FAA INSPECTOR FOUND THAT A C152 FAILED TO HAVE ACFT EQUIP PROB SQUAWKS COMPLIED WITH BY AN A&P MECH BY RECORDING AND PLACARDING ON INOP EQUIP PER FAR SECTION 91 PT 213 (D)(3)(II).

Narrative

FAA AIRWORTHINESS INSPECTOR WAS AT TRAINING FACILITY FOR INSPECTION AND FOUND THAT SQUAWK SHEETS FOR THE CESSNA C152 WERE NOT COMPLIED WITH BY AN APPROPRIATE A&P SIGNATURE. 3 ITEMS IN PARTICULAR THAT THE INSPECTOR DIDN'T APPROVE OF WERE THE FOLLOWING: THE R NAV LIGHT WAS SQUAWKED INOP; RADIOS WERE SQUAWKED WEAK BUT READABLE AND THE PUSH-TO-TALK WAS SQUAWKED 'STICKS.' THE ACFT WAS STILL FLOWN EVEN THOUGH THESE SQUAWKS WERE NOT COMPLIED WITH AND FIXED BY AN A&P. IT WAS TO MY KNOWLEDGE THAT IF AN ITEM WAS INOP AND NOT REQUIRED FOR DAY VFR THE ACFT WAS LEGAL TO FLY. EXAMPLE WOULD BE THE NAV LIGHT BEING INOP. AS FOR THE RADIO PROBS; THE FARS DO NOT DESCRIBE A SIT THAT PERTAINS TO THIS. IT WAS TO MY KNOWLEDGE THAT AS LONG AS AN INOP INST WAS NOT REQUIRED FOR THE TYPE OF ACFT OP IT WAS LEGAL TO FLY. I DID NOT; HOWEVER; KNOW THAT THE INOP INST HAD TO BE PLACARDED INOP WHEN IT WAS SQUAWKED ON THE SQUAWK SHEET. THE FAA INSPECTOR DID NOT STATE WHETHER A LETTER OF INTENT WAS GOING TO BE SENT; BUT I FEEL THAT THIS MATTER CAME OUT OF NOT UNDERSTANDING FAR 91.213. I AM FAMILIAR WITH THIS REG BUT HAVE SOME DIFFICULTY INTERPRETING EXACTLY WHAT IT STATES. I FEEL THAT THIS REG MAY NEED TO BE REWRITTEN TO BETTER EXPLAIN ITSELF. I ALSO FEEL THAT THIS INCIDENT IS NOT SOMETHING THAT WOULD NOT REQUIRE A LEGAL ACTION FROM THE FAA. I BELIEVE IT IS A LACK OF UNDERSTANDING OF AN FAR AND I WOULD APPRECIATE AN EXACT EXPLANATION FROM THE FAA SO THIS TYPE OF INCIDENT CAN BE AVOIDED IN THE FUTURE. ALSO NOTE THAT OTHER INSTRUCTORS AT OUR FACILITY HAVE DIFFICULTY INTERPRETING FAR 91.213 AND HAVE SOME CONFUSION ON EXACTLY WHAT IT STATES.