Minimum equipment lists

It was one of those moments during a checkride when one relies more on blind luck than pure
knowledge. I had just started both engines of the Piper Seminole I was flying for my multiengine
rating, and I was scanning the engine instruments: oil pressure in the green; fuel pressure in the
green; vacuum pressure - left OK, right - I>not OK. The right vacuum pump was out. The
examiner looked at me and said those infamous words, "Can we go?"

My mind went blank. This wasn't supposed to happen; mechanical failures don't happen on
checkrides, they happen in briefing rooms with my instructor. But there I was, faced with a real
mechanical failure and two possibilities: Either we're legal to fly or we aren't. I remembered that
this aircraft operated with a minimum equipment list (MEL). I told the examiner that I would
need to check the MEL before I could give a definite answer to his question. With his approving
nod, I shut the aircraft down and proceeded to verify if we could continue the flight.

I ended up switching aircraft and passing the checkride. However, if my instructor hadn't
explained operations with an MEL, the outcome would have been very different. Operations with
inoperative equipment is a topic of utmost importance that doesn't always receive proper
coverage during instruction. When a piece of equipment is found to be inoperable, there are two
paths to determine if the aircraft is airworthy - using an approved MEL or FAR 91.213. Let's
examine both options.

Operations with a MEL

An MEL is a list of equipment that must be installed and operable for the aircraft to be
considered airworthy. It is aircraft-specific and spells out which pieces of equipment may be
inoperable while maintaining airworthiness. If something is found to be inoperative, the pilot
goes to the MEL, finds the entry for that item, and determines if the airplane must be grounded
until that piece of equipment is fixed.

An MEL for a specific aircraft originates from a master minimum equipment list (MMEL). The
MMEL is a list of all equipment on an aircraft type; it details which equipment is allowed to be
inoperative without grounding the aircraft. (Think of a MMEL as a general, broader MEL.) The
FAA has developed and has on file MMELs for most of the type-certificated aircraft in use
today. The owner/operator who wishes to obtain an MEL for his or her specific aircraft will first
contact the local flight standards district office and request a copy of the MMEL for that aircraft
type. At that point it is the responsibility of the owner/operator to use the MMEL in conjunction
with the airplane flight and maintenance manuals to create a specific procedures document for
the aircraft.

The procedures document outlines the actual procedures to make the aircraft airworthy in the
event of the failure of a specific piece of equipment. There are two categories of procedures:
maintenance procedures (M) and operations procedures (O). An authorized mechanic must
complete "M" procedures, but the pilot or flight crew can do "O" procedures. If an "O" procedure
is required, it will be accompanied by a detailed action list for that particular piece of equipment.
Once the owner/operator has created the procedures document, it is presented to the FAA for
approval. If granted, the FAA inspector will issue a letter of authorization (LOA). When this
letter is received the MEL is complete and the aircraft may be operated within the guidelines of
the MEL rather than the procedures outlined in the regulations. This formula will help you
remember: MMEL + Procedures Document + LOA = MEL.

When a part of the aircraft is found to be inoperative the pilot will refer to the MEL. If the item is
not in the procedures document, the aircraft is grounded. If the item is found, the pilot will take
the appropriate actions required by the procedures document. Once the procedures are completed
the aircraft is ready to fly.

An MEL is equivalent to a supplemental type certificate and is required to be on board the

Operations under FAR 91.213

For those aircraft operating without an MEL, FAR 91.213 describes the process of determining
the airworthiness of an aircraft with inoperative equipment. Use these four questions to verify
whether or not your aircraft is legal to fly under 91.213.

1. Is the affected equipment part of the VFR-day type certificate (91.213 [d][2][i])? If yes,
the aircraft is grounded. If no, go to the next question.
2. Is the affected equipment listed as required on the aircraft's equipment list or kinds of
operation list (91.213 [d][2][ii])? If yes, the aircraft is grounded. If no, go to the next
question.
3. Is the affected equipment required by any other regulation, i.e. 91.205, 91.207, etc.
(91.213 [d][2][iii])? If yes, the aircraft is grounded. If no, go to the next question.
4. Is the affected equipment required to be operative by an airworthiness directive (91.213
[d][2][iv])? If yes, the aircraft is grounded. If no, go to the final step.

The final step is that the affected item must be removed from the aircraft or deactivated and
placarded inoperative (91.213 [d][3][ii-iii]).

The go/no-go decision is one of the most fundamental decisions that a pilot will make, and an
integral part of that decision is determining the airworthiness of the aircraft. Understanding how
to make that determination is crucial to a student’s development. No one needs to be sweating
bullets next to an examiner who asks the simple question, "Can we go?"

David Wright is director of training for the AOPA Air Safety Foundation. A former pilot for US
Airways Express, he is a CFI with more than 2,000 hours

By David Wright