Understanding D095, D195, and MEL LOAs: What Operators Need to Know

If you operate under 14 CFR Part 91 and work with a Minimum Equipment List (MEL), you may feel confused about the FAA’s use of D095 and D195 Letters of Authorization (LOAs).

Over the years, the FAA has changed how it manages MEL approvals. Many operators are unsure which authorization applies or if their current MEL is still valid. This article provides a clear, up-to-date background and explanation of what’s going on and how to move forward.

Understanding D095

The MEL approved under LOA D095 consists of three documents: the LOA, the aircraft M/M/S-specific MMEL, and the Procedures Document. The Procedures Document must contain the following sections:

(M) and (O) Procedures

The presence of either (M) or (O) symbols in the MMEL “Remarks or Exceptions” column indicates specific (M) or (O) procedures that must be accomplished before operation when the item is inoperative.

As Required by 14 CFR

The procedures document will either list the specific 14 CFR part and section (e.g., 14 CFR part 91, § 91.209) or specify the requirements and/or limitations to conduct the flight in accordance with the appropriate 14 CFR regulations. The operator must ensure the applicable 14 CFR section is accessible on board the aircraft.

Definitions

MMEL and MEL definitions are contained in MMEL PL-25. Operators must include all applicable definitions in their Procedures Document as shown in FAA MMEL PL-25.

Preamble

The preamble contained in FAA MMEL PL-36 is applicable to all § 91.213(a) MEL approvals under LOA D095. This preamble must be reproduced verbatim in the Procedures Document and include the aircraft type.

D095 is often seen as the quicker and easier option since it requires less customization than D195. However, operating under a D095 LOA involves more than just downloading the MMEL and calling it good.

Understanding D195

The MEL approved under LOA D195 must contain the following sections:

Table of Contents

This section lists all chapters in the MEL by title and the corresponding page identification.

Log of Revisions

This log contains the MEL revision identification (typically a number and/or letter) and the date of the MEL revision.

Definitions

Operators must include all applicable MMEL and MEL definitions, as contained in MMEL PL-25, in their MEL.

Preamble

Similar to D095, the preamble from FAA MMEL PL-36 applies to all § 91.213(a) MEL approvals under LOA D195. This preamble must also be reproduced verbatim in the Procedures Document and include the aircraft type.

Control Pages (LEP)

Control pages track the status of the MEL and include a record of the revision status or the date of each page of the operator’s MEL.

ATA/JASC Coded System Sections

These sections are organized by aircraft system according to the ATA/JASC coded numbering system. They include individual item sequence numbers, items, repair categories, number of items installed, number of items required for dispatch, remarks or exceptions, and (M) and (O) procedures. The operator-developed MEL must be organized using the MMEL ATA/JASC coded numbering system. Each section will list individual items in the aircraft along with requirements for operation when the items are inoperative.

While D195 requires more time and customization than D095, it provides a standardized and FAA-approved framework for MEL compliance.

Understanding AC 91-67A

Advisory Circular (AC) 91-67A gives operators a clearer path to comply with MEL requirements, which also aids the FAA in its approval process.

To obtain a D095 LOA, you must submit a D095 Request Letter to the responsible Flight Standards office that oversees your principal base of operations. If a D095 operator submits an attestation letter stating compliance with AC 91-67A, they are not required to submit the Procedures Document to the FAA, except when reapplying after cancellation, rescission, or revocation.

For D195 approval, the operator must submit a signed, written request for the issuance of LOA D195, along with a copy of the operator-developed MEL, to the responsible Flight Standards office. If a D195 operator submits an attestation letter stating their MEL complies with AC 91-67A, the FAA can conduct an abbreviated review of the MEL per 8900 Volume 4, Chapter 4, Section 2. While this allows for quicker reviews, each inspector retains the right to conduct full reviews whenever deemed necessary. Therefore, it’s crucial to maintain communication with your POI (Principal Operations Inspector) to understand their expectations.

Why the Confusion?

Let’s start with some background. Operators flying with a D095 LOA in Europe have historically faced issues during ramp checks. Some Civil Aviation Authority (CAA) inspectors did not consider the D095 LOA sufficiently compliant with the International Civil Aviation Organization (ICAO) MEL requirements of Annex 6, Parts II and III. Even though the FAA views MEL approvals under LOA D095 as meeting ICAO requirements, CAA inspectors still argue that the D095 MEL is not adequately customized for compliance.

This has led to inconsistencies across FSDOs in how they interpret CAA requirements. Some offices still allow the use of existing D095 MELs, usually for domestic operations. Others require all operators, both domestic and international, to transition to D195, regardless of previous approvals. Consequently, many operators are now being told they need a D195 LOA, even if they previously operated under D095. Guidance can vary significantly depending on the FSDO and even among individual inspectors.

The Overall Trend

The overall trend is clear: operators, especially those flying internationally, should expect to follow the D195 process moving forward.

What Should You Do?

First, I recommend reviewing your current MEL/Procedures Document to ensure it aligns with the latest FAA guidelines. Check that all required sections and parts are included, whether authorized under LOAs D095 or D195.

Next, it’s wise to start preparing for the D195 process, especially if you fly internationally. This involves customizing your MEL to your specific aircraft and operations and submitting it for FAA review and approval. You should also reach out to your local FSDO to confirm their current expectations and any documentation they may require.

How We Can Help

We specialize in developing FAA-compliant, custom MELs fully prepared for D195 submission and LOA approval. Our process includes tailoring the MEL to your aircraft and operational profile, formatting the document according to FAA standards.

Whether you’re transitioning from D095, applying for your first MEL, or just need help navigating the MEL process, our team is here to ensure everything is done accurately and efficiently.

For more information on how we can assist you, feel free to reach out. We’re here to make complex regulatory requirements easy to handle, so your aircraft stays airworthy and operational, saving you time and money.