The FAA is set to issue new guidance to provide a resolution to the long-running MMEL vs MEL debacle. However, it may not be the one we were expecting!
Last year, ramp checks on some US aircraft in France 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. An MEL that references the MMEL was not acceptable.
This was a pain for US operators, as to get an individual MEL approved under the Letter of Authorisation (LOA) from the FAA takes time – but by not doing so, they ran the risk of failing a ramp check in a European country.
At the start of 2018, we understood that the FAA had reached an agreement with EASA: the FAA would start requiring international operators to obtain new D195 LOA’s, and in return EASA would halt any findings for a period of 12 months to allow for these new LOA’s to be issued.
But now we understand the FAA have decided that making operators get new D195 LOA’s will be far too much work for everyone involved!
Instead, they intend to just continue to issue the D095 approvals – but they will more vigorously validate the required components (such as the Preamble and M&O procedures).
This certainly appears to present a reversal of the previous commitment to EASA, who may very well not accept these LOA’s. If that happens, then the approval won’t be valid over in Europe – meaning ramp checks of N-reg aircraft in European countries will once again throw up the old MMEL finding, just like before.
We expect the FAA to officially issue this updated guidance to inspectors in the very near future, to be followed by a FAA InFo Letter to Part 91 Operators. The NBAA have said they will issue a bulletin to share the guidance as soon as it is released.
We wrote a 2017 article all about how to make a ramp check painless.
We have also updated the FSB SAFA Ramp Checklist. Download it here.
Keep a copy with you and run through it before you head towards the EU.
- EU SAFA ramp checks NOT on the rise – but are you ready for one?
- SAFA Ramp Checks – Guidance Material
- How are ramp checks performed?
- Special thanks go to Mitch Launius at 30westip.com for help with this post.