PA.I.B.R1· R

Inoperative equipment

Inoperative equipment discovered prior to flight

This element is about decisions, not memorization. The DPE will hand you a scenario — a missing position light, a balky vacuum gyro, an inop fuel gauge — and watch how you reason through whether you can fly. The vehicle for that reasoning is ; the no-MEL path is captured by the RAKETS gates.

Airworthiness · PA.I.B.R1

Inop equipment — the RAKETS gates

§91.213(d)

six gates the inop item must clear before it can be deferred.

R
R — Regulations
§91.213(d)(2)(iii)
Not required by §91.205 (A-TOMATO-FLAMES for day VFR, plus FLAPS for night), §91.207 (ELT), §91.215 (transponder), or §91.225 (ADS-B Out) for the kind of flight you're conducting.
A
A — Airworthiness Directives
§91.213(d)(2)(iv) + §39.7
Not required to be operational by an AD.
K
K — KOEL
§91.213(d)(2)(ii)
Not required by the Kinds of Operations Equipment List in POH/AFM Section 2 for this kind of flight (VFR Day, VFR Night, IFR Day, IFR Night).
E
E — Equipment list
Not marked Required on the aircraft's Comprehensive Equipment List in the POH.
T
T — TCDS
Not required by the aircraft's Type Certificate Data Sheet.
S
S — Safety
§91.7
PIC's final judgment — can you honestly fly this airplane on this flight today without that item?

★ The PIC question

Can you honestly fly this airplane today without that item?

Don’t fly.

Even if technically legal.

★ The four-step deferral

Deactivate or remove
An A&P, or the pilot if it’s on the §43 Appendix A(c) preventive-maintenance list.
§43.3
Placard INOPERATIVE
In view of the pilot, near the affected item.
§91.213
Record
A maintenance-log entry of the action.
§43.9
Fly
The final airworthiness determination, made as PIC before each flight.
§91.7

Deferrable flight

Aircraft with an MEL. Operators with an FAA-approved Minimum Equipment List follow the MEL instead, controlling under §91.213(a)/(b). Most flight schools don't have one, so this flow assumes no MEL.

Fail any of R, A, K, E, or T → repair, MEL relief, or special flight permit §21.197.

KOEL vs. CEL

The two equipment-list gates trip up candidates because they live in different sections of the POH:

KOEL (Section 2, Limitations) — operation-driven. Columns for VFR Day / VFR Night / IFR Day / IFR Night, rows for each piece of equipment marked required or not.
CEL (Section 6 or an appendix) — installation-driven. Every installed item marked R (Required), S (Standard), or O (Optional).

KOEL tells you what's required for this kind of flight; CEL tells you what was required to be installed in the first place. RAKETS checks both as separate gates.

The safety filter

The first five RAKETS gates are legal filters; S is the safety filter. Items can clear R-A-K-E-T and still be a bad idea today:

Inop landing light for daytime VFR — legally deferrable, but not if the destination is a busy Class D field at dusk.
Inop vacuum gyro for VFR — legally deferrable, but not on a marginal-VMC day with deteriorating ceilings.
Inop second comm for VFR in Class B — legally deferrable, but you've lost redundancy in busy airspace.

The DPE wants to hear you separate "is this legal?" from "is this safe today?" — and to make a defensible call on both.

Worked examples:

Inop vacuum-driven attitude indicator on a day-VFR sightseeing flight — The attitude indicator isn't on the day-VFR list (it's an IFR-only requirement under § 91.205(d)(8)). If the KOEL, CEL, TCDS, and ADs all clear, the gyro can be deactivated, placarded INOPERATIVE, logged, and the flight conducted. PIC still makes the safety call: if today's weather is severe-clear, defer is reasonable; if there's any chance of inadvertent IMC, don't.
Inop landing light on a Part 91 dual-instruction flight, charged to a student — The landing light is required at night when the aircraft is operated for hire . "Flight instruction for hire" arguably triggers the for-hire rule; an A&P would need to repair before a paid night-flight lesson. Day-VFR with a paid student is OK from the landing-light angle — the night rule doesn't apply.

Common DPE questions

Ideal answer
If the aircraft has an FAA-approved MEL, that's controlling — most flight schools don't have one, so I run the no-MEL flow under 91.213(d). Use the RAKETS mnemonic: Regulations (91.205/91.207/91.215/91.225), Airworthiness Directives, KOEL, Equipment list (CEL) in the POH, Type Certificate Data Sheet, and Safety (the PIC's 91.7(b) judgment). If any of the first five says the item is required, I'm grounded — repair, MEL relief, or a 21.197 ferry permit. If all six pass, the item gets deactivated/removed by an authorized person, placarded INOPERATIVE, logged under 43.9, and I make the final 91.7(b) airworthiness call before flight.
Key points to mention
- MEL operators follow the MEL (91.213(a)/(b)); most flight schools don't have one
- No-MEL flow under 91.213(d) — RAKETS
- R — Regulations (91.205/207/215/225)
- A — Airworthiness Directives
- K — KOEL in POH §2
- E — Comprehensive Equipment List in POH
- T — TCDS
- S — Safety / PIC under 91.7(b)
- All six pass → deactivate, placard, log, fly
REF: 14 CFR 91.213(d), 91.7
Ideal answer
R — Regulations: is the item required by 91.205 for the kind of flight, 91.207 for ELT, 91.215 for transponder, or 91.225 for ADS-B Out? A — Airworthiness Directives: does any AD require the item to remain operative? K — KOEL: does the Kinds of Operations Equipment List in POH Section 2 require it for THIS kind of flight (VFR day, VFR night, IFR day, IFR night)? E — Equipment list: is the item marked Required on the aircraft's Comprehensive Equipment List in the POH? T — TCDS: is the item required by the Type Certificate Data Sheet? S — Safety: as PIC under 91.7(b), can I honestly say the airplane is safe to fly without this item, today, on this route? Fail any of the first five and I'm grounded; fail S and I don't fly even if it's technically legal.
Key points to mention
- R = 91.205, 91.207, 91.215, 91.225 — operating-rule equipment requirements
- A = ADs requiring the item to be operative (39.7)
- K = KOEL in POH §2 — can require items beyond 91.205
- E = CEL in POH — items marked Required (R)
- T = TCDS for the aircraft type
- S = PIC's 91.7(b) safe-to-fly determination
- Fail any reg gate → grounded; fail S → don't fly anyway
REF: 14 CFR 91.213(d), 91.7
Ideal answer
Both live in the Pilot's Operating Handbook. The KOEL — Kinds of Operations Equipment List — is in Section 2 (Limitations) and tells you which equipment is required for each kind of flight: VFR Day, VFR Night, IFR Day, IFR Night. The CEL — Comprehensive Equipment List — is typically in Section 6 or an appendix and lists every piece of installed equipment marked Required (R), Standard (S), or Optional (O). KOEL is operation-driven; CEL is installation-driven. RAKETS makes me check both.
Key points to mention
- KOEL in POH §2 (Limitations) — operation-by-operation requirements
- Columns typically: VFR Day / VFR Night / IFR Day / IFR Night
- CEL in POH §6 / appendix — every installed item marked R / S / O
- KOEL = what's required for this flight; CEL = what was originally required to be installed
- RAKETS checks both gates separately (K and E)
REF: 14 CFR 91.213(d)(2)(ii); POH §2 and §6
Ideal answer
When the equipment matters for THIS flight in particular — that's the S gate. A landing light is regulatorily deferrable for daytime VFR, but I wouldn't fly into a busy Class D field at dusk with one inop. A vacuum gyro might be deferrable for VFR, but not on a marginal-VMC day with deteriorating ceilings. A second comm in Class B is technically optional, but losing redundancy in busy airspace isn't worth it. PIC judgment under 91.7(b) is the final filter — legal does not equal safe.
Key points to mention
- RAKETS R-A-K-E-T checks legality; S checks safety
- Consider today's specific conditions: weather, terrain, time of day, airspace
- Consider redundancy lost — backup gyros, second comm, etc.
- Consider the destination's expectations
- 91.7(b) keeps the safe-for-flight call with the PIC
- Document the decision either way
REF: 14 CFR 91.7, 91.213
Ideal answer
RAKETS is closed. Three paths remain: repair before flight (an A&P fixes it and signs the logbook), MEL relief if the operator has an approved MEL with relief for that item (most flight schools don't), or a special flight permit under 14 CFR 21.197 to ferry the aircraft to a maintenance base. Cancel and reschedule is often the cheapest answer.
Key points to mention
- Option 1: repair — A&P fixes and signs
- Option 2: MEL relief — only if operator has an FAA-approved MEL
- Option 3: 21.197 special flight permit to ferry to maintenance
- Option 4: cancel/reschedule
REF: 14 CFR 91.205, 91.213, 21.197

1 of 5

Multiple choice

In the RAKETS mnemonic for no-MEL deferral under 14 CFR 91.213(d), the 'R' stands for:

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PA.I.C.K1 · Sources of weather data

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