The FAA Air Transportation Division (AFS-200) conducted a review of MMEL PL-98. As a result of this review, AFS-200 determined that MMEL relief for a navigation database that is operative, but out of currency is not necessary. PL-98, revision 1, removes MMEL relief for an out of currency navigation database while still allowing relief for an inoperative database. For an instrument or equipment item to be considered for relief, the item must be inoperative. Inoperative is defined in MMEL PL-25, revision 20, MMEL and MEL Definitions:
“Inoperative: A system and/or component malfunction to the extent that it does not accomplish its intended purpose and/or is not consistently functioning normally within its approved operating limit(s) and/or tolerance(s).”
Since the navigation database continues to operate normally and can be used while in and out of currency status, it is not inoperative per the definition and is not identified as inoperative as required by regulation. Therefore, it does not require MMEL relief under 14 CFR.
Recommended Action: Operators should conduct a review of their procedures for aircraft operation with a non-current navigation database. As appropriate, operators should coordinate with their Principal Operations Inspector (POI) or local FAA Flight Standards District Office (FSDO) with oversight responsibility and verify that their procedures achieve an acceptable level of compliance. In many, if not most cases, operator procedures developed for MEL compliance to MMEL PL-98, revision 0, should be acceptable for continued use.
MMEL Policy Letter 98, Revision One:
http://fsims.faa.gov/PICDetail.aspx?docId=PL-098
FAA Notice N 8900.424:
http://www.faa.gov/documentLibrary/media/Notice/N_8900.424.pdf
InFO 17007: https://www.faa.gov/other_visit/aviation_industry/airline_operators/airline_safety/info/all_infos/media/2017/InFO17007.pdf
Contact: Questions regarding PL 98 should be directed to: Marlan Perhus, Air Transportation New Program and Implementation Branch, AFS-240, at marlan.perhus@faa.gov.
