Airworthiness Questions on the Checkride: AV1ATE, 91.205 and Inoperative Equipment

Airworthiness is the second most common way to fail the private pilot oral. Larry Bothe, the designated pilot examiner whose records of 157 checkrides are one of the few public tallies of failures, put it right behind airspace, and he named the exact weak spot: applicants who do not understand the difference between required and optional equipment (NAFI Mentor, 2018). His reasoning is practical. The average general aviation airplane is decades old, things break, and a new pilot has to know what to do when they do.

The ACS task is PA.I.B, Airworthiness Requirements. It covers certificates, inspections, ADs, special flight permits, preventive maintenance and equipment requirements, but the skill elements decide the grade: locate the airworthiness and registration information, determine the airplane is airworthy in a scenario, and apply the procedures for inoperative equipment (FAA-S-ACS-6C, PA.I.B).

The question underneath all of them is one sentence: is this airplane legal to fly today, and how do you know? Answer it in the same order every time.

The order to answer in

1. The paperwork on board.
2. The inspections, in the logbooks.
3. Airworthiness directives.
4. The equipment the flight requires.
5. Anything that is broken today.

Over all five sits 14 CFR 91.7: no one may operate a civil aircraft unless it is airworthy, and the pilot in command is responsible for determining whether it is in condition for safe flight. The owner or operator is primarily responsible for keeping it airworthy, including compliance with ADs (91.403(a)), but the decision to go is yours.

Step 1: The paperwork on board

91.203(a) requires two certificates in the airplane: an appropriate and current airworthiness certificate, and an effective registration certificate. The airworthiness certificate must be displayed at the cabin or cockpit entrance so that it is legible to passengers or crew (91.203(b)). Add the operating limitations, which must be available in the airplane as the approved flight manual, markings and placards (91.9), and the weight and balance data you need to compute loading. Most students learn this as ARROW: airworthiness, registration, radio station license, operating limitations, weight and balance. The radio license is the odd one out: it is an FCC matter, not an FAA one, and for a U.S. airplane it only comes into play on international flights.

Step 2: The inspections (AV1ATE)

AV1ATE is a memory aid, not a rule, and half its letters do not apply to a VFR checkride. The examiner wants to hear that you know which ones do.

The details examiners probe

• The 100-hour overfly. The limit may be exceeded by no more than 10 hours, and only while en route to a place where the inspection can be done; those extra hours count toward the next 100 (91.409(b)). It is not a 10-hour grace period for rentals.
• Annual versus 100-hour. An annual satisfies the 100-hour requirement. The reverse is not true: a 100-hour inspection counts as an annual only if it was performed by a person authorized to do annual inspections and entered as an annual (91.409(a)). The person who can approve return to service is defined in 43.7; in practice, annuals are signed by a mechanic holding an inspection authorization.
• ELT battery. It must be replaced (or recharged) after more than 1 cumulative hour of use, or when 50 percent of its useful life has expired; the new expiration date is marked on the outside of the transmitter and in the maintenance record (91.207(c)). The ELT requirement does not apply to training operations conducted entirely within 50 NM of the airport where they began, among other exceptions (91.207(f)).

Step 3: Airworthiness directives

ADs are legally enforceable rules that apply to aircraft, engines, propellers and appliances (39.3). Compliance is the owner or operator’s primary responsibility (91.403(a)), and the records must show the current status of each applicable AD: the AD number and revision date, the method of compliance and, for recurring ADs, when the next action is due (91.417(a)(2)(v)). Know where that AD list lives in the logbooks of the airplane you bring, and be ready to find one recurring item on it. Special Airworthiness Information Bulletins, also named in the ACS, are advisory: they recommend, ADs require.

Step 4: Equipment the flight requires

For day VFR, 91.205(b) lists what must be installed and operable in a powered airplane with a standard airworthiness certificate:

• Airspeed indicator, altimeter and magnetic direction indicator.
• Tachometer for each engine; oil pressure gauge for each engine using a pressure system.
• Temperature gauge for each liquid-cooled engine; oil temperature gauge for each air-cooled engine; manifold pressure gauge for each altitude engine.
• Fuel gauge indicating the quantity in each tank.
• Landing gear position indicator, if the gear is retractable.
• Anticollision lights for small airplanes certificated after March 11, 1996 (the airplane may continue to a place where repairs can be made if one fails).
• Flotation gear and at least one pyrotechnic signaling device, if operated for hire over water beyond power-off gliding distance from shore.
• Safety belts for each occupant 2 or older; shoulder harnesses for front seats in small airplanes manufactured after July 18, 1978 (all seats after December 12, 1986).
• An ELT, if 91.207 requires one.

For night VFR, 91.205(c) adds approved position lights, an anticollision light system on all U.S.-registered aircraft, one electric landing light if the flight is for hire, an adequate source of electrical energy, and one spare set of fuses (or three of each kind) accessible in flight. The mnemonics (A TOMATO FLAMES, FLAPS) help you recall the list; the examiner will be happier if you can open the regulation and read it.

Step 5: Something is broken

If the airplane has an approved Minimum Equipment List with a letter of authorization, you follow the MEL (91.213(a)). Most training airplanes don’t, so the answer for a non-turbine airplane is 91.213(d). Say it as a sequence:

1. Is it required? The item may not be part of the VFR-day type certification equipment; indicated as required on the equipment list or the KOEL for the kind of operation; required by 91.205 or any other Part 91 rule for that operation; or required by an AD. If any answer is yes, you cannot go.
2. If it is optional: remove it (placard the cockpit control and record the maintenance under 43.9), or deactivate it and placard it “Inoperative.” If deactivation involves maintenance, it must be done and recorded under Part 43.
3. Make the determination: a certificated pilot or a qualified mechanic determines that the inoperative item does not constitute a hazard.

Bothe teaches the same logic from the other end. If the item is required, you have two choices: repair it, or get a special flight permit to fly the airplane to where it can be fixed. If it is optional, you have two choices: placard it inoperative or remove it.

What you may fix yourself

A pilot certificated under Part 61 (other than a sport pilot, who has narrower privileges) may perform preventive maintenance on an aircraft the pilot owns or operates, as long as it is not used under parts 121, 129 or 135 (43.3(g)), and a private pilot may approve that work for return to service (43.7(f)). “Preventive maintenance” is a closed list in Part 43, Appendix A, paragraph (c), limited to work that does not involve complex assembly. Examples from that list: servicing landing gear shock struts, replacing bulbs, reflectors and lenses of position and landing lights, replacing or cleaning spark plugs, replacing and servicing batteries, and cleaning or replacing fuel and oil strainers or filter elements.

Then comes the part applicants forget: the logbook entry, with a description of the work, the date completed, and your signature, certificate number and kind of certificate (43.9(a)). No airplane may be operated after maintenance until it has been approved for return to service and that entry is made (91.407(a)). If the work may have appreciably changed the flight characteristics, a pilot with at least a private certificate must fly it, check it and log the flight before anyone else is carried (91.407(b)).

Logbook exercise: can this airplane fly today?

The scenario is fictional. Today is October 14. You rented a flight school Cessna 172 for a cross-country 80 NM away, day VFR, no instructor on board. The school uses it for dual instruction. Here is what the logbooks and placards show:

How to sound ready

Bring the logbooks with the inspections and ADs tabbed. When handed a broken item, say “required or optional?” and run the 91.213(d) checks out loud: that is what the risk management element, inoperative equipment discovered prior to flight, is testing.

Airworthiness links to the rest of the oral: an expired transponder check changes which airspace you can enter, and the scenario walkthrough shows how an examiner slips a broken item into the middle of a cross-country discussion. If you want the full picture of how orals go wrong, read why applicants fail.

Quick answers