July 9, 2020
The FAA recently published Policy Letter 36 (PL-36) Revision 3 regarding approval of and the preamble for Part 91 Minimum Equipment Lists (MEL).
PL-36 describes different paths for additions or changes to an MEL, depending on whether the change is driven by the aircraft Type Certificate or a Supplemental Type Certification (STC). The FAA directs operators to PL-109, Supplemental Type Certificate MMEL/MEL Relief Process, for additional guidance on how to add STC installed items to an MEL.
PL-36 also updates Part 91 MEL preamble language and clarifies operator requirements to develop maintenance and operations procedures for items listed in the MEL.
NBAA has for years been working with the FAA, the European Aviation Safety Agency, and the International Civil Aviation Organization to bring clarity to provide clear guidance MEL’s and Master Minimum Equipment Lists. The lack of clarity has led to confusion for operator documentation requirements, especially in regard to Safety Assessment of Foreign Aircraft ramp inspections at European airports. The association offers a white paper with guidance regarding SAFA inspections and required documentation.
“This revision is a big step in helping to clarify the processes related to Part 91 MELs, especially in regard to STCs,” said Stewart D’Leon, NBAA’s director of technical operations. “When you consider ADS-B compliance, COVID response and other quickly evolving technology, even newer aircraft might have a lot of STCs. Operators should review Policy Letters 36 and 109 and be sure those items are properly referenced in the MEL.”
Operators should update their MELs to include the new preamble language and contact their responsible Flight Standards Office with any questions.