FAA on CAP Aircraft Discrepancies

Federal Aviation Administration

By AuxBeacon News Staff

There were some problems last year.




28 October 2009


SUBJECT: INTERIM CHANGE LETTER – Aircraft Equipment Requirements and Reporting Maintenance Discrepancies

1. The Federal Aviation Administration (FAA) has brought to our attention that some of our pilots may be in need of clarification regarding aircraft equipment requirements and the proper procedures for reporting aircraft discrepancies. I’m confident we all take maintaining our aircraft to FAA standards very seriously so we must ensure we are in compliance with all applicable Federal laws.

2. Attached is an excerpt from the Code of Federal Regulations (CFR’s) § 91.205 that lists the instruments and equipment required to operate in the various types of flight conditions. All pilots need to become very familiar with these requirements and those in § 91.213(d). If the item specified in 91.205 is reported as inoperative, it automatically precludes that aircraft from operating in those flight conditions (VFR, Night, IFR) until the discrepancy is corrected by an authorized maintenance facility and signed off in the aircraft log books.

3. The FAA reminds pilots to review all aircraft discrepancy items and ensure the aircraft is in an airworthy condition prior to flight. Pilots need to be aware of the procedures contained in CFR § 91.213(d). (see Attachment 2) Any inoperative equipment must be addressed prior to flight. These may be addressed by CFR § 91.213(d)

4. CFR § 91.213 specifies that anytime there is inoperative equipment, a certificated pilot or mechanic must make a determination that the inoperative item does not constitute a hazard to safety of the flight or the airworthiness of the aircraft. If it does, then it must be corrected prior to flight.

If it is not a grounding item, the item must be either removed from the aircraft or deactivated and placarded ‘inoperative’. If the aircraft is grounded, the pilot must place the red “Aircraft Grounded Placard” from the Aircraft Information File on the pilot’s seat.

4. To ensure that CAP is complying with all applicable CFRs, all discrepancy logs will be removed from the aircraft. These logs will now be maintained by the aircraft maintenance officer. The aircraft maintenance officer should be better prepared to ensure CAP is in compliance with the CFRs. At the completion of every flight for which there is a new discrepancy noted, the pilot in command (PIC) must contact the aircraft maintenance officer and the aircraft maintenance officer will enter the discrepancy and a subsequent corrective action for every discrepancy as outlined in paragraphs 2 and 3 above. PICs must contact the aircraft maintenance officer before a scheduled flight to determine what discrepancies exist.

5. To make the entire maintenance discrepancy reporting process easier and more transparent, we have begun a test of an online system to monitor the status of our aircraft. It is working well in PA and FL wings so we are expanding it to several more wings. All CAP wings will eventually transition to this system. The online system allows maintenance officers and pilots to be able to more easily track individual discrepancies and determine whether or not they constitute a hazard to flight. Wings that are involved in the test of the online system automatically meet the tracking and reporting requirements stated in the paragraphs above.

6. This interim change letter will remain in effect until CAP regulations are modified to incorporate this change.

7. In closing, please tell your members that if they notice items are not getting repaired on our aircraft in a timely manner, they should report that to their unit commander, group commander (if applicable) or yourself. The safety of operating all of our equipment, including our airplanes, should be our primary concern.

Thank you for your selfless commitment to serve your communities, your individual states, and our nation. Our organization has provided outstanding service for over 67 years and we want to continue doing that by making sure all our resources are properly maintained.

Major General, CAP
National Commander

3 Attachments
1. Excerpt from FAR Sec 91.205
2. Excerpt from AOPA Article
on Operations Under FAR 91.213
3. Discrepancy Log (to be completed/maintained by the aircraft maintenance officer)

CAP-USAF Region Commanders
CAP-USAF State Directors
CAP Wing Administrators
CAP Maintenance Officers
CAP Directors of Operations
Col Skiba
Col Guimond

1 Comment on "FAA on CAP Aircraft Discrepancies"

  1. Avatar FAA Evasion | July 20, 2018 at 13:18 | Reply

    “To ensure that CAP is complying with all applicable CFRs, all discrepancy logs will be removed from the aircraft.”

    Oh yeah? That seems like an excellent way to evade FAA ramp inspectors who might find a paper discrepancy log in the aircraft and see how long it is taking for the clock to get fixed. A few years back, multiple wings of Civil Air Patrol were caught flying with perpetual deferments of discrepancies and so they set up an online system. Clever.

    This was announced in a letter on 14 May 2010 and you can find it here [redacted] and your editors/authors should create a story for that date.

    4. Pilots can take a copy of all open write-ups to the aircraft with them. To do this they can use the “Printable Log” button at the bottom of the discrepancy sheet in WMIRS. The printed copy will have formatted areas that pilots can use to add new write-ups they find before or during their flights.

    These write-ups should be entered into the eAircraft Discrepancy System as soon as possible after their flight. The “Printable Log” sheets should not be left in the aircraft.

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