would it be fair to say...

jaybee said:
that 91.205 is a MEL ? semantics aside.
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No. Because you cannot put "semantics aside". A minimum equipment list is a very specific regulatory artifact and is defined in regulations. Since you referenced 91.205, we are clearly in the regulatory arena and, in that arena, we do not put semantics aside.

An example from my job: I manage State and Federal permits for large facilities; permits that have their basis in things like the Clean Air Act (CAA) and are covered by 40 CFR in the same sense that the FARs are actually in 14 CFR. If we want to modify one of our facilities, I determine the regulatory impact and make the appropriate application for new or modified permits. One important factor is often whether the work we want to do constitutes a "major modification". This is not my opinion, it is not based on how much we spend or how important it is. There is a very specific definition for "major modification" and when I am talking to regulators, I do not put semantics aside.

So while you can tell your buddy that there is a certain minimum equipment list for VFR flight, and I can tell my buddy we are doing some major modifications at the plant, that is not how we deal with things in the regulatory framework.
 
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There are semantics regarding 91.205? No it is not an MEL. 91.213(if I remember right) talks about MELs. 91.205 is minimum required equipment for the type of flight you are doing. There is a manufacturer equipment list in the POH, technically all that stuff needs to be working, or properly placarded. 91.205 states the stuff that cannot be placarded.
 
It was argument that I had with an an incorrect Instructor.....

The premise was that 91.205 is a list of equipment that you must have in order to fly... an MEL is a list of equipment that you must have in order to fly....
 
jaybee said:
It was argument that I had with an an incorrect Instructor.....

The premise was that 91.205 is a list of equipment that you must have in order to fly... an MEL is a list of equipment that you must have in order to fly....
Click to expand...

Bad logic.
 
jaybee said:
It was argument that I had with an an incorrect Instructor.....

The premise was that 91.205 is a list of equipment that you must have in order to fly... an MEL is a list of equipment that you must have in order to fly....
Click to expand...

That's the thing with technical vocabulary, it is precise. Semantics are everything, small differences are the difference between modifiers; they put the difference there specifically to NOT make it the same.
 
jaybee said:
It was argument that I had with an an incorrect Instructor.....

The premise was that 91.205 is a list of equipment that you must have in order to fly... an MEL is a list of equipment that you must have in order to fly....
Click to expand...

No, an MEL is a list of equipment that can be inop, and associated limitations.
 
An MEL also spells out performance or operational limitations, the duration something may be inoperative, the procedures or actions necessary when something is inoperative, and any limitations that apply because of the inoperative equipment. An MEL, when approved, is aircraft or fleet -specific.

An MEL represents preapproval to operate outside the boundaries of the aircraft as certified and represents temporary authorization as a supplemental type certificate; it's not an STC, but does represent a manner in which the aircraft may be altered in a manner acceptable to the Administrator.
 
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