Mastering 14 CFR 91.213: Inoperative Equipment Flowchart

The Dreaded Scenario: "Can I Still Fly?"

You’re out on the ramp, preflighting for your long-awaited cross-country solo or your Private Pilot checkride. You flip the landing light switch, walk to the front of the cowl, and see... nothing. The bulb is burnt out.

Your heart sinks. Does this ground the flight? Can you just ignore it because it's daytime? This is the moment where many student pilots freeze during their oral exam. The DPE (Designated Pilot Examiner) isn't just looking for a 'yes' or 'no'—they are looking for your ability to navigate the legal framework of 14 CFR 91.213.

Understanding flying with inoperative equipment is one of the most critical safety and regulatory skills you can possess. In this guide, we’ll break down the 91.213 flowchart, explain the difference between a KOEL and an MEL, and walk through real-world scenarios so you can ace your equipment questions with confidence.

Understanding the Regulatory Hierarchy

Before we dive into the specific steps, we need to understand that the FAA provides a specific hierarchy for determining if an aircraft is airworthy with broken gear. Most small training aircraft (like a Cessna 172 or Piper Archer) operate under 91.213(d).

However, some larger or more complex aircraft operate under a Minimum Equipment List (MEL). It is vital to know which one your airplane uses.

MEL vs. KOEL: What’s the Difference?

This is a common point of confusion. Let’s clear it up:

MEL (Minimum Equipment List): This is a specific, FAA-approved document for a particular tail number. If your plane has an MEL, 91.213(d) does not apply to you. You simply look at the MEL; if the item isn't listed as allowed to be broken, you can't fly.
KOEL (Kinds of Operations Equipment List): This is found in your Pilot’s Operating Handbook (POH). it specifies what equipment is required for specific types of flight (VFR Day, VFR Night, IFR, etc.).

Checkride Tip: Most flight school Cessnas do not have an MEL. If the DPE asks, "Does this plane have an MEL?" don't just say no—tell them you use the procedures outlined in 14 CFR 91.213(d).

The 14 CFR 91.213(d) Flowchart

If your aircraft does not have an MEL, you must follow this four-step sequence to determine if you can fly with inoperative equipment. If the answer to any of these questions is YES, the aircraft is grounded until the item is repaired.

1. Is it part of the VFR-Day Type Certificate?

Every airplane is certified under a Type Certificate Data Sheet (TCDS). This document lists the equipment the manufacturer must include for the plane to be airworthy. If the broken item is required by the TCDS, you aren't going anywhere.

2. Is it listed as "Required" on the KOEL?

Check your POH (usually Section 2 or 6). The Kinds of Operations Equipment List will tell you if that landing light or strobe is required for VFR Day. If the KOEL says it’s required for your specific flight, the plane is grounded.

3. Is it required by 14 CFR 91.205?

This is where your acronyms come in (like ATOMATO FLAMES). Even if the manufacturer didn't require it, the FAA might. For example, if your fuel gauge is inoperative, 91.205(b) says you cannot fly, as it is required for all VFR flight.

4. Is it required by an Airworthiness Directive (AD)?

ADs are mandatory spirit-crushers. Sometimes the FAA issues a directive stating a specific piece of equipment must be functional for safety. If an AD requires that equipment to work, you cannot fly until it is fixed.

The Scenario: The Burnt-Out Landing Light

Let’s apply the 91.213 flowchart to a scenario frequently discussed on Reddit and in flight schools: You’re preflighting a Cessna 172 for a VFR flight, and the landing light is out.

Question: Can you fly during the day?

Type Certificate: Is it required? No.
KOEL: Check the POH. Most C172 KOELs only require the landing light for "Operations for Hire."
91.205: Does ATOMATO FLAMES require a landing light for VFR Day? No.
ADs: Are there any ADs requiring it? Unlikely.

The Verdict: Yes, you can fly during the day!

Question: What about at night? If you are flying for hire (like a flight lesson where you pay an instructor), the KOEL and 91.205(c) will likely require it. If you are flying solo (not for hire), 91.205(c) only requires a landing light if the aircraft is operated for hire. However, you must still check your specific KOEL, as many manufacturers require it for all night operations.

What If I Can Fly? (The Final Steps)

Just because the law says the plane can fly doesn't mean you can just jump in and take off. If you've determined the equipment is not required, you must follow these two mandatory steps:

Deactivate or Remove: The inoperative item must be either removed (and the weight/balance updated) or deactivated. Usually, this means pulling the circuit breaker and zip-tying it, or simply turning the switch off.
Placard: You must place a sticker or label over the control or the instrument that says "INOPERATIVE."

Safety Check: After the legal check, perform a pilot's self-assessment. Ask yourself: "Does the loss of this equipment significantly increase my workload or decrease safety?" If the answer is yes, stay on the ground regardless of what the FARs say.

Required by Type Certificate vs. Required by Regulation

This is a classic "gotcha" question on the Private Pilot oral exam.

Required by Type Certificate: This means the airplane was literally built and certified with this equipment as a core requirement for its existence. Without it, the airplane doesn't match its "birth certificate."
Required by Regulation: This refers to the FAA’s operating rules (like 91.205). The airplane might be perfectly fine according to the manufacturer, but the FAA says, "If you want to fly in our airspace at night, you need X, Y, and Z."

Tips for the Private Pilot Oral Exam

When your DPE asks you about inoperative equipment, they are testing your decision-making. Here is how to handle it:

Don't Guess: Have your POH and a copy of the FAR/AIM ready. It is much better to say, "I would use the flowchart in 91.213(d) and check my KOEL in Section 2 of the POH," than to guess.
Be Methodical: Literally walk the DPE through the four steps. "First, I'd check the TCDS, then the KOEL..."
Show, Don't Just Tell: Open the POH to the KOEL page. This proves you know exactly where to find the information in a real-world scenario.
Mention ADs: Many students forget the Airworthiness Directives step. Mentioning it shows a high level of regulatory knowledge.

Summary Checklist for Inoperative Equipment

To make it easy, keep this checklist in your flight bag or saved on your phone:

Check for MEL: Does this specific tail number have an FAA-approved MEL?
Step 1 (TCDS): Is the item required by the Type Certificate?
Step 2 (KOEL): Is the item required for this type of flight in the POH?
Step 3 (91.205): Is it required by ATOMATO FLAMES / FLAPS?
Step 4 (ADs): Is it required by any Airworthiness Directives?
Action: If 'No' to all, deactivate/remove and placard "INOPERATIVE."
Decision: Is the flight still safe to conduct?

Conclusion

Mastering 91.213 and the inoperative equipment flowchart is about more than just passing your checkride; it’s about becoming a safe, competent Pilot in Command. The next time you see a broken light or a finicky gauge, you won't have to wonder if you're legal. You'll have the tools to make a professional "Go/No-Go" decision.

Are you preparing for your checkride? Check out our other guides on Mastering the ACS and How to Pass Your Private Pilot Oral Exam.

Safe skies!

91.213 Explained: Can You Fly With Inoperative Equipment?