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Maintenance recordkeeping for inoperative components

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General Aviation

In a previous question we established that I don't need mode C for my instrument checkride, but that I need to have the transponder placarded and the appropriate entry in the logbook in accordance with 91.213. 

That paragraph refers to Part 43.9 for how to make the record entry. That part doesn't say whether the person making the entry needs to be an A&P, but does say "the signature, certificate number, and kind of certificate held by the person approving the work" is required. Since labeling the instrument is not a major alteration, am I correct in assuming I can make that entry and use my pilot's license as certificate number? Thanks 

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2 Answers

  1. Traffic in Sight on Oct 28, 2014

    91.213(d)(3)(ii) states that “If deactivation of……..involves maintenance, it must be accomplished and recorded in accordance with Part 43…..”

    It seems to me that since no maintenance is being performed or required, no record is required to be entered into the logbook.

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  2. Nibake on Oct 29, 2014

    You are right! In (d)(3)(i) it implies the entry because removal implies maintenance, but in (ii) it looks like deactivating/placarding alone does not require a logbook entry if there is no maintenance involved.

    Having said that, it still probably still best to log work done, even if it is preventative maintenance or 91.213 stuff.

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