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3 Answers

Inoperative equipment, without an MEL. (4-step test)

Asked by: 3168 views , ,
Commercial Pilot, FAA Regulations, Private Pilot

I was taught that without an MEL, you had to look at the vfr-day type certificate, aircraft equipment list or kinds of operation list, 91.205, and airworthiness directives. Besides 91.205, I'm confused as to what each of these are, and where I'm supposed to find them. In the POH? Mx? I know this is basic stuff, but for some reason has never stuck with me.

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3 Answers

  1. John D Collins on Jun 03, 2014

    The type data certificate is an FAA document that provides a list of all of the various options for a certified aircraft You can find them by using Google to search on the make and model and TCDS. The aircraft equipment list is part of the W&B data documentation that is part of the aircraft records; It can often be found in the POH. The kinds of operations list is found in the POH as a part of Section 2: Limitations. It lists for Day and Nite VFR as well as IFR what equipment is required.

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  2. Sam Dawson on Jun 03, 2014

    It does not say type certificate. What it says is:
    “(i) Part of the VFR-day type certification instruments and equipment prescribed in the applicable airworthiness regulations under which the aircraft was type certificated;”

    This is CAR 3 for older airplanes and FAR 23 for modern airplanes. Usually it will state somewhere in the airplane manual what regulation was used for the certification of the airplane or you can find it on the TCDS.
    Some of the required equipment may be listed on the TCDS (Type Certificate Data Sheet), but many times you won’t find required items. For example, airplanes with carb engines require carb heat (FAR 23.1093) and aircraft with cowl flaps require CHT gauges (23.1305) under both these regulations, though you won’t find these items listed in other locations to include the TCDS. FAR 23 airplanes require stall horns and pitot heat if certified for IFR (23.1323).
    Also don’t forget STC (Supplemental Type Certificates), and any requirements/limitations listed there. For example almost every GPS/Autopilot requires that the manual be on board the airplane and accessible to the PIC.
    Finally one other thing that is mentioned in 91.213 are items required by AD’s and other regulations. An example of an AD item is the vented fuel caps in Cessna 100/200 series airplanes. An example of an item required by other regulations might be a transponder which is required under some operations.

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  3. Mark Kolber on Jun 04, 2014

    IIt’s a bit of a soapbox item for me, but part of the problem is the undeserved overemphasis given to 91.205.

    Your real starting point – and where the process you describe is found, is 91.213(d). They are equipment that is:

    (i) Part of the VFR-day type certification instruments and equipment prescribed in the applicable airworthiness regulations under which the aircraft was type certificated;
    That technically requires a reference to the regs, whether the current Part 23 (and those following it) or the former CAR 5. That’s quite a job. Fortunately, most of the required equipment reauired by those regs will also show up in the Type Certificate Data Sheet (searchable on the FAA website) and in the equipment list (not MEL) in the modern POH, marked as “required.”

    (ii) Indicated as required on the aircraft’s equipment list, or on the Kinds of Operations Equipment List for the kind of flight operation being conducted;
    That’s a direct reference to material in the AFM/POH.

    (iii) Required by § 91.205 or any other rule of this part for the specific kind of flight operation being conducted; or
    …”any other rule” Like 91.209 (lights), 91.207 (transponders), etc.

    (iv) Required to be operational by an airworthiness directive;
    Hopefully you wer taught what those are and where to find them.

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