Overhead Speaker

[DaveF]

I'm no IA, but if the speaker is "optional" in the installed equipment list, I think you're good without it. How its removal is recorded in the logs is a different issue.

MEL is a 135/121/turbine thing. Is there a 170 anywhere with an MEL?

[Bruce Fenstermacher]

MEL is a 135/121/turbine thing. Is there a 170 anywhere with an MEL?

No there isn't a MEL for a 170 but there could be for some aircraft. IN 2017 the FAA rescinded AC 91.67 which told 91 operators how to fly with inop equipment. Today we have FAR 91.213 (d) which we can follow.

The point I was making is that the statement " If it was equipment with the plane when it left the factory it needs to work." is not entirely correct.

[GAHorn]

The point I was making is that the statement " If it was equipment with the plane when it left the factory it needs to work." is not entirely correct.

Bruce is correct, and I’ve edited my previous comment in blue to note the error I previously made.

The FAA has two acceptable methods of deferring maintenance on small rotorcraft, non-turbine powered airplanes, gliders, or lighter-than-air aircraft operated under part 91:
1-The deferral provision of 14 CFR, part 91, section 91.213(d), and
2-An FAA-approved MEL

Deferral:
The deferral provision of 14 CFR, part 91, section 91.213(d) is widely used by most pilot/operators
Its popularity is due to simplicity and minimal paperwork
When inoperative equipment is found during a preflight inspection or prior to departure, the decision should be to cancel the flight, obtain maintenance prior to flight, or to defer the item or equipment
Maintenance deferrals are not used for inflight discrepancies
The manufacturer's AFM/POH procedures are to be used in those situations
Assuming the pilot wishes to defer maintenance for equipment that would ordinarily be required prior to flight:
The pilot first determines whether the inoperative equipment is required by type design, 14 CFR, or ADs
If the inoperative item is not required, and the aircraft can be safely operated without it, the deferral may be made
The inoperative item shall be deactivated or removed and an INOPERATIVE placard placed near the appropriate switch, control, or indicator
If deactivation or removal involves maintenance (removal always will), it must be accomplished by certificated maintenance personnel and recorded in accordance with 14 CFR part 43
For example, if the position lights (installed equipment) were discovered to be inoperative prior to a daytime flight, the pilot would follow the requirements of 14 CFR, part 91, section 91.213(d)
The deactivation may be a process as simple as the pilot positioning a circuit breaker to the OFF position or as complex as rendering instruments or equipment totally inoperable
Complex maintenance tasks require a certificated and appropriately rated maintenance person to perform the deactivation

(But says I, IF your uAvionix ADS-B gets it’s power from the position lights YOU CANNOT DEFER THIS ITEM IF ADS-B IS ALSO REQUIRED FOR THE FLIGHT.)

Minimum Equipment List:
Once an operator requests an MEL, and a Letter of Authorization (LOA) is issued by the FAA, then the use of the MEL becomes mandatory for that aircraft
All maintenance deferrals must be accomplished in accordance with the terms and conditions of the MEL and the operator-generated procedures document
The use of an MEL for an aircraft operated under 14 CFR part 91 also allows for the deferral of inoperative items or equipment
The primary guidance becomes the FAA-approved MEL issued to that specific operator and N-numbered aircraft
The FAA HAS developed master minimum equipment lists (MMELs) for aircraft in current use

The majority of the words above were plagiarized from: https://www.cfinotebook.net/notebook/pu ... pment-list

The Bottom Line is: Our Cessna 170s have an applicable Master Minimum Equipment List (MMEL) developed by FAA. We can use that MMEL to develop one for our own aircraft... and then have that individualized MEL approved for our use. The advantage might be in the event we loan or rent our aircraft out for other pilots who then MUST USE THAT MEL and no other authorization is allowed by that pilot. A Flight School or Club might find that route useful.

Otherwise, as individual owners, we should follow the guidelines above under Deferral (FAR 91.213(d).).... AND... MUST have deferred items repaired at the NEXT INSPECTION per 91.405.

91.405 Maintenance required.
Each owner or operator of an aircraft -

(a) Shall have that aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter;

(b) Shall ensure that maintenance personnel make appropriate entries in the aircraft maintenance records indicating the aircraft has been approved for return to service;

(c) Shall have any inoperative instrument or item of equipment, permitted to be inoperative by § 91.213(d)(2) of this part, repaired, replaced, removed, or inspected at the next required inspection; and

(d) When listed discrepancies include inoperative instruments or equipment, shall ensure that a placard has been installed as required by § 43.11 of this chapter.

So, according to 91.405(c) you CANNOT leave that speaker INOP INDEFINITELY! You must either repair it or have it removed in some otherwise approved method.

[n2582d]

...The Bottom Line is: Our Cessna 170s have an applicable Master Minimum Equipment List (MMEL) developed by FAA. We can use that MMEL to develop one for our own aircraft... and then have that individualized MEL approved for our use. ...

George,
You've been sniffing too much jet fuel. I'd love to spend a year developing an approved MEL for my C-170 so I can takeoff without having to immediately replace a missing ashtray. Please show me where I can find the Master Minimum Equipment List (MMEL) for the C-170. The smallest Cessna with an MMEL that I can find is one for the C-337 found here. I would get laughed out of my FSDO if I asked to get an MEL approved for my plane. Have you actually heard of anyone getting an MEL for a part 91 single-engine recip which weighs less than 12,500 lbs.? According to AC 91-67 (6)(w) I could submit a Proposed Master Minimum Equipment List (PMMEL) as a basis for the development of an MMEL (to be used as a basis for the development of an MEL). I'm guessing it might be easier to just replace the missing ashtray. Here Aviation Safety writes about Deferring Airplane Maintenance.

[floatplaneflyer]

Excellent discussion. I don’t want to loose sight of the make model of the speaker itself? Any pictures besides mine? Love to know if the Jensen is the official speaker? Historians out there?

-Harmon

[GAHorn]

Gary, when I approached FSDO-SAT for a MMEL for my 170B they mailed a MMEL which was generic to single-engine aircraft from which I could develop an MEL for my personal aircraft to submit for their approval. The submission had to include a current W&B and Equipment List, per FSDO.

This example is going to appear a “cop out” but the truth is I cannot recover that document because of my computer issues suffered last June during convention. I had scanned the document into WORD format to work on it and do not believe I still have the original sent to me by FSDO. I will admit it was a discouraging thing to work on because it contained so much uninstalled equipment listed (presumably in an FAA effort to be comprehensive) that was not applicable.... I spent considerable time editing-out things that were not applicable... I finally decided it wasn’t worth the effort. What really ended my quest was when I tried to save the document and the R/M/O format did not “save” properly and required additional time to make it print correctly. I gave up since I’m the only person who’s ever flown my 170 anyway.

But I believe still that a flight school, rental facility, or flight club, etc., could benefit by specifying what equipment must be operational in an approved MEL for their aircraft.

The article you linked addressed FSDO’s reluctance to deal with this issue... but THEY are the ones who promote MELs for commercial operators and THEY are obligated to meet the user’s request if the operator is willing to go thru the process.

BTW, Gary... the Advisory Circular to which you linked is an out-of-date reference. AC 91-67 was issued in June 1991 and was cancelled Nov 2017.

https://www.faa.gov/documentLibrary/med ... n_Memo.pdf

Is your ash tray listed on your equipment list?

[n2582d]

Excellent discussion. I don’t want to loose sight of the make model of the speaker itself? Any pictures besides mine? Love to know if the Jensen is the official speaker? Historians out there?

-Harmon

Hey, quit getting us off topic Harmon!

The '48 C-170 lists p/n P770053 as a G.E. speaker. I believe this may by a typo as two places in the C-120/140 IPC the G.E. speaker is p/n P7770053. I'm guessing by the format (starting with a "P") that that is a G.E. p/n. The C-170A IPC still lists the speaker as a General Electric speaker but now it is a Cessna p/n in fig. 53-41; p/n 0411062-1. The C-170B IPC lists the speaker as 0411062-2 in fig. 70A-3. Note that it is only for s/n 20267-26995 (1952-1955 models). In 1956 the control yoke, rudder pedals, and an opening window on the right side were removed as standard equipment. The overhead speaker also got the cost savings axe. All this equipment became optional in 1956. The 0411062-2 part number was revised to 0411062-4 in 1995. Preferred Airparts has a new one in stock.

[DaveF]

The point I was making is that the statement " If it was equipment with the plane when it left the factory it needs to work." is not entirely correct.

And I thought I was agreeing.

[Bruce Fenstermacher]

Harmon,

Like many things in the 170 world it may take years to learn something is so in the production of the 170. Your speaker is a Jenson and it might or might not be original. But now it is documented. maybe the next speaker we see that could be original is labeled a Jenson and we start to see a pattern. On the other hand if we never see another Jenson then perhaps yours is a really nicely done replacement.

[gfeher]

So, according to 91.405(c) you CANNOT leave that speaker INOP INDEFINITELY! You must either repair it or have it removed in some otherwise approved method.

This is not entirely correct in view of a 2018 legal interpretation by the FAA. Despite the seemingly clear language of 91.405(c), according to the 2018 legal interpretation, you are not required to repair, replace or remove the inoperative item at the next inspection, so long as "the inoperative item [is] inspected again (reevaluated) at that inspection in order to ensure that the discrepancy will not have an adverse effect on the safe operation of the aircraft." Further "this the process of reevaluating the item at each required inspection may be continued "indefinitely," so long the reevaluation is accomplished and documented at each required inspection." Apparently, this interpretation is based upon the intent of the regulation. It's a big loophole. Go figure.

Here's a copy of that legal interpretation (I'm also putting a copy in the MX Library):

FAA 2018 Legal Interpretation re INOP Instruments or Equipment.pdf

(229.49 KiB) Downloaded 351 times

[GAHorn]

Thanks for that, Gene. I just KNEW there had to be some more ambiguity somewhere in the beuracracy!

[floatplaneflyer]

Thanks Bruce

[Markjobe]

Bought a replacement speaker online, it was an exact match to original, replaced light with a new led fixture for $15 bucks, love it!

[DaveF]

What kind of LED fixture?

[strangebird]

Where did you buy the speaker that was an exact replacement?