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Minimum Equipment List

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Old 27th May 2003 | 05:40
  #1 (permalink)  
Saab Dastard
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Question Minimum Equipment List

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
 
Old 27th May 2003 | 07:04
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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
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Old 27th May 2003 | 07:13
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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.
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Old 27th May 2003 | 07:17
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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
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Old 27th May 2003 | 14:26
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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'.
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Old 27th May 2003 | 15:12
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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)
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Old 27th May 2003 | 17:00
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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

IMHO a working compass is mandatory - even if many/most pilots rarely look at it.
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Old 27th May 2003 | 17:23
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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?
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Old 28th May 2003 | 01:54
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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
 
Old 28th May 2003 | 04:22
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Question

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.
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Old 28th May 2003 | 04:59
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bookworm

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.
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Old 28th May 2003 | 05:15
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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 and for the PA28, here (longish.pdf file)

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.)

Last edited by Genghis the Engineer; 28th May 2003 at 14:27.
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Old 28th May 2003 | 06:28
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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.
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Old 28th May 2003 | 06:38
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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!

SD
 
Old 28th May 2003 | 07:05
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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.
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Old 28th May 2003 | 16:31
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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?
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Old 28th May 2003 | 21:20
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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.
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Old 28th May 2003 | 21:36
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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
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Old 28th May 2003 | 23:50
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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
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Old 29th May 2003 | 01:45
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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.
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