Hello, the new requirements for LOA D095 are the significant change as you’ve gathered and it’s required if not applying for LOA D195. Supporting FAA new changes issued in October are attached.
This is a mandate and it’s not an option for Turbine Aircraft which prior to October 11, 2023 in the past, a 91 Operator could “Use the FAA MMEL as the MEL” (this LOA was never an “FAA-APPROVED” MEL) and was subject to a few additional requirements.
*EASA will still require a Serialized Special MEL with FAA LOA D195
Let’s clarify these new requirements. An FAA-approved MEL is now required for Turbine Aircraft and cannot be used under CFR Part 91.213(d)(1)(i) and (ii) as of October 13, 2023, the FAA MMEL can no be used in it’s previous form and is no longer accepted as an MEL in any form. It must be used under CFR 91.413(a). The flow chart illustrates this:
Why does an operator require an FAA-APPROVED MEL? This is the real benefit as soon as an ATA Item listed in the MEL becomes inoperative as it is an STC for the aircraft and allows the operator to conduct flight operations with MEL listed inoperative items as follows:
The 1st requirement:
- 14 CFR Part 91 states that all Turbine Aircraft require an MEL that complies with FAA Order 8900.1A Volume 4, Chapter 4, Section 2 and in accordance with AC 91-67A.
- The FAA now considers both LOAs D095 (D095 as of October 11th, 2023) and D195 to be accepted Worldwide for an FAA-Approved MEL.
- The FAA now considers an FAA-APPROVED MEL under LOA D095 and D195 as a mandatory requirement for all Turbine Aircraft Worldwide.
The 2nd and 3rd requirements:
- Under the new FAA requirements as of October 11th, 2023 as referenced above, the following changes have replaced FAA LOA D095 Use of the FAA MMEL as the MEL.
- It is important to note that Operators who were previously issued LOA D095 for Use of the FAA MMEL as the MEL prior to October 11th, 2023 ARE NOT considered “FAA-APPROVED” as the follow the expired FAA requirements and previous AC 91-67.
- The MMEL is now converted to a Serialized MEL with Maintenance, Operating, Placarding Procedures and 91 CFR as applicable under LOA D095.
- The MMEL is still converted to a Serialized MEL with Maintenance, Operating, Placarding Procedures and 91 CFR as applicable under LOA D195.
So what’s the difference between LOA D095 and D195 for a CFR Part 91 Operator?
Answer:
- D195 LOA is issued for an Operator-created Custom Serialized MEL based on the MMEL and other FAA Approved Aircraft Documents which uses a Custom Maintenance, Operating, and Placarding Procedures with CFR Document and is more specific and defined in it’s format and presentation of information. It also contains a Management, Training, and Non-Essential Furnishings Sections with a Maintenance Discrepancy Form. This is the most complete and useful version.
- D095 LOA is issued for an Operator-created minimal customized MEL based on the MMEL which uses the Aircraft Manufacturer’s Maintenance, Operating, and Placarding Procedures Document with CFR as an Appendix. It contains a Maintenance Discrepancy Form.
- These are the basics as the MEL M & O Procedures are serialized to specifically reflect which items are physically installed which requires removal of Maintenance and Operations Procedures for ATA Items not installed e.g., 1 HF Radio vs 2 or Satphone installed or not.
- The issue is the FAA duration of the Approval. The FAA will have to review with 2-3 Inspectors and the timeframe varies between FSDO’s and their current workload at the times its submitted.
- We provide LOA/OpSpec D195 quality Level 91, 125, and 135 Serialized and Fleet MELs.
- Every MEL is a custom document based on the Aircraft’s configuration and serial number.
- Revision service is provided when required for standard FAA MMEL Revisions and must be complied with when issued. MEL Revision service is provided at a Flat rate of $250.00 per day. SourceOne Aviation Compliance does not charge annual subscriptions fees of $500 to $1000 that several companies charge.
FAA Approval Time Frame: MELs after the FAA review starts, range from 14 days and 11 months for FAA approval. The FSDO’s and IFO’s control the duration. By calling your FSDO, they can provide an estimate of the duration. E.g., the FAA is staffed at approximately 40% Staffing Levels from Thanksgiving thru January 10th approximately.
Please let us know if you have any additional questions
