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That document has been superceded by FAA-G-8082-11B.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.