Minimum Equipment List

[Saab Dastard]

Question (or two) -

The magnetic compass in a PA28 has lost all its damping fluid. The compass still functions accurately - but only on the ground, when stationary (in the air it is whirling like a dervish).

a) Is it legal to fly?

b) If so, is it sensible to fly VFR cross-country? - only other nav kit is nav1 VHF and panel mount GPS (Bendix-King)

I'm not sure about the legality, but my thought is that a FUNCTIONING compass is what the min. equipment list requires, so therefore it is not legal.

I will not fly it x/c, but I have flown it in the local circuit - which is when I noticed the "erratic" behaviour!

Anyone else got any thoughts?

SD

[Genghis the Engineer]

The list of minimum required instrumentation will be in a document called the TCDS (Type Certificate Data Sheet). I'm afraid that I don't have a copy, but the LAME who looks after the aircraft might. Failing that, ring the local CAA office.

That's the legalities, my opinion would be not to get airborne in a medium performance light a/c without a compass (and I'm pretty sure it will be on the MMEL anyway) but you do need to check.

A copy of the MMEL might also be in the POH?

G

[tacpot]

Question 2 is a no-brainer for me - it's not safe to fly it VFR across country.

Things don't always work out as intended, and even on a nice day, the weather can close in on you and reduce good visibility to poor. Without a reasonable compass, you can't steer way from trouble, if you loose track of exactly where you are.

I think you have answered question 1 yourself, if the ME List says "Compass", it has to be fully functioning in the air. And if the aircraft has a C of A, it must have been swung within the last three years to be regarded as fully functioning, so that the compan deviations are correct.

[mad_jock]

Sod that for a game of solders.

That is completly gash of whoever is giving you the plane.

Write it in the techlog when you get back and if whoever hired you the plane moans. Change schools.

If they change the techlog after you have written in it, the person who did it is looking at a goal sentence.

MJ

[BEagle]

If that was one of my aeroplanes, I'd limit it to "Dual flight only under day VFR. The ac shall not leave the aerodrome circuit except for one delivery flight to the maintenance aerodrome in day VFR."

It must not be used for routine VFR navigation!

Common sense should overrule any 'minimum equipment list'.

[TANGOWHISKEYINDIA]

I can't honestly answer on whats mandatory VFR day minimum instrumentation in the UK (I'm from sweden), but swedish regulations specify minimum instrumentation to carry for VFR day operations and that is:

- HSI
- Altimeter
- Magnetic Compass

(BCL-D Chapter 3.2 Section 6.2)

[IO540-C4D5D]

Mad_jock

If every time I had a CFI give me a bollocking for writing about some defective piece of kit in the school's tech log, I would not have done much flying.

Schools especially are very selective about what gets written down. The charitable view is that anything that isn't legally required for VFR should not be written down because it isn't necessary, and reduces the value of the aircraft to a prospective buyer when he sees a long list of breakages. But the same planes get used for IMC training also... I used to write down stuff like INOP DME, INOP VOR1, INOP VOR2, INOP ADF, INOP instrument lights, INOP pitot heat, INOP OAT gauge and then got a bollocking :O

IMHO a working compass is mandatory - even if many/most pilots rarely look at it.

[topcat450]

I've often questioned the fit on a/c and if the a/c is airworthy without certain bits of kit...for example I learnt on 150s...the checklist says to check the vacuum pump is 4-5 inches I think...however when the guage is knackered.. I had one instructor say to me...oh its just the guage that's broke...don't worry about it...you'll be fine - off you go.

As it happens it all was fine, but now I've passed I'm quite selective and if bits are broken and haven't been fixed I won't take it - afterall, if I know they're that tight when it comes to maintenance, how do I know they won't have cut a few corners in an attempt to save a few £££

Having said all that, if the worst happens..and you did get lost...and you spoke to 121.5 and they saved the day...would you then like to explain to the CAA afterwards why you went XC with an inop compass? :bored:

[Saab Dastard]

Thanks, Guys,

You all confirm exactly what I believe - it sure aint safe, whatever about the legality.

This particular airplane has had the techlog full of "Compass leaking fluid", "Compass unstable and erratic" for more than 6 weeks!

No wonder nobody is flying it!

How much can it cost to fix the compass, and how much is it losing in lost rental?

It must, surely, be a no-brainer?

Cheers,

SD

[bookworm]

The list of minimum required instrumentation will be in a document called the TCDS (Type Certificate Data Sheet). I'm afraid that I don't have a copy, but the LAME who looks after the aircraft might. Failing that, ring the local CAA office.
...
A copy of the MMEL might also be in the POH?

Genghis

I've never heard of this with regard to G-registered aircraft. In fact I've never seen any reference to a Minimum Equipment List anywhere in UK legislation. What's your basis for suggesting that this forms part of a UK C of A (presumably that's what you're suggesting)?

A compass doesn't seem to get a mention in Schedule 4 of the ANO, which specifies equipment required on G-registered aircraft.

[A and C]

The CAA has published a list of MEL,s and a list of them could be found in Airworthiness Notices CAP455.

I dont have my copy with me right now so I cant tell you the AN number.

[Genghis the Engineer]

The CofA is issued on the basis of a combination of inspection and a Type Certificate (TC). The conditions of the TC are listed in the TCDS - Type Certificate Data Sheet.

The TCDS lists flying limitations, max and min weight, relevant documentation (POH, Maintenance Schedule, etc.) and in most cases the master minimum equipment list (MMEL). Individual operators may set their own MEL, but it mustn't contain less than is in the MMEL.

For some reason UK CAA doesn't like publishing its TCDS in the public domain - I've had rows with them over that before now. However under ICAO procedures they'll almost certainly reflect the content of the TCDS issued by the country of origin - in this case the US and therefore the FAA issued TCDS. FAA TCDS are online here (http://www2.airweb.faa.gov/Regulatory_and_Guidance_Library/rgMakeModel.nsf/MainFrame?OpenFrameSet) and for the PA28, here (longish.pdf file) (http://www2.airweb.faa.gov/Regulatory_and_Guidance_Library/rgMakeModel.nsf/0/62576bf580f2d27586256b5700597808/$FILE/2a13.pdf)

On page 35 it says (I quote) The basic required equipment as prescribed in the applicable airworthiness regulation (see certification basis) must be installed in the aircraft for certification.

Cross-checking to page 34, it lists (with a stack of caveats and issue states) the certification basis as FAR-23.

FAR-23 you can download from the FAA's website, but I happen to have a copy. It lists the minimum instrumentation that has to be fitted. At paragraph 23.1303 it says...

Sec. 23.1303 Flight and navigation instruments.

The following are the minimum required flight and navigation instruments:
(a) An airspeed indicator.
(b) An altimeter.
(c) A direction indicator (nonstabilized magnetic compass).
(d) <plus lots of other stuff applying to heavy and turbine powered aeroplanes that aren't relevant to this discussion>



So in a nutshell, a compass is mandatory equipment for flying a PA28 on a CofA.

Okay, I'll admit that isn't all that intuitive but the information is there.


G

(or being simplistic, look at section 6.9 of the PA28 operators manual. It lists all the equipment that must be installed (and by implication serviceable). It starts obviously enough with the engine, prop, fuel pump etc. On page 6-25 it lists the compass, Tacho and engine cluster as mandatory, and altimeter and ASI as mandatory unless replaced by an approved alternative.)

[Keef]

This is most odd! I know (from my FAA PPL/IR) about MELs for N-registered aircraft. I even know where to find the MEL for the ones I've flown in the US.

However, there is NOTHING in the POH for our G-reg Arrow (PA28R201) that refers to an MEL or even mentions a compass. The CAA C of A doesn't mention one, either.

So, nothing in anything I have as the "legal" aircraft documents says I need a compass.

I have a copy of the UK AIM, but the index is nbg and life's too short to read the whole book looking for CAA mandating of a compass for flight in the UK, or mandating the FAA MEL. However, bookworm is famous for knowing his way round that tome, and if he says it ain't there, that'll do me.

While I would never fly without a compass (other maybe than in the circuit, where I can see what's going on), I'm baffled as to how I'm supposed to know a compass is mandatory. If it's in some secret document, we need to take that up with the CAA to avoid folks being prosecuted for failing to comply with laws and regulations they know nowt about.

[Saab Dastard]

Genghis,

Thanks for your post - in depth information (as always). I spent quite a long time on various search engines trying to find any information on MMEL and such like.

Keef, I agree with you about how difficult it is to find the information!

Thinking about it, I don't think I would even fly it in the circuit again - what happens if another aircraft has a prang, or there is some incident that closes the single runway? If I didn't have enough fuel to orbit and had to divert to an alternate I might just need the compass! :uhoh:

SD

[Keef]

SD - yep, point taken.

I suppose you do have the gyro DI, which you could set against the runway heading, and hope it didn't precess too far.

Agree. Stay on the ground.

[bookworm]

Genghis

I don't agree with your thread.

1) Whether or not the TCDS is part of the basis for issue of the C of A, the C of A, once issued, incorporates only the AFM, not the TCDS. Limitations are in the Limitations section of the AFM.

2) Your TCDS talks about requirements for certification, not for operation. FAR 91.213 does not apply to G-reg aircraft.

3) It's not reasonable to expect an aircraft to be operated in accordance with a document that is not available (note, BTW, that the incorporated certification basis is CAR 3 from 1956, not the 14 CFR that is the current FAR set. 23.1303 doesn't get a mention).

I think the references to the POH are closer to the mark. I don't have a PA28 AFM, but I do have Mooney M20J and PA30 AFMs. Neither offer a list of mandatory equipment. Section 6 is the weight and balance section in the M20J one, and it does have an "equipment list" that consists of engine, radiator, prop and governor. It has only an "X if installed" column. I can't argue with what's in your PA28 AFM, and if it says that certain instruments are mandatory, then they are. But it does seem strange that there such inconsistencies between types.

I would assert that the minimum equipment for flight is governed by Articles 14/15 (incorporating Schedules 4/5), Art 43(b)/(c) and where relevant Art 31 (Ops Manual for PT).

I'm not 100% that my interpretation is correct. Shall we ask A&C?

[Genghis the Engineer]

Ultimately the TC/TCDS are the top level documents. They're also totally unusable by a normal pilot.

For that reason we have the POH. The POH is authorised by and listed in the TCDS. If there is any conflict between the two it's because somebody made a mistake - there shouldn't be. I was referring to the US TCDS because it was available, I would expect the UK TCDS to also agree with the content of the POH, or the UK version of the POH if that is any different (so far as I know it isn't).

Any aircraft has an approved build state. The aircraft, to fly legally, has to be in that state. So far as airworthiness regs are concerned, a U/S compass is similar to the wrong propeller type or flat tyres. It would be illegal from an airworthiness viewpoint to fly the aircraft in that state, even if from an operational viewpoint you're doing nothing wrong.

To use a simple analogy, if your car MoT has run out, it's illegal to drive it on the road - even if you obey all the speed limits and drive on the correct side of the road; it's driving an un-MOT'd car that's illegal, not how you were driving it.

Different types of-course have different equipment lists. For example, I think that an EGT gauge is MEL on Cessna singles? but not on Pipers. A manufacturer is likely to err on the side of a longer list of minimum instruments than required since it probably reduces the risk of stupid accidents for which they may get blamed.

G

N.B. Try Article 9 point 7. I'd say that anything listed on the TCDS or in the POH as "mandatory" is by definition "necessary for the airworthiness of the aircraft".

N.B.B. The more the merrier.

[NinjaBill]

Hi there,

although im in no position to be able to comment on documentation requireed by aircraft, i do know that ANO articles 63 and 64 say that a pilot (or indeed anyone) may not act in a manner that is likely to endnager the aircraft.

Could it not be argued that having an aircraft take off without having a means of knowing in which direction it is flying, is acting negligently, and in a manner that may endanger the aircraft?

Feel free to flame me regarding this point

NB

[Genghis the Engineer]

A fair point, well made, and arguably absolutely correct.

But, if I'm honest, I think we got beyond that and were enjoying the technical argument.

G

[bookworm]

N.B. Try Article 9 point 7. I'd say that anything listed on the TCDS or in the POH as "mandatory" is by definition "necessary for the airworthiness of the aircraft".

I don't think that there's any doubt that if the AFM (POH) requires something, the aircraft is not airworthy without it. I don't think the TCDS has the same authority as far as operations are concerned. Art 9(7) doesn't actually cover U/S kit, only kit that has been repaired/modified or replaced. :) I think Art 8(1) is sufficient authority for the AFM requirements and limitations. My scepticism, and understand that this is mild scepticism because you are, after all, Genghis, purveyor-of-pretty-damned-reliable-information, comes from not having seen an MEL in an AFM.

If an MEL is a routine part of an AFM, why does the FAA go through all the fuss of 91.213?

Could it not be argued that having an aircraft take off without having a means of knowing in which direction it is flying, is acting negligently, and in a manner that may endanger the aircraft?

The point is that the technical argument does not just affect that scenario. I can take off in my aircraft with an EHSI/gyrocompass, standby DI and two GPSs. I'm not going to get lost! But it does worry me that someone, particularly someone from an insurance company, could question the legality of such a flight because the wet compass is leaking a little.

For that reason, it seems important that we establish the basis for the "approved build state" which Genghis eloquently describes. I'm enjoying the debate too.

[mad_jock]

I have recently had to try and track down a MMEL for a C172.

Ended up talking to a nice chap at the CAA who said that they don't produce MMEL's for under 5700kg.

After talking to one of the inspector of paperwork blokes he told me to copy the FAR for SEP and hack out the bits that we don't have.

IO540-C4D5D i am welll aware of students who write everything down. And I don't bollock them for it.
There are things going on tech all the time.

Fuel pumps
Vac pumps
Mags
Alternators

If the Authorities got hold of a log book where none of these items went tech ever they would be a bit suprised.

But schools being schools will want to postpone them getting fixed until the next check.
I have as proberly most instructors have run with a knackard vac pump but the plane is only used dual or by an experenced pilot who knows the score in VFR.

But there are some things which should go in, all of which effect flight safety.

Compass
Dead mag
tyre creep
alt.
leaking fuel tank

Etc if you don't log these type of items and an accident occurs and you were the last to fly it, your in for a day in court as well.

The view i was putting across was if you have complained repeatedly about about an important instrument and there not doing anything about it log it.

MJ

[Genghis the Engineer]

Bookworm, whilst I disagree with you about which is the top level document, I do agree with you that the POH is the definitive working level document. It does seem more than mildly wrong that the POH doesn't contain a clear list of minimum serviceable equipment since that is the document any operator has most available to them.

I took a look at a Cessna TCDS and that's no more clear, and from memory (I'm allergic to single engined Cessnas so don't keep their documentation around) the Cessna POH doesn't have a clear instrumentation MEL either. Neither can I find anything in CAP455 which is the other obvious place to look. Looking deeper, into JAR-VLA 1-App H which is a JAA approved sample format for an operators manual although it says there must be systems description, there's no requirement listed to state what should be fitted and serviceable for flight.

It's starting to strike me that although the information is there if you look hard enough, there is a definite weakness in current practice - this information should be out in the open. Anybody feel brave and fancy flagging this up to the powers that be?

G

[Pilotage]

Interestingly, if you look at the data sheet for a microlight at http://www.bmaa.org/hads.htm it quite clearly tells you the minimum instruments to be fitted. (bottom of page 4 on HADS HM2 for example).

P

[Sensible]

I rented a PA 28 once, the compass didn't work at all in the climb cos there was a fluid leaking all over my knee and the DI didn't rotate whilst the aircraft was climbing either! I got in so much trouble with ATC that I will never fly an airplane again if the compass and DI are both on the iffy side! The aircraft only had one com as well but that's another story but at least the donk didn't pack up!

[benhurr]

I have flown from a number of schools in the UK - MEL was always in the Flying/Pilots Order Book in each case. This document has to get CAA approval.

Magnetic compass and compass deviation card must be present and functioning correctly.

[Keef]

But there's no MEL in the POH for our Arrow III. Since it's on Private Cat and not hired out, there is no Flying/Pilot's order book anyway.

Does that mean that legally we don't need a compass?

[mad_jock]

As usual with CAA stuff there s nothing in writing.

if the **** hits the fan its up to pilots call.

everything is eventually referenceds to a FAR under 5700kg

Which say you must have a working alt, compass and clock.

Which thinking about it is all you really need for VFR.

Is still whooly as **** and basically lets you fly as long as nothing happens. Buts allows them to shaft you as they see fit.

BTW this is exactly the same in motor law which is all set up so that a car exiting a factory is illegal as soon as it leaves the preduction line.

MJ

Who has poked 40tonne lorrys down the road for the last 10 years and still hasn't driven a legal HGV on the road yet.

[Circuit Basher]

MJWhich say you must have a working alt, compass and clock. - well, I think there must be very few of the aircraft that I've flown in the last few years that have had a working clock! There was one that I could get working if I wound it up and set it, but I'm struggling to think of any others!!
:O ;)

[Keef]

WORKING clock? No, it says you must have a CLOCK. An approved-for-aircraft-use one.

I don't think I've ever been in a C1xx or a PA28 with a clock that works. We tried for a while to get one that did, but the cost was prohibitive. A Breitling, araldited to the panel, would be cheaper.

I wear a watch, and carry a spare one (with my spare glasses).

[mad_jock]

Fair comment about the clock.

:D

MJ

[BEagle]

I understand that only FTOs, not RFs have to have an 'approved' flying order book?

We worked out a simple list for the PA28 together with associated restrictions based on commonsense and experience - never had any problem. For example, we require that 2 radios must be serviceable for fligh above overcast cloud. This is the list we use:

Radio: 1 VHF Comm radio shall be serviceable. With only 1 serviceable VHF Comm, the aircraft shall not be operated above overcast cloud.

Intercom: Shall be serviceable with more than 1 aircraft occupant.

Transponder: If unserviceable, the aircraft shall be flown dual only or by qualified licence holders approved and briefed by the Duty Instructor. ATC shall be informed of the unserviceability.

GPS: Warrior II aircraft – No restrictions. Cherokee 140C aircraft – VHF element of Comm 2 (GPS/Comm) shall be serviceable if Comm 1 is unserviceable.

Parking brake: Shall be serviceable.

Toe Brakes: Shall be serviceable on LH side.
(RH side shall also be serviceable for early dual lessons)

Engine oil leaks: If minor, one ferry flight to the maintenance organisation may be flown with the specific authorisation of the CFI. Suspected leaks shall be notified to the Duty Instructor before flight.

Starter motor: If unserviceable, the aircraft shall not be flown.

Alternator: If unserviceable, one day VMC ferry flight to the maintenance organisation may be flown with the authorisation of the CFI.

Suction pump: If unserviceable, one day VMC ferry flight to the maintenance organisation may be flown with the authorisation of the CFI.

Carb Heat: If unserviceable, one day VMC ferry flight to the maintenance organisation may be flown.

Primary Flying Controls: Shall be serviceable.

Flaps/Trimmers: Shall be serviceable.

Stall Warner: Shall be serviceable.

Fuel System:

Electric Pump: If unserviceable, one ferry flight to the maintenance organisation may be flown. Aircraft Commanders shall use the maximum runway length available on departure and shall minimise flight time below 1000 ft agl.

Fuel Leaks: The aircraft shall not be flown.

Magnetic Compass: If unserviceable, the aircraft shall not leave the aerodrome circuit except for one day VMC ferry flight to the maintenance organisation.

Artificial Horizon: If unserviceable, the aircraft may be flown in day VMC only.

Direction Indicator: If unserviceable, the aircraft may be flown on dual local flights in day VMC only.

Pitot Heater: If unserviceable, the aircraft may be flown in day VMC only.

Internal Lighting: Shall be serviceable for Night Flying.

Navigation Lights: Shall be serviceable for Night Flying.

Landing Light: If unserviceable, Night Flying may only be conducted with the approval of the Duty Instructor at the Commander’s discretion.

Fin Beacon: Shall be serviceable for Night Flying.

[IO540-C4D5D]

Beagle,

"Direction Indicator: If unserviceable, the aircraft may be flown on dual local flights in day VMC only."

I am sorry to ask this but does this mean that some instructor would still take a student up in such a plane and get him to pay the £100/hour or whatever?

Let's face it, no PPL with more than two braincells are going to self fly hire a plane with a duff DI.

Your list makes sense but it makes a very sad commentary on the state of GA - how long does it take to change a light bulb for example? (no light bulb jokes please :O )

[FormationFlyer]

Hate to dfiffer here...

Why do you need a DI unless required by the ANO as a PPL??? Cant you fly with just a compass? ;)


As an instructor I dont need a DI for Effects of controls pt1 or part 2, nor ex10A, 11A, 10B.1, 10B.2 - none of these require use of the DI per se - my students arent navigating at this stage and therefore navigation of the aircraft is controlled by me and they fly by reference to visual points outside the cockpit - which is where I want them to be flying - not heads inside.....

So it can work quite happily - you just need to be intelligent about how you use an aircraft.

P.S Microlights manage without DIs. This may come as a shock to some....In fact I even got my PPL without ever seeing a DI.....

Regards,
FF

IO540-C4D5D - With regard to 'sad commentry on GA' - I assume you are on an airfield where approved engineers are available 24x7. Ah thought not. **** happens as they say....it takes time and timing to get problems rectified.

FF

[Pilotage]

It should be said however FF that most microlights are fitted with big, chunky, easy to read compasses - usually the Silva yacht types. Most GA compasses are only used for updating the DI, and therefore are only designed to be read whilst flying straight and level in reasonably unbumpy conditions.

I find it much easier generally to navigate by compass alone in a microlight than in a GA type such as a PA28 with a u/s DI.

P

[FormationFlyer]

Granted. GA compassess are fickle affairs...but its not impossible. I personally use timed turns in light aircraft anyway...but still not impossible for those of us who havent given way to GPS as sole means of nav.....

Hell if you have GPS then why do you need a DI anyway? ;)