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  1. I know my best bet is to ask the FSDO or apply for a legal interpretation, but I'm looking for input on here first. This is mainly referencing 91.213, where it states "small rotorcraft" may operate without an MEL even if an MMEL has be developed for this aircraft. If you go by small aircraft definition then this would lead you to believe the small rotorcraft is anything under 12,500lbs. I personally wouldn't consider an 12,00 helicopter a small rotorcraft, but I'm no lawyer so I'm looking for input. When you start reading legal interpretation there are many instances where they somewhat break down rotorcraft into turbine powered or non-turbine powered but never classify them as small or large rotorcraft. Thanks for your input.
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