MEL · October 31, 2026 · 6 min read · By BizJetDocs

Part 91 MEL: LOA D195 (your own MEL) vs D095 (the MMEL as your MEL)

D195 or D095? How each Part 91 MEL approval works under 91.213, what you submit, how revisions differ, and which fits international flying.

Short answer: both LOAs give a Part 91 operator an approved MEL under 14 CFR 91.213(a). Under D095 your MEL is the aircraft's Master Minimum Equipment List (MMEL) plus your own procedures document, and you do not send the procedures document to the FAA. Under D195 you write an operator-developed MEL based on the MMEL, send it with your request, and send every later revision for approval. D095 is less paper. D195 gives you a single document written for your aircraft, and it is the one to choose if a foreign authority may not accept D095.

What 91.213 requires

Section 91.213(a) says no person may take off with inoperative instruments or equipment installed unless an approved MEL exists for that aircraft, the aircraft carries a letter of authorization from the responsible Flight Standards office, the aircraft records available to the pilot describe the inoperable items, and the aircraft is operated under the conditions and limitations of the MEL and the letter. Under 91.213(a)(2), "the Minimum Equipment List and the letter of authorization constitute a supplemental type certificate for the aircraft."

The alternative in 91.213(d), operating without an MEL, is limited by 91.213(d)(1) to rotorcraft, non-turbine-powered airplanes, gliders, lighter-than-air aircraft, powered parachutes and weight-shift-control aircraft without an MMEL, and to small rotorcraft, non-turbine-powered small airplanes, gliders and lighter-than-air aircraft with one. A turbine business jet is not on either list, so it needs an MEL and LOA for relief.

The two approvals side by side

AC 91-67A, paragraph 3.3.1, describes both. The comparison below uses AC 91-67A chapters 3, 6 and 9.

Either way the MEL "may be more restrictive than the MMEL, but it will not be less restrictive" (AC 91-67A, para 3.1.2). Paragraph 3.1.4 lists what an MEL may not be less restrictive than: the MMEL, the operating rules, the LOA, the approved flight manual limitations and emergency procedures, any MMEL policy letters with a current global change designation that you use, STC instructions and applicable airworthiness directives.

What goes in each document

D095 procedures document. The sample request letter in AC 91-67A, Figure 6-1, has the operator attest that the procedures document contains the operator name, aircraft serial and registration numbers (or "Fleet"), make, model and series, the MMEL revision number, (M) and (O) procedures matching the MMEL provisos, the list of MMEL items that say "as required by 14 CFR," definitions per the current MMEL Policy Letter 25 and a preamble per Policy Letter 36.

D195 operator-developed MEL. Figure 6-2 lists the content the operator attests to: the same identifying information, a table of contents, a log of revisions, the PL-25 definitions and PL-36 preamble, control pages, ATA (or JASC) coded system sections, (M) and (O) procedures and the "as required by 14 CFR" items.

If your D195 MEL does not conform to the AC 91-67A content, paragraph 6.3 lets you ask for approval anyway, with a letter explaining how it meets 91.213(a), and warns that approval may be delayed.

International flying

The definition of MEL in AC 91-67A, paragraph 1.8.13, carries this note: "MEL approvals under LOA D095 meet the International Civil Aviation Organization (ICAO) MEL requirements of Annex 6, Parts II and III. However, some CAAs may not accept LOA D095 as a valid MEL approval." Paragraph 6.2 asks operators who conduct international operations and currently hold D095 to say so in their D195 request letter. If your trips take you to countries whose ramp inspectors expect an operator MEL, D195 removes that question.

Things that apply to both

• The LOA follows operational control, not the aircraft. AC 91-67A, paragraph 3.3.3: under a dry lease the lessee "may use only an MEL LOA specifically issued to them." Only one D095 and one D195 can be issued per operator (para 3.3.2), but one LOA can list several aircraft.
• Fleet MELs. One MEL can cover several aircraft of the same make, model and series if the MMEL applies to all of them, with each configuration difference identified (paras 3.5 and 3.5.1).
• No MEL management program required. Paragraph 3.1.6 says a Part 91 operator does not need one, but "a means of recording discrepancies and corrective actions must be available to the pilot in command."
• Equipment added after certification. Relief is available only for items in the MMEL, an STC relief approval letter, or an MMEL policy letter with a current global change designation (para 3.1.3). New installations without one of these cannot be deferred until the MEL is revised (para 3.5.2 and chapter 10).
• Nonessential equipment and furnishings. Either MEL can carry an NEF program. See NEF and your MEL.

Choosing

Pick D095 if you fly domestically, want the least paper, and are comfortable keeping the procedures document current against each mandatory MMEL revision on your own. Pick D195 if you fly internationally, want a single MEL your crews and maintenance providers use as written for your aircraft, or plan to use the streamlined LOA application. Note that the streamlined guidance says inspectors should not process D195 through that process if you already hold D095 for the same aircraft.

What you submit and who submits it

The operator submits a signed, written request to the responsible Flight Standards office for the area of its principal base of operations (AC 91-67A, paras 6.1 and 6.2). An electronic signature, or a signed and scanned request sent by email, is acceptable. For D195 the MEL goes with the request.

We prepare the D195 MEL from the current MMEL revision and your aircraft's configuration, or the D095 procedures document, plus the request letter and instructions for sending it. You review, sign and submit. Only the FAA issues the LOA.

Frequently asked questions

Can I switch from D095 to D195?

Yes. Apply for D195 with your MEL, and state in the request letter that you currently hold D095 if you fly internationally (AC 91-67A, para 6.2). The streamlined process cannot be used for that aircraft while you hold D095.

Do I have to submit every D195 revision?

Yes, except revisions made only to document that a mandatory MMEL revision does not apply, or only to incorporate revised PL-25 or PL-36 content (AC 91-67A, para 9.1.2 note).

Does a new owner keep the MEL LOA?

No. The LOA is issued to the operator with operational control. A buyer requests its own.

Have it prepared

An aircraft-specific D195 MEL is from $550 by aircraft class, and a D095 procedures document with request is $650. See the format below.

Sources

Primary sources, as retrieved when this article was last updated. Check the current text before you rely on it.

• 14 CFR 91.213, Inoperative instruments and equipment
• AC 91-67A, Minimum Equipment Requirements for General Aviation Operations Under 14 CFR Part 91
• FAA Order 8900.1, Volume 3, Chapter 18, Section 15, Streamlined Part 91 Operational Approvals (CHG 973)
• FAA Order 8900.1, Volume 4, Chapter 4, Section 2, MEL Requirements for Part 91 Operators (CHG 994)
• FAA Order 8900.1, Volume 3, Chapter 2, Section 2, Responsibility for Part 91 LOAs (CHG 976)

Informational only. Not legal advice, not FAA guidance and not a promise of FAA approval or of any FAA timeline. The operator submits its own application; only the FAA approves, accepts or issues an authorization.