B727 FLT CREW QUESTIONS OPERATING THE ACFT WITHOUT AN OPERABLE ALT ALERTER VICE AN AUTOPLT ALT HOLD FUNCTION.

Narrative

THE PROB WAS DISPATCHING A TURBOJET ACFT ON A ROUTINE PART 121 FLT WITH AN INOP ALT ALERTER. THE ALT ALERTER WAS INOP AND HAD BEEN DEFERRED IN ACCORDANCE WITH THE MEL WHICH STATES 'EXCEPT WHERE ENRTE OPS REQUIRE ITS USE; MAY BE INOP PROVIDED THE AUTOPLT WITH ALT HOLD IS OPERATIVE.' IN THIS CASE IT WAS CLRLY REQUIRED FOR 'ENRTE OPS.' FAR 91.219 STATES; '...NO PERSON MAY OPERATE A TURBOJET POWERED US-REGISTERED CIVIL AIRPLANE UNLESS THAT AIRPLANE IS EQUIPPED WITH AN APPROVED ALT ALERTING SYS OR DEVICE THAT IS IN OPERABLE CONDITION...' EXCEPT AS PROVIDED BY PARAGRAPH (D). PARAGRAPH (D) STATES THAT THE ALT ALERTER IS NOT REQUIRED FOR ACFT WITH AN EXPERIMENTAL CERTIFICATE OR FOR THE PURPOSE OF FERRYING THE AIRPLANE UNDER SEVERAL DIFFERENT CONDITIONS; OR FOR SALES DEMONSTRATION FLTS. CLRLY NONE OF THESE CONDITIONS APPLIED TO THIS FLT. WE WERE FIRST TOLD BY DISPATCH THAT PART 91 DID NOT APPLY TO US BECAUSE WE ARE A PART 121 OPERATOR. REACHING AN IMPASSE WITH DISPATCH; WE CALLED THE CHIEF PLT. THE CHIEF PLT TOLD US THE ALT ALERTER WAS NOT REQUIRED BECAUSE THE ALT HOLD PORTION OF THE AUTOPLT WAS OPERATIVE. THE AUTOPLT DID NOT HAVE AN ALT ARM AND CAPTURE FEATURE; IT WAS STRICTLY ALT HOLD TO BE ENGAGED WHEN REACHING THE DESIRED ALT. THE CAPT WAS DIRECTED BY THE CHIEF PLT TO TAKE THE FLT AND SO WE DEPARTED. I BELIEVE WE VIOLATED FAR 91.219. THERE ARE TRAINING ISSUES HERE; PRESSURE FROM SUPVRS AND OTHER HUMAN FACTORS THAT LEAD PEOPLE TO THE CONCLUSION THEY WANT; NOT NECESSARILY THE CORRECT CONCLUSION. THIS REQUIRED AN INCREASE IN PLT WORKLOAD TO COMPENSATE FOR THE INOP ALT ALERTER.