How Do You Handle Inoperative Equipment on an Aircraft Without a Minimum Equipment List?

Why 91.213 Is a Checkride Favorite

Imagine your DPE points to the aircraft squawk sheet and asks what you would do if you showed up to fly and found that the clock was inoperative. Simple question, right? Not quite. Many candidates either freeze or give a dangerously incomplete answer, and it costs them. Inoperative equipment under 14 CFR 91.213 is one of the most nuanced airworthiness topics on the private pilot oral exam, and the FAA expects you to walk through a specific, logical process — not just make a judgment call on the ramp.

The reason this question carries so much weight is that it sits at the intersection of regulations, aircraft documentation, and airworthiness decision-making — exactly the kind of multi-layered thinking a competent pilot needs. Getting it right demonstrates that you understand your responsibilities as pilot-in-command before you ever leave the ground.

The Four-Source Check: Your Roadmap Under 91.213

When an aircraft does not have a Minimum Equipment List, 91.213 requires you to work through what is commonly called the KOEL process — a systematic check of four authoritative sources before you can determine whether a flight is legal with inoperative equipment.

The first place you look is the Kinds of Operations Equipment List, found in the aircraft Pilot Operating Handbook or Approved Flight Manual. The KOEL tells you which equipment is required for specific kinds of operations — day VFR, night VFR, IFR, and so on. If the inoperative item appears there for the kind of operation you are planning, the aircraft cannot be flown until it is fixed.

If the item does not appear on the KOEL, your next stop is the applicable FARs. The most relevant regulation is 14 CFR 91.205, which lists the instruments and equipment required for day VFR, night VFR, and IFR flight. A well-known mnemonic — ATOMATOFLAMES for day VFR, FLAPS for night additions — can help you recall the required items quickly. If the broken equipment is on that list for your planned operation, the aircraft is grounded until repaired.

Third, you check for any Airworthiness Directives that reference the equipment in question. An AD can mandate that a specific piece of equipment be operational, and overlooking this source is a common and serious mistake during oral exams. Fourth and finally, you consult the aircraft type certificate data sheet, which defines the certificated configuration of that specific make and model. Equipment required by the type certificate must be functioning for the aircraft to remain airworthy.

What Happens When the Item Is Not Required

If you work through all four sources — the KOEL, the FARs, any applicable ADs, and the type certificate data sheet — and the inoperative item does not appear in any of them, you are not simply free to go flying. There are still two mandatory steps that many candidates forget entirely.

First, an appropriately rated mechanic must either remove the equipment or deactivate it, and make a logbook entry reflecting that the item has been addressed. The pilot cannot simply decide on the ramp that something is non-essential and proceed. That decision requires a certificated person making a proper maintenance record entry. Second, the inoperative item must be placarded to indicate it is inoperative. The placard alerts any future pilot-in-command that the equipment is not functional, maintaining transparency about the aircraft condition.

Skipping either of these steps — the logbook entry or the placard — leaves you operating an aircraft that does not meet the airworthiness standard, even if the broken item itself was legally non-required. Your DPE will absolutely ask whether these steps are necessary, and the answer is always yes.

MEL vs. 91.213: Do Not Confuse the Two

One of the most reliable ways to lose credibility during the oral exam is to mix up the MEL process with the 91.213 process. A Minimum Equipment List is a formal, FAA-approved document that operators — typically commercial operators or flight schools with Letter of Authorization — use to authorize flight with specific inoperative items already identified and approved in advance. It is a sophisticated, operator-specific tool that requires FAA approval to create and use.

The 91.213 process is what applies to the average general aviation aircraft that does not carry an MEL. As a private pilot flying a typical training aircraft or rental, you will almost certainly be working under 91.213, not an MEL. Understanding that distinction shows the examiner you grasp the regulatory structure, not just a memorized answer. When your DPE asks how you handle inoperative equipment, clarify upfront whether the aircraft has an MEL — and if it does not, walk confidently through the KOEL, the FARs, the ADs, and the type certificate data sheet.

Airworthiness decisions made before engine start are among the most important a pilot-in-command will ever make. The 91.213 process exists precisely to ensure those decisions are grounded in regulation and documentation, not guesswork. Know it cold before you sit across from your DPE.

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