That MMEL Thing: Here’s an Update

By David Mumford


It looks like there might finally be a solution to the long-running MEL vs MMEL issue for US operators headed to Europe, keen to not get a ramp check finding!

The brief Backstory

Since 2017, US aircraft have been getting hit with ramp check findings in Europe because EASA decided that the D095 LOA wasn’t good enough – they wanted to see a D195 LOA instead, but it was taking operators a long time to get these approved by the FAA in the US due to a big backlog of applications.

The Solution

The FAA has published an updated Advisory Circular (AC 91-67A) which speeds up the process of getting this D195 LOA.

The NBAA have reported that the FAA has also updated guidance to its field offices, who will now issue the LOA after a brief review, provided the application is accompanied by an “attestation letter”.

The slightly longer Backstory

Over the past few years, ramp checks on some US aircraft in Europe highlighted an important issue – EASA and the FAA have different interpretations of the ICAO standards regarding deferring aircraft discrepancies.

In the US, with FAA authorization operators can use a master minimum equipment list (MMEL) to defer repairing certain equipment. But in Europe, MMEL cannot be used in lieu of an MEL specific to each aircraft or fleet.

The European Aviation Safety Agency (EASA) began requiring all aircraft transiting European airspace to have an approved Minimum Equipment List (MEL) for each, individual aircraft (i.e. a D195 LOA). An MEL that references the MMEL was not acceptable (i.e. a D095 LOA).

This was a pain for US operators, as to get an individual MEL approved under the LOA from the FAA takes time – but by not doing so, they ran the risk of getting a ramp check finding in a European country. (France seems to be the place where this happens most often!)

At the start of 2018, the rumour was that the FAA and EASA reached an agreement: the FAA would start requiring international operators with D095 LOAs to obtain new D195 LOA’s instead, and in return EASA would halt any findings for a period of 12 months to allow for these new LOA’s to be issued. There was no official announcement on this, but SAFA data did indicate that ramp check findings for use of D095 were greatly reduced for a time.

The FAA proposed a policy change to phase out the D095 LOA over the next 3-5 years, and to work out a streamlined approval process to issue everyone with D195’s instead.

The French CAA said they would stop issuing ramp check findings once the FAA has launched the new policy.

FSDOs across the US then started processing the backlog of D195 requests from operators (there were lots!). In the meantime, US operators with the D095 LOA continued to face the same old MMEL findings on ramp checks in Europe.

How to prepare for a ramp check in Europe?

Here’s the article we wrote all about how to make a ramp check painless.

And here is a copy of the OPSGROUP SAFA Ramp Checklist. Download it here.

Keep a copy with you and run through it before you head to Europe.

Further Reading


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