GM No 2 to 21.A.93(b)(1)(iii) Interaction of changes to the type design and changes to the master minimum equipment list (MMEL)

• ED Decision 2019/018/R found in: Initial Airworthiness and Environmental Protection (748/2012) Part-21 Part-21L (Jul 2024)

GM No 2 to 21.A.93(b)(1)(iii) Interaction of changes to the type design and changes to the master minimum equipment list (MMEL) ED Decision 2019/018/R In general, it has to be assumed that changes to the type certificate (TC) that affect the type design can have an effect on the MMEL. Due to its alleviating nature, the MMEL is developed to improve aircraft use, thereby providing a more convenient and economical air transportation for the public. Therefore, not introducing MMEL relief for new equipment, system or function has no effect on the safety of the operation. The introduction of MMEL relief for new equipment can, therefore, be treated as a stand-alone MMEL change, separately from the design change, and can be processed at a later date than the date of entry into service of the aircraft including the design change. Not modifying an MMEL item whose validity is altered by a type design modification may, however, have an effect on the safety of the operation. The applicant for a change to the TC that changes the type design should, therefore, identify whether this change needs to be supplemented by a change to the MMEL. However, the update of an MMEL relief for an already addressed equipment, system or function can be treated at a later date than the date of entry into service of the aircraft including the design change, provided that the change to the MMEL is of an alleviating nature. When the change to the MMEL is not of an alleviating nature, it has to be approved according to point [21.A.97](#_DxCrossRefBm1649096997)(b)(2) and (c). It may be assumed that a change to the type design requires a change to the MMEL if any of the following conditions are fulfilled: (a)     the change affects an existing MMEL item in a more restrictive manner: there is a change to equipment, system or function linked to an MMEL item, or a change to the operational limitations and procedures linked to an MMEL item; (b)     the change invalidates the assumptions used to justify an existing MMEL item, and requires a more restrictive MMEL item; and (c)      the change invalidates any dispatch conditions of the MMEL. Examples of the above three conditions, where no change to the MMEL is required: (a)     introduction of new equipment, system or function in the type design; (b)     the change has no adverse impact on the qualitative and quantitative assessment used to justify an MMEL item; and (c)      the dispatch conditions do not need to be more restrictive if the current intent of (o) or (m) procedures (as referred in CS MMEL.125) is not impacted. The following diagram summarises the interaction between type design changes and changes to MMEL (see Figure 1). ![Aviation.Bot AI suggestion, not from EASA source: [Image caption skipped for debugging]](/static/files/file_ocz75zUMmy4/image014.jpg) Figure 1 ##### GM No 2 to 21.A.93(b)(1)(iii) Interaction of changes to the type design and changes to the master minimum equipment list (MMEL) *ED Decision 2019/018/R* In general, it has to be assumed that changes to the type certificate (TC) that affect the type design can have an effect on the MMEL. Due to its alleviating nature, the MMEL is developed to improve aircraft use, thereby providing a more convenient and economical air transportation for the public. Therefore, not introducing MMEL relief for new equipment, system or function has no effect on the safety of the operation. The introduction of MMEL relief for new equipment can, therefore, be treated as a stand-alone MMEL change, separately from the design change, and can be processed at a later date than the date of entry into service of the aircraft including the design change. Not modifying an MMEL item whose validity is altered by a type design modification may, however, have an effect on the safety of the operation. The applicant for a change to the TC that changes the type design should, therefore, identify whether this change needs to be supplemented by a change to the MMEL. However, the update of an MMEL relief for an already addressed equipment, system or function can be treated at a later date than the date of entry into service of the aircraft including the design change, provided that the change to the MMEL is of an alleviating nature. When the change to the MMEL is not of an alleviating nature, it has to be approved according to point [21.A.97](#_DxCrossRefBm485230488)(b)(2) and (c). It may be assumed that a change to the type design requires a change to the MMEL if any of the following conditions are fulfilled: (a) the change affects an existing MMEL item in a more restrictive manner: there is a change to equipment, system or function linked to an MMEL item, or a change to the operational limitations and procedures linked to an MMEL item; (b) the change invalidates the assumptions used to justify an existing MMEL item, and requires a more restrictive MMEL item; and (c) the change invalidates any dispatch conditions of the MMEL. Examples of the above three conditions, where no change to the MMEL is required: (a) introduction of new equipment, system or function in the type design; (b) the change has no adverse impact on the qualitative and quantitative assessment used to justify an MMEL item; and (c) the dispatch conditions do not need to be more restrictive if the current intent of (o) or (m) procedures (as referred in CS MMEL.125) is not impacted. The following diagram summarises the interaction between type design changes and changes to MMEL (see Figure 1).  ***Figure 1***