Most applicants are familiar with the items listed in §91.205 (remember “TOMATOFLAMES” anybody?).  As pilots we are taught early on that the equipment listed in §91.205 must be operational.  But what happens if something not listed in §91.205 is inoperative?  A dated but still valid guiding document for this dilemma is AC 91.67.  This AC discusses the use of a Minimum Equipment List (MEL).  A MEL solves this problem by providing guidance as to what must be done (or what you can do) if some component not listed in §91.205 is inoperative.  But what to do if your airplane doesn’t have a MEL?  Check out chapter 2 of AC 91.67.  Chapter 2 provides a step by step guideline for what the pilot must do to ensure the airplane is both safe and legal to fly.  The first step is to check the equipment list or “kinds of equipment” list.  Here are some examples of a “kinds of equipment” list:

The example above is from a C172M POH and is not very specific. Note that there is no addtional “equipment list” for this model.

This is from a C172N POH and not much better, also no equipment list.  And below we have a newer model, a C172S.  The C172 lists “kinds of operation” and then goes further with a equipment list.  This helps because the equipment list will state whether or not you can fly with a component inoperative.  Remember, an equipment list IS NOT an MEL.  They sound similar but in this usage they are two completely different animals.

Next, go to step 2 and check the type certificate requirements.  Search for “type certificate data sheet” (TCDS) for your aircraft.  Again you may find that not much information is provided for the older airplanes such as the C172M and C172N.  The newer aircraft may have more information.   The next step is to search for Airworthiness Directives (AD) that might have required the installation of the component that is inoperative.  Finally, if you haven’t found the item in one of the previous steps then go back to §91.205 to see what applies for your flight.    Night time flight?  Then you need the equipment listed in §91.205 (b) and (c).  The AC also says to check other pertinent regulations such as §91.207, §91.215. If after going through the regulations you find that your inopertive component is not listed then you may be able to deactivate/remove it, placard it, and continue to fly.  I say “may” because you might need an A&P to do the work.  As the pilot in command (and a pilot applying for a rating) you should be familiar with the procedures for determining the airworthiness of your airplane both with, and without, a minimum equipment list.

 

The change from Practical Test Standards (PTS) to the Airmen Certification Standards (ACS) is happening this June.  The first ratings to change over to the new ACS are the Private – Airplane and Instrument – Airplane.  Guidance is posted on the FAA.gov web site and I’m not going to go into the codes or format but I do want to bring up a few points.   The ACS does not change the standards for the evaluation but each Area of Operation task now has three specific sections; Knowledge, Risk Management, and Skills.  The PTS has always had a “skills” section but the knowledge and Risk Management area were perhaps somewhat vague to many applicants and CFIs.  Knowledge pertains to the knowledge requirements of §61 for your respective rating (e.g. §61.105 for the Private Pilot) and these areas are examined both on the knowledge test (“written test”) and on the oral portion of the practical test (your “check ride”).  The future “written” tests will link a code specifically to a subtask on the knowledge section making it much clearer as to which areas were missed on the written (and making it easier for the examiner to recheck these areas!).

The ACS has brought new and needed attention to Risk Management.  The risk management section of the ACS contains much information that was in the “special emphasis” section of the PTS.  The special emphasis area on page 7 of the Private Pilot PTS (FAA-S-8081-14B) was sometimes overlooked by both CFIs and students.  Also overlooked was the Single Pilot Resource Management (SRM) section of the old PTS especially as it pertains to Aeronautical Decision Making (ADM).  ADM includes tools such as the PAVE model, the 3Ps – Perceive, Process, Perform, and DECIDE.  I’M SAFE is another risk management tool. Now risk management is right out front and center on each task in the ACS. The FAA has many great handbooks that are available free on the faa.gov web site.  These handbooks serve as the references for just about everything contained in the ACS (or old PTS for that matter).  One handbook that may have been overlooked in your training is the Risk Management Handbook (FAA-H-8083-2 with change 1).  This handbook is a primary resource for the new ACS risk management section.