Rear Seat Removal

[voorheesh]

http://www.faa.gov/about/office_org/hea ... ob-Aid.pdf

Check this out. BTW, it is not fun

[DaveF]

It really takes the fun out of airplanes.

Not for some people ...

[bagarre]

It really takes the fun out of airplanes.

Not for some people ...

The same people that enjoy reading Home Owner Association By-Laws and then measure the height of their neighbor's grass

[cfzxo]

I can see a job for F Lee Baily or is it Lee F Baily? anyway the Lawyer guy.

[Joe Moilanen]

As far as I'm concerned the appropriate procedure for removing the back seat starts and ends with a 1/4" drive ratchet and and a 3/8 and 7/16 socket....

Joe

[T. C. Downey]

As far as I'm concerned the appropriate procedure for removing the back seat starts and ends with a 1/4" drive ratchet and and a 3/8 and 7/16 socket....

Joe

Getting in and out is easy and can be done under FAR 43-A, (by the owner operator) but is it legal to fly with it removed. Is it a portion of the type design for the 170?

[Joe Moilanen]

As far as I'm concerned the appropriate procedure for removing the back seat starts and ends with a 1/4" drive ratchet and and a 3/8 and 7/16 socket....

Joe

Getting in and out is easy and can be done under FAR 43-A, (by the owner operator) but is it legal to fly with it removed. Is it a portion of the type design for the 170?

Actually in my case I have a legal (Cessna camera port option) camera port installed and carry two weight and balance scenario documents with me, one without the seat and one with the seat, since while using the port the back seat must be removed. Even if I didn't have the port, I don't think I would lose much sleep over removing it though, other peoples mileage may vary however.

[Bruce Fenstermacher]

Joe, do you have documentation such as Cessna dwgs for that port? Any and all evidence Cessna thought nothing of removing the seat may come in handy should an approval (FAA wide ) become necessary.The other option of course is the stretcher option that has been mentioned. But I don't know any aircraft that might have the stretcher documentation.

[T. C. Downey]

Joe, do you have documentation such as Cessna dwgs for that port? Any and all evidence Cessna thought nothing of removing the seat may come in handy should an approval (FAA wide ) become necessary.The other option of course is the stretcher option that has been mentioned. But I don't know any aircraft that might have the stretcher documentation.

His camera port requires the seat be removed, that in its self is approval on the 337 that approved the modification.

the stretcher is optional equipment authorized by the type design, that requires nothing but the installation instructions.

[Bruce Fenstermacher]

The point I was making Tom is that Cessna must have had adequate data or simply did not consider the rear seat essential as it was removed for at least two options. This information might be helpful as part of a package to attain approval to remove the seat now.

[c170b53]

I've taken the rear seat out and have a W&B for it when removed. The only issue I see is to have the cargo properly tied down under a net. The seat is not a structural member that reinforces the fuselage, hence I can't see why you couldn't remove it, just as you could strip out the interior and fly bare bones. Tom mentions the 4 seats as being in the TC doc. and thus it must have 4 seats. I'm not sure, that the intent of that statement means you couldn't remove the back seat but rather it is stating the max seating capacity of the interior configuration.
I also understand most regulations coming from the authorities have plenty of wiggle words embedded into them to allow lots of wasted time. I just wish I had a buck for each "may" in the regulations.

[voorheesh]

I caught up with inspector Jensen today and he stands by his statement that return to service of a Cessna 170 without the rear seat is a major alteration. When I asked him what his reference was he stated that it is the "policy" of his FSDO. He did not intend to suggest that such a configuration would result in a violation. He may have said that but he was referring to it as a "possibility". We also discussed the safety ramifications of seat removal and we agree that the most important issue is for the airplane to be properly loaded and cargo secure. David Jensen did not come up with this on his own. He asked others in his office for their opinion and was trying to be helpful in providing an answer to an inquiry.

I spoke with a colleague at Sacramento FSDO who is a 15 year maintenance inspector and he respectfully disagrees with all the "opinions" we have heard on this subject. He informed me that removal of the rear seat from a Cessna 170 is preventive maintenance. It is not a minor alteration. There is no need for a certificated mechanic to be involved in the actual removal or return to service. He recommends that any owner who wants to remove his/her seat do so and keep a log of removal/installation. A pilot should be capable of making a simple change to the empty weight/CG. I asked him to comment on the argument over the word "replacement" in the preventive maintenance list in 43. He replied that the word replacement is sufficient to allow pilots to remove and install seats for private operations. There is no language in either the TCDS or AFM indicating the rear seat is required equipment. We discussed potential ramifications from inspectors based in Oakland, San Antonio, and Little Rock and this Sacramento Inspector stated that those offices would not have a leg to stand on if they challenged an operator on this issue. 43 allows it and there is no written rule that supports any other opinion. I stand corrected.

Obviously, we have some significant differences of opinion here which is no help to operators who just want to do the right thing. So, I sent this issue to the Technical Standards Branch of Western Pacific Region in LA and spoke with an inspector there who is responsible for finding answers to these questions. He immediately assured me that whatever is involved with removing the rear seat from a Cessna 170, IT IS NOT A MAJOR ALTERATION. He was that emphatic. He is as frustrated as I that an FAA Inspector or an office would take it upon themselves to "interpret" a rule with no documentation or reference. He has sent this question to the Aircraft Evaluation Group (AEG) in ICT and is asking an engineer there to give him an opinion on the simple question of whether or not operation without the seat has any implications regarding the type design of this airplane. Once that is determined, our region inspector will seek a determination in writing concerning this issue and try and get it disseminated to FSDOs across the country. For what it is worth, he is highly confident that it is not a major alteration and somewhat confident he can get it reduced to writing.

Most of you probably don't care about this and many of you are laughing at me. I just want to tell you that this exact situation involving the absence of a standard is very frustrating to the FAA and is a priority to fix. You probably know that most FAA employees come from the aviation industry and come in with the same strong opinions and backgrounds that you have. Discussions in FAA FSDOs have a strong resemblance to those on this forum. Again, I want to assure everyone that I am no expert and I am simply trying to get a reliable answer to this otherwise simple question.

[n2582d]

Harlow,
I believe all this nonsense about seat removal being a major alteration started with the late Bill O'Brien. I recall him making this point at IA renewal seminars in the late '80's.

[Bruce Fenstermacher]

Harlow, I assure you no one is laughing at your effort. Yes many think this seat removal thing nonsense and seem to be laughing but in reality they are crying at the state of affairs that exist with lack of standardization.

Believe me if I had the opportunity within the system as you might have, I'd be doing exactly what you are doing. The fact is the FAA is just not readily available to most of us for one reason or another. Yes I could call my local FSDO. I might even get to talk to a inspector. They may take the time to understand an issue and they may even have the correct answer. Though for all practical purpose what ever answer they give right or wrong, becomes the right answer. There is no recourse for most of us. Sure I could call again and get another inspector in the same office. The second inspector might even opine a different answer if he doesn't lean over his desk to ask the first his opinion before rendering his. But when confronted with both opinions, one, the most conservative opinion, will usually prevail. And pretty soon these inspectors start to think maybe there is a owner operator who needs his aircraft inspected or at least this is the popular belief of many owner operators as to what would happen next.

This is also why most IAs will not make waves with differing opinions than their PMI. Their lively hood is to easily brought to question. I've not meet in person one IA in my area who will even discuss a major alteration with their PMI. Which means they won't even ask their PMI, they will simply assume all modifications are major and without an STC, will not approve of them.

So Harlow, please continue your effort I applaud it.

[voorheesh]

Thanks Bruce. I will see where this goes and get back with any information. This could very well have started with comments by Bill O'Brien. He was like a god to Aviation Maintenance Technicians and having heard him speak, I understand the impact of his words. However, for simple questions like this, we don't need gods. We need people who can read and understand english along with a little common sense (forgive me Bill).