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JAR-MMEL/MEL NPA – Revision 1

JAR-MMEL/MEL NPA – Revision 1. SARAH DOHERTY Chairman, JAA MMEL/MEL WG. Presentation. Background to NPA Main Issues from NPA: Effectivity and Compliance Flight Day Authority JAR v EASA Acceptable level of safety Types of Operation (O) and (M) Procedures

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JAR-MMEL/MEL NPA – Revision 1

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  1. JAR-MMEL/MEL NPA – Revision 1 SARAH DOHERTY Chairman, JAA MMEL/MEL WG

  2. Presentation • Background to NPA • Main Issues from NPA: • Effectivity and Compliance • Flight Day • Authority • JAR v EASA • Acceptable level of safety • Types of Operation • (O) and (M) Procedures • Revisions to MMELs

  3. Presentation (cont.) • Main Issues from NPA: • Non-safety Related Equipment BASA / IPA • Ferry Flights • Rectification Interval • Rectification Interval Extensions • Approval v Acceptance • Requirement to Produce MMEL JAR-OPS 1/3 • TGL 26

  4. Background to NPA • JAR-MMEL/MEL first issued 1 May 2000 • Reviewed by MMEL/MEL WG • Main changes for clarification • Produced NPA for Revision 1 • Consultation completed 1 April 2004 • WG dispositioned comments • Produced CRD Request OST approval of CRD and NPA

  5. Effectivity and Compliance JAR-MMEL/MEL.002 (CRD REF: 036, 045, 078, 089) • Some confusion over effectivity of JAR • WG seek to clarify by introducing new paras: • .002 Effectivity • “Amendments to JAR-MMEL/MEL become effective 6 months after publication.”

  6. Effectivity and Compliance (cont.) JAR-MMEL/MEL.003 .003 Compliance “This JAR will not be applied retrospectively. MMELs and MELs existing prior to 1 May 2000 will continue to remain valid and applicable.” Request OST and RST to endorse this change

  7. Flight Day JAR-MMEL/MEL.005 (CRD REF: 049) • WG agreed to add definition of Flight Day • Based on FAA definition • Changed at last WG meeting • “Flight day” means a 24 hour period (from midnight to midnight) either Universal Coordinated Time (UCT) or local time, as established by the operator, during which at least one flight is initiated for the affected aircraft.” • Request OST and RST endorsement of this definition

  8. Authority JAR-MMEL/MEL.005(b) (CRD REF: 015, 049) • WG aligned definition with JAR 1, and removed reference to NAA: • “Authority” means the competent body responsible for the safety regulation of Civil Aviation. In the context of JAR-MMEL/MEL this means the Authority of the State of Registration / Operator.” • Request OST and RST to endorse definition

  9. JAR v EASA JAR-MMEL/MEL.005 (CRD REF: 028, 087) • Comment – align TC Holder and STC Holder with JAR 21 / EASA Part 21 • JAR-MMEL/MEL.005 changed accordingly • Which requirement should be referred to? • Request OST and RST to advise on JAR 21 or EASA Part 21

  10. JAR v EASA (cont.) JAR-MMEL/MEL.010(a) • Comment – replace “applicable JAR” with “applicable JAR or CS or equivalent” • WG view – should still refer to JARs at this stage • There will still be countries under JAA system that are not part of EASA • Suggest change to “applicable JAR or equivalent requirement” • Request OST and RST to advise

  11. Acceptable Level of Safety JAR-MMEL/MEL.010 (CRD REF: 024, 026, 030, 086) • Introduced instead of “required level of safety” • Allow dispatch below requirements / TC basis • Under controlled conditions: • MMEL provisos • (O) and (M) procedures • Rectification Interval • Based on risk assessment from TC Holder: • Systems Safety Assessment • Detailed justification of dispatch conditions • Limited exposure time

  12. Acceptable Level of Safety (cont.) JAR-MMEL/MEL.010 • Definition does not currently exist • JAR 25.1309 HWG task • MMEL/MEL WG to provide some guidance: • JIP MMEL Procedures Manual

  13. Types of Operation JAR-MMEL/MEL.015/055 (CRD REF: 044) • Comment – add statement that JAR-MMEL/MEL applies to commercial operations only • WG disagree… • JAR-MMEL/MEL.015 states that the MMEL shall cover the types of operation for which the aircraft type is certificated

  14. Types of Operation (cont.) JAR-MMEL/MEL.015/055 • JAR-MMEL/MEL.055 states that the MEL may include specific provisions for particular types of operation • ACJ.055 refers to crew training, positioning and demonstration flights • Therefore, JAR-MMEL/MEL does not just apply tocommercial operations (e.g. JAR-OPS 1/3)

  15. (O) and (M) Procedures JAR-MMEL/MEL.035/075 (CRD REF: 018, 032, 051, 063, 083) • (O) and (M) procedures not approved • Added new requirement • Produced and published by TC / STC Holder • Procedures amended when MMEL revised • Intent identified during MMEL development • Referenced in MMEL • Published concurrently with MMEL

  16. (O) and (M) Procedures (cont.) JAR-MMEL/MEL.035/075 • Comment – not clear whether (O) and (M) procedures are required to be approved in MEL • WG agreed to add: • “An operator shall be prepared to present these procedures to the Authority during the MEL approval process.” • NAA decision whether to review the (O) and (M) procedures during MEL approval

  17. Revisions to MMELs JAR-MMEL/MEL.046 (CRD REF: 055) • In response to a comment, WG propose to add: • .046 MMEL Revisions • “The TC or STC Holder, as appropriate, shall positively inform the operators when a revision to the JAA MMEL (including MMEL Supplement) is published.” • Receipt of the revision, letter or e-mail • Not just publish on internet site without notification

  18. Non-Safety Related Equipment JAR-MMEL/MEL.050(c) (CRD REF: 008, 009, 054, 075) • Equipment that is not required for airworthiness or operational reasons • WG propose to add ACJ material • Based on DRAFT FAA policy letter • FAA policy letter currently being re-written • Request OST decision on whether to include this ACJ material

  19. BASA / IPA JAR-MMEL/MEL.060(b) (CRD REF: 025, 035) • ACJ-MMEL/MEL.060(b) states: • “If a MMEL has not been approved by the Authority for a particular type, then the operator may use a MMEL produced by the manufacturer and approved by the State of manufacture. If this does not exist, an alternative MMEL produced or approved by another NAA (e.g. FAA, TCCA) may be used.”

  20. BASA / IPA (cont.) JAR-MMEL/MEL.060(b) • Use of MMEL produced or approved by non-JAA Authority • Supported in principle • Limited to where NAA has BASA / IPA with non-JAA Authority • Include this restriction in JAR? Request OST decision on whether this should be restricted to where a BASA / IPA is in place

  21. Ferry Flights ACJ-MMEL/MEL.065 MEL Preamble (CRD REF: 022, 034, 062, 074) • Confusion over whether ferry flights are outside of the MEL… • … or should the MEL should be complied with? • NPA sought to clarify this situation in ACJ: • Non-revenue flights, below MEL • Comply with AFM • Permission from Authority before flight

  22. Ferry Flights (cont.) ACJ-MMEL/MEL.065 MEL Preamble • Several comments on NPA • WG agreed to revert to pre-NPA wording • Seek clarification from OST on ferry flights • Should there be a separate TGL? • What exactly is the relationship between the MEL and ferry flights? • Should we even mention ferry flights in JAR-MMEL/MEL? • Request OST decision on this issue

  23. Rectification Interval JAR-MMEL/MEL.040/080 (CRD REF: 048) • Comment – rectification interval definition should be aligned with FAA / TCCA • ‘Dispatch’ interval v. ‘rectification’ interval • WG believe that defect should be rectified within rectification interval • Aircraft should not be dispatched if the rectification interval is due to expire during the flight • FAA / TCCA different – WG agreed to maintain this difference

  24. Rectification Interval Extensions JAR-MMEL/MEL.081 (CRD REF: 023, 082) • Notification of an RIE • WG wanted to allow flexibility and removed 10 day notification period • NPA proposed to allow each Authority to determine their own timescale • Comment – standardise timescale • WG agreed to limit timescale to 1 month

  25. Rectification Interval Extensions (cont.) JAR-MMEL/MEL.081 • Extension of RI in MEL, or MMEL? • NPA proposed to change to MEL • If RI in MEL is more restrictive - good reason • WG recommend extension of RI in MEL

  26. Approval v Acceptance GENERAL (CRD REF: 004, 033) • Propose to remove reference to MMEL ‘approval’ • Replace with MMEL ‘acceptance’ • No real legal difference • But different processes involved • In accepting a JAA MMEL, the NAA does not have do to a full review and approval of the document

  27. Requirement to Produce MMEL GENERAL (CRD REF: 029) • Comment – introduce new requirement: • “An approved MMEL must be published prior to entry into service of the aircraft type.” • WG rejected this comment: • Further justification required • Scope and applicability not clear • Part 21, not JAR-MMEL/MEL • Request OST and RST to confirm whether this proposal should be addressed to EASA

  28. JAR-OPS 1/3 GENERAL (CRD REF: 069) • Comment – amend JAR-OPS 1/3 by inserting a reference to JAR-MMEL/MEL • Best place would be JAR-OPS 1.030/3.030 relating to ‘MEL Approval’ Request decision from OST whether to add reference in JAR-OPS 1/3 to JAR-MMEL/MEL

  29. TGL 26 GENERAL (CRD REF: 070) • Comment – include a reference to TGL 26 in JAR-MMEL/MEL Subpart C • Not common practice to refer to a TGL in a JAR, as TGL is a temporary document • WG recommend to include TGL 26 in JAR-MMEL/MEL Subpart C as ACJ material Request decision from OST whether to include TGL 26 in JAR-MMEL/MEL as ACJ

  30. REVISION 1 TO JAR-MMEL/MEL • WG request endorsement of: • Comments / Response Document • Subsequent changes to NPA • Publication of Revision 1 to JAR-MMEL/MEL Request decision from OST

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