Legality of taking out seats?

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JC150

Pre-takeoff checklist
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JC150
Can anyone tell me if it is legal to take out the rear seats out of my PA28 and fly that way? It's nice to be able to fit larger items in the back and be able to take out the rear seats.

Someone told me that the Type Certificate does not say the aircraft can fly with 1,2, or 3 seats; it says 4, and therefore by operating with a configuration other than 4 seats, I would be operating an unairworthy aircraft.

Can anyone tell me if this is correct? Thanks.
 
You have to get an A&P to do a second weight and balance sheet with the rear seats removed. The airplane can then be operated in the utility category with the rear seats removed.

At least this is the case for an Archer II. Not sure that's so for every PA-28.
 
And...

One of the marketing hypes, first from Piper and since then in the resale market, has been the quick release and take-out capability of the rear seats in the PA32.

We certainly have to consider that weight removed, as "minuses" in the W&B calculation, but I have never heard of doing a second certified W&B sheet.

This is an interesting question by the OP....
 
I think it depends on the type certificate for your particular aircraft. If you look at your equipment list, it will likely say if the back seats are required or some version of optional. (In my plane's case, it says if something is required, standard, or optional.) If required, I think you have to get an STC, and an A & P to prepare the weight and balance data for you to use for your W & B calcs. Then, when you remove the seats, you have to log the removal in the seatss, and have the revised W & B data on board, and do your W & B calc for flight based on that.

If its just optional, I think you can remove the seats, log the removal in your maintenance manual, carry your original W & B data (as usual) and simply do the weight and balance calculation as you would for any flight, including the reduction in weight and change in datum with the seat missing.
 
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You can do the math if you carry a passenger. Do the math if you take out a seat. The equipment list establishes what was in there at weighing. It isn't a limitation. That would be required equipment on the TCDS and my back seats aren't listed there. I figure Cessna installed my quick-release jump seats with removal in mind.
 
cowman said:
You have to get an A&P to do a second weight and balance sheet with the rear seats removed. The airplane can then be operated in the utility category with the rear seats removed.

At least this is the case for an Archer II. Not sure that's so for every PA-28.
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Unless you have a letter from the FAA that states that the pilot can remove the seats of the PA 28, or the seat is made in a manor that it can be removed with out tools and the TCDS says it is a pilot function to configure the aircraft for cargo.... You can not do this legally.

The 170 association went thru this with the FAA and got a letter saying it is a pilot function to remove the seat, but they must have a W&B sheet for each configuration.
 
The PA28 71 Flite Liner that I used to own came from the factory with no back seat. Jump seats had been added. In or out was a W&B thing.
 
Topic discussed here as well

Most people said to get an alternate W&B from my A&P, but remove the seats myself.

I called my mechanic and he echoed the same advice to get an alternate W&B that goes in and out of the AFM as the seats go in and out of the airplane. So that's what I have done.

From a practical standpoint, I found that removing my seats was pretty easy but reinstalling them was an absolute pain in the ass. I would recommend several tapered punches in order to align bolt holes and to keep them aligned while inserting bolts. I thought maybe it was just my seat, but I asked my IA if it was common for Cessna seats to be such a pain to install. He said "very common - not just Cessna." I got no sympathy from him :D

I couldn't decide whether to remove the front seats during the rear seat install or just leave it in. Ultimately I had the front seat out when I put the rear seat back in.. and then I regretted that decision. I did eventually get the front seat back in, with the rear installed, but it was a PITA too. I put the rear wheels on the track and then slid the seat foreward to align the front wheels but it would interfere with the heater vent shroud. I eventually removed that shroud and gained the 2 mm I needed to get the front wheel on the seat track.

I can see why my annual costs so much... and why I do not want to assist. :-/
 
Tom-D said:
Unless you have a letter from the FAA that states that the pilot can remove the seats of the PA 28, or the seat is made in a manor that it can be removed with out tools and the TCDS says it is a pilot function to configure the aircraft for cargo.... You can not do this legally.

The 170 association went thru this with the FAA and got a letter saying it is a pilot function to remove the seat, but they must have a W&B sheet for each configuration.
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This. If you have to start wrenching on tools to remove/replace seats, then you probably need an A&P involvement.

That is one thing I like about the back seats in the Baron - simple cotter pins - no tools needed.
 
Tom-D said:
Unless you have a letter from the FAA that states that the pilot can remove the seats of the PA 28, or the seat is made in a manor that it can be removed with out tools and the TCDS says it is a pilot function to configure the aircraft for cargo.... You can not do this legally.

The 170 association went thru this with the FAA and got a letter saying it is a pilot function to remove the seat, but they must have a W&B sheet for each configuration.
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Tom, I appreciate your input on this. If my aircraft equipment list shows the back seat as optional (and I presume that it's consistent with the type certificate), and the equipment list gives me the weight and datum for the seat, what regs/rules/orders prevent me as a pilot from removing the seat myself, and performing the weight and balance calcs myself? As a starting point, "replacing seats" is listed as "preventative maintenance" under part 43, which aircraft owners may perform themselves. Just trying to get a better understanding to keep myself out of the soup; not trying to say your wrong. Thanks.
 
So a Piper probably doesn't have an equipment list. I know that removing the seat, at least the lower cushion is a pilot task because that's how you get to the battery to service it...it just pulls up. I don't know what's involved with getting the rest of the seat out, but if you're doing this in a PA-28, you need to account for protecting the battery from whatever you're putting in or pulling out of the plane.
 
Tom-D said:
Unless you have a letter from the FAA that states that the pilot can remove the seats of the PA 28, or the seat is made in a manor that it can be removed with out tools and the TCDS says it is a pilot function to configure the aircraft for cargo.... You can not do this legally.

The 170 association went thru this with the FAA and got a letter saying it is a pilot function to remove the seat, but they must have a W&B sheet for each configuration.
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My rear seats can be removed without tools, but I don't see anything in the TCDS that says its a pilot function to configure the aircraft...

I did have 2 separate weight and balances at one time, but had some avionics work done and they amended the w&b for 4 seats, but wouldn't amend the w&b with the rear seats taken out because they said flying without the rear seats did not meet the TCDS and it wouldn't be legal to fly that way.
 
Tom-D said:
Unless you have a letter from the FAA that states that the pilot can remove the seats of the PA 28, or the seat is made in a manor that it can be removed with out tools and the TCDS says it is a pilot function to configure the aircraft for cargo.... You can not do this legally.

The 170 association went thru this with the FAA and got a letter saying it is a pilot function to remove the seat, but they must have a W&B sheet for each configuration.
Click to expand...

The rear seats on my Archer can be removed without tools. They are in a track and all you have to do is push down a spring loaded retaining pin and they slide out. It has been a while since I read it but the TCDS does allow for 4 seat or 2 seat operation but with 2 seats it is only allowed to operate in the utility category which brings the max gross weight down quite a bit.
 
That was helpful. So in your case you could because it says in the TCDS that you can operate in the utility category. For my PA28 specifically, I cannot because the utility category is not an option, even though I have the same remarks in my POH about removing the rear seats for bulky items. Interesting
 
The FAA says:

At the next annual inspection, or sooner, have a mechanic work two weight and balances sheets. One sheet with the seat in, one sheet with the seat out. Also have him create two equipment lists, one with the seat in and one with the seat out. I recommend that you identify each weight & balance and equipment list with an identifying letter or number so that particular W&B and equipment list can be properly referenced in the log book entry.

I also recommend that the mechanic sign both W&B and equipment lists with his signature and certificate number and date.

When the pilot removes the seat, he makes a log book entry in accordance with section 43.9, This tells the world what seat is removed and the new weight and balance/equipment list is in effect, (reference the identifying letter or number of the new weight/balance/ equipment list.) The new weight & balance and equipment list should be put in the flight manual or someplace handy so the pilot can get to it. The old weight & balance/equipment list should be taken out of the aircraft and stored someplace until it is needed. In this way no chance of error exists when the pilot computes his weight and balance.

When the seat goes back in, the pilot makes another log book entry in accordance with section 43.9; the log book should now state that the original weight and balance/equipment list is now in effect. (reference the identifying letter or number of the new weight/balance/equipment list..) In this way the pilot can remove and install the same seat twenty times a week, without an A&P and the weight and balance and equipment list is always current.”
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I don't know of any light airplane that can't legally have the rear seat removed unless it's welded right in there (Husky) or has to be soloed from the rear seat (Cub). Just need the W&B amendment.

There was a version of the PA-28 that was a two-seat airplane. The PA-28-140 Cherokee Cruiser.
 
PPC1052 said:
Tom, I appreciate your input on this. If my aircraft equipment list shows the back seat as optional (and I presume that it's consistent with the type certificate), and the equipment list gives me the weight and datum for the seat, what regs/rules/orders prevent me as a pilot from removing the seat myself, and performing the weight and balance calcs myself? As a starting point, "replacing seats" is listed as "preventative maintenance" under part 43, which aircraft owners may perform themselves. Just trying to get a better understanding to keep myself out of the soup; not trying to say your wrong. Thanks.
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Many aircraft are no so well versed in the seat removal, most say nothing about it. Your aircraft type certificate and the MEL authorizes you to remove the seat.
When the topic is not addressed that way, you must have a letter of authorization from the FAA Airworthiness stating this can be done by the pilot. Otherwise, you are operating an aircraft that does not meet its design, or to put it another way, not fully equipped.
many seats are considered by the FAA as structure. The only way to determine what they believe, is to ask for a letter of authorization to allow the seats to be removed and the configuration of the aircraft changed.
 
Tom-D said:
you must have a letter of authorization from the FAA Airworthiness stating this can be done by the pilot. Otherwise, you are operating an aircraft that does not meet its design, or to put it another way, not fully equipped. many seats are considered by the FAA as structure. The only way to determine what they believe, is to ask for a letter of authorization to allow the seats to be removed and the configuration of the aircraft changed.
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Who do I go to for that letter? Just email my local FSDO and tell them I want a letter so I can operate with seats removed?
 
JC150 said:
Who do I go to for that letter? Just email my local FSDO and tell them I want a letter so I can operate with seats removed?
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According to our local FSDO, I didn't need any such letter. I suppose it would be nice to have. Not sure about other aircraft but for my Skylane , all I needed was a new W&B from my mechanic with seats removed. I remove the seats myself and remove the "Standard Configuration W&B" from the POH and replace it with the "Cargo Configuration W&B". When I reinstall, I do the reverse.

My POH does have a configuration statement (see attached) with all the configuration arms. (maybe other aircraft do not have that).

Kevin
 
I recently went through this with my local FBO - we researched the POH and there is no verbiage to indicate that anything needs to be done for the rear seat removal; this is for a PA-28-181. The rear seats remove easily in 5 minutes, simply pop up and out; I just subtract the weight of the seats from the W&B for that area.
 
Fearless Tower said:
This. If you have to start wrenching on tools to remove/replace seats, then you probably need an A&P involvement.

That is one thing I like about the back seats in the Baron - simple cotter pins - no tools needed.
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Removing and installing seats is one of the items allowed to be performed by the pilot per the FARs. I don't see what tools would have to do with it.

Now operating the aircraft with them removed is obviously a different story...
 
You'd need a separate W&B for all configurations in which you intend on operating the aircraft. Since it is technically a maintenance item you would need to sign it off with your pilot cert # or have a seat tracking log like most of the 135s in alaska.
 
Does the POH equipment list give you the weight and arm of the rear seat?
 
When was the last time any of you got ramped? Do you really think an FAA guy cares about your back seats? Seriously?
 
^ From Alaska... not shocked.

Some pilots like to stay legal. Perhaps you are critical of that, but I doubt anyone cares.
 
So even if it doesn't say it is legal in the type certificate, you can do it if you follow the instructions in that document? Had an avionics shop that wouldn't ammend the other W&B because the Type Cert. didn't allow for any other configuration.
 
30 years ago I used my PA-28-151 as a transport for racing engines shuttled to and from tracks I raced at....

Seats are NOT structural..:no:

Do a new weight and balance..:yes:

My A&P /IA checked with the FSDO and they approved that configuration..

And as another poster stated... You need to protect the battery posts from shorting out.. I just used a 1/2 CDX piece of plywood to cover the seat box..

Very similar to the AD fix PIPER sells for the lower seat springs over the battery... Seems a REALLY fat person sat in the right rear somewhere in the world and the springs of the seat shorted out the battery and the plane caught fire in flight..:redface:
 
N801BH said:
30 years ago I used my PA-28-151 as a transport for racing engines shuttled to and from tracks I raced at....

Seats are NOT structural..:no:

Do a new weight and balance..:yes:

My A&P /IA checked with the FSDO and they approved that configuration..

And as another poster stated... You need to protect the battery posts from shorting out.. I just used a 1/2 CDX piece of plywood to cover the seat box..

Very similar to the AD fix PIPER sells for the lower seat springs over the battery... Seems a REALLY fat person sat in the right rear somewhere in the world and the springs of the seat shorted out the battery and the plane caught fire in flight..:redface:
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The TCDS for the PA-28-151 shows both 4 seats and 2 seats as approved configurations so it is legal for that model. (It also states that with 2 seats it is only approved in the utility category so max weight is reduced to 1950lbs.) Not all Type Certificates authorize a configuration with seats removed. The definition of airworthy in the FARs is:

3.5 Statements about products, parts, appliances and materials.
(a) Definitions. The following terms will have the stated meanings when used in this section:

Airworthy means the aircraft conforms to its type design and is in a condition for safe operation.
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Just for grins I looked it up. My TCDS lists seats.
Number of seats (max.) 6 (2 at +36 to +50, 2 at +65 or +73, 2 at +97)
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That leads me to believe that I can utilize fewer than the maximum and that's typical of 6 seat Skywagons since overwhelmingly most have had the aft bench seat removed. Removable seats make for a much more useful airplane. It isn't uncommon for me to fly with only one seat installed.
 
N801BH said:
Seats are NOT structural..:no:
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Is that a safe assumption? Never?

I can imagine a weight-conscious designer using the rear seat structure to reinforce/strengthen the aft fuselage.

Removal can also expose things best not left exposed. I believe the STC for removal of the Cirrus rear seats includes reinforcement of a flimsy panel that is otherwise protected by the seat. Unreinforced, an item carried above it could punch through it and jam controls or short wiring - I believe BAT2 is carried down there.
 
FastEddieB said:
Is that a safe assumption? Never?

I can imagine a weight-conscious designer using the rear seat structure to reinforce/strengthen the aft fuselage.

Removal can also expose things best not left exposed. I believe the STC for removal of the Cirrus rear seats includes reinforcement of a flimsy panel that is otherwise protected by the seat. Unreinforced, an item carried above it could punch through it and jam controls or short wiring - I believe BAT2 is carried down there.
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I should have said..... Rear seats in a PA-28-151 are NOT structural ...:redface::redface::redface:
 
Stewartb said:
When was the last time any of you got ramped? Do you really think an FAA guy cares about your back seats? Seriously?
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A couple of years ago an eager FAA inspector set up at Fort Pierce and hassled pilots returning from the Bahamas about the W&B for removed seats.
 
N801BH said:
I should have said..... Rear seats in a PA-28-151 are NOT structural ...:redface::redface::redface:
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If they are not considered to be structural the why does the TCDS show a 375 lb reduction in max weight allowed when they are removed? They must be giving some type of structural support if you are allowed to carry more weight when they are installed.
 
The POH for the A36 shows the different configurations of seats that are allowable. The weight is printed on the seat. When I asked the mechanic about a second set of W&B he said that there can only be one at a time to maintain the chain of one referencing the prior one it replaces. His opinion was that any configuration shown in the POH is allowable.
 
weilke said:
A couple of years ago an eager FAA inspector set up at Fort Pierce and hassled pilots returning from the Bahamas about the W&B for removed seats.
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Those pilots should have asked him to show them where in the regs they were not in compliance. My W&B was done with empty fuel yet I'm allowed to add at my discretion providing I stay within the W&B limits. Why are seats any different? Show me in the regs. I'm genuinely interested.
 
Stewartb said:
Those pilots should have asked him to show them where in the regs they were not in compliance. My W&B was done with empty fuel yet I'm allowed to add at my discretion providing I stay within the W&B limits. Why are seats any different? Show me in the regs. I'm genuinely interested.
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This was just to answer the question where one could get ramp checked on this issue.

The handling of this within the FAA seems to be far from uniform. For my particular aircraft I am satisfied that I can install and remove seats in the approved configurations.

The fuel in your plane is not bolted on and your POH gives you the information of what it does to W&B.
 
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