Insurance Q: Removing 2 seats from 6 seater lower cost?

[k9medic]

When returning from MYAT, I once unloaded 7 people, a dog and baggage at KFPR. When we went inside, I was asked where my plane was and I pointed to the Cherokee 6 on the ramp. He thought for sure that there was a jet on the ramp.

I have gotten to know those guys pretty well (by sight) and realize just how fortunate I am to clear there instead of other places.

 

[Bell206]

As long as I do a weight and balance before my flight to account for the weight not being there, how am I operating beyond the scope of the rules?

From strictly the regulatory side any time you remove an item listed on equipment list it becomes a minor alteration to the certified empty weight and a pilot is not authorized to sign off alterations. The seat removal is the easy part and actually falls under prevent mx in most cases. But its the change of the certified empty weight that puts it outside the "scope of the rules." And if you look in the W&B section of the POH/AFM it will state to start your loading calculations based on this basic empty weight from the factory. However, there are several legal methods for a pilot to accomplish this with easiest (at least it was) to get a LOA from the FSDO to allow the pilot to correct the certified EWB. Other options include seeing if an STC exists providing the same pilot approval for your model aircraft, or see if Piper offers a bulletin/letter that alllows a pilot to remove seats and correct the EWB.

 

[EdFred]

From strictly the regulatory side any time you remove an item listed on equipment list it becomes a minor alteration to the certified empty weight and a pilot is not authorized to sign off alterations. The seat removal is the easy part and actually falls under prevent mx in most cases. But its the change of the certified empty weight that puts it outside the "scope of the rules." And if you look in the W&B section of the POH/AFM it will state to start your loading calculations based on this basic empty weight from the factory. However, there are several legal methods for a pilot to accomplish this with easiest (at least it was) to get a LOA from the FSDO to allow the pilot to correct the certified EWB. Other options include seeing if an STC exists providing the same pilot approval for your model aircraft, or see if Piper offers a bulletin/letter that alllows a pilot to remove seats and correct the EWB.

What about your A&P signing off on two separate W&Bs?

 

[Jim K]

From strictly the regulatory side any time you remove an item listed on equipment list it becomes a minor alteration to the certified empty weight and a pilot is not authorized to sign off alterations. The seat removal is the easy part and actually falls under prevent mx in most cases. But its the change of the certified empty weight that puts it outside the "scope of the rules." And if you look in the W&B section of the POH/AFM it will state to start your loading calculations based on this basic empty weight from the factory. However, there are several legal methods for a pilot to accomplish this with easiest (at least it was) to get a LOA from the FSDO to allow the pilot to correct the certified EWB. Other options include seeing if an STC exists providing the same pilot approval for your model aircraft, or see if Piper offers a bulletin/letter that alllows a pilot to remove seats and correct the EWB.

What about your A&P signing off on two separate W&Bs?

I'm thinking of getting my ia to do a w&b with only the two front seats, then the back 5 can be added as necessary. See any holes in that strategy?

I ran across this when I went up to 6y9 as that was the first time I flew with all the seats out and realized I can't subtract weight from the baseline in garmin pilot. Had to do it the old fashioned way. Then I put all the seats back in because it would be super illegal and dangerous to fly without them.

What am I supposed to do if I need to haul a bunch of helium balloons for my kids' birthdays?

 

[EdFred]

I pull my bench seat in and out a few times a year. The seat technically isn't even installed, it just sits in a cradle and friction of the seat belts hold it in. The seat itself has no bolts or anything.

 

[Sluggo63]

What about your A&P signing off on two separate W&Bs?

I don't think that works, because legally the new W&B has to have a statement that it supersedes a previous W&B. Therefore you can only have one current W&B.

 

[EdFred]

I don't think that works, because legally the new W&B has to have a statement that it supersedes a previous W&B. Therefore you can only have one current W&B.

Only keep one in the plane with a statement on each one saying each one supersedes the other. Never produce the other W&B if inspected.

Yes, same date on both W&B.

My A&P actually just did 2 W&B on the same day with each one superseding the previously dated W&B. There was some work done at the same time, so a new W&B needed to be done, and just swap which ever W&B is needed.

 

[Bell206]

What about your A&P signing off on two separate W&Bs?

Only keep one in the plane with a statement on each one saying each one supersedes the other. Never produce the other W&B if inspected.

The problem with that is each time the seats are removed/installed counts as separate work performed and requires its own entry specific to the TT/Date in the record per 43.9. And each of those 43.9 sign-offs need to show the EWB corrected. Now the actual calculations can be filled out and reused which is how I usually set up things by using either a Form ABC schedule or something like Mooney uses. Sometimes we would laminate the different configurations with a specific label. The key is getting authorization for the pilot to sign off the EWB change each time it is changed.

I pull my bench seat in and out a few times a year. The seat technically isn't even installed, it just sits in a cradle and friction of the seat belts hold it in. The seat itself has no bolts or anything.

Is the bench seat listed on the certified EWB equipment list? If not and it is not “permanently” attached to the airframe then it could be called loose equipment. However, seats and berths have their own requirements but the only time those may come into play is after an incident or ramp check and you have someone sitting in a “non-existent” seat.

 

[Bell206]

because legally the new W&B has to have a statement that it supersedes a previous W&B.

Not necessarily as that type of note normally applies to actual weight and balance. Plus not everyone makes that note after an new actual weight and balance. I prefer to use a rolling W&B change record that has blank lines for any future corrections. At the top of this record has the current certified EWB in predetermined columns which makes longhand correction easier. No superseded statements needed as the previous EWB values are listed in the line above the new EWB values.

 

[Bell206]

I'm thinking of getting my ia to do a w&b with only the two front seats, then the back 5 can be added as necessary. See any holes in that strategy?

As mentioned above, each time the seats get moved requires a separate sign off at that particular TT and date per 43.9. The alteration of the EWB in included in that sign-off each time the seats get moved.

it would be super illegal

Only when you have an incident or get ramped checked.

What am I supposed to do if I need to haul a bunch of helium balloons for my kids' birthdays?

Fill up the balloons when you get there?

 

[EdFred]

The problem with that is each time the seats are removed/installed counts as separate work performed and requires its own entry specific to the TT/Date in the record per 43.9. And each of those 43.9 sign-offs need to show the EWB corrected. Now the actual calculations can be filled out and reused which is how I usually set up things by using either a Form ABC schedule or something like Mooney uses. Sometimes we would laminate the different configurations with a specific label. The key is getting authorization for the pilot to sign off the EWB change each time it is changed.

Is the bench seat listed on the certified EWB equipment list? If not and it is not “permanently” attached to the airframe then it could be called loose equipment. However, seats and berths have their own requirements but the only time those may come into play is after an incident or ramp check and you have someone sitting in a “non-existent” seat.

Seat belts pass between the seat back and the seat bottom in the center of the seat and a single bolt passes through then end of the seat belts and to a clevis that connects to the airframe. With some work and no tools the seat belts can be pushed out of the bench seat where they are pinched in which case the rear seat becomes a projectile.

 

[Sinistar]

Thanks for all the replies. It seems that some are doing this but the reduction in premiums is rather small and maybe to the point of not being worth it. I figured it would bring the amount down more since they'd be less likely to haul huge families, less likley to blow W&B, etc.

Good discussions otherwise. We always have a W&B with wheel pants and without. Never had one with back seat removed (182). Clearly the POH indicates the option. Just never got one written up and signed off.

 

[cowman]

I'm just going to comment on the seat thing in the PA-32R from a practical perspective... My rear seats can be removed without tools(although a screwdriver or something to push the little metal plunger in so you don't pinch your fingers is advisable). It takes a minute to do it and most of that is just wrestling the seat back far enough against a shelf to clear it's bracket. The weight of the seats themselves is negligible especially in an aircraft this size, I haven't put them on a scale but by arm feel they can't be much more than a couple lbs. I would wager many of us are flying with a greater error between calculated W&B and actual than these seats represent.

I suppose there could be an issue with calculating CG for large objects when you don't know the exact arm for it but I expect most of us are able to interpolate that well enough.

So, in my opinion there's no good reason to have a bunch of hoops to jump through for the FAA and insurance to swap seat configurations in these airplanes. For some unfathomable reason the FAA and insurance companies don't consider my opinion to be regulatory though so... lawyer this out at your own risk. Just know some guy on the internet is fairly certain it won't cause you to crash.

 

[EdFred]

Thanks for all the replies. It seems that some are doing this but the reduction in premiums is rather small and maybe to the point of not being worth it. I figured it would bring the amount down more since they'd be less likely to haul huge families, less likley to blow W&B, etc.

Good discussions otherwise. We always have a W&B with wheel pants and without. Never had one with back seat removed (182). Clearly the POH indicates the option. Just never got one written up and signed off.

Do you put an entry in the logbook every time the wheel pants go on or off? No? Scofflaw!

 

[Jim K]

The weight of the seats themselves is negligible especially in an aircraft this size, I haven't put them on a scale but by arm feel they can't be much more than a couple lbs.

They'll surprise you. My middle row are 12lb, the "seventh seat" is 8, and the rear seats are 16(!) each. That adds up.

Is the bench seat listed on the certified EWB equipment list? If not and it is not “permanently” attached to the airframe then it could be called loose equipment

So what defines "permanently attached"? Use of tools? "Complex disassembly"?

Like cowman said, it's pretty obvious what Piper's intention was, but the FAR's don't always match up with common sense.

 

[schmookeeg]

So before I get into my next micturition match with the fedholes, I suppose what I did here for our W/B is not correct then?

 

[Bell206]

I suppose what I did here for our W/B is not correct then?

Whats wrong with it? Thats the way to go especially if you routinely change configurations. I would usually set up something similar if the situation warranted it.

 

[schmookeeg]

Whats wrong with it? Thats the way to go especially if you routinely change configurations. I would usually set up something similar if the situation warranted it.

It seems to fly in the face of the "one true w/b configuration, all others must be superceded" advice being bandied here. I'm a new enough A&P to think my idea had merit, and maybe enough to sheepishly defend it to a fed, but not to presume success in said defense.

 

[Bell206]

So what defines "permanently attached"? Use of tools? "Complex disassembly"?

There is varying guidance but the definition I use is whether the item is considered loose or portable equipment, i.e., not affixed to the airframe. Velcro attached is a gray area where I make the call depending on the item.

but the FAR's don't always match up with common sense.

FWIW: FARs are merely minimum aviation standards created to meet our obligations as signatory on international agreements and to meet certain domestic needs. They all have their place in the big picture. But where those standards really come into their own is when someone who thinks they are senseless rules or government overreach gets screwed by the next guy and they post on PoA how can anyone be so low as not follow the same rules they complained about 3 months earlier but demand justice now. Then again if everyone were to follow the rules then my maintenance gravey train would dry up. Hmmm. FARs... what FARs.... Who needs them.

 

[Bell206]

one true w/b configuration, all others must be superceded

Perhaps some different terminology. There must be a certified (signed) actual empty weight and balance record along with its required equipment list in the aircraft to meet its TC. Separately you can have multiple aircraft configuration sheets that indicate the change from the original EWB. For example, a common system out there is to label the actual EWB Form A, the Equipment List Form B, and the configuration change sheet Form C. Mooney uses something similar except their "form c" is a single sheet with multiple blank lines to allow for multiple changes on one sheet. All these documents are kept in the aircraft to make it legal. Make more sense?

 

[schmookeeg]

Perhaps some different terminology. There must be a certified (signed) actual empty weight and balance record along with its required equipment list in the aircraft to meet its TC. Separately you can have multiple aircraft configuration sheets that indicate the change from the original EWB. For example, a common system out there is to label the actual EWB Form A, the Equipment List Form B, and the configuration change sheet Form C. Mooney uses something similar except their "form c" is a single sheet with multiple blank lines to allow for multiple changes on one sheet. All these documents are kept in the aircraft to make it legal. Make more sense?

Appreciate confirmation of my "common sense" approach to easily reconfigured items which were included in the prior W/B

Worst case is a fed makes me undo it, so it seemed convenient to do.

 

[Bell206]

Worst case is a fed makes me undo it,

Based what I've done and seen, I would think the only issue they may want would be to put each configuration on a separate sheet to prevent confusion/errors. Is this for straight 91 or 135 also?

 

[schmookeeg]

Based what I've done and seen, I would think the only issue they may want would be to put each configuration on a separate sheet to prevent confusion/errors. Is this for straight 91 or 135 also?

pure delicious pt 91, with my insurer saying I'm covered (liability and hull) for my maintenance actions on the plane I own.

 

[Jim K]

Perhaps some different terminology. There must be a certified (signed) actual empty weight and balance record along with its required equipment list in the aircraft to meet its TC. Separately you can have multiple aircraft configuration sheets that indicate the change from the original EWB. For example, a common system out there is to label the actual EWB Form A, the Equipment List Form B, and the configuration change sheet Form C. Mooney uses something similar except their "form c" is a single sheet with multiple blank lines to allow for multiple changes on one sheet. All these documents are kept in the aircraft to make it legal. Make more sense?

But you're saying that strictly following the letter of the law, even with these multiple configuration forms, the actual install/ removal of the seats has to be logged?

A solid argument could be made (I think) that an owner could log this as it doesn't require "complex disassembly". Of course it does change w&b, but that's already accounted for.

Further iirc there no requirement to keep logs other than those required by regulation, so couldn't I scribble which configuration im using on a piece of paper (like maybe my kneeboard, and definitely not after the asi asks for it)?

Or am I misunderstanding and having all the configurations listed out like schmoo negates the need for logging?

 

[Bell206]

But you're saying that strictly following the letter of the law, even with these multiple configuration forms, the actual install/ removal of the seats has to be logged?

Yes. Part 43.9. All mx must be logged.

A solid argument could be made (I think) that an owner could log this as it doesn't require "complex disassembly". Of course it does change w&b, but that's already accounted for.

Yes the owner could log the seat removal as it actually can fall under preventative maintenance. But as noted the EWB minor alteration is the issue for the removal entry by the owner.

Further iirc there no requirement to keep logs other than those required by regulation, so couldn't I scribble which configuration im using on a piece of paper (like maybe my kneeboard, and definitely not after the asi asks for it)?

Correct. There is also no standard on what constitutes a “maintenance record.” It could be a logbook, a sticky label, a bar napkin, or your knee board. However, the regulation (91.417) states the record “shall be retained until the work is repeated or superseded by other work or for 1 year after the work is performed.” May want to get a case of kneeboards on order.

Or am I misunderstanding and having all the configurations listed out like schmoo negates the need for logging?

Yes on misunderstanding, no on negating the logging. As noted all mx must be logged. The pre-listed configurations facilitates the logging and calculating of the required maintenance. For example, “Reconfigured aircraft and corrected W&B per details listed in Configuration Four of the aircraft empty weight and balance record.”

 

[k9medic]

So before I get into my next micturition match with the fedholes, I suppose what I did here for our W/B is not correct then?

View attachment 100084

We do something similar for Part 135 operations and keep copies in the flight manual. There is zero documentation put into the aircraft logbooks when we fly with different weight configurations. If we pull a seat or install a seat we have to sign it off in the logbook.

 

[Bell206]

I suppose what I did here for our W/B is not correct then?

For example, “Reconfigured aircraft and corrected W&B per details listed in Configuration Four of the aircraft empty weight and balance record.”

FYI: the above example also highlights why it might be a good reason to put each configuration on a separate sheet. Given that logbooks are not kept in private GA as the norm, having all on one sheet may lead to confusion even though you would know which config you were on. With separate sheets you could leave the current config with the EWB record and store the others. For example, when possible, I would reduce the created EWB records to the same size as the POH/AFM and insert them in Chap 6 and the pilot would swap out the different config change sheets as needed so there was only one option in Chap 6 at a time. Would also include a copy of the pilot LOA if applicable.