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JammedStab
17th Apr 2017, 18:48
Is there a particular reason for this?

EASA: U.S. Operators Can’t Use MMEL in Europe
U.S. Part 91 twin turboprops and jets flown in Europe must now operate with a Minimum Equipment List (MEL) developed for that specific aircraft under Letter of Authorization (LOA) D195, rather than with a manufacturer’s aircraft model Master MEL (MMEL) approved by the FAA under LOA DO95. Laurent Chapeau, head of the ramp inspection office of the French Safety Oversight Authority, which administers SAFA ramp inspections for third-country operators in France, has affirmed EASA’s recent recognition of the ICAO standard.

“The regulation is now clearly written from last November,” Chapeau said, adding that his agency has noted a lack of compliance “during ramp inspections in the last few months.” In some cases, inspectors “did raise Category 2 findings,” which represent “significant impact on safety” and require operators to take follow-up preventive action.

Under ICAO guidelines, LOA DO95 doesn’t provide the oversight or approval process required for a valid MEL. FAA Flight Standards is reportedly developing compliance solutions for affected U.S. operators. The U.S. is the sole ICAO signatory country that allows operators to use an MMEL as an MEL.

galaxy flyer
18th Apr 2017, 00:50
This is ridiculous for corporate operators.

BizJetJock
18th Apr 2017, 10:05
Is it? Why? If you know your aircraft well enough that you can look at the MMEL and say authoritatively "this doesn't apply to my aircraft since we have SB xxxx", then creating an MEL is about an hours' work.
The whole point of this is that the majority of crews not only can't do that, but often there is no easy way for them to find out, rendering the MMEL at best useless and sometimes outright dangerous.

galaxy flyer
18th Apr 2017, 15:53
First, the shear volume of US Operators means the FAA couldn't possibly review and approve an MEL for each plane. Heck, they're months behind on simple LOAs like RNP and CPDLC. I've heard of FSDOs taking six months to approve new requests. There is reason the FAA is trying for a workaround, they don't want it.

Second, a CAMP report will easily uncover the SB status, if it applies. As opposed to commercial operators, almost no private operator has the technical knowledge and tech writing support to publish a MEL for each type operated.

Third, the number of open MELs in the corporate FAR 91 fleet is vanishingly small, meaning the cases where the MMEL use would be causal to a safety hazard is infinitesimal.

EASA really is a Campaign Against Aviation. Or is it European Agency to Smother Aviation?

BizJetJock
18th Apr 2017, 18:47
First, the shear volume of US Operators means the FAA couldn't possibly review and approve an MEL for each plane. Heck, they're months behind on simple LOAs like RNP and CPDLC. I've heard of FSDOs taking six months to approve new requests. There is reason the FAA is trying for a workaround, they don't want it.

A very good point. Although if you can show it is pending an MEL being approved this should be no problem, since EASA issues temporary authorisations to use an MMEL for new aircraft.
almost no private operator has the technical knowledge ... to publish a MEL for each type operated
Is this not the nub of the issue? If they haven't got the technical knowledge to produce an MEL from the MMEL, how can they use the MMEL on a day to day basis?
the number of open MELs in the corporate FAR 91 fleet is vanishingly small
Unfortunately, 20 years of Part 91 experience tells me that this is more down to nothing being put "in the book" until the aircraft goes for maintenance rather than there being no snags on the aircraft. Again, the lack of technical knowledge comes to the fore, since often they are things that could not have been deferred anyway but people carry on flying oblivious to how they have reduced their safey margins. All in all not a good argument for the current system.

Amadis of Gaul
18th Apr 2017, 21:17
Is there a particular reason for this?

EASA: U.S. Operators Can’t Use MMEL in Europe
U.S. Part 91 twin turboprops and jets flown in Europe must now operate with a Minimum Equipment List (MEL) developed for that specific aircraft under Letter of Authorization (LOA) D195, rather than with a manufacturer’s aircraft model Master MEL (MMEL) approved by the FAA under LOA DO95.


I'm curious how big of an issue this is in reality. Are the very many N-reg King Airs running around Europe?

galaxy flyer
19th Apr 2017, 16:10
No, but large number of large cabin jets do.

Ifly4folks
5th May 2017, 18:07
We are a large cabin operator that is currently suffering with this newly imposed D195 requirement from EASA. The situation has finally boiled over the top and the FAA is having to face inquiries and requests from numerous 91 operators wanting to convert their D095 to a D195, and have it done expeditiously. I have been personally told by our FSDO and Regional Office that there will be no special consideration given to any/all 91 operators seeking relief from this EASA requirement. The FAA stated that there was a effort underway in Washington that is attempting to get relief (temporarily) from this requirement. The bottom line, as I am told, is the FSDO and FAA Regional does not have anywhere near the human resources necessary to address this issue. It is a difficult situation. Many of the Fortune 500 companies that routinely fly in and out of Europe are canceling and rescheduling their European travels until this issue gets resolved. Sadly, unless you are subjected to a SAFA inspection while in Europe you could actually dodge this inspection requirement. But, if grounded as a result of non-compliance, would it have been worth it?

galaxy flyer
6th May 2017, 16:18
Utterly ridiculous requirement! Can you go sans MEL, if anything breaks, just be grounded or is there an EASA requirement for an MEL regardless of maintenance status?