MEL - RWR Pilot Training

I’m Glad You Asked
MEL requirements for the turbine PA46
By Dick Rochfort, ATP, MCFI, CFII, MEI
QUESTION: I am getting conflicting answers about the requirements for an MEL for my Part 91 operated
Meridian, can anyone clear up the confusion? Thanks.
ANSWER: I’m glad you asked …
There is a bit of confusion on the topic of MEL requirements and I would like to help sort this out. Let’s look first at
91.213 since this is where the requirement for an MEL exists. It reads in part:
“(a) Except as provided in paragraph (d) of this section, no person may takeoff an aircraft with
inoperative instruments or equipment installed unless the following conditions are met:
(1) An approved Minimum Equipment List exists for that aircraft.
(2) The aircraft has within it a letter of authorization (LOA), issued by the FAA Flight Standards
District Office (FSDO) having jurisdiction over the area in which the operator is located, authorizing
operation of the aircraft under the Minimum Equipment List. The letter of authorization may be
obtained by written request of the airworthiness certificate holder. The Minimum Equipment List and
the letter of authorization constitute a supplemental type certificate for the aircraft.”
In summary, 91.213 says that if there is an MMEL (Master Minimum Equipment List) for the aircraft (and there is
one for the P46T), you may not takeoff with inoperative equipment without an approved MEL and an LOA (letter of
authorization).
It does not say you have to have an MEL. It says you must have an MEL if you want to takeoff with inoperative
equipment.
There are exemptions for fixed wing piston powered aircraft and others, however, 91.213 does not exempt the P46T
because it is turbine powered. It is also true that the FAA at the Baltimore FSDO is not currently enforcing the Part
91 MEL requirements, nor is the Philadelphia FSDO. Each FSDO may make their own judgment about enforcement,
so you will need to check with your local FSDO on this and I suggest you do so in writing to avoid any
misunderstanding.
Fly Safely – Train Often
Phone 410-435-3333 - Toll Free 866-870-8196 - Fax 410-435-7311
www.rwrpilottraining.com - mail@rwrpilottraining.com
Richard W. Rochfort, ATP, MCFI, CFII, MEI - 6031 Bellona Avenue - Baltimore, Maryland 21212-2923

Page 1 of 3Page 1 of
3
If you decide to create an MEL for your aircraft look first at the FAA MMEL:
http://www.rwrpilottraining.com/PA46P91.DOC
The MMEL is the document you should use to develop your own MEL.
I have a developed a MEL for the PA46-500T and it is posted on my website in Microsoft Word format:
http://www.rwrpilottraining.com/RWRPT_%20Meridian_MEL.doc
You are welcome to use this one if you like, although you will need to address any equipment differences. Once you
have done so, fax the MEL to your local FSDO with a request for an LOA, and then place these documents in your
POH. That's all there is to it.
Download the FAA Op Spec as well. It will help you with knowing how to proceed.
http://www.rwrpilottraining.com/FAA_OP_Spec_PL-036_R02.pdf
The MEL requirement is in addition to the Kinds List in your POH which affects airworthiness. It is also in addition
to the requirements of 91.205, although there is significant overlap. Make sure you consider these items when
developing your MEL.
If you are unsure about these regulations, have questions or need help, feel free to give me a call.
I hope this information is helpful.
Fly Safely – Train Often
Dick Rochfort, ATP, MCFI, CFII, MEI
410-435-3333
mail@rwrpilottraining.com
www.rwrpilottraining.com
“I’m Glad You Asked” is a regular column written by Master Flight Instructor Dick Rochfort. Dick answers
questions which come up frequently while conducting training in the Malibu, Mirage and Meridian aircraft. If you
have a question for Dick, you can send it to him at mail@rwrpilottraining.com. He’ll be … “glad you asked”.
Fly Safely – Train Often
Phone 410-435-3333 - Toll Free 866-870-8196 - Fax 410-435-7311
www.rwrpilottraining.com - mail@rwrpilottraining.com
Richard W. Rochfort, ATP, MCFI, CFII, MEI - 6031 Bellona Avenue - Baltimore, Maryland 21212-2923

Page 2 of 3Page 2 of
3
____________________________________________________________
Biography
Richard W Rochfort
A former corporate pilot and primary flight instructor, Dick is a full-time Master Certified
Flight Instructor providing insurance approved initial and recurrent pilot training in the Piper
PA46 Malibu, Mirage, and Meridian aircraft. He is currently flying over 450 hours per year
and trains 60-80 pilots every year exclusively in these aircraft.
He holds multi-engine ATP and Gold Seal Flight Instructor Certificates with CFII, MEI and
CE-525S ratings. He has been actively involved in flight training since 1991 and has trained
pilots all over the US, Canada and Europe.
Dick is an Aviation Safety Counselor for the FAA Baltimore FSDO, a National Industry
Member of the FAA Safety Team (FAAST) and has conducted hundreds of programs for the
pilot community. He is an instructor for the M/MOPA Safety and Training Foundation and The National
Association of Flight Instructors has designated him Master CFI. Less than 1% of all flight instructors have earned
this designation.
Dick served as a Staff Sergeant E6 in the US Army Special Forces from 1970 until 1976 as an A team radio
operator, training indigenous personnel in field communications. He worked from 1976 until 1991 as an industrial
engineer training manufacturing personnel for the production of communication and navigation equipment for US
military.
His education includes undergraduate degrees in Clinical Psychology and Engineering and a Masters Degree in
Business Administration. Dick lives in Baltimore, Maryland with his wife and two daughters. He is a PADI
Certified Scuba Diving Instructor, First Aid Instructor and an Eagle Scout.
____________________________________________________________
Fly Safely – Train Often
Phone 410-435-3333 - Toll Free 866-870-8196 - Fax 410-435-7311
www.rwrpilottraining.com - mail@rwrpilottraining.com
Richard W. Rochfort, ATP, MCFI, CFII, MEI - 6031 Bellona Avenue - Baltimore, Maryland 21212-2923