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allowed with inoperative items, as long as the inoperative
items were determined to be nonessential for safe
flight. At the same time, it allowed part 91 operators,
without an MEL, to defer repairs on nonessential
equipment within the guidelines of part 91.
There are two primary methods of deferring maintenance
on rotorcraft operating under part 91. They are the deferral
provision of 14 CFR part 91, section 91.213(d) and an
FAA-approved MEL.
The deferral provision of section 91.213(d) is widely
used by most pilot/operators. Its popularity is due to
simplicity and minimal paperwork. When inoperative
equipment is found during preflight or prior to departure,
the decision should be to cancel the flight, obtain
maintenance prior to flight, or to defer the item or
equipment.
Maintenance deferrals are not used for in-flight discrepancies.
The manufacturer's RFM/POH procedures are
to be used in those situations. The discussion that
Minimum Equipment List (MEL)—An inventory of instruments and
equipment that may legally be inoperative, with the specific conditions
under which an aircraft may be flown with such items inoperative.
9-2
follows assumes that the pilot wishes to defer maintenance
that would ordinarily be required prior to flight.
Using the deferral provision of section 91.213(d), the
pilot determines whether the inoperative equipment is
required by type design, the CFRs, or ADs. If the inoperative
item is not required, and the helicopter can be
safely operated without it, the deferral may be made.
The inoperative item shall be deactivated or removed and
an INOPERATIVE placard placed near the appropriate
switch, control, or indicator. If deactivation or removal
involves maintenance (removal always will), it must be
accomplished by certificated maintenance personnel.
For example, if the position lights (installed equipment)
were discovered to be inoperative prior to a daytime
flight, the pilot would follow the requirements of section
91.213(d).
The deactivation may be a process as simple as the pilot
positioning a circuit breaker to the OFF position, or as
complex as rendering instruments or equipment totally
inoperable. Complex maintenance tasks require a certificated
and appropriately rated maintenance person to
perform the deactivation. In all cases, the item or equipment
must be placarded INOPERATIVE.
All rotorcraft operated under part 91 are eligible to use
the maintenance deferral provisions of section 91.213(d).
However, once an operator requests an MEL, and a Letter
of Authorization (LOA) is issued by the FAA, then the
use of the MEL becomes mandatory for that helicopter.
All maintenance deferrals must be accomplished in
accordance with the terms and conditions of the MEL and
the operator-generated procedures document.
The use of an MEL for rotorcraft operated under part 91
also allows for the deferral of inoperative items or
equipment. The primary guidance becomes the FAAapproved
MEL issued to that specific operator and
N-numbered helicopter.
The FAA has developed master minimum equipment
lists (MMELs) for rotorcraft in current use. Upon written
request by a rotorcraft operator, the local FAAFlight
Standards District Office (FSDO) may issue the appropriate
make and model MMEL, along with an LOA, and
the preamble. The operator then develops operations
and maintenance (O&M) procedures from the MMEL.
This MMEL with O&M procedures now becomes the
operator's MEL. The MEL, LOA, preamble, and procedures
document developed by the operator must be on
board the helicopter when it is operated.
The FAA considers an approved MEL to be a supplemental
type certificate (STC) issued to an aircraft by
serial number and registration number. It therefore
becomes the authority to operate that aircraft in a condition
other than originally type certificated.
With an approved MEL, if the position lights were discovered
inoperative prior to a daytime flight, the pilot
would make an entry in the maintenance record or discrepancy
record provided for that purpose. The item is
then either repaired or deferred in accordance with the
MEL. Upon confirming that daytime flight with inoperative
position lights is acceptable in accordance with the
provisions of the MEL, the pilot would leave the position
lights switch OFF, open the circuit breaker (or whatever
action is called for in the procedures document), and placard
the position light switch as INOPERATIVE.
There are exceptions to the use of the MEL for deferral.
For example, should a component fail that is not listed
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