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No TCAS, no flight

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Old 26th Apr 2023, 07:15
  #21 (permalink)  
 
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Originally Posted by mnttech
The FAA does not know if you are going to operate the aircraft Part 91, Part 121, Part 135 etc.
Of course they do (or at least, here they do). We have an approved MEL for our operation. Either operation for three days with the TCAS inop is in the MEL and therefore approved, or it's not. You can't have some wally in an out-office saying "the MEL doesn't apply, you have to have the TCAS working for every flight" because the base rule says you need it.
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Old 26th Apr 2023, 07:39
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Originally Posted by Capn Bloggs
Of course they do (or at least, here they do). We have an approved MEL for our operation. Either operation for three days with the TCAS inop is in the MEL and therefore approved, or it's not. You can't have some wally in an out-office saying "the MEL doesn't apply, you have to have the TCAS working for every flight" because the base rule says you need it.
Not only that, but the base rule will say the equipment must be fitted to the aircraft, but there will be another rule allowing the development of an MEL that permits the fitted equipment to be unserviceable for a period of time. I haven’t checked FAR 121 but 135 is done that way and I’m sure 121 will have a similar clause.
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Old 26th Apr 2023, 09:36
  #23 (permalink)  
 
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Just for the nervous flyers; over the last 20 years; flying regularly in VERY busy airspaces, including the London FIR, Paris and New York, I have only ever had a handful of TCAS TAs, (Traffic Advisories, i.e. warnings of potentially conflicting traffic, but no recommendation to change flight path), but NEVER any RAs, (Resolution Advisories, i.e. recommending action to be taken to avoid actual conflicting traffic).

We do get them in every 6 month Simulator check, to practice the avoidance manoeuvre(s), but I have never had one for real.

Air traffic control in 'civilised' places is very good and safe

PS, Most TAs are caused by your, or other, aircraft climbing or descending more rapidly than 'normal' but nevertheless to a safe flight level above or below the conflicting traffic; so there is no collision risk. Such TAs are easily and quickly resolved by simply reducing their (or your) vertical speed.

TCAS is an extra safety layer on top of the many other tried and tested ATC procedures and systems.
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Old 26th Apr 2023, 11:41
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I have updated my post
The FAA team that writes the MMEL does not know if you are going to operate the aircraft Part 91, Part 121, Part 135 etc. Each operator has to then take the MMEL, and update it for their operation, and submit it to the FAA for approval.
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Old 26th Apr 2023, 12:08
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Originally Posted by mnttech
Each operator has to then take the MMEL, and update it for their operation, and submit it to the FAA for approval.
If a company even hinted it was going to run a high-capacity pax operation ie Part 121 op the FAA would be all over it like a rash well before even the MEL-approval stage. And as you say, the MEL has to be approved for that company aircraft.

Unless Horizon is/was operating without an approved MEL, or their MEL did not permit the normal 3 day grace period for TCAS rectification, that FAA inspector is out of line by unilaterally stopping them from operating with a U/S TCAS. I suppose we'll never know unless we get a copy of their approved MEL for the 175.
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Old 26th Apr 2023, 12:33
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Some interesting scenarios here:

https://www.airliners.net/forum/view...?f=3&t=1483455
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Old 26th Apr 2023, 13:00
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Originally Posted by Capn Bloggs
I suppose we'll never know unless we get a copy of their approved MEL for the 175.
Something I was about to post, thank you

Along with what equipment is on the aircraft, as you noted the in the airliner.net link the background between the two groups, and what the writer of the report meant.
A quick check here does not show any of the majors with an posted FAA exemption to 121.356.
https://aes.faa.gov
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Old 26th Apr 2023, 13:45
  #28 (permalink)  
 
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I doubt whether an exemption is granted to anybody to allow use of an MEL. I can't find any reference to US operators, but have a look at the extensive information on MELs for foreign operators of US registered aircraft:

https://www.ecfr.gov/current/title-1...section-129.14

Clearly, the approval for and use of an MEL is embedded in the regs and presumably not an "exemption".

I also severely doubt that there are any 121 operators in the US that don't have an MEL that allows 3 days grace for TCAS.

Something fishy going on.
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Old 26th Apr 2023, 14:26
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Just an aside:
in “Olden Daze” it was quite normal when using Maps, ADF, VOR ect to operate betwixt Greater Moosepoop and Little Moosepoop and see no other traffic.
Then along came GPS and we would see a lot more traffic because we were all exactly on track

There was an unwritten rule that you always flew on the right side of any river, lake, road, dogsled track, valley, railway or power-line for avoidance of opposite direction traffic. (“Humm 200 overcast 1 mile in rain and fog! Weather’s too bad for IFR! Guess we’ll have to go VFR”)
.

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Old 26th Apr 2023, 15:08
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Originally Posted by mnttech
Something I was about to post, thank you

Along with what equipment is on the aircraft, as you noted the in the airliner.net link the background between the two groups, and what the writer of the report meant.
A quick check here does not show any of the majors with an posted FAA exemption to 121.356.
https://aes.faa.gov
You don’t need an exemption, you just need an MEL in accordance with 121.628. That is the method by which the FAA approve an aircraft to be flown with inoperative equipment. An exemption would be required for something that was not covered by the MEL.

https://www.ecfr.gov/current/title-1...ection-121.628

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Old 26th Apr 2023, 15:53
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And around and around and around and around we go...
Originally Posted by AerocatS2A
You don’t need an exemption, you just need an MEL in accordance with 121.628.
https://www.ecfr.gov/current/title-1...ection-121.628
§ 121.628 Inoperable instruments and equipment

(b) The following instruments and equipment may not be included in the Minimum Equipment List:

(3) Instruments and equipment required for specific operations by this part.
Does the requirement for TCAS under 121.356 fall under 121.628(b)(3)?
We don't know....
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Old 26th Apr 2023, 16:03
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Originally Posted by mnttech
And around and around and around and around we go...

Does the requirement for TCAS under 121.356 fall under 121.628(b)(3)?
We don't know....
That would cover specific operations, like ETOPS. The TCAS is a general requirement of 121, it’s not related to a specific operation.
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Old 26th Apr 2023, 16:43
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Originally Posted by mnttech
And around and around and around and around we go...

Does the requirement for TCAS under 121.356 fall under 121.628(b)(3)?
We don't know....
How do you read 121.303? https://www.ecfr.gov/current/title-1...ection-121.303

The TCAS isn’t listed.
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Old 26th Apr 2023, 18:34
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Originally Posted by AerocatS2A
That would cover specific operations, like ETOPS. The TCAS is a general requirement of 121, it’s not related to a specific operation.
OK, where is “specific operations” defined? Not disagreeing, but in a quick search I don’t see the term defined in 121 or 14 CFR 1. Would Night IFR over water be a specific operation?
Originally Posted by AerocatS2A
How do you read 121.303? https://www.ecfr.gov/current/title-1...ection-121.303
The TCAS isn’t listed.
Not sure, the only thing I noted is the TCAS rule is a weight and class controlled while 121.303 is for all operations. There appear to be a couple other rules that drop out too.
We can play rule poker all day long, but those that work for the FAA have a little more pull. I have not dug into any of the policies, orders or Memo's (which may set policy) that the FAA has that defines the rules (law). Nor have I looked at any of the AC's that provide guidance to reaching the rule.
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Old 26th Apr 2023, 22:58
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Originally Posted by mnttech
OK, where is “specific operations” defined? Not disagreeing, but in a quick search I don’t see the term defined in 121 or 14 CFR 1. Would Night IFR over water be a specific operation?

Not sure, the only thing I noted is the TCAS rule is a weight and class controlled while 121.303 is for all operations. There appear to be a couple other rules that drop out too.
We can play rule poker all day long, but those that work for the FAA have a little more pull. I have not dug into any of the policies, orders or Memo's (which may set policy) that the FAA has that defines the rules (law). Nor have I looked at any of the AC's that provide guidance to reaching the rule.
Do you fly? What does your MEL say? We only need any US 121 operator to be shown to have TCAS on their MEL to demonstrate that it is allowed by the rules. It’s on my MEL for the A320 but it’s not a US company, so a bit irrelevant. Ours is even more lenient, running up to 10 days except for specific operations including uncontrolled airspace and NATS airspace with half degree track spacing.
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Old 27th Apr 2023, 01:47
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Originally Posted by AerocatS2A
Do you fly?
Not any more, the B707 I crewed was retired long before TCAS was approved, and the 14 CFR 135 operator I work for does not need TCAS.
I would like to see a USA 121 MEL too.
But that is kind of the drift of the whole thread, do we have a rouge inspector, or has everyone not been reading the rules?
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Old 27th Apr 2023, 16:42
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Originally Posted by mnttech
.
But that is kind of the drift of the whole thread, do we have a rouge inspector, or has everyone not been reading the rules?
The airframer publishes the Master MEL (BTW, the MMEL has different provisions for ETOPS and the like). Each operator then takes that MMEL and 'customizes' as necessary for their operation and gets that approve by the local regulator(s) - usually their MEL is identical (or nearly identical) to what the airframer put out. An operator can put in more restrictive provisions into their customized MEL, but it is very, very rare that an operators MEL is less restrictive than the MMEL (and it is very messy to get that approved by the regulators).
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Old 28th Apr 2023, 15:03
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The Seattle Times editorial board has produced this hot mess of an opinion piece, concluding that the 3-day TCAS grace period is a “huge risk.”

FAA’s priority should be passenger safety, not airlines’ profits
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Old 28th Apr 2023, 15:37
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Originally Posted by BFSGrad
The Seattle Times editorial board has produced this hot mess of an opinion piece, concluding that the 3-day TCAS grace period is a “huge risk.”

FAA’s priority should be passenger safety, not airlines’ profits
And they are being royally roasted in the comments for talking about something they know nothing about.
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Old 28th Apr 2023, 19:02
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Originally Posted by tdracer
And they are being royally roasted in the comments for talking about something they know nothing about.
Hah! Hadn’t read the comments. A well-deserved weenie roast. These days it’s not unusual for the comments associated with a news article to be more informative than the article itself. Both the original Gates’ article and the editorial do a poor job of quantifying the risk of an inoperative TCAS.
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