Rear Seat Removal

How to keep the Cessna 170 flying and airworthy.

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lowNslow
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Re: Rear Seat Removal

Post by lowNslow »

voorheesh wrote:Hey low & slow, what is sad about this? He is telling you that if you have a W&B for both configurations and document it on a 337 and mail it in to the FAA, you are covered. Do you know what a 337 is? It is a two sided document that takes minimal time to fill out and most A&Ps will help you with it for minimal charge. I don't think "G" said it needed to be field approved by the FAA. In the very unlikely event you ever get ramp checked, tell the FAA you have a W&B for that configuration and go about your business. What kind of "trouble" do you think the FAA will give you for that? I do not understand what this argument is about.
Yes, I do know what a 337 is and as an A&P have filled out many. Any 337 needs to signed by AI who is not always as handy as your friendly neighborhood AP and many AIs are getting more picky what 337s the are willing to sign (maybe for good reason), but more to the point I have a pet peeve about many mechanics filling out unnessary 337 just to cover their a**. It just creates a lot of useless paperwork that is not required and creates a enviorment were SOME FSDO offices are expecting 337 when they are not needed.
Also, George's arguement is that you need a 337 because you are changing the aircraft from it's original TCDS. If this is so it WOULD require a field approval. This is why in the FAAs own "Weight and Balance Handbook" they specifically allow this to be treated as "minor alteration" with no 337.
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Re: Rear Seat Removal

Post by mod cessna »

"Dubya"..... several of the most prolific contributors of this message thread are not members and it would remove their ability to participate if I moved the thread. I posted my long-winded disclaimer earlier in an effort to de-fuse the volatility of this discussion and I certainly do hope that everyone is willing to allow strong feelings to be politely expressed without taking offense at individual viewpoints.
This is all hanger talk guys no offense ever taken. No I am not a member. I however do occasionally work on members aircraft. My name is Matthew Voit and i am a full time IA/A&P in Anchorage Alaska.

As for the Owners Manual (once again, there is no POH for a 170).... it was not approved by anyone other than the Cessna marketing department. But it might be of interest to notice that on page 9 of the 170-A manual (and on page 37 of the 170-B owners manual) in the Weight and Balance section the following statement: "Changes in the original equipment affecting weight empty c.g. are required by the CAA to be recorded in the repair and alteration Form 337."
Ok let me try once more with this one. FAA form 337's use to be required for W&B changes. Most of your aircraft will have a few 337's from early on in life that are simple equipment removals and a W&B changes documented on a 337. When the Owners Manual(did i get it right this time?) for the 170 was written this was a true fact. It no longer is, and has not been for a long time. Please review FAA-G-8082-11A "Weight and balance checks are no longer required to be entered on a FAA form 337."

Removing your rear seat or Co-pilot seat is a minor alteration log book entry. Have a great day. :)
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mit
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Re: Rear Seat Removal

Post by mit »

The FSDO told IA's to stop doing CYA 337's years ago...... If it is a major coming out, then it is a major going in why wouldn't you have to do one every time that you changed the configuration? Is it a major to install EDO 2000 Floats? Is it a major to install an O-300A? I want to figure out where the Texas FSDO is coming from? :cry:
Tim
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Bruce Fenstermacher
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Re: Rear Seat Removal

Post by Bruce Fenstermacher »

Ok guys you've drug me in AGAIN. (This has got to be the third go around for this subject)

After thought I personally do not believe a 337 is required to cover the removal of the seat but having one will cover any bases and arguments.

We don't need one because:
  • A private pilot/owner can legally remove and reinstall the either front or rear seat.
    A private pilot/owner can legally adjust and record the W&B and equipment list for the change in configuration.
    A private pilot/owner can legally make the necessary log book entry for the work performed.
    The co-pilots seat or rear seat is not a required per the TCDS.
So assuming that you are the owner and at least a private rated pilot and you remove the co-pilot or rear seat then update the W&B and equipment list to be carried in the aircraft, record the maintenance performed in the aircraft logs, you are legal flying the aircraft as long as you are not flying under FAR Parts 121,129, and 135. In my opinion of course. :)
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mit
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Re: Rear Seat Removal

Post by mit »

I knew you couldn't stand it Bruce :lol: :lol: :lol:

The most correct answer is consult your IA and FSDO...... :?
Tim
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Re: Rear Seat Removal

Post by W.J.Langholz »

[quote="N9149A"]Now if your still reading this thread

Did you think you were going to chase me away that easily.......I was actually enjoying the little butt whoopin the Texas boy was gettin :wink: of course at times it was 3-4 to 1(just about even) but that's ok cause sometimes the world gets a little tilted towards Texas and needs to be straighten upright again :wink: I sure hope that Tim, Matt, and Karl stick around and help keep it on the up and up. BUT when the argument of "LESS FILLING.......TASTE GREAT" gets a little loud over in the corner..................

Have a Good Day :D
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Bruce Fenstermacher
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Re: Rear Seat Removal

Post by Bruce Fenstermacher »

mit wrote:I knew you couldn't stand it Bruce :lol: :lol: :lol:

The most correct answer is consult your IA and FSDO...... :?
Tim I've been a little under the weather lately with a stomach virus and now that I'm feeling better it's easier to dedicate time to think of these things and put the effort into typing the right (and wrong) keys. 8)

I think the most correct answer is to do some investigation and study for oneself. Decide what you think the regulations allow. Then with a more educated view consult with your local IA and FSDO guys for the local flavor of thought. Of course remembering the IA and or FSDO guy isn't always right but they are the people you have to deal with.

Hopefully that was the intent of the original poster and I do believe they got their moneys worth for it and it was all good. Even the stuff that I don't agree with.
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lowNslow
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Re: Rear Seat Removal

Post by lowNslow »

N9149A wrote:Ok guys you've drug me in AGAIN. (This has got to be the third go around for this subject)

After thought I personally do not believe a 337 is required to cover the removal of the seat but having one will cover any bases and arguments.

We don't need one because:
  • A private pilot/owner can legally remove and reinstall the either front or rear seat.
    A private pilot/owner can legally adjust and record the W&B and equipment list for the change in configuration.
    A private pilot/owner can legally make the necessary log book entry for the work performed.
    The co-pilots seat or rear seat is not a required per the TCDS.
So assuming that you are the owner and at least a private rated pilot and you remove the co-pilot or rear seat then update the W&B and equipment list to be carried in the aircraft, record the maintenance performed in the aircraft logs, you are legal flying the aircraft as long as you are not flying under FAR Parts 121,129, and 135. In my opinion of course. :)
OK Bruce, I'm leaving now. I'll come relieve you in a couple more pages. :wink:
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Re: Rear Seat Removal

Post by GAHorn »

mod cessna wrote:... Please review FAA-G-8082-11A "Weight and balance checks are no longer required to be entered on a FAA form 337." ..
That document has been superceded by FAA-G-8082-11B. It was/is an Authorization Test Guide and the question quoted was only a sample question and applies only to "weight and balance checks" which were an item once required to be completed and entered on the form 337. This is not the same as an aircraft alteration or change of basic equipment or other equipment list additions/deletions.

The section of the new document which may apply under this discussion is in reference to alterations which affect weight and balance. The following is a quote from FAA-G-8082-11B:

"Determine that aircraft record entries have been made and the weight and balance data and equipment list have been revised, when appropriate. There should be a statement on the FAA Form 337 to the effect that the weight and balance data and equipment list have been revised. When an alteration results in a change in the center-of-gravity (CG) position, the affected CG limit should be investigated under adverse loading conditions unless the new CG falls within an approved empty CG range. For instance, if the CG has shifted aft, the loading conditions should be computed to see that the aircraft does not exceed the aft CG limit. It is the pilot’s responsibility to have the aircraft correctly loaded. However, when approving an alteration, it is the IA’s responsibility to see that weight and balance data have been revised."

The TCDS lists the rear seat as basic equipment and provides the weight and arm for the purpose of re-calculating empty weight.

Since it has been more than two years since I last confirmed their position, I will re-contact both SAT FSDO and FTW FSDO to see if any change in their positions on this subject have been made and will post the results here.

Bruce, it is true that a pilot may remove/install a front seat under the provisions of FAR 43, Appdx A, but that item specifically states "Replacing" seats...not removing them. That would not involve any complex assembly-operations and, since the removed seat was re-installed, would not include any change in empty weight or CG.
It is also true a pilot (owner) may make a change to the equipment list. And of course any weight and balance changes is also allowed to be recorded by the pilot. This is an entirely different matter than the preventive maintenance issue, however. This discussion involves a change of basic equipment specified in the TCDS or original equipment of the aircraft which affects empty weight and CG. That fine point is the one that's been so "sticky" with ASI's at the FSDO.
lowNslow wrote:...The sad part is that a pilot can do a whole host of "preventive maintenace" items (including removing and replacing the seats) but is not allowed to fly his aircraft without the seat and without documention for that occasional camping trip. ...
Yes, there are many areas of "grey" as already noted in this discussion. Another example which I find particularly distasteful is that FAR 43 Appdx A "Preventive Maintenance" allows several operations to be performed by the owner/pilot but does not provide guidance or procedure for accomplishing the operation. Example: A pilot may re-pack wheel bearings and change a tire. In order to accomplish that task he must remove the brakes from the aircraft, however installing brakes are not allowed, as they are not considered "preventive maintenance". I personally disregard that inconsistency,... pilots must reinstall/replace as necessary the brakes whenever they repack wheel bearings/replace tires, and enter the entire excersize in the records. I'm fairly certain that would cause all sorts of heartburn at SAT FSDO but it's illogical to do otherwise and that is my opinion. Yours may vary.
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Re: Rear Seat Removal

Post by Bruce Fenstermacher »

George one sticking point seems to be you feel that some how the seat rear or front is required equipment.** Not according to the TCDS or any other regulation I know of. I don't even see them listed as basic equipment but that would matter because they are not REQUIRED equipment or basic equipment of CAR 3. Here is that part of the TCDS for the '48 170:

[quote=A-799 TCDS]Required Equipment In addition to the pertinent required basic equipment specified in CAR 3, the following
items of equipment must be installed:
Landplane: Items 1(a), 103, 104, 201(a), 202(a), 204(a), 402(a).
Skiplane: Items 1(a), 103, 104, 204(a), 208(a), 402(a), and (e) or (d).
Note: For night flying, cabin dome light and instrument lights or equivalent, to
provide illumination of all placards and instruments are required in addition to
equipment required by CAR 43.[/quote]

I think you have said that with out the rear seat you are changing the aircraft from a 4 place to a 2 place aircraft and therefor it is a major alteration. You are not changing the airplane from a 4 place to 2 place by removing the rear seat, there is just no comfortable place for 2 of the 4 passengers to sit and in the 170's case no seat belts in those positions. BTW the TCDS approves all models of 170 as both a 4 PCLM (Normal Category) and 2 PCLM (Utility Category) so you are covered that way as well.

In order to replace the seat a pilot/owner would have to remove it so the act of removing the seat is not illegal nor is completing the paperwork for that work performed. The rear seat and at least one of the front seats are no different than the headliner or carpet. Or do you think George that removing the headliner and carpet is a major alteration as well.



** You do need at least one front seat but not because the TCDS says so.
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Re: Rear Seat Removal

Post by GAHorn »

N9149A wrote:George one sticking point seems to be you feel that some how the seat rear or front is required equipment.** Not according to the TCDS or any other regulation I know of. I don't even see them listed as basic equipment ....
That is patently incorrect. The basic design is the basis of the TCDS. I suggest re-reading the TCDS. The TCDS describes what consists of a basic airplane at the beginning of each model description where it specifies "4 seats" and lists the wt and arm of those seat locations.... and THAT is what defines the airplane. A 4PCLM or a 2PCLM (utility)... does not specify the rear seat being removed...but is a restriction on the number of persons carried in that category. The TCDS goes on to describe variations of the basic airplane that may exist depending upon which "required equipment" is installed, and it lays out that required equipment depending upon the basic configuration. In all cases, four seats are listed as "basic equipment" just as it lists flaps, etc. (In an extreme example, just to prove the error of your argument, ... your example would mean that as long as a collection of all the required equipment items were collected together,... without ANY of the prior-mentioned items in the TCDS... then that would define and describe a Cessna 170 and therefore be airworthy.)

(In a related discussion: Required equipment isn't just a listing of equipment that must be installed... it is a specification of that equipment. In other words, the airplane must have a propeller... and the propeller MUST specifically be one of those listed. Any other requires a further basis of approval. Notice for example that not just any 35 amp generator may be used, but only specific models, such as the Delco-Remy 1101898 are approved. But clearly, different equipment may also suffice. In other words, the required equipment section of the TCDS can be thought of as a listing of various equipment that create various configurations of the basic airplane... for example skis, or floats, or specific wheels. Seats are not listed there because no other seat or variations of seats are allowed. (Certain other equipment may be substituted for Cessna original equipment per the required equipment list, but not seats. Atlee-Dodge seats can only be installed by STC. A pilot may not remove a Cessna rear seat and replace it with an Atlee-Dodge. That must be performed per STC.) But because Cessna's seats are not listed in the "required equipment" section does not mean they may be dispensed with so easily, any more than the flaps may be.
N9149A wrote:...In order to replace the seat a pilot/owner would have to remove it so the act of removing the seat is not illegal nor is completing the paperwork for that work performed. The rear seat and at least one of the front seats are no different than the headliner or carpet. Or do you think George that removing the headliner and carpet is a major alteration as well.....
The regulation (FAR 43, Appdx A) is pretty clear. It does not state "remove". It specifically states "Replacing a seat"(is allowed as a pilot action.) Any attempt to use that as an excuse to permanently remove a seat for purposes of flight is wrong on the face of it. And it would change the empty weight and CG of the airplane so it would be an alteration, not preventive maintenance.

Show me where the carpet and headliner are listed anywhere in the TCDS. (But the seats certainly are.) When upholstery shops replace an interior (or carpet or headliner) they do so under the "preventive maintenance" provision. But if they installed an interior into an airframe that had never had such installation, (such as convert a cargo interior to a passenger interior including the addition of previously non-existent seats) a Form 337 would be required.
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Re: Rear Seat Removal

Post by Bruce Fenstermacher »

So George using your example of 4 seats being required because 4 are listed in what you are calling a basic equipment list in the TCDS, we would also be required to have maximum baggage of 120 lbs, full tanks of fuel and 2 gallons of oil in the engine and nothing less. These are also listed right there below the 4 seats.
No. of Seats 4 (2 at +36), (2 at +70)
Maximum Baggage 120 lb. (+95)
Fuel Capacity 37.5 gal. total, 33.5 gal. usable (three 12.5 gal. tanks in wings at +45). See NOTE 1 for
weight of unusable fuel
Oil Capacity 2 gal. (-20)
I think not. This is a listing of possible equipment or weights and it's location. Nothing more.

Where does the TCDS say you are restricted to 2 persons while operating with the W&B in the utility area of the CG. It doesn't. It does restrict maneuvers through the placards that must be in place,
"This airplane must be operated as a normal or utility category airplane in compliance with the Airplane Flight
Manual."
NORMAL
"No acrobatic maneuvers including spins approved.
With two people in the rear seat both front seats
must be occupied."

UTILITY
"No acrobatic maneuvers approved except those listed in the Airplane Flight Manual. Baggage compartment and rear
seat must not be occupied.""
Notice the placard doesn't say the rear seat must be installed just not occupied and the fact you can't have any baggage according to the placard contradicts the basic equipment list where 120 lbs is specified according to your thinking George.

Are we all really looking at the same TCDS? I'll bet that's exactly what your thinking as you read this George. And I can hear Ol Gar rolling on the ground laughing as we all hash this out. I can't even imagine what ol Blue Leader is thinking of this.
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Re: Rear Seat Removal

Post by GAHorn »

N9149A wrote:So George using your example of 4 seats being required because 4 are listed in what you are calling a basic equipment list in the TCDS, we would also be required to have maximum baggage of 120 lbs, full tanks of fuel and 2 gallons of oil in the engine and nothing less. These are also listed right there below the 4 seats.
No. of Seats 4 (2 at +36), (2 at +70)
Maximum Baggage 120 lb. (+95)
Fuel Capacity 37.5 gal. total, 33.5 gal. usable (three 12.5 gal. tanks in wings at +45). See NOTE 1 for
weight of unusable fuel
Oil Capacity 2 gal. (-20)
I think not. This is a listing of possible equipment or weights and it's location. Nothing more.

Where does the TCDS say you are restricted to 2 persons while operating with the W&B in the utility area of the CG. It doesn't. It does restrict maneuvers through the placards that must be in place,
"This airplane must be operated as a normal or utility category airplane in compliance with the Airplane Flight
Manual."
NORMAL
"No acrobatic maneuvers including spins approved.
With two people in the rear seat both front seats
must be occupied."

UTILITY
"No acrobatic maneuvers approved except those listed in the Airplane Flight Manual. Baggage compartment and rear
seat must not be occupied.""
Notice the placard doesn't say the rear seat must be installed just not occupied and the fact you can have any baggage contridicts the basic equipment list where 120 lbs is specified according to your thinking George.

Are we all really looking at the same TCDS? I'll bet that's exactly what your thinking as you read this George. And I can hear Ol Gar rolling on the ground laughing as we all hash this out. I can't even imagine what ol Blue Leader is thinking of this.
Bruce, I think this response is easily seen to be illogical. Where is it required that the seat be occupied? And where is it specified that each time it's occupied that it be with an FAA 165 lb occupant?
It isn't, of course, any more than it would be required to carry full fuel or 120 lbs baggage on every flight. Those are not required quantities....those are capacities. (But notice that the pilot is not allowed to remove the tanks, just because he doesn't want to fill one of them.) :wink:

As for the placard which states: "UTILITY-"No acrobatic maneuvers approved except those listed in the Airplane Flight Manual. Baggage compartment and rear seat must not be occupied."" ...I would respond that clearly the placard expects a rear seat to be present. Otherwise it could not be unoccupied, and would not be mentioned.

As for the suggestion that 120 lbs would be required on all flights.... That would clearly not be the case or the wt/bal graphs would not provide for lesser amounts. Same thing for fuel, oil, persons., etc etc ad nauseum. They are not requirements. They are capacities. And the wts given for the seats are for the seat, not the occupant, of course.

On a brighter note: I have heard in a preliminary response from one FAA-type that his FSDO does not consider the removal to be a big deal. It was stated that it was felt to be a preventive mx action. I have asked him to clarify why the rule does not use the word "remove", and instead uses the word "replace", and will report back when I get further word.
SAT FSDO has not yet responded.

Ol' Gar cannot find his rearseat with both hands :lol:
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Re: Rear Seat Removal

Post by Brad Brady »

Bruce,
I think I have to agree with George in this....The normal and utility categories are a flight issue...not maintenance.....Where they are both covered by the TC's the intent is different....so is the maximum baggage. No mater what, as I have heard here before....start at the trial and work backwards to see what you need to do... :lol:
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Re: Rear Seat Removal

Post by Bruce Fenstermacher »

GAHORN wrote:Bruce, I think this response is easily seen to be illogical. Where is it required that the seat be occupied? And where is it specified that each time it's occupied that it be with an FAA 165 lb occupant?
It isn't, of course, any more than it would be required to carry full fuel or 120 lbs baggage on every flight. Those are not required quantities....those are capacities. (But notice that the pilot is not allowed to remove the tanks, just because he doesn't want to fill one of them.) :wink:
George, I'm trying to show how illogical your reasoning is. 4 seats is a total capacity. There will never be 5 seats. Doesn't mean there has to be 4 seats just like there doesn't have to be full tanks and 2 gallons of oil.

I know the Normal/Utility category has to do with flight but it seemed to me George tried to tie it to how many people were on board and so if that was the case how that didn't follow the rest of his logic.

Bottom line. Some of us see this one way, some see it another and neither are going to be convinced. (Though by the sounds of Georges last post the area of Texas a 337 might be required is getting smaller. :) )

I personally think this is another case of an era gone by when people used more common sense and took responsibility. People didn't have to be shown everything with a 10 page manual. At that time the FAA didn't think it necessary to spell out every different configuration possible and so Cessna didn't have it spelled out.

Today of course it is different. We have ten lawyers for every pilot and FAA examiner. My helicopter has about 6 different seating positions and capacities spelled out from the factory and we switch between many of them on the fly with no paperwork other than adjusting the W&B and equipment list.

We are trying to apply what we see today and today's mind set to what we have from the past and it is just not working well in some cases. We have to keep in mind how things were done in the past and interpolate. As time passes and the old timers go it's harder to remember the past and past practices. This is the case both in the pilot/owner pool as well as the FAA.
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