You show up to fly your airplane and discover that one of the position lights isn’t working. Let’s assume this is your personal, certified airplane, operating under Part 91.
It’s daytime. As a good pilot, you work through any Kinds of Operations Equipment List (KOEL) or equipment list provided in the operator’s manual. You then move on to the VFR-day type-certification requirements, review any relevant airworthiness directives, and finally check the FAA’s minimum equipment requirements in the FARs.
After working through all that, you decide, as pilot in command, that it’s safe to fly without the position light.
Sweet, you think. This is no big deal. You can continue with your planned trip. Following §91.213(d)(3)(ii), all you need to do is pull the circuit breaker, secure it with a zip tie, placard the position light “INOPERATIVE,” make a logbook entry, and you’re good to go.
Or are you?
Section 91.213(d)(3) offers two options for inoperative equipment: remove it from the aircraft with the proper maintenance record, or deactivate and placard it “Inoperative.” If deactivation of the inoperative instrument or equipment involves maintenance, it must be accomplished and recorded in accordance with Part 43.
That tells us what deactivation means. It doesn’t tell us who’s authorized to perform it. And that’s where most people stop short.
Under §43.3, a certificated mechanic may perform maintenance within the privileges of that certificate. A person may also perform maintenance under the supervision of a certificated mechanic. But an owner or operator who holds a pilot certificate gets a much narrower privilege: §43.3(g) authorizes that pilot to perform preventive maintenance on an aircraft they own or operate.
Appendix A to Part 43 further limits that privilege by naming which tasks qualify as preventive maintenance. Deactivation of inoperative equipment isn’t one of them.
That brings us to the FAA’s current guidance.
In AC 91-67A, paragraph 4.2.2, the FAA states that deactivation of an inoperative system is not preventive maintenance. The AC even names pulling and securing a circuit breaker as one way to deactivate equipment.
And there’s the trap.
Pulling a circuit breaker feels like something any pilot can do. We use circuit breakers in normal operation and in abnormal and emergency procedures. Pulling one and zip-tying it doesn’t feel like “maintenance.”
But difficulty isn’t the issue. The issue is what privilege your certificate gives you to perform that task.
So, back to our position light: pulling and securing the circuit breaker may well be the right way to deactivate it.
But that doesn’t mean your pilot certificate lets you perform that deactivation.
That leads to the next question: What if an A&P isn’t available to perform the deactivation?
Section 91.213(d)(3) requires you to either remove the inoperative equipment or deactivate and placard it “Inoperative.” Deciding the position light isn’t required doesn’t erase that requirement. If deactivation involves maintenance, only someone authorized under Part 43 can perform it. If no one authorized is available, you can’t operate under §91.213(d).
That’s exactly the kind of question AC 91-67A exists to answer—full title: Minimum Equipment Requirements for General Aviation Operations Under 14 CFR Part 91, § 91.213—and it leaves you one clean way out.
The good news is there’s a way out—but you have to know the regulation to find it. Deactivation isn’t yours to perform, but replacing the bulb, reflector, or lens is. Appendix A(c)(17) puts it on the list of preventive maintenance you’re already privileged to do as the owner: no A&P, no placard, and legal.
And this is precisely what is driving the EAB push in GA. There is zero room for common sense in the certified world.
EAB might be the only remaining way to own a 100% legal GA aircraft.
You forgot to mention the cheap non-pullable circuit breakers that Cessna used. You can’t pull ’em … they can only pop themselves and be reset by pushing them in.
Not just Cessna. A lot of earlier (likey pre-1995ish) GA aircraft have few or no pullable breakers.
Also, like my 1973 Piper PA28-180…
And even if you can pull a breaker, there is a huge difference between pulling it and pushing it back in if it pops out. That’s just asking for a fire unless you have a specific checklist that authorizes a reset.
I find it hard to believe that a checklist has a “Don’t or Do Push Breaker” back in on it. I was trained that one push back in is OK … if it does it again … you have a problem.
Larry, please allow me to correct your instructor and potentially save your life.
Asking AI or any electrician what causes a circuit breaker to trip yields the following answer.
“ A circuit breaker trips to shut off the electrical flow when it senses an abnormal or unsafe power draw, preventing overheating and potential electrical fires.”
If you have an old, or a bad circuit breaker, sometimes it can trip and you just might get away with resetting it. But you should assume that it tripped because it cannot handle the electrical load that has been placed upon it leading to an overheat situation. And yes, there are checklists on airplanes that specifically tell you to reset certain circuit breakers in certain situations.
Jay … I spent 21 years in the USAF as an avionics type and a 2nd career as an avionics engineer. And I’ve been flying airplanes over half a century. I think I have a bit of experience here. You didn’t maybe know that but …
AI isn’t the FAR’s. AI isn’t common sense, either. Pilots are trained to have some of that … remember? Speaking generically about resetting a CB ONCE in an online article such as this is ridiculous. You wouldn’t reset a breaker on an unneeded system but you might reset a breaker for a system you need in any given situation. You wouldn’t reset a breaker if you smelled something smoke, either. You wouldn’t remove a lock out collar on a breaker but you’d also have known it was there before departing, too. One size fits all situations don’t work in every case or in every situation.
Common sense … some people have it and some people don’t.
Ok Larry, you’re right that I didn’t know you were an avionics technician and engineer in the USAF. Granted, AI can be and often is wrong. I’ll agree with that. But I think that most electricians would tend to agree with AI on the above statement about circuit breakers tripping due to overload, leading to overheating with possible fire and smoke as the result.
So is your advice to pilots, both young and old, that it is ok to reset a tripped circuit breaker as long as you use common sense and you are sure of what you are doing?
Thank you for your service to our country in the United States Air Force!!!
My wife served a few years, too, Jay. Each of us were on Honor Flights – separately – last year and this out of AirVenture. The way we were treated by everyone associated with that operation out of Appleton brought tears to our eyes. Thanks.
When is the last time you heard of a GA airplane coming down because a pilot reset a popped circuit breaker or installed a spare fuse and the airplane came down because of an electrical generated fire ensued? You don’t go from a popped CB to an electrical fire in seconds, normally. Could it happen … of course but I’ve never ever heard of such a situation directly or indirectly. I’m sure one of the barracks lawyers here will prove me wrong 🫤
Assuming we’re talking about a GA airplane where most of the airplane is visible and there’s a master switch to back up isolating power from the airplane / source, there are ways to isolate the source of energy. If you were flying a B-2 bomber and a CB popped on a critical system … what’re you gonna do … ask AI if it’s OK to reset it once? That might be more of an issue since you might not be able to see the system but … ya gotta be thinking of the pro’s and con’s and necessity of any given system. There are NO easy one size fits all answers here. That was my main point, here.
In my home, I just had a CB for my well pump go bad because I use it to turn off the well if we’re gone a long time. It finally gave up the ‘ghost’ after 20 years so … a bad CB could be the problem and not the system it’s protecting. I’m going to install a switch now so the CB can sleep and await its job. Again … see my point?
Now then, you’re NOT hearing me say it’s OK to keep pressing a CB in that’s popping although I have heard AND seen the necessity of same. That’d be nuts. And you’re NOT hearing me say it’d be OK to reset an entertainment system CB for a rich guy riding in back, either. That’s where the ‘common sense’ part comes in. MY position is … engage the gray matter between your ears in situations like this. And I’d be damned if I cared about either a checklist or the FAR’s depending upon what was going on. Just last nite at the airport, we all took CPR and defibrillator training. The trainer told us that IF we think CPR or the defib is called for … do it and worry about what was right later.
Ah the usual confused FAA. §43.3(g) and its famous associated list was reviewed by FAA Legal who ruled that this “changing light bulbs” list is an *example* of owner/operator allowed tasks, and not exclusionary. (This pointed out by Mike Busch, among others). Don’t believe me? Find checking tire pressure on the list – it’s not there. Should every pilot who (wisely) checks tire pressures get the ban hammer?
Then what about the CFI who pulls the lighting CB to see if the student is really doing the pre-flight checks? Or in-flight simulation of a minor emergency? How does one do that legally? Carry aircraft logs, label maker and an A&P in the back seat?
The rules make (sort of) great Oral test questions, but where’s the real life? I had some hope that the article would point out one, very missed, aspect of the whole inop thing, that is, it’s not a permanent “fix”. IDK how many planes I’ve flown in that had tags, sometimes multiple ones, which had been in place for years. Fix that old ADF/whatever or remove it. It’s one requirement that makes sense.
“one … aspect of the whole inop thing, that is, it’s not a permanent “fix”. IDK how many planes I’ve flown in that had tags, sometimes multiple ones, which had been in place for years”
Reminds me of the old saying, “there’s nothing more permanent than a temporary repair.”
Reminds me of the place where I used to work.
We had a Lot of Temporary buildings (RV trailers) that people worked out of.
VERY temporary —> multiple decades worth of temporary…..
If every airplane operator in the USA was forced to comply with the letter of the law today, there would be a lot less air traffic in the sky instantly.
There also is no mention of changing oil, which the owner/operator of the aircraft is allowed to do.
Appendix A to Part 43 really should be changed to use more common-sense wording, and the examples under “Preventive Maintenance” moved into an AC. It doesn’t, for example, include any work specific to an electric-powered aircraft even though it includes performing maintenance on spark plugs.
I still remember the talk that our chief pilot gave the other pilots at a commuter airline I worked for decades ago. It was designed to clear up misunderstandings of mechanical issues pilots had with daily maintenance procedures at the airline. So standing in the middle of the room on meeting night in Kansas City with about 50 other pilots, (we’ll call him Mike) he said “guys, it’s real simple. We are operating with an MEL. When something breaks, or fails, you only have 2 options as a pilot. Write it up in the squawk book, Call maintenance and Either fix it, or defer it as per the MEL. There are no other options.”
For those operating without an MEL, every factory installed system that has anything to do with the airworthiness of the airplane has to work 100%.
I’ve seen this land several ways at my company, depending on who in MC picks up the phone that evening.
Pilot pulls and collars breaker
Pilot pulls and collars with log entry stating they had MC authorization
Mechanic is flown out to pull and collar breaker
Contract maintenance performs the above
I get that as pilots we are not expected to be electrical wizards, and that’s where some of the hesitation occurs. I would argue that if we are expected to pull a circuit breaker during the stress of an emergency, we should be able to on the ground as well.
The AC in question had changed wording between AC 91-67, and AC 91-67A on this very subject. So someone at the FAA changed their mind on this topic.
ACs are not regulatory in nature, so the individual FSDO will likely be making a determination based on the severity of the screw up.
Just my 2cp.
What about switches that are also circuit breakers? Can we turn those off? The reality is we have a lot of latitude when performing maintenance. The legal interpretation of “the list” is that it is merely an illustration of what types of activity may be acceptable.
lee
“The FAA 2009 Coleal Legal Interpretation established that the list of preventive maintenance tasks in 14 CFR Part 43, Appendix A, paragraph (c) is not all-inclusive or exhaustive. [1, 2]”
What if replacing the bulb doesn’t fix the light? Are you still legal to make a Day VFR flight if you don’t turn on the lights?
I say, many of these silly non safety related items can just happen while in flight and ignored before departure because they appeared to be working then. An illegal opinion. But I’m afraid I grew up flying with my dad who first flew in 1937 and always had a more common sense approach to reality.
And then there’s the old false argument that part 91 is mechanically safer than 135 and 121 because if you don’t have an MEL, everything has to be working. More like, unreported and unfixed.