Rear Seat Removal

[mit]

I called and talked to FSDO again today, I will just stick with Minor. I thought they had more common sense down in Texas than that. Sounds like this all started with a pissing contest about a paint Job?????? sigh........... George George George sigh.... Did you notice how it says Max on the 185 TC for seats? Sounds like the ANC FSDO is using some sense too. Merry Christmas! I gotta go fly more and stay away form this web sight.

[n2582d]

he turned the state into the FSDO for operating without interiors documented as removed.

George,
I'm surprised that you were required to follow the FARs on a state owned aircraft. When I flew a (O-540 powered ) L-19 for the Riverside County Sheriff's Dept. we were not required to do so as it was a government owned aircraft.

[GAHorn]

The rules for a "public" aircraft are different. (Nothing applies....you can drive a "public" aircraft with a drivers license!) The state of Texas operates Part 91, however. Perhaps as the result of their policy of allowing the state universities to use the aircraft for athletic teams.

[170C]

I just spent 3 days with an IA getting some avionics work done. This gentleman is an IA, DER, and has all the other designations a non FAA employee can obtain. He does fire burn tests as well as other required testing to meet vrs FAR regs plus teaches numerous courses so I have to have quite a bit of confidence in his opinions whether I might like or not like what he tells me. With the opportunity to ask a lot of questions while we were together I had to ask the question about removing my back seat or passenger seat or both. His reply was that I, as a private pilot/aircraft owner, could remove any or all of the above and fly the aircraft with one or both of these seats removed. The only requirement is that I must have in my aircraft a weight & balance data sheet for each configeration including one with all seats in the plane. I asked if a form 337 would be required and his reply was a 337 is only needed when there is a MAJOR modification to the aircraft. I'm sure he verbalized a good deal more detail on the subject, but this was the crux of his answer. Sooo, now to doing some W&B calculations.

Hope everyone had a nice Christmas and that 2009 will be a super one!

[voorheesh]

Some contributors to this long thread have indicated they appreciate some education on some of the rules, so for those who might want to know about public aircraft, here are a few things to add to George's comments "rules are diferent" comments. Public aircraft are those owned or leased by US, state govt, and official agencies used for governmental purposes. The definition is in FAR part 1. All other aircraft are either Civil (thats us) or military. The rules for public aircraft are not diferent there are just a few that don't apply. For example 61.3 requires us to have a pilot certificate to act as pilot of a "civil aircraft". There is no rule requiring a pilot certificate for the pilot of a public or a military aircraft. 91.119 specifies minimum altitudes for "aircraft". So this rule applies to civil, military, and public aircraft (waivers can be issued for this rule). In general, public aircraft have to follow the operating rules of part 91 but do not have to follow pilot and aircraft certification rules. You can pull seats out of a public aircraft for example and replace them without having to consult the FAA. Public operators are supposed to follow an "equivalent level of safety" and they may not carry passengers or cargo for compensation even if they are on public business. A sheriff dept OH58 helicopter can fly around all day on law enforcement missions, but it can't fly the mayor up to the state capital and have his office pay for the fuel. The pilot of a public aircraft does not need a pilot license or medical but does need to have an equivalent level of expertise to operate safely. The governmental agencies are left to determine what this definition is and some have struggled. Ask pilots who fly for the US Forest Service and you will likely hear some very interesting stories concerning how to fly safe.
Happy New Year

[GAHorn]

I just spent 3 days with an IA getting some avionics work done. This gentleman is an IA, DER, and has all the other designations a non FAA employee can obtain. He does fire burn tests as well as other required testing to meet vrs FAR regs plus teaches numerous courses so I have to have quite a bit of confidence in his opinions whether I might like or not like what he tells me. With the opportunity to ask a lot of questions while we were together I had to ask the question about removing my back seat or passenger seat or both. His reply was that I, as a private pilot/aircraft owner, could remove any or all of the above and fly the aircraft with one or both of these seats removed. The only requirement is that I must have in my aircraft a weight & balance data sheet for each configeration including one with all seats in the plane. I asked if a form 337 would be required and his reply was a 337 is only needed when there is a MAJOR modification to the aircraft. I'm sure he verbalized a good deal more detail on the subject, but this was the crux of his answer. Sooo, now to doing some W&B calculations.

Hope everyone had a nice Christmas and that 2009 will be a super one!

The crux of this discussion has always agreed with those opinions expressed by your AP/IA, Frank. The problem is: SAT-FSDO (and some others) will violate you if you follow his opinion. What he has actually said regarding wt/bal is correct. No one disagrees with that part of his statement. A Form 337 is required of any major alteration. No one disagrees with that portion of his opinion.
The difference of opinions surround the judgement of whether or not the removal of that seat is a major alteration or not. No one disagrees that a pilot is authorized to "replace" a seat. That means he can "remove and reinstall" the same or identical seat type. The removal for purposes of flight is held to be an alteration, and SAT-FSDO (and others) consider that a major alteration. Unless you have a Form 337 providing for and describing that alteration, those FSDO's will consider you to be in violation of the FAR's. I will bet your mechanic will not be in SAT or LIT or ??? when you land there, and he will not spend his time in court futilely arguing with an FAA inspector who holds the trump cards.

[hilltop170]

Sounds like it might be time to ask the FAA for a legal opinion on the matter since the rules are being interpreted differently by different FSDOs

[HA]

Oh no, you don't want that Richard. If forced to standardize they will default to the method most likely to cover their butts and we will all be living under the interpretations that George and his fellow Texicans are saddled with.

Our local FSDO has obviously been forced to think on this subject some, as we have procedures in our 135 ops specs to convert the King Airs between passenger and airmed configs - used to do the same thing with Barons years ago too. We have a sheet with the aircraft that logs the config changes and the pilot doing it must sign that. Realistically, it's a big enough job that we just do it in the shop and let the pilots off the hook, but the option is there.

we don't have to do 337's here, unless you had to drill rivets or fabricate special fittings to make the seats go in and out they consider it minor. As an IA that likes things simple, I'm more than happy with that interpretation.

[hilltop170]

George-
I have a STC, wt&bal sheets for different configurations, AND a 337 describing the major alteration of installation of REMOVABLE 206 middle seats. What you have said is according to the SAT FSDO, they contend I can remove and install the seats but I can't fly with them removed. Just what in the H**L else do those guys think they want to see in order for them to be satisfied it is legal for me to fly with one or more of the seats removed? What exact verbage would make them happy or is it even possible to make them happy?

[GAHorn]

If seats are removed, they want to see a 337 removing them, and documenting the new empty wt/bal, and providing for securing of any cargo. Once a 337 is submitted for that condition, the pilot may remove/replace/install approved seats at will, but must carry wt/bal and equip. list addressing the operational configuration.

[mit]

Like I have said before in this thread George, If they say it is a Major to remove it. Then why isn't it a Major to install it? You can't just say it is a major; "changes the TC",then it Does the same thing then going the other way!

[GAHorn]

I've already answered that question (from their point of view) several times in this thread.

[mit]

I've already answered that question (from their point of view) several times in this thread.

I must have missed it?

[GAHorn]

OK, well, this has been so cussed and discussed and I have been blamed (incorrectly) so many times supposedly for promoting and/or accused of defending their position that I am feeling like the best thing everyone can do is simply call them and get it straight from the horse's mouth.

Here's where you can find all the FSDO's phone numbers, including San Antonio.
http://www.airresearch.com/fsdodir.htm

[mit]

OK, well, this has been so cussed and discussed and I have been blamed (incorrectly) so many times supposedly for promoting and/or accused of defending their position that I am feeling like the best thing everyone can do is simply call them and get it straight from the horse's mouth.

Here's where you can find all the FSDO's phone numbers, including San Antonio.
http://www.airresearch.com/fsdodir.htm

Several folks already told you they did and SAT is wrong.