the operator chooses this course of action, the POI must examine each proposed administrative control item on the operator’s proposed MEL to ensure that the following conditions are met:

·    No item is included as an administrative control item if it is included elsewhere in the MMEL;

·    Administrative items are not included as a subsystem of items listed in the MMEL; and

·    Administrative items are not granted relief in the MEL unless the release conditions or limitations are contained in another approved document.

8.   Number of Items Installed. The MEL will normally contain the actual number of items of particular equipment installed on the aircraft. This number may be either greater or less than the number shown on the MMEL. The MMEL shows the number of items installed as the number of those items normally installed on a particular aircraft type. Individual aircraft operated by an operator may have a different number of items. Frequently the MMEL shows a dash in the “Number Installed” column. This dash indicates that a variable quantity of these items is generally installed on the aircraft. If the operator has an MEL for a single aircraft or identical aircraft, the actual number of these items on the particular aircraft must be listed in the MEL. If the operator has an MEL for multiple aircraft, and the equipment is not installed on all aircraft or there is a variable quantity between aircraft, and the operator’s MEL will not reference specific aircraft identifications; the “Number Installed” column may contain a dash.

9.   Number of Items Required for Dispatch. Normally, the number of items required for dispatch is determined by the FOEB and may be modified in the MEL in only two cases:

·    When the item is not installed on the aircraft, in which case a zero may be shown as the number required for dispatch; and

·    When the item is shown in the MMEL as being a variable number required for dispatch.

NOTE: In this case of the second bullet above, the reviewing inspector should ascertain that the operator has made a determination as to the number required for dispatch. There can be several factors that establish this number. In some cases, it is determined by a reference to specific requirements listed in the “Remarks or Exceptions” column of the MMEL. An example would be cabin lights. In this case, the MMEL may show a variable number installed while the “Remarks or Exceptions” column might state that 50 percent of those items be operable. The number required for dispatch would therefore be 50 percent of the number of lights determined to be actually installed on the individual aircraft. Another case where the MMEL may show a variable number required for dispatch is when the “Remarks or Exceptions” column of the MMEL contains the statement, “As Required by FAR.” In this case, the number is the minimum quantity of these items that must be installed for operations under the least restrictive regulation under which the operator conducts operations. For example, part 135 requires two communications transmitters for operating a small airplane as a commuter operator under instrument flight rules (IFR). Only one transmitter is required by part 135 for on-demand charter operations, and none are required for visual flight rules (VFR) operations when operating outside of controlled airspace. If none are required, the minimum number of transmitters required for dispatch could be zero.

10. “Remarks or Exceptions.” Certain items demand specific relief developed by the operator as authorized through OpSpecs/MSpecs, area of operation, and 14 CFR. “As required by CFR” is an example of this type of relief.

11. Other Items. Other items in which relief has been specifically written to reflect actions or restrictions to the operation may be changed only when the FOEB chairman makes a change to the MMEL. Generally they contain “O” and “M” procedures in which the operator develops its company procedures to comply with the MEL.

12. Equipment Required for Emergency Procedures. Each FOEB chairman shall determine that, in the development of MMELs, relief is not provided to instrument or equipment systems or components that are required to accomplish emergency procedures. Each FOEB chairman shall review each current MMEL for which he has responsibility and amend any proviso that states “As Required By CFR” to include an added provision that would effectively assure that “no relief is provided to an inoperative system or component if powered by an emergency bus or equivalent and required to accomplish an emergency procedure.”

8)   Evaluation of Associated Documentation. The inspector should evaluate the supporting documentation submitted by the operator to ensure that it is complete and appropriate.
a)   The Operator’s Manual. Inspectors should evaluate the operator’s manual to ensure that it contains adequate guidance for the operator’s personnel in conducting operations using the MEL. Generally, if the operator does not presently have an MEL program, the applicable portions of its manual and other guidance material should be submitted at the time the MEL is submitted for initial review. When evaluating the operator’s manual, inspectors should use the guidance in b) below.
b)   Documentation Procedures. The procedures for documenting inoperative equipment and any required maintenance release procedures should be clear. At a minimum, provisions for recording the following items should be developed:

·    An identification of the item of equipment involved;

·    A description of the nature of the malfunction;

·    An identification of the person making the entry; and

·    The MEL item number for the equipment involved.

9)   Crew Notification. The operator should establish procedures for advising the pilot in command (PIC) of inoperative items and required procedures such as affixing placards, alternate operating procedures, and instructions for the isolation of malfunctions. The PIC and the operator are both responsible for ensuring that flights are not dispatched or released until all of the requirements of the “O” procedures and “M” procedures have been met.
10) Flight Restrictions. The operator should establish procedures to ensure that dispatch or other operational control personnel, as well as the flightcrew, are notified of any flight restrictions required when operating with an item of equipment that is inoperative. These restrictions may involve maximum altitudes, limitations for the use of ground facilities, weight limitations, or a number of other factors.
11) Training Program Material. Inspectors should ensure that the operator’s flight and ground personnel training programs contain adequate instruction for MEL use.
12) MEL Management Program. The POI should coordinate closely with both the PMI and the operator on the MEL management program. Operators must develop an MEL management program as a comprehensive means of controlling the repair of items listed in the approved MEL. Operators must include a description of the program in their maintenance manual or other documents. The MEL management plan must include the following:

·    A method for tracking the date and time of deferral and repair;

·    The procedures for controlling extensions to maximum repair categories;

·    A plan for coordinating parts, maintenance personnel, and aircraft at a specific time and place for repair;

·    A review of items deferred due to unavailability of parts; and

·    The specific duties and responsibilities of the managers of the MEL management program, listed by job title.

4-800   TERMS AND CONDITIONS OF RELIEF. This section contains the terms and conditions of relief granted to an operator for operating the aircraft with items of installed equipment that are inoperative. The operator must state the terms and conditions under which operations may be conducted with inoperative items for the operator’s particular organization and aircraft. The reviewing inspector must address the following elements of this section:

A.  Standard Phraseology. When reviewing the MEL, inspectors should ensure that the operator generally uses the phraseology used in the MMEL to ensure clarity and standardization. In some cases modified phraseology is appropriate for the operator’s specific installation. The POI should refer questions about non-MMEL phraseology to the FOEB chairman for resolution.

B.  “As Required by FAR.” The general term, “As Required by FAR,” applies to ATA chapters 23 (Communications), 31 (Instruments), 33 (Lights), and 34 (Navigation Equipment). When this term appears in the “Remarks or Exceptions” section of an MMEL, the operator’s MEL must contain the specific conditions that apply. The operator usually must research the applicable regulations in detail to develop the appropriate provisions that apply to that operator’s particular operations. An example of a typical distance measuring equipment (DME) remark could read, “Not required for flights below FL 240.”

NOTE: The operator’s MEL must clearly establish the actual requirement for its operation when the MMEL stipulates “As Required by FAR.” It is not acceptable for the MEL to simply refer to the regulation.

C.  “O” and “M” Procedures.

1)   “O” and “M” procedures must contain descriptions of the individual steps necessary to accomplish each process. For example, if the MMEL contains an “M” symbol with a provision that a valve must be closed, the operator must include the appropriate procedures to close the valve as part of the operator’s manual or MEL. The reviewing inspector must ensure that the procedure addresses the following:

·    How the procedure is accomplished;

·    The order of accomplishing the elements of the procedure; and

·    The actions necessary to complete the procedure.

2)   Inspectors should consult the Guidelines for “O” and “M” Procedures of the MMEL when evaluating these procedures. The section about the Guidelines for “O” and “M” Procedures does not have to be contained within the operator’s MEL. If the “O” and “M” procedures are not contained within the MEL, the MEL should include a reference to the location of the procedures.

NOTE: While inspectors should ensure that the procedures are detailed and explicit, it is not necessary that the operator repeat obvious requirements of the MEL item, of 14 CFR, or of other established standards.

3)   “O” Procedures. The “(O)” symbol indicates a requirement for a specific operations procedure that must be accomplished in planning for and/or operating 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. The satisfactory accomplishment of all procedures, regardless of who performs them, is the responsibility of the operator. Appropriate procedures are required to be published as a part of the operator’s manual or MEL.
4)   “M” Procedures. The “(M)” symbol indicates a requirement for a specific maintenance procedure which must be accomplished prior to operation with the listed item inoperative. Normally these procedures are accomplished by 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 maintenance procedures, regardless of who performs them, is the responsibility of the operator. Appropriate procedures are required to be published as part of the operator’s manual or MEL.
5)   Provisos. The “Remarks and Exceptions” section of the MMEL generally contains provisos that include specific conditions under which an item of equipment may be inoperative. These provisos must be carried over either verbatim into the operator’s MEL or by using equivalent terminology. Provisos are distinct from “O” and “M” procedures. A procedure is an action that must be performed. A proviso is a condition that must exist. For a proviso that operations must be conducted under VFR, an operation under an IFR flight plan is not permitted, regardless of the weather conditions. When reference is made to visual meteorological conditions (VMC), operations may be conducted under an IFR flight plan, but only in VMC.
6)   POI Review of “M” and “O” Procedures. Each POI should review the MEL provisions with their assigned certificate holders or fractional ownership program. At the discretion of the operator or fractional ownership program manager, the operator or fractional ownership program manager may include additional (M) and (O) symbols for a specific item in the MEL based on their needs. These additional (M) and (O) symbols are based on a determination made by the operator for dealing with an inoperative item and are in addition to those required by the MMEL. Any additional (M) and (O) symbols added to the operator’s or fractional ownership program manager’s MEL will not alter in any way the definitions of the (M) and (O) symbols as shown in paragraphs 15 and 16 of the “Definitions” section of the current MMEL.

4-801   DEMONSTRATION PHASE. A demonstration phase is normally not required for an MEL approval. When an operator is developing an MEL in conjunction with original certification for initial issuance of an operating certificate, or when instituting service with a new aircraft type, a demonstration of the operator’s ability to use an MEL may be conducted during any required aircraft proving tests.

4-802   POI APPROVAL OF THE OPERATOR’S MEL. After the POI is satisfied that the MEL is in full compliance with all applicable requirements, the POI shall sign the MEL control page or the individual MEL pages to signify approval. If the operator has not previously been authorized to operate under an MEL, the PMI should issue OpSpec/MSpec D095 concurrently.

4-803   PROGRAM TRACKING AND REPORTING SUBSYSTEM (PTRS) INPUT. The POI should record the initial approval of an MEL on FAA Form 8000-36, “PTRS Data Sheet” using activity code 1321 under “Organizational and Technical Administration.” The PTRS should be used to track the MEL approval process from phase one through phase five. After receiving the proposed MEL from the operator, the POI can open a record for the approval and document each phase of the approval process in Section IV of the data sheet by making additional comments when required. Once the MEL is approved, the PTRS is closed with a “C.”

4-804   FINAL STEP. As the final step in the MEL approval process, the POI enters the operator and MEL information into the MMEL Subsystem as described in volume 4, chapter 4, section 9.

RESERVED. Paragraphs 4-805 through 4-820.

Figure 4-49, Example of Letter to Operator Denying Approval of MEL

FAA Letterhead


Mr. Robert Smith

Director of Operations

ABC Airlines

1 Park Avenue

New York, NY 11021

Dear Mr. Smith:

This letter is to inform you that the Minimum Equipment List (MEL) submitted for approval on June 6 is being returned to your office. A comparison of ABC’s MEL against the current Master Minimum Equipment List (MMEL) shows that in the following places ABC’s MEL is less restrictive than the MMEL.

Specifically, these System and Sequence Numbers do not comply with acceptable procedures:

1. Page 24-1, item 3. DC Loadmeter

2. Page 28-1, item 1. Boost Pumps

3. Page 30-3, item 13. Pitot Heater

Additionally, ABC’s MEL does not include the required Control Page.

If you have further questions on the MEL approval process, please feel free to contact me.


John Doe

Principal Operations Inspector