July 7, 2016
NBAA recently submitted comments to the FAA opposing the agency’s proposed revision to Master Minimum Equipment List Policy Letter-98, Navigation Databases (MMEL PL-98).
The original policy letter describes how operators may defer an expired navigation database until a time and location in which the database can be properly updated, by verifying navigational waypoints in the expired database with current aeronautical charts. The proposed revisions would rescind operators’ ability to defer an expired navigation database in accordance with a minimum equipment list (MEL), as is currently permitted.
NBAA’s comments, submitted June 30, highlight how the proposed revision to MMEL PL-98 is not in agreement with the FAA chief legal counsel’s interpretation addressed to Thomas Letts in November 2012 (known as the Letts interpretation). Letts asked the FAA if he might supplement his expired navigation database with an iPad, and the agency said that to fly with an expired navigation database, an operator must utilize an approved MEL that allows for dispatch of an aircraft with inoperative equipment.
“It is not uncommon for business aircraft operators to travel to remote destinations for more than 14 to 28 days where a reliable internet connection or other supplies may not be available to facilitate timely navigation database updates,” said Jason Herman, lead captain for Latitude 33 Aviation and chairman of NBAA’s Part 135 Subcommittee.
“Additionally, these areas may have limited or no qualified maintenance facilities to assist in performing database updates,” he added. “It is important that operators have a safe, legal, and efficient means to continue their mission should a navigation database expire during a trip.”
The consequences of the proposed revision remain unclear. NBAA is seeking to clarify whether operators will be able to operate VFR with an expired navigation database, as outlined in the Aeronautical Information Manual, or if they will simply not be permitted to fly until such time as the navigation database can be updated, as required by the Letts interpretation.