Rear Seat Removal

[T. C. Downey]

Bottom line n all this discussion is " If it is good with the IA signing off the annual "


But when the accident happens the insurance company will ask the FSDO accident inspector if the aircraft was airworthy when the accident occurred ?

What would you like the inspector to say.

[Bruce Fenstermacher]

Things that make you go "ha".

Pretty clear Cessna considered the seats a removable accessory isn't it.

[bagarre]

I'm still curious about those illegal ash trays.

[Bruce Fenstermacher]

So to review. I think we agree that the seats, passenger front and rear, came be removed and not effect the ability of the aircraft to safely fly. The bone of contention is the paperwork considered to be correct to satisfy the FAA.

We all know that any maintenance or work performed needs to be logged and this would include an entry by a qualified individual even in this case if Cessna had made it clear the seats were removable items. For example you can't add or remove wheel pants without a log entry.

We also have regulations that require a Form 337 to be filed for a change in W&B and this is the case no matter whether the change is a major or minor alteration. Comments?

The 337 of course is not for minor alterations except apparently for a change in weight and balance. Comments?

If I follow Tom, he says his FSDO will not be happy that a seat is removed unless a log entry is made, a for 337 is filed recording the change that needs to be made to the W&B in that configuration and then the W&B records recorded to reflect the W&B of the aircraft in that configuration. He says block 3 of the form has to be signed by the FAA.

So Tom, to get that signature in block 3 to remove a seat, what kind of documentation does your PMI want to see? Is this merely a formality in your case because the PMI believes it is a minor alteration that requires a 337 or do they consider it a major alteration.? If they consider it a major alteration what supporting documentation do they want to see to retain a signature?

George says his local FSDO will also not be happy that a seat is removed unless a log entry is made, a for 337 is filed recording the change that needs to be made to the W&B in that configuration and then the W&B records recorded to reflect the W&B of the aircraft in that configuration. But George's opinion is that block 3 does not have to be signed because the change is a minor alteration only requiring a Form 337 to be completed to document the change in W&B. I think, but not sure George has this opinion because that is what he was advised by his FSDO.

It has become clear that a Form 337 must be completed, What is not clear is what documentation is required to retain a signature in block 3 if indeed a signature is even required. Comments?

Sorry to keep this alive, I've sure both Tom and George feel they've communicated their information thoroughly.

Wouldn't it be great if the FAA Inspectors had a meet and greet say every quarter where a pilot could simply ask and discuss these things in person with their local authority.

[lowNslow]

We also have regulations that require a Form 337 to be filed for a change in W&B and this is the case no matter whether the change is a major or minor alteration. Comments?

The 337 of course is not for minor alterations except apparently for a change in weight and balance. Comments?

If I follow Tom, he says his FSDO will not be happy that a seat is removed unless a log entry is made, a for 337 is filed recording the change that needs to be made to the W&B in that configuration and then the W&B records recorded to reflect the W&B of the aircraft in that configuration. He says block 3 of the form has to be signed by the FAA.

I disagree with Tom's assessment of the 337 requirement. Part 43 appendex A states a 337 is required if:

"(xi) Changes to the empty weight or empty balance which result in an increase in the maximum certificated weight or center of gravity limits of the aircraft."

You are not changing the max certified weight or center of gravity limits by removing the rear seat. When the FAA went from CAR certification to TCDS in '58 the only seat listed as "required" was the pilot seat, all others including the co-pilot seat, were listed as "standard" equipment. I find it hard to believe the FAA could argue you made a major alteration removing the rear seat.

[T. C. Downey]

Filing a 337 simply for W&B change is contrary to the FAA's AC 43.9-1e. (yes I know the AC is not regulatory in nature)

Times and methods of using the 337 have changed since our aircraft were built and the Owners manuals were written.

AS pointed out, the 1956 owners manual is different than my 48, when your owners manual allows the removal of the seats, then in my humble opinion you have authority to operate the aircraft with them removed, because the owners manual is the W&B for determining if the aircraft is safe to fly, and a required placard IAW the type certificate.

each year the FAA gives guidance and re-currency training by each FSDO, you can attend and ask your FSDO any questions you wish. you can also call them any work day.

[T. C. Downey]

I'm still curious about those illegal ash trays.

Who says they are illegal?

Who makes the decision as to which is a major or minor alteration?

[T. C. Downey]

I disagree with Tom's assessment of the 337 requirement. Part 43 appendex A states a 337 is required if:

"(xi) Changes to the empty weight or empty balance which result in an increase in the maximum certificated weight or center of gravity limits of the aircraft."

You are not changing the max certified weight or center of gravity limits by removing the rear seat. When the FAA went from CAR certification to TCDS in '58 the only seat listed as "required" was the pilot seat, all others including the co-pilot seat, were listed as "standard" equipment. I find it hard to believe the FAA could argue you made a major alteration removing the rear seat.

I have never said we were changing the W&B beyond the limits given in the Owners manual, thus I advocate we do not submit a 337, we only need to record the change in the owners manual.

Were you to change the maximum empty weight beyond 2200# then you would need approval of the FAA in block 3 of the 337. We as Pilots and owners and A&Ps can re-weigh any aircraft find the new empty weight, and compute a new empty weight C/G, and enter it in the aircraft records. there would be no 337 required for this.

[T. C. Downey]

I disagree with George's assessment of the 337 requirement. Part 43 appendex A states a 337 is required if:

"(xi) Changes to the empty weight or empty balance which result in an increase in the maximum certificated weight or center of gravity limits of the aircraft."

You are not changing the max certified weight or center of gravity limits by removing the rear seat. When the FAA went from CAR certification to TCDS in '58 the only seat listed as "required" was the pilot seat, all others including the co-pilot seat, were listed as "standard" equipment. I find it hard to believe the FAA could argue you made a major alteration removing the rear seat.

Fixed that for ya,

[T. C. Downey]

"NOTE
Measurements are with co-pilot seat, rear seat, and baggage compartment shelf removed - giving maximum usable areas and saving 40 lbs on empty weight"

Loading your 170.jpg

Is there a page in the 56 manual giving the maximum weights for each cabin station for loading the aircraft, which could be use as loading data to calculate CG IAW the graphs in the W&B section ?

[bagarre]

It might be possible that removing the back seat could put the CG forward of it's allowed limit.
Full tanks, two big dudes in the front seat and 30 less pounds in the back might cause that condition.
If swapping a 10 pound starter for a 5 pound starter requires a new weight and balance, I can see the concern for pulling 30 pounds out of the airplane.

RE: Ashtrays. My thought process is this. (preface: I also have headphone jacks in the back seat ashtrays)
Ash trays are required to be in the aircraft OR if removed a "No Smoking" placard needs to be installed. That's pretty clear.

There is nothing to address leaving the ashtrays in the airplane but modifying them for another use. In this case, they are no longer ashtrays they are headphone jack holders. But we don't have any approval to modify the function of an existing piece of equipment. Certainly not one that requires a special placard if it's not present.

So, at a minimum it would seem that you also require the No Smoking placard because you no longer have functional ashtrays.
And since they are no longer functional as ashtrays but still LOOK like ashtrays, they might also need to be marked "INOPERATIVE" along with the No Smoking placard.

THAT actually shows that using ashtrays as headphone jacks requires approval more-so than removing the back seat.

Certainly "Any reasonable person would know..." is a valid response to that but the FAA is anything but reasonable.

[170C]

This discussion gets more interesting as time goes forward. Trying to separate the wheat from the chaff, it sort of seems to me that to comply with the FAA one would need to log each time a seat (rear or co-pilot) is removed for a flight and upon placing the seat back in the aircraft another logbook entry would be required Who is authorized to make these entries in the aircraft logbook---the aircraft owner? Does it require an A&P or IA to do so? In either case is a form 337 required? I don't know many A&P or IA's who would be happy to do a logbook entry for me everytime I elected to take out my backseat in order to either go camping or go on a trip where I needed the extra room for baggage, etc (not exceeding the W&B limits). Sure is confusing We mere mortals will be glad when a final analysis is reached

[cfzxo]

My Javelin tank has more input on the weight and balance than the removal or replacement of that none used rear seat that I have . You can see where I am going with this.Would I need a signature at every fillup? Keeping it in the envelope of W&B with whatever you may or may not have inside would be the safe and proper thing to do. The nice thing about this north country is that there isn't a lawyer hidding under every rock looking to feed himself
Bill CFZXO 55170B

[bagarre]

He mentioned an AC that outlines for aircraft less than 5000 lbs, any alteration that results in more than 1 lb change would be a major alteration.

I just died a little inside.

[GAHorn]

I disagree with George's assessment of the 337 requirement. Part 43 appendex A states a 337 is required if:....

Fixed that for ya,

I realize that was a joke...but it wasn't my assessment. It was SAT-FSDO stated policy.
Additionally, the Owners Manual has no bearing on this subject as it is un-approved. It is not the WT/Bal document for the airplane. Each airplane must have it's own equipment list and wt/bal document. The equipment list must be modified to accomodate any required/optional equipment, and must reflect the status of the airplane. (Large airplanes have CDL's---Conformity Deviation Lists....which similarly document equipment which may be missing/removed for flight. Light planes do not. They must have equipment lists, wt/bal documents, and form 337s for alterations which do not meet the TCDS and/or Production Certs. Tom's opinion regarding the need for tools to remove the rear seat is interesting and carries some weight, if you'll pardon the pun.)

As for the "No Smoking" placard: I don't believe ashtrays are required for smoking in an airplane. The requirements for "No Smoking" placards relate to interior-materials/cargo/etc. carried and/or aircraft-system restrictions (such as a fuel tank behind the firewall not vented to outside, or not plumbed with fire-sleeve, etc.)

Besides...back when I smoked...(before many of you were born)...I rolled the embers off and threw my cig-butts out the window.