Roger Roger
Bottom of the list
Didn’t part 91 used to be able to just use the MMEL or am I hallucinating that?
Part 91 jet ops and “open write ups”
- Thread starter FL350
- Start date
FL350
Well-Known Member
Our AFM has a KOEL section,but reading part 91 makes me think we can not use the KOEL. At least for turbine operations. @deadstick
FL350
Well-Known Member
I think that was a couple decades ago now. It's a little crazy in my mind that you need the MMEL approved, even though the MMEL is a published FAA document. The one for our aircraft has published M&O procedures and all. I guess thats the FAA though
deadstick
Well-Known Member
FL350
Well-Known Member
Yes it is, but reading the regs makes me think that it is not allowed to be used for turbine ops. It seems like they publish the KOEL as a basis to build the MEL from.
Both these make me believe it is not allowed to be used to fly the plane with inop instruments and equipment. Though I was hoping it could be.
Gotta have it?
A minimum equipment list (MEL) might be the most confusingly named item in aviation. I’ve lost track of how many times during a checkride I’ve had a private pilot applicant confidently (and incorrectly) tell me an MEL is a list of the equipment on an airplane that must be operative—you know, the...
www.aopa.org
deadstick
Well-Known Member
I just realized KOEL usage was addressed indirectly in the good ol’ Nichols (2009) LOI that is used in discussions of logging SIC time.
Roger Roger
Bottom of the list
Well, painful as it may be to admit, it was a couple decades ago that I was first learning this stuff.
Why you need an LOA to use the MMEL makes no sense, just as the amount of hoops to jump through to approve an AAIP makes no sense. The FAA literally makes it harder to do things the way the manufacturer intended them to be done.
FL350
Well-Known Member
That's interesting to note. But still doubt you can apply a KOEL like an MEL to inoperative equipment. As they reference removing it in an approved manner.
FL350
Well-Known Member
Unfortunately this is all too true.People without common sense or circumnavigating common sense intentionally, have made it impossible for the rest of us to use common sense.
TUCKnTRUCK
That guy
In general, they just want to make sure that your using the current MMEL, and that it’s actually the approved document.
It’s far to easy to “modify” one and present during a ramp inspection etc in an effort to cheat something that you can’t do... like fly at night with an ice light out. I know having the op spec /loa doesn’t mean you won’t do this, however I guess it’s a step better than Wild West.
Our MMEL has some stupid stuff on it. I’d def. like to highlight and delete prior to pushing to the pilots iPads
To the OP - wait until you have a Cat “B” Mel item in your plane - only to find out the part is 5-7 days away, and it’s for something you don’t even need for 91 ops. Say - autopilot disconnect annunciator light PC board. So you do what any good 91 pilot does, and try to get an extension
. ( you can’t, the CAT a/b/c/d system if for operators on an approved program, 121,135,91k)Sent from my iPhone using Tapatalk
gotWXdagain
Polished Member
Good thing 91.213 covers all these scenarios
Also, if you work for a 91 jet operator too cheap to get a MEL or fly planes with no writeups...you're probably in south Florida.
91.213(d) relief only applies to non-turbine, as I read it. So it seems like the answer is that the airplane in this case is grounded.
Yup. Gotta love that “there’s a letter for that (tm)” though. I’d assumed the KOEL in the AFM was the basis each civil aviation authority created their MMEL off of or something. Seriously, a MEL LOA is stupid simple. I’ve somehow gotten several issued to me.
FL350
Well-Known Member
Haha some of this is beyond aggravating. Hopefully this plane is on the 135 cert sooner than later then.In general, they just want to make sure that your using the current MMEL, and that it’s actually the approved document.
It’s far to easy to “modify” one and present during a ramp inspection etc in an effort to cheat something that you can’t do... like fly at night with an ice light out. I know having the op spec /loa doesn’t mean you won’t do this, however I guess it’s a step better than Wild West.
Our MMEL has some stupid stuff on it. I’d def. like to highlight and delete prior to pushing to the pilots iPads
To the OP - wait until you have a Cat “B” Mel item in your plane - only to find out the part is 5-7 days away, and it’s for something you don’t even need for 91 ops. Say - autopilot disconnect annunciator light PC board. So you do what any good 91 pilot does, and try to get an extension
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I’ve been out of the D.O. position for only eight months, so I’m pretty confident that you just send the FSDO a letter requesting an LOA D095 to use the MMEL as an MEL. Provide your source for M&O procedures (most manufacturers provide this) and you should be good to go. Not a difficult process at all.
Guidance (scroll to Part 91 section)
spbrian
Well-Known Member
The FSDO still needed to see a completed packet including the MMEL with the M&O procedures and also the policy letter from the 8900. This was for an older gulfstream and a FSDO on the west coast.
Agreed. The letter is the only thing that I had to generate myself, the other items can be downloaded and attached.
Space Monkey
Arbitrariness replaces reason with authority.
Generik Kaveat: the following rant is not based on, nor directed toward any particular post, but rather toward the dismal tide.
Hey! I've got an idea! Let's all be pilots. And do pilot stuff. Make good, sound decisions. Demonstrate aeronautical competence. Fly the airplane.
Holy Mother of God. I'm so damned sick of rule making based on regression to least common denominators. They're just not even close to high enough anymore. And yet we "debate" them as if they are a worthy realm of investigation. And we create rules around them so that chipmunks will be able to sit in pilot seats and not hurt anybody.
What dismissive disrespect. What a waste of time and human potential... ... ...
I need a new freaking planet.
We live in a world in which Kompetence, Kreativity, and Kraft are dead.
When you kill Kompetence, Kreativity, and Kraft, all you’re left with is Katas and Kabuki, and Kommissioners.
While FAA have never, nor will ever possess the ability to materially enforce any of their pre/proscriptions in any time-frame relevant to proximate hazard abatement, FAA exists now solely to ensure that the paperwork says "the Quarter Pounders will be flipped at precisely 56 seconds on a grill at 156 degrees F".
To think! ... if we'd just started with the untainted beef... If we'd just started with "cooks" who were actually cooks, you know, in possession of proper knowledge and capacities in the preparation of food...
Let's stop using our magnificent tools as Krutches.
Let's stop Kidding ourselves into Kontrivances, Konundrums and Konfabulations.
Science is good. Math is important.
But it's Art that gives us the required perspective.
Kill the Art, Inherit theFa…Wind.
Hey! I've got an idea! Let's all be pilots. And do pilot stuff. Make good, sound decisions. Demonstrate aeronautical competence. Fly the airplane.
Holy Mother of God. I'm so damned sick of rule making based on regression to least common denominators. They're just not even close to high enough anymore. And yet we "debate" them as if they are a worthy realm of investigation. And we create rules around them so that chipmunks will be able to sit in pilot seats and not hurt anybody.
What dismissive disrespect. What a waste of time and human potential... ... ...
I need a new freaking planet.
We live in a world in which Kompetence, Kreativity, and Kraft are dead.
When you kill Kompetence, Kreativity, and Kraft, all you’re left with is Katas and Kabuki, and Kommissioners.
While FAA have never, nor will ever possess the ability to materially enforce any of their pre/proscriptions in any time-frame relevant to proximate hazard abatement, FAA exists now solely to ensure that the paperwork says "the Quarter Pounders will be flipped at precisely 56 seconds on a grill at 156 degrees F".
To think! ... if we'd just started with the untainted beef... If we'd just started with "cooks" who were actually cooks, you know, in possession of proper knowledge and capacities in the preparation of food...
Let's stop using our magnificent tools as Krutches.
Let's stop Kidding ourselves into Kontrivances, Konundrums and Konfabulations.
Science is good. Math is important.
But it's Art that gives us the required perspective.
Kill the Art, Inherit the
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TUCKnTRUCK
That guy
Say what? Let’s play a game called never have I ever.
I’ll start.
Never have I ever wanted to do charter /135
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Space Monkey
Arbitrariness replaces reason with authority.
Never have i ever gotten in trouble with a 135 operator for telling the moron/lying/self-deluded/I-want-reality-to-be-different-than-what-it-really-is DO that I could and would be happy to do a trip 91, but that I could not and would not do the trip 135 because the OpSpecs did not authorize flight to that area/airport... and, you know, that would put both his certificate and mine at risk.
Never have I ever found aviation companies who mouthed words about safety and compliance who turned around and abrogated any knowledge of or respect for either.
Never have I ever turned down a broke-ass airplane. Then had to explain to a CP how an MEL worked, and why it was we could not legally fly the plane. Then had a DO concur that the plane was not legal. Then, an hour later the same day, had the plane I turned down dispatched with another pilot with no Mx having occurred.
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