Flying a PA/32 on BasicMed

sferguson524

sferguson524

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Hey y'all,

An opportunity for a partnership in a lance came up, and I was wondering if I was going to be able to fly it on BasicMed? I know SOME were certified with 7 seats, so that's a no go.. But if it's got 6, is it good to go?
 
The 7th seat is not a certification. It's an optional installation in the center of the middle row when you have 2+2+2 seating. So if the seat is not installed, then it's not installed.
 
I think it may be more complicated than stated above. This was discussed extensively on the Piper page.

"The Piper PA-32R-300 (Lance), Piper PA-32RT-300 (Lance II), PA-32RT-300T (Turbo Lance II), PA-32R-301 (Saratoga SP), PA-32R-301T (Turbo Saratoga SP), PA-32-301 (Saratoga), and PA-32-301T (Turbo Saratoga) are authorized to be equipped with 7 seats. Although the center seats may be removed and replaced by Optional Club Seats to carry 6 occupants and some aircraft are also authorized for an unmodified 6 seat configuration, all these aircraft are authorized to carry more than 6 occupants without further modification and therefore may not be operated under BasicMed. These aircraft may only be operated under BasicMed pursuant to the issuance and inclusion in their type design of a Supplemental Type Certificate (STC) that restricts the aircraft to 6 seats."
 
Somebody in the PA32 Facebook group was working on the STC to remove the 7th seat from the TCDS. He said mid-March was expected completion.

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Niiiice! Lines up with my plans. Is this something that could be done as a field approval on a 337 from a A&P as well?
 
We have a partnership with a PA32. After reading through everything, we all maintain a Class3 Medical. There’s a lot of confusing info out there. YMMV.


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I think the uninstalled 7th seat is a red herring. The basicmed language says the aircraft must be authorized to carry not more than 6 people. An aircraft that only has six seats is not authorized to carry seven people, right? If you had six seats and took off with seven occupants, one without a seat or seatbelt, you would be in violation of the law.

I am sure this is the same discussion that happened on the piper board. Too many people want to make things something they aren’t.
 
bflynn said:
I think the uninstalled 7th seat is a red herring. The basicmed language says the aircraft must be authorized to carry not more than 6 people. An aircraft that only has six seats is not authorized to carry seven people, right? If you had six seats and took off with seven occupants, one without a seat or seatbelt, you would be in violation of the law.

I am sure this is the same discussion that happened on the piper board. Too many people want to make things something they aren’t.
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The FAA has posted clarification for this. By Authorized they mean on the type certificate. They have specifically called out the PA32 as an example of an aircraft (for later models) that are authorized for 7 seats but in some cases have 6.
 
Heftiger said:
The FAA has posted clarification for this. By Authorized they mean on the type certificate. They have specifically called out the PA32 as an example of an aircraft (for later models) that are authorized for 7 seats but in some cases have 6.
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That's correct. It's an unfortunate side effect of how Congress wrote Section 2307 creating BasicMed. As such, for aircraft whose type certificate allows 7 seats, they would need a STC to fly it under BasicMed. I really don't know why the 6,000 pounds 6 seats was an aircraft limitation rather than an operational limitation, but it is what it is.
 
Brad Z said:
I really don't know why the 6,000 pounds 6 seats was an aircraft limitation rather than an operational limitation,
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That's how the sport pilot rule works - aircraft must meet the limits. Plus for LSA, you have the words "continuously since certification" - Can't have an STC to down size an existing aircraft to fit under the LSA limits.
 
Capt. Geoffrey Thorpe said:
That's how the sport pilot rule works - aircraft must meet the limits. Plus for LSA, you have the words "continuously since certification" - Can't have an STC to down size an existing aircraft to fit under the LSA limits.
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Yep, doesn't mean it makes sense though. Over the last few years the FAA has been shifting to performance based rulemaking, focusing on outcome. An aircraft certified with 7 seats being flown with 6 occupants is no more of a hazard then an aircraft certified for 6 seats being flown with 6 occupants.
 
It doesn’t even have to be a PA32 where the 7th seat has been removed. I have a PA32-301 where the type certificate says 7 people. It came from the factory with 6 seats in the club configuration. It would require a major modification to give me that 7th seat. From a basic med standpoint it’s frustrating (for those that need it) but maybe Piper was thinking ahead on this and knew that by putting 7 on the type certificate they were simplifying the process for anyone wanting to add the 7th seat later. I guess it depends on which angle you’re looking at.

It’s a not issue for me (currently) as I have no problems obtaining a standard medical.
 
bflynn said:
I think the uninstalled 7th seat is a red herring. The basicmed language says the aircraft must be authorized to carry not more than 6 people. An aircraft that only has six seats is not authorized to carry seven people, right? If you had six seats and took off with seven occupants, one without a seat or seatbelt, you would be in violation of the law.

I am sure this is the same discussion that happened on the piper board. Too many people want to make things something they aren’t.
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Doesn’t work that way, unfortunately.

It’s no different than an airplane certified with a gross weight over 12,500.

Just because you strip it bare and operate it below 12,500 doesn’t mean you can do it without a type rating.
 
There's no need for speculating or interpreting on this issue, as the FAA has published an "FAQ" clarifying which PA32s are "BasicMed" compliant and which are not:

See Question 33 of the below FAQ:

https://www.faa.gov/licenses_certificates/airmen_certification/basic_med/media/basicmed_faq.pdf

"A: The Piper PA-32-260 (Cherokee Six 260) and PA-32-300 (Cherokee Six 300) aircraft are authorized by their type certificate (as set forth in Type Certificate Data [TCDS] A3SO) to be equipped with 6 seats and also to be equipped with 7 seats only if they have been converted by the installation of Piper Kit No. 69072-3. If your PA-32-260 or PA-32-300 is equipped with 6 seats and has not been converted to a 7-seat configuration by installation of the Piper kit, you may fly the aircraft under BasicMed. If your aircraft has been converted to the 7-seat configuration using the Piper kit you may not fly the aircraft under BasicMed. To fly that aircraft under BasicMed you would have to remove the installed kit and document its removal in the aircraft’s maintenance records. An FAA Form 337 would not be required to document the installation or removal of the kit. You may also fly the aircraft under BasicMed if it is equipped with the 6-seat Optional Club Seat configuration.

A total of 14 aircraft models are listed on TCDS A3SO and their eligibility to be operated under BasicMed depends upon the specific aircraft model.

The Piper PA-32R-300 (Lance), Piper PA-32RT-300 (Lance II), PA-32RT-300T (Turbo Lance II), PA-32R-301 (Saratoga SP), PA-32R-301T (Turbo Saratoga SP), PA-32-301 (Saratoga), and PA-32-301T (Turbo Saratoga) are authorized to be equipped with 7 seats. Although the center seats may be removed and replaced by Optional Club Seats to carry 6 occupants and some aircraft are also authorized for an unmodified 6 seat configuration, all these aircraft are authorized to carry more than 6 occupants without further modification and therefore may not be operated under BasicMed. These aircraft may only be operated under BasicMed pursuant to the issuance and inclusion in their type design of a Supplemental Type Certificate (STC) that restricts the aircraft to 6 seats.

The PA-32R-301 (Saratoga II HP), PA-32R-301FT (Piper 6X), and PA-32R-301XTC (Piper 6XT) are only authorized to be equipped with 6 seats and may be operated under BasicMed.

The PA-32R-301T (Saratoga II TC) is authorized to be equipped with 5 or 6 seats and may be operated under BasicMed.

The PA-32S-300 (Cherokee Six Seaplane), PA-301-32R-301 is authorized to be equipped with 7 seats and may only be operated under BasicMed pursuant to the issuance and inclusion in its type design of an STC that restricts the aircraft to 6 seats.

If your aircraft has been altered to permit the installation of a 7th seat by an STC, the seat may be removed and the aircraft may be operated under Basic Med provided the removal is recorded in the aircraft’s maintenance records and also on FAA Form 337 (unless the removal instructions were provided as part of the STC)."
 
bradg33 said:
There's no need for speculating or interpreting on this issue, as the FAA has published an "FAQ" clarifying which PA32s are "BasicMed" compliant and which are not:

See Question 33 of the below FAQ:

https://www.faa.gov/licenses_certificates/airmen_certification/basic_med/media/basicmed_faq.pdf

"A: The Piper PA-32-260 (Cherokee Six 260) and PA-32-300 (Cherokee Six 300) aircraft are authorized by their type certificate (as set forth in Type Certificate Data [TCDS] A3SO) to be equipped with 6 seats and also to be equipped with 7 seats only if they have been converted by the installation of Piper Kit No. 69072-3. If your PA-32-260 or PA-32-300 is equipped with 6 seats and has not been converted to a 7-seat configuration by installation of the Piper kit, you may fly the aircraft under BasicMed. If your aircraft has been converted to the 7-seat configuration using the Piper kit you may not fly the aircraft under BasicMed. To fly that aircraft under BasicMed you would have to remove the installed kit and document its removal in the aircraft’s maintenance records. An FAA Form 337 would not be required to document the installation or removal of the kit. You may also fly the aircraft under BasicMed if it is equipped with the 6-seat Optional Club Seat configuration.

A total of 14 aircraft models are listed on TCDS A3SO and their eligibility to be operated under BasicMed depends upon the specific aircraft model.

The Piper PA-32R-300 (Lance), Piper PA-32RT-300 (Lance II), PA-32RT-300T (Turbo Lance II), PA-32R-301 (Saratoga SP), PA-32R-301T (Turbo Saratoga SP), PA-32-301 (Saratoga), and PA-32-301T (Turbo Saratoga) are authorized to be equipped with 7 seats. Although the center seats may be removed and replaced by Optional Club Seats to carry 6 occupants and some aircraft are also authorized for an unmodified 6 seat configuration, all these aircraft are authorized to carry more than 6 occupants without further modification and therefore may not be operated under BasicMed. These aircraft may only be operated under BasicMed pursuant to the issuance and inclusion in their type design of a Supplemental Type Certificate (STC) that restricts the aircraft to 6 seats.

The PA-32R-301 (Saratoga II HP), PA-32R-301FT (Piper 6X), and PA-32R-301XTC (Piper 6XT) are only authorized to be equipped with 6 seats and may be operated under BasicMed.

The PA-32R-301T (Saratoga II TC) is authorized to be equipped with 5 or 6 seats and may be operated under BasicMed.

The PA-32S-300 (Cherokee Six Seaplane), PA-301-32R-301 is authorized to be equipped with 7 seats and may only be operated under BasicMed pursuant to the issuance and inclusion in its type design of an STC that restricts the aircraft to 6 seats.

If your aircraft has been altered to permit the installation of a 7th seat by an STC, the seat may be removed and the aircraft may be operated under Basic Med provided the removal is recorded in the aircraft’s maintenance records and also on FAA Form 337 (unless the removal instructions were provided as part of the STC)."
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Thanks for posting that. Having just looked at the PA32 TCDS, I was about to ask if anyone had actually ASKED the FAA about it since the TCDS would imply that SOME PA32s could be operated under Basic Med, while others would clearly not.

So, while they all fall under one common TCDS, there are enough differences in models that some are certified as 7 seats, some as 6 seats and some can be 'converted' to 7.
 
Fearless Tower said:
Doesn’t work that way, unfortunately.

It’s no different than an airplane certified with a gross weight over 12,500.

Just because you strip it bare and operate it below 12,500 doesn’t mean you can do it without a type rating.
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Actually, it is different because there is different language used in BasicMed. You cannot fly an airplane certified over 6000 lbs. You cannot fly an airplane authorized to carry more than six passengers. What weight the plane is certified at is set and doesn't change. But how many passengers it is authorized to fly with can change with configuration. Take a Cherokee Six that could be configured to have seven seats. Remove both back seats out and it is now authorized to carry two people because it only has two places to sit. That makes it legal.

Unclear how skydivers might impact something like this, but I suspect you can't fly meat bombs under BasicMed.
 
bflynn said:
Actually, it is different because there is different language used in BasicMed. You cannot fly an airplane certified over 6000 lbs. You cannot fly an airplane authorized to carry more than six passengers. What weight the plane is certified at is set and doesn't change. But how many passengers it is authorized to fly with can change with configuration. Take a Cherokee Six that could be configured to have seven seats. Remove both back seats out and it is now authorized to carry two people because it only has two places to sit. That makes it legal.

Unclear how skydivers might impact something like this, but I suspect you can't fly meat bombs under BasicMed.
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Your interpretation is the correct, common-sense and plain language reading of the statute; an aircraft with 6 installed seats is only authorized to carry 6 people. However, that plain-language, common sense reading is, of course, inconsistent with the FAA's currently-controlling position that the TCDS data controls how many passengers the aircraft is "authorized" to carry.

From AC 68-1A:

"For type certificated aircraft, the aircraft’s design approval would authorize the number of occupants the aircraft may carry and would contain the maximum certificated takeoff weight. The aircraft’s design approval may be a type certificate (TC), a supplemental type certificate (STC), or an amended TC (ATC). The FAA recognizes that changes could be made to an aircraft’s type design. For example, an aircraft type certificated to carry more than six occupants may be altered to carry six or fewer occupants. In order to make such a change, that aircraft would have to obtain a new design approval, such as an STC or an ATC. So long as an aircraft’s design approval (i.e., TC, STC, or ATC) authorizes the aircraft to carry no more than six occupants, that aircraft would meet the requirements of § 61.113(i)(1). Additionally, if an aircraft with a maximum certificated takeoff weight of more than 6,000 pounds is altered to have a maximum certificated takeoff weight of less than 6,000 pounds, then that aircraft would likewise meet the requirements of § 61.113(i)(1)."
 
bflynn said:
Actually, it is different because there is different language used in BasicMed. You cannot fly an airplane certified over 6000 lbs. You cannot fly an airplane authorized to carry more than six passengers. What weight the plane is certified at is set and doesn't change. But how many passengers it is authorized to fly with can change with configuration. Take a Cherokee Six that could be configured to have seven seats. Remove both back seats out and it is now authorized to carry two people because it only has two places to sit. That makes it legal.
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No. Again, it doesn’t work that way. If the TCDS says it is certified /approved for 7 seats, than it is authorized for seven seats.

Again, you have to get into the reference, as some PA32s are certified for 7, some only for 6 and some are approved for seven only after conversion.

Just like with LSAs, you can’t take two seats out of a 4 seat airplane and say, look I’m legal to fly sport pilot.




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So, if we decide to go the Lance route, I will need to purchase the yet to surface STC from aeronautix :)
 
Fearless Tower said:
No. Again, it doesn’t work that way. If the TCDS says it is certified /approved for 7 seats, than it is authorized for seven seats.

Again, you have to get into the reference, as some PA32s are certified for 7, some only for 6 and some are approved for seven only after conversion.

Just like with LSAs, you can’t take two seats out of a 4 seat airplane and say, look I’m legal to fly sport pilot.




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The Light Sport rules, as they relate to seating capacity, do make reference to the aircraft's "certification." The FAA's (well, Congress') use of the word "authorized" in the Basic Med rules is what makes it different. An aircraft can be certified to seat 8 people, but in order to actually be "authorized" to carry 8 occupants it has to have 8 seats installed and 8 seat belts (save for sky diving and rules regarding kids). In other words, authorized and certified don't mean the same thing.
 
Fearless Tower said:
No. Again, it doesn’t work that way. If the TCDS says it is certified /approved for 7 seats, than it is authorized for seven seats.

Again, you have to get into the reference, as some PA32s are certified for 7, some only for 6 and some are approved for seven only after conversion.

Just like with LSAs, you can’t take two seats out of a 4 seat airplane and say, look I’m legal to fly sport pilot.




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The same argument could be made for those who put three children in the back seats of Cessnas or Pipers. Still authorized to carry 4 (I believe, haven't looked at the type cert), but you can have 5 in there. Does the FAA differentiate between children and adults on the type cert? I still do a second class medical, so no dog in this fight other than I DO own a PA32R...
 
You're saying that all the FAA cares about is the designed max, not what the aircraft is actually capable of. The airplane is only configured to carry 2 people because all the seats were removed, it could carry 7 and therefore it's authorized to carry 7. But the rules only authorize it carry 2 because of the seat belt rules. So it's only authorized to carry 2, but it's authorized to carry 7.
 
bflynn said:
You're saying that all the FAA cares about is the designed max, not what the aircraft is actually capable of. The airplane is only configured to carry 2 people because all the seats were removed, it could carry 7 and therefore it's authorized to carry 7. But the rules only authorize it carry 2 because of the seat belt rules. So it's only authorized to carry 2, but it's authorized to carry 7.
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That's what the FAA has said, yes. Stupid? Yes. A mis-interpretation of the word "authorized," as it's used in this context? Yes.
 
bradg33 said:
The Light Sport rules, as they relate to seating capacity, do make reference to the aircraft's "certification." The FAA's (well, Congress') use of the word "authorized" in the Basic Med rules is what makes it different. An aircraft can be certified to seat 8 people, but in order to actually be "authorized" to carry 8 occupants it has to have 8 seats installed and 8 seat belts (save for sky diving and rules regarding kids). In other words, authorized and certified don't mean the same thing.
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Where is this definition of "authorized" found?
 
Lindberg said:
Where is this definition of "authorized" found?
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I believe he is an attorney, so he may be referring to the way the term is usually interpreted by judges.
 
So has anyone seen this new STC?
 
bradg33 said:
In the FAA's "guidance" on BasicMed.

https://www.faa.gov/documentLibrary/media/Advisory_Circular/AC_68-1A.pdf (Section 5.1.2).

https://www.faa.gov/news/updates/media/final_rule_faa_2016_9157.pdf (see page 19)
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What I could find in both of those suggest that authorized and certificated mean the same equivalent with respect to aircraft. In fact, the AC says, "For type certificated aircraft, the aircraft’s design approval would authorize the number of occupants the aircraft may carry and would contain the maximum certificated takeoff weight." I might have misunderstood, but I thought you said they mean different things.
 
If they meant exactly the same thing, why would there be two different words? Common sense, and an understanding of what the words mean, tells us that certified is broader than authorized. Like I mentioned above, an airplane can be certified to carry 8 passengers, but it's not authorized to do so unless it has 8 seats and seat belts. An airplane can be certified to fly at FL350, but it's not authorized to do so unless it otherwise meets RVSM criteria. Further, an airplane can be certified to fly at 6,000 pounds but be specially authorized to fly at 7,000 pounds under a ferry permit. The words don't mean the same thing.
 
Any word on the STC from the Facebook group?
 
Anything? How's about the name of the group working on it?
 
Brad Z said:
Yep, doesn't mean it makes sense though. Over the last few years the FAA has been shifting to performance based rulemaking, focusing on outcome. An aircraft certified with 7 seats being flown with 6 occupants is no more of a hazard then an aircraft certified for 6 seats being flown with 6 occupants.
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Couldn't a 337 make the aircraft legal for BasicMed? Although it's a different situation, NTSB comments below seem to make that assertion.

Does anyone recall the Commander 690B crash out of Falcon Field a few years ago? The seatbelt at the convertible lavatory seat was removed, apparently an attempt to avoid the requirement that six seat twin turbine aircraft have TAWS installed.

"The NTSB said the airplane's nonairworthy condition was more a paperwork issue and that there is no indication of any mechanical problems. However, the Board noted the airplane was not equipped with TAWS as required by FAA regulations, but only because the seatbelt of its sixth seat, a belted lavatory, was removed by the previous owner.

The FAA noted that the change was never approved or documented through the Form 337 process. Whether the seatbelt was removed solely to skirt the TAWS regulation is unknown, but that was the effect
 
Unit74 said:
Any word on the STC from the Facebook group?
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I don't think you need it? If you read a few posts up, the FAQ on the FAA's website says the aircraft can be flown under basic med as long as the optional 7th seat is not installed.
 
dell30rb said:
I don't think you need it? If you read a few posts up, the FAQ on the FAA's website says the aircraft can be flown under basic med as long as the optional 7th seat is not installed.
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Read it again (the FAQ linked in post #15).

It all depends on which specific model of PA32. Some can be flown basic Med without the 7th seat while others cannot. The FAQ points out that there are 14 models of PA32 on the Type Certificate. Some can be flown basic med, while some cannot. Need to look at it to see which one applies.
 
You have to look further than the type certificate. Most of the models can be certificated either way. You need to look at the particular aircraft. If it came from the factory with the seventh seat, it is not legal for basic med even if you yank out the seventh seat. If it came as a 6 seater and was modded to seven seats afterward, you can likely undo it to make it OK.
 
flyingron said:
You have to look further than the type certificate. Most of the models can be certificated either way. You need to look at the particular aircraft. If it came from the factory with the seventh seat, it is not legal for basic med even if you yank out the seventh seat. If it came as a 6 seater and was modded to seven seats afterward, you can likely undo it to make it OK.
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Mine is a 1982 club seating Saratoga SP. It has never had more than 6 seats, and do not think it was even an option on the plane. When I look at the FAA registration it lists the plane as a seven seater. So I anticipate having an issue with basic med ( although I have and plan to keep my 3rd medical), because you know, the government.

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dell30rb said:
I don't think you need it? If you read a few posts up, the FAQ on the FAA's website says the aircraft can be flown under basic med as long as the optional 7th seat is not installed.
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Do you work for the FAA and will you put that on a formal letterhead?

"The Piper PA-32R-300 (Lance), Piper PA-32RT-300 (Lance II), PA-32RT-300T (Turbo Lance II), PA-32R-301 (Saratoga SP), PA-32R-301T (Turbo Saratoga SP), PA-32-301 (Saratoga), and PA-32-301T (Turbo Saratoga) are authorized to be equipped with 7 seats. Although the center seats may be removed and replaced by Optional Club Seats to carry 6 occupants and some aircraft are also authorized for an unmodified 6 seat configuration, all these aircraft are authorized to carry more than 6 occupants without further modification and therefore may not be operated under BasicMed. These aircraft may only be operated under BasicMed pursuant to the issuance and inclusion in their type design of a Supplemental Type Certificate (STC) that restricts the aircraft to 6 seats."
 
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