The central purpose of the Minimum Equipment List (MEL) is to aid the pilot-in-command with determining whether a flight may be commenced or continued safely, and within applicable regulatory requirements, from any intermediate stop should any instrument, equipment or systems become inoperative. This position paper discusses the MEL utilized by U.S. non-commercial operators governed by 14 CFR 91, excluding Subpart K. The scope addresses the validity of the Master Minimum Equipment List (MMEL) as an MEL in United States domestic airspace and airspace of a foreign state. During analysis of compliance documents, where an LOA D095 has been issued for the use of an MMEL as an MEL, 100% of operators audited by Air Safety Group have failed to meet the requirements specified within the issued Letter of Authorization, thereby rendering their MEL invalid for use in any airspace Although the emphasis of this paper is on regulatory compliance, implications extend to the risk of substantial pecuniary damages. Often overlooked is the potential impact on lease/finance agreements and insurance coverages. A finding of regulatory non-compliance in a post-event or -accident investigation, exposes all stakeholders to the possibility of significant loss.
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