Flying with the rear seat removed

[Keith Lane]

What paperwork would be necessary for flying a C-172 with the rear seat removed. I ask for two reasons. W/B? Mechanics signoff? FSDO dispensation?
I'd like to remove it for some maintenance on the seat it self and want to fly it home after dropping the seat off.
Also I'd like to carry a bukly, but not terribly heavy (75lbs or so, and properly restrained) Item to a friend in Fla while it's out.
inquiring mind wants to know.
Thanks

 

[gismo]

What paperwork would be necessary for flying a C-172 with the rear seat removed. I ask for two reasons. W/B? Mechanics signoff? FSDO dispensation?
I'd like to remove it for some maintenance on the seat it self and want to fly it home after dropping the seat off.
Also I'd like to carry a bukly, but not terribly heavy (75lbs or so, and properly restrained) Item to a friend in Fla while it's out.
inquiring mind wants to know.
Thanks

AFaIK, a private pilot is allowed to remove and re-install seats as long as no major structures are involved. You should, of course make and sign a log entry. AFaIK, to fly without them would only require that you make a W&B calculation.

 

[inav8r]

Isn't there an airworthy issue if it's the A/C is missing equipment listed on the equipment list? Or is that part 135 only?

 

[Tom-D]

AFaIK, a private pilot is allowed to remove and re-install seats as long as no major structures are involved. You should, of course make and sign a log entry. AFaIK, to fly without them would only require that you make a W&B calculation.

The C-172 rear seat comes out with nuts and bolts, it is not made to be removed by a Pilot.

It requires removal by an A&P and a new W&B. and a 337 for a major mod to the airframe.

 

[Ed Guthrie]

The C-172 rear seat comes out with nuts and bolts, it is not made to be removed by a Pilot.

It requires removal by an A&P and a new W&B. and a 337 for a major mod to the airframe.

Just to clarify a bit, the above is probably quite true for the C172 (I defer to Tom who would know a Cessna much better than I would) but nuts and bolts installation is not necessarily the limiting criteria in all cases with respect to whether or not removing a rear seat is a pilot legal activity. The Mooney M20J rear seat back is also held in place with nuts & bolts, but per the POH it may be removed by the pilot if so desired.

 

[Keith Lane]

Just to clarify a bit, the above is probably quite true for the C172 (I defer to Tom who would know a Cessna much better than I would) but nuts and bolts installation is not necessarily the limiting criteria in all cases with respect to whether or not removing a rear seat is a pilot legal activity. The Mooney M20J rear seat back is also held in place with nuts & bolts, but per the POH it may be removed by the pilot if so desired.

I have removed the seat before, to assist in the installation of a new carpet set, and to facilitate the installation of rear passenger intercom connections, cable runs for glideslope receiver, etc., just never left the ground like that for fear of just such news as I'm hearing now. (Mechanical stuff is my life, so to speak.) It has 4 (.25 inch I think) bolts holding it down. A 337 ?? How hard would that be to get? How do you get one for a one time flight? (OK two, I have to get it home.)

WOW.....​

 

[Ed Guthrie]

I have removed the seat before, to assist in the installation of a new carpet set, and to facilitate the installation of rear passenger intercom connections, cable runs for glideslope receiver, etc., just never left the ground like that for fear of just such news as I'm hearing now. (Mechanical stuff is my life, so to speak.) It has 4 (.25 inch I think) bolts holding it down. A 337 ?? How hard would that be to get? How do you get one for a one time flight? (OK two, I have to get it home.)

WOW.....​

A couple of things. First, with respect to the Mooney M20J, per the POH the seat back may be removed by the pilot and the aircraft flown that way. The POH provides weight & balance data as well as directions as to how to remove the seat back.

Second, with respect to obtaining a 337, even if it is a one time event I'd approach it as an operating change. IOW, I would try to build a 337 allowing the pilot to remove/reinstall (including W&B data and removal/installation instructions) rather than simply remove this one time (or permanently). Tom D. will probably give you the exact method required, but I would simply take the problem to my local maintenance shop/IA and ask him what could be done.

 

[AirBaker]

Do you really need an A&P? You're allowed to do 'minor' work to your plane as a Private Pilot. I'd say just remove it and recalculate the W&B minus the missing seat.

 

[Jeff Oslick]

Do you really need an A&P? You're allowed to do 'minor' work to your plane as a Private Pilot. I'd say just remove it and recalculate the W&B minus the missing seat.

I, too, thought that if the rear seat is not listed as required equipment it could be removed/reinstalled by the owner under the provisions of Part 43, provided the POH provides detail needed to adjust the W&B, and the owner/operator adjusts the W&B calculations to reflect the change, and the removal/reinstallation meets the other criteria below. If the seat just bolts to brackets on the floor, I don't see why this would be considered disassembly of a primary structure or operating system.

Jeff


(c) Preventive maintenance. Preventive maintenance is limited to the following work, provided it does not involve complex assembly operations:

(15) Replacing seats or seat parts with replacement parts approved for the aircraft, not involving disassembly of any primary structure or operating system.

 

[PoAdeleted5]

Seats are tricky. On some aircraft, they are intended to be removable by the pilot/operator. On others, they are not. If the POH doesn't say you can, then most likely, you can't do it yourself.

If it requires a new W&B to be calculated, that's not going to be an option under owner maintenance items.

 

[poadeleted20]

Without a C-172 equipment list in front of me, I can't give a "for sure" answer.

However, if the rear seat is listed as an S-suffix item, the aircraft may be flown with it removed merely by following the steps in 14 CFR 91.213(d). Further, based on my reading of paragraph (c)(11) of Appendix A to Part 43, a pilot may remove and replace seats to facilitate the repair of upholstery (since the seats are not "primary structure"). One should, however, have a C-172 maintenance manual handy to use as a reference for the process of removing/replacing the seat. (I keep an AA-5-series maintenance manual in my hangar for just such instances, as well as for reference by visiting A&P's as needed.)

The pilot removing/replacing the seat would have to note the removal/replacement in the airframe logs, citing the above paragraph as his authority and the maintenance manual as his reference. He would also use the weight/arm info from the equipment list to make appropriate modifications to the empty weight/arm of the aircraft in his W&B computations for flights with the seat removed. And, of course, the pilot would have to be sure that at most only two people were in the plane when it is being operated.

If the rear seat is an R-item, flight is prohibited with it removed, but since I know for sure that the co-pilot seat in a C-152 is an S-item (just covered that on a Pvt oral prep last week), I strongly doubt that the rear seat of a C-172 is not the same.

 

[Ed Guthrie]

Without a C-172 equipment list in front of me, I can't give a "for sure" answer.

However, if the rear seat is listed as an S-suffix item, the aircraft may be flown with it removed merely by following the steps in 14 CFR 91.213(d).

The '79 C172 rear seat is an S/O item (one piece back/two piece back).

The difference and important point is whether or not the POH authorizes the pilot to remove without creating a new aircraft W&B (decidedly NOT a pilot allowed item). The Mooney POH does. I don't see a similar section in the Cessna POH.

 

[poadeleted20]

The '79 C172 rear seat is an S/O item (one piece back/two piece back).

The difference and important point is whether or not the POH authorizes the pilot to remove without creating a new aircraft W&B (decidedly NOT a pilot allowed item). The Mooney POH does. I don't see a similar section in the Cessna POH.

You need not create a new W&B -- you need only use the equipment list data to make appropriate computations when you do your W&B for the flight with the seat removed. This is standard for any and all flight with any equipment temporarily removed and appropriately placarded. I guess y'gotta put a sticker on the floor "Rear Seat Removed -- Do Not Sit Here."

 

[Ed Guthrie]

You need not create a new W&B -- you need only use the equipment list data to make appropriate computations when you do your W&B for the flight with the seat removed."

While I suspect you may be correct, I think you need a regional counsel opinion before you offer that advice. Is "removed for pilot convenience" legally synonymous with "inoperable"? If not, pray tell, what condition would make a seat "inoperable"?

§ 91.213 Inoperative instruments and equipment.

(d) Except for operations conducted in accordance with paragraph (a) or (c) of this section, a person may takeoff an aircraft in operations conducted under this part with inoperative instruments and equipment without an approved Minimum Equipment List provided -
(3) The inoperative instruments and equipment are -
(i) Removed from the aircraft,

 

[Jeff Oslick]

A tale from the dark side...

http://www.ntsb.gov/ntsb/brief.asp?ev_id=20001206X01822&key=1

This part of the full narrative is what is most interesting to review: (I would add that my guess is an aft-CG condition is the most likely key factor here, not an overweight condition).

ADDITIONAL INFORMATION

Weight and Balance

According to FAA Advisory Circular AC-195-2C, titled Sport Parachute Jumping, it stated:

"Installation and removal of equipment must be handled in accordance with the applicable sections of FAR Part 43. The original alteration to the jump configuration is required to be performed by an appropriately certificated person and recorded in the aircraft records. The equipment list and weight and balance data are required to be revised to show both the jump configuration and the standard configuration."

According to Mr. Printz, all non-essential equipment was removed from N1124V prior to the jump flight. This equipment was examined in a nearby hanger. The passenger door, and the front and rear seats were examined and weighed. Also examined were records, logs, charts, papers and miscellaneous items. The most recent weight and balance form was dated February 22, 1992. No computations indicating a parachute jump configuration were found. Calculations for the removal of the passenger door, and the front and rear seats, adjusted the weight and balance as follows:

February 1992 empty weight 1632 pounds (lbs) minus front passenger seat 23 lbs at C.G. station 37 minus front door 24 lbs at C.G. station 37 minus rear seat 22 lbs at C.G. station 73

The revised airplane empty weight would be 1,563 lbs, with a revised moment of 56973.

The maximum allowable takeoff weight for N1124V was 2,550 pounds (lbs). Using 27 lbs for each jumper's parachute and a 15 lbs parachute for the pilot, the weight and balance computed as follows:

Empty Weight 1563 lbs Pilot (228+15) 243 Jumper (180+27) 207 Jumper (175+27) 202 Jumper (200+27) 227 Fuel 5/8 full=30.6 gallons 184 ======== Total Takeoff Weight 2626

According to the Pilot's Operating Handbook for N1124V, the aft center of gravity (C.G.)limit, at it's maximum allowable gross weight, was 47.3 inches aft of the Datum. Two C.G. ranges were computed for N1124V at takeoff. Both utilized the two forward seats for the pilot and one jumper. The best C.G. scenario places both of the other jumpers in the vicinity of the rear passenger seat. The worst scenario places one jumper in the vicinity of the rear seat and the other in the vicinity of the child seat area. The best C.G. computed to 45.3 inches, and the worst C.G. computed to 47.2 inches.

FAA Waiver and Operating Limits with door removed.

The Cessna 172 is listed on a chart in the FAA Advisory Circular AC-105-2C, that states, "Aircraft that may be operated with one cabin door removed." A FSDO that issues a waiver uses this chart to determine if the airplane is eligible for the blanket waiver. Several of the airplanes listed on the chart cite an applicable supplemental type certificate number required to be applied to the airplane. There are also footnotes that indicate if there is a procedure in the aircraft flight manual supplement or the aircraft pilot operating handbook. The Cessna 172 listing has none of these. According to Martha Lunken, an FAA Inspector at the Cincinnati Flight Standards District Office (FSDO), a waiver was issued to the Mad River Airport on July 7, 1993, to operate N1124V with the door removed; however, the FSDO was unable to locate their copy.

The waiver is a form with blank spaces for the make and model of airplane, and the purpose of the flight. The form has pre-printed limits that are then applied to the stated airplane.

Operation of the 172 with the door removed is not discussed in the Cessna Pilot's Operating Handbook. According to the Cessna Aircraft Company, there are no records of any tests relating to the operation of the R172K with the cabin door removed.

AC-105-2C was initiated by the FAA office of Flight Standards Service (AFS-340), Washington, D.C. AFS-340 was contacted to obtain information relative to the testing, or certification of the Cessna 172 for operation with one door removed. Mr. Ralph Carr of AFS-340 stated, they had no documents on file in their office relative to the approval of the Cessna 172.

Additional FAA offices contacted included Airworthiness Certification Service AIR-230 in Washington, D.C., Aircraft Certification Office ACE-115A in Atlanta, Georgia, and ACE-115W in Wichita, Kansas. None of the offices had any information relative to the Cessna 172 listing as certified for operation with one door removed.

 

[Tom-D]

While I suspect you may be correct, I think you need a regional counsel opinion before you offer that advice. Is "removed for pilot convenience" legally synonymous with "inoperable"? If not, pray tell, what condition would make a seat "inoperable"?

I would suggest that any Cessna seat that does not meet the requirements of the Seat track AD or proper installation would be "inoperable"

In several law suits Cessna has declared that their seats are structure. in the famious seat track AD the seat frame is described as structure.

In Atlee Dodge's attempt to gain STC for their jump seats, The FAA required they gain structural engineering approval to modify the airframe.

And to top it off, the POH of the 172 (any model), does not give the option of rear seat removed,

BUT it does give the pilot the option of "0" weight in that position.

Again every time the FAA has been required to get involved, they have sided with Cessna, "seats are structure" after all, the seat belts for the back seat are attached to the seat frame, want to talk about removal of seat belts? lets talk about another 337.

we must remember, Cessna nearly lost the company over a seat track, You want the back seat out? you better have a A&P do it, and return it to service with a new weight and balance, or your insurance is not worth the stamp on the envelop you mailed the check in.

 

[Tom-D]

Isn't there an airworthy issue if it's the A/C is missing equipment listed on the equipment list? Or is that part 135 only?

Seats are not on the 172 equipment list, they are a part of the fuselage assembly parts list, see the 172 IPB, removing them is in the same catagory as removing any skin panel.

 

[Tom-D]

Without a C-172 equipment list in front of me, I can't give a "for sure" answer.

However, if the rear seat is listed as an S-suffix item,

Most 172 operators do not operate on a minimum equipement list, it's type certificate, and IPB, what's off the assembly line is what you fly with.

part 135 operators MAY have a required minumum equipment list, maybe not.

 

[Ed Guthrie]

Seats are not on the 172 equipment list, they are a part of the fuselage assembly parts list, see the 172 IPB, removing them is in the same catagory as removing any skin panel.

Now mind you, I don't fully subscribe to Ron L's "Inoperative Equipment" FAR allows removal theory since I'm really not convinced that "inoperative" is synonymous with "undesired", and furthermore I don't find seat removal in the Cessna 172 POH so I'm somewhat suspicious that you may be correct regarding removal is taboo. However, if that is indeed the case then I suspect the reason may not be the one you have proposed above.

FWIW, I do find the rear seats listed on the C172N equipment list:

"Cessna 1979 Skyhawk (Model 172N) Information Manual"

"Equipment List" (Section 6)

Section E, "Cabin Accommodations"

Item #E-09S, "SEAT, REAR (ONE PIECE BACK CUSHION)"
Item #E-09O, "SEAT, REAR (TWO PIECE BACK CUSHION)"

According to the footnotes, "R" items are required for FAA certification, "S" items are standard equipment, "O" items are optional, and "A" items are optional in addition to the required and standard items.

The above two items are "S" and "O" respectively.

 

[poadeleted20]

Most 172 operators do not operate on a minimum equipement list, it's type certificate, and IPB, what's off the assembly line is what you fly with.

part 135 operators MAY have a required minumum equipment list, maybe not.

First, an MEL is another story -- in fact, I don't even know if there's a Master MEL for the C-172, but even if there is, the percentage of 172 operators with approved MEL's is probably very, very small -- everyone else uses the 91.213(d) procedure. And, as Ed notes, the seats are in the equipment list supplied with the aircraft, so the W&B change data are there along with notification that they are not "required" items. And the question of W&B is answered if you do the computations as described and keep a copy for the record.

As for "structure," the quoted reg says "primary structure" [emphasis added], and that's an important distinction. To say merely that the seats themselves are "structure" is not sufficient to remove them from the paragraph (c)(11) allowance, and I really doubt if even Cessna will say the seats are "primary structure," i.e., stuff which keeps the airplane from falling apart, especially given that C172's fly with seats out all the time as jump planes. We pilots routinely pulled the seats from our 182's, Aztecs, and C-401 for cargo flights under our 135 certificate with NO logbook documentation, and the inspectors didn't think anything of it.

Finally, we go through this all the time on practical test orals. Both the local FSDO inspectors and the DPE's agree on the interpretation I gave above as being the "right" answer. While one COULD go ask the RC, we're all very happy with the situation as it is, and feel no need to go further.

 

[Ed Guthrie]

Finally, we go through this all the time on practical test orals. Both the local FSDO inspectors and the DPE's agree on the interpretation I gave above as being the "right" answer. While one COULD go ask the RC, we're all very happy with the situation as it is, and feel no need to go further.

The above philosophy works fine until one of your ex-students flies into another FSDO district and meets an inspector who read the preamble to 91.213 and the final rule, and has decided that the intent of the rule was to allow pilots to proceed with minor equipment inop, and that the intent of the rule was not to allow pilots to make aircraft equipment changes without the appropriate w&b modifications through an appropriate IA signature. At that point the student is royally hosed.

As you often note, caveat aviator.

 

[poadeleted20]

The above philosophy works fine until one of your ex-students flies into another FSDO district and meets an inspector who read the preamble to 91.213 and the final rule, and has decided that the intent of the rule was to allow pilots to proceed with minor equipment inop, and that the intent of the rule was not to allow pilots to make aircraft equipment changes without the appropriate w&b modifications through an appropriate IA signature. At that point the student is royally hosed.

As you often note, caveat aviator.

Point taken -- question has been sent to the EA RC.

 

[waldo]

This brings up another fine question . . . . I see a few pilots that load there plane (C-172) down with plywood and such for the hanger that is in the middle of nowhere (the "C" stands for Cessna not Cargo ). How in the heck can you do a W&B on a few pieces of plywood? Some of the wieght is in the front and some is in the rear. I've even seen it sticking out the window. Go figure!

 

[Jeff Oslick]

This brings up another fine question . . . . I see a few pilots that load there plane (C-172) down with plywood and such for the hanger that is in the middle of nowhere (the "C" stands for Cessna not Cargo ). How in the heck can you do a W&B on a few pieces of plywood? Some of the wieght is in the front and some is in the rear. I've even seen it sticking out the window. Go figure!

Obviously having it stick out of the plane isn't good...

But to determine the W&B on something like a 2x4, you find its total weight, and presuming it's an evenly cut piece of wood, you should be able to determine the arm based on where in the plane the mid-length point of the piece is located (the center of mass of the wood itself).

Jeff

 

[poadeleted20]

Quote:
Originally Posted by Ed Guthrie
The above philosophy works fine until one of your ex-students flies into another FSDO district and meets an inspector who read the preamble to 91.213 and the final rule, and has decided that the intent of the rule was to allow pilots to proceed with minor equipment inop, and that the intent of the rule was not to allow pilots to make aircraft equipment changes without the appropriate w&b modifications through an appropriate IA signature. At that point the student is royally hosed.

As you often note, caveat aviator.

Point taken -- question has been sent to the EA RC.

And the answer is...

Mr Levy:

The pilot may use the weight/arm/moment data from the aircraft's equipment list to show the absence of the component on the weight and balance sheet for the aircraft. The pilot must comply with the requirements of Part 91.213, Part 43 Appendix A para C and Part 43.9 (a). If you have any other concerns feel free to contact me @ (781) 238-7234.

Roger Fortune Jr.
ANE-230M
(781) 238-7234

Yes, I know, he's not AGC-200, but his answer came back via the EA RC.

 

[Ed Guthrie]

Quote:
Originally Posted by Ed Guthrie
The above philosophy works fine until one of your ex-students flies into another FSDO district and meets an inspector who read the preamble to 91.213 and the final rule, and has decided that the intent of the rule was to allow pilots to proceed with minor equipment inop, and that the intent of the rule was not to allow pilots to make aircraft equipment changes without the appropriate w&b modifications through an appropriate IA signature. At that point the student is royally hosed.

As you often note, caveat aviator.

And the answer is...

Mr Levy:

The pilot may use the weight/arm/moment data from the aircraft's equipment list to show the absence of the component on the weight and balance sheet for the aircraft. The pilot must comply with the requirements of Part 91.213, Part 43 Appendix A para C and Part 43.9 (a). If you have any other concerns feel free to contact me @ (781) 238-7234.

Roger Fortune Jr.
ANE-230M
(781) 238-7234

Yes, I know, he's not AGC-200, but his answer came back via the EA RC.

Ron, would you mind posting scanned images of both the question letter and the reply letter? I occasionally fly the Mooney with the rear seat removed via the POH wording. I would like to send Mr. Fortune the POH page (copy) along with your letter & his response and ask him if the 43.9(a) entry is required given that the POH seems to declare removing the seat to be a simple W&B calculation (flight, no document) item.

OTOH, if he replies to my inquiry with a statement that the 43.9 entry is required even for the Mooney I would like to keep the two letters in the aircraft records just in case...

 

[poadeleted20]

Ron, would you mind posting scanned images of both the question letter and the reply letter?

No can do -- all done by email. If you want a real letter, you'll have to write or email Mr. Fortune. His email is roger.fortune@faa.gov. You can also reach the EA Asst RC who handled this stephen.brice@faa.gov. Here's the original question posed to the EA RC:

"A question has arisen regarding compliance with 91.213(d). If a pilot removes an inoperative or nonrequired item as 'preventive maintenance' under the authority of paragraph (c) of Appendix A to Part 43 (e.g., removal of a tray-mounted radio), does a full official updated weight and balance sheet have to be made for the aircraft and signed by an A&P, or may the pilot simply use the weight/arm/moment data from the aircraft’s equipment list to allow for the absence of the component when doing the normal preflight W&B computations?"




The full response was already posted. However, I think it's pretty clear that he is saying an entry in the log book is required to document removal/replacement of any item. I would so log it, with the appropriate section of 43A(c) referenced as authority for the work and my signature under the entry. The only question at issue was whether the work required a new W&B sheet signed by an A&P or just the pilot making the appropriate adjustment based on equipment list weight/arm data for the removed item.

 

[Stache]

To answer the question about removing and operating the aircraft with the rear seat removed. Yes you can, BUT you will need a FAA form 337 Major alteration field approved from your local FSDO before doing it.

This can be accomplished by submitting the request and having the FSDO stamp and sign block 3 off before the seat is removed. Doing this will change the type certificate and weight and balance this is why the field approval is required.

If you want to haul equipment as long as you are with in the weight and balance and it is secured properly you should be okay with a field approval. However discuss this with your FSDO before doing it.

OR

You could get a Special Flight Permit (Ferry Permit) to remove the seat for maintenance day VFR direct for a one time flight and one for the flight back. Again contact your local FSDO. This will require a A&P to determine the aircraft is safe for flight and give you a temp weight and balance.

Stache

 

[Tom-D]

To answer the question about removing and operating the aircraft with the rear seat removed. Yes you can, BUT you will need a FAA form 337 Major alteration field approved from your local FSDO before doing it.

This can be accomplished by submitting the request and having the FSDO stamp and sign block 3 off before the seat is removed. Doing this will change the type certificate and weight and balance this is why the field approval is required.

If you want to haul equipment as long as you are with in the weight and balance and it is secured properly you should be okay with a field approval. However discuss this with your FSDO before doing it.

OR

You could get a Special Flight Permit (Ferry Permit) to remove the seat for maintenance day VFR direct for a one time flight and one for the flight back. Again contact your local FSDO. This will require a A&P to determine the aircraft is safe for flight and give you a temp weight and balance.

Stache

Well, That's 2 FSDO's that agree, you and my PMI.

 

[poadeleted20]

To answer the question about removing and operating the aircraft with the rear seat removed. Yes you can, BUT you will need a FAA form 337 Major alteration field approved from your local FSDO before doing it.

I'm curious to know how you conclude that removal of the rear seat is a "major alteration." I've looked through the list in paragraph (a)(1) of Appendix A to Part 43, and I don't see anything in that list that seems to apply.

(a) Major alterations—(1) Airframe major alterations. Alterations of the following parts and alterations of the following types, when not listed in the aircraft specifications issued by the FAA, are airframe major alterations:

(i) Wings.

(ii) Tail surfaces.

(iii) Fuselage.

(iv) Engine mounts.

(v) Control system.

(vi) Landing gear.

(vii) Hull or floats.

(viii) Elements of an airframe including spars, ribs, fittings, shock absorbers, bracing, cowling, fairings, and balance weights.

(ix) Hydraulic and electrical actuating system of components.

(x) Rotor blades.

(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.

(xii) Changes to the basic design of the fuel, oil, cooling, heating, cabin pressurization, electrical, hydraulic, de-icing, or exhaust systems.

(xiii) Changes to the wing or to fixed or movable control surfaces which affect flutter and vibration characteristics.

 

[JohnSBA]

I've just read this entire thread for a second time, and was still not clear whether the pilot can remove the rear seat assembly (or at least the 1-piece seat back) and note it in log and w/b (with a post-it). I was also wondering whether there's been any change in the regs (or more likely their interpretation) since June '05 when the last post was made. My impression is that back then some FAA people ruled it ok, and others said it requires their approval.

We're getting ready to fly our 1983 172Q to Oshkosh and it would be very helpful to know for sure if I can pull the seat, log it, and put a post-it on the w/b sheet to show the new numbers.

Question: After looking it up with the help of reg numbers cited in this thread, I've come to the conclusion that pilots can remove the C-172 rear seat and fly without it if we don't try to seat passengers on the floor. Is this accurate?

*References:
I looked on http://rgl.faa.gov/Regulatory_and_Guidance_Library/rgFAR.nsf/0/ac9bed30f1d032b9852566ab006bc89c!OpenDocument and found this [my notes in cited regs underlined inside square brackets] (my emphasis added):
"Part 43 Appendix A--Major Alterations, Major Repairs, and Preventive Maintenance

• (a) Major alterations-- [does not seem to apply]
• (b) Major repairs-- [does not seem to apply]
• (c) Preventive maintenance. ...

(11) Repairing upholstery and decorative furnishings of the cabin, cockpit, or balloon basket interior when the repairing does not require disassembly of any primary structure or operating system or interfere with an operating system or affect the primary structure of the aircraft.
...
​

(30) The inspection and maintenance tasks prescribed and specifically identified as preventive maintenance in a primary category aircraft type certificate or supplemental type certificate holder's approved special inspection and preventive maintenance program when accomplished on a primary category aircraft provided:
(i) They are performed by the holder of at least a private pilot certificate issued under part 61 who is the registered owner (including co-owners) of the affected aircraft and who holds a certificate of competency for the affected aircraft ..."
​

[So apparently, pilots are authorized to remove the seat.]

I then looked at http://rgl.faa.gov/Regulatory_and_Guidance_Library/rgFar.nsf/FARSBySectLookup/91.213
"Sec. 91.213
[note: (a) through (c) apparently don't apply to removing the rear seat]

...
(d) Except for operations conducted in accordance with paragraph (a) or (c) of this section, a person may takeoff an aircraft in operations conducted under this part with inoperative instruments and equipment without an approved Minimum Equipment List provided--
​

(1) The flight operation is conducted in a--[nonturbine-powered airplane (e.g. C-172)]...
​

(2) The inoperative instruments and equipment are not--
(i) Part of the VFR-day type certification instruments and equipment prescribed in the applicable airworthiness regulations under which the aircraft was type certificated;
(ii) Indicated as required on the aircraft's equipment list, or on the Kinds of Operations Equipment List for the kind of flight operation being conducted;
(iii) Required by Sec. 91.205 ["Equipment, Instrument, and Certificate Requirements" - does not mention rear seat requirement] or any other rule of this part for the specific kind of flight operation being conducted; or
(iv) Required to be operational by an airworthiness directive; and
​

(3) The inoperative instruments and equipment are--
(i) Removed from the aircraft, the cockpit control placarded, and the maintenance recorded in accordance with Sec. 43.9 of this chapter; or
(ii) Deactivated and placarded "Inoperative." If deactivation of the inoperative instrument or equipment involves maintenance, it must be accomplished and recorded in accordance with part 43 of this chapter; and
​

(4) A determination is made by a pilot, who is certificated and appropriately rated under part 61 of this chapter, or by a person, who is certificated and appropriately rated to perform maintenance on the aircraft, that the inoperative instrument or equipment does not constitute a hazard to the aircraft. An aircraft with inoperative instruments or equipment as provided in paragraph (d) of this section is considered to be in a properly altered condition acceptable to the Administrator. ..."
​

So apparently pilots can determine that it's ok to fly without the seat, provided it's logged and perhaps placarded.

Finally, I checked this: http://rgl.faa.gov/Regulatory_and_Guidance_Library/rgFar.nsf/FARSBySectLookup/43.9
"Sec. 43.9

(a) Maintenance record entries. Except as provided in paragraphs (b) and (c) of this section, each person who maintains, performs preventive maintenance, rebuilds, or alters an aircraft, airframe, aircraft engine, propeller, appliance, or component part shall make an entry in the maintenance record of that equipment containing the following information:
​

(1) A description (or reference to data acceptable to the Administrator) of work performed.
(2) The date of completion of the work performed.
(3) The name of the person performing the work if other than the person specified in paragraph (a)(4) of this section.
(4) If the work performed on the aircraft, airframe, aircraft engine, propeller, appliance, or component part has been performed satisfactorily, the signature, certificate number, and kind of certificate held by the person approving the work. The signature constitutes the approval for return to service only for the work performed. ..."
​

So apparently the pilot logs it in this manner, and adds another log entry (and removes the optional w/b post-it) when the seat goes back in. I say optional presuming that the pilot is always responsible for w/b before flight and will probably want the convenience of the post-it as a starting point.

 

[Henning]

Well, if it's illegal to pull and replace the seat as required for various missions, there's a heck of a lot of people breaking the law on a regular basis.

 

[RotorAndWing]

I've just read this entire thread for a second time, and was still not clear whether the pilot can remove the rear seat assembly (or at least the 1-piece seat back) and note it in log and w/b (with a post-it). I was also wondering whether there's been any change in the regs (or more likely their interpretation) since June '05 when the last post was made. My impression is that back then some FAA people ruled it ok, and others said it requires their approval.

We're getting ready to fly our 1983 172Q to Oshkosh and it would be very helpful to know for sure if I can pull the seat, log it, and put a post-it on the w/b sheet to show the new numbers.

Question: After looking it up with the help of reg numbers cited in this thread, I've come to the conclusion that pilots can remove the C-172 rear seat and fly without it if we don't try to seat passengers on the floor. Is this accurate?

*References:
I looked on http://rgl.faa.gov/Regulatory_and_Guidance_Library/rgFAR.nsf/0/ac9bed30f1d032b9852566ab006bc89c!OpenDocument and found this [my notes in cited regs underlined inside square brackets] (my emphasis added):
"Part 43 Appendix A--Major Alterations, Major Repairs, and Preventive Maintenance

• (a) Major alterations-- [does not seem to apply]
• (b) Major repairs-- [does not seem to apply]
• (c) Preventive maintenance. ...

(11) Repairing upholstery and decorative furnishings of the cabin, cockpit, or balloon basket interior when the repairing does not require disassembly of any primary structure or operating system or interfere with an operating system or affect the primary structure of the aircraft.
...
​

(30) The inspection and maintenance tasks prescribed and specifically identified as preventive maintenance in a primary category aircraft type certificate or supplemental type certificate holder's approved special inspection and preventive maintenance program when accomplished on a primary category aircraft provided:
(i) They are performed by the holder of at least a private pilot certificate issued under part 61 who is the registered owner (including co-owners) of the affected aircraft and who holds a certificate of competency for the affected aircraft ..."
​

[So apparently, pilots are authorized to remove the seat.]

I then looked at http://rgl.faa.gov/Regulatory_and_Guidance_Library/rgFar.nsf/FARSBySectLookup/91.213
"Sec. 91.213
[note: (a) through (c) apparently don't apply to removing the rear seat]

...
(d) Except for operations conducted in accordance with paragraph (a) or (c) of this section, a person may takeoff an aircraft in operations conducted under this part with inoperative instruments and equipment without an approved Minimum Equipment List provided--
​

(1) The flight operation is conducted in a--[nonturbine-powered airplane (e.g. C-172)]...
​

(2) The inoperative instruments and equipment are not--
(i) Part of the VFR-day type certification instruments and equipment prescribed in the applicable airworthiness regulations under which the aircraft was type certificated;
(ii) Indicated as required on the aircraft's equipment list, or on the Kinds of Operations Equipment List for the kind of flight operation being conducted;
(iii) Required by Sec. 91.205 ["Equipment, Instrument, and Certificate Requirements" - does not mention rear seat requirement] or any other rule of this part for the specific kind of flight operation being conducted; or
(iv) Required to be operational by an airworthiness directive; and
​

(3) The inoperative instruments and equipment are--
(i) Removed from the aircraft, the cockpit control placarded, and the maintenance recorded in accordance with Sec. 43.9 of this chapter; or
(ii) Deactivated and placarded "Inoperative." If deactivation of the inoperative instrument or equipment involves maintenance, it must be accomplished and recorded in accordance with part 43 of this chapter; and
​

(4) A determination is made by a pilot, who is certificated and appropriately rated under part 61 of this chapter, or by a person, who is certificated and appropriately rated to perform maintenance on the aircraft, that the inoperative instrument or equipment does not constitute a hazard to the aircraft. An aircraft with inoperative instruments or equipment as provided in paragraph (d) of this section is considered to be in a properly altered condition acceptable to the Administrator. ..."
​

So apparently pilots can determine that it's ok to fly without the seat, provided it's logged and perhaps placarded.

Finally, I checked this: http://rgl.faa.gov/Regulatory_and_Guidance_Library/rgFar.nsf/FARSBySectLookup/43.9
"Sec. 43.9

(a) Maintenance record entries. Except as provided in paragraphs (b) and (c) of this section, each person who maintains, performs preventive maintenance, rebuilds, or alters an aircraft, airframe, aircraft engine, propeller, appliance, or component part shall make an entry in the maintenance record of that equipment containing the following information:
​

(1) A description (or reference to data acceptable to the Administrator) of work performed.
(2) The date of completion of the work performed.
(3) The name of the person performing the work if other than the person specified in paragraph (a)(4) of this section.
(4) If the work performed on the aircraft, airframe, aircraft engine, propeller, appliance, or component part has been performed satisfactorily, the signature, certificate number, and kind of certificate held by the person approving the work. The signature constitutes the approval for return to service only for the work performed. ..."
​

So apparently the pilot logs it in this manner, and adds another log entry (and removes the optional w/b post-it) when the seat goes back in. I say optional presuming that the pilot is always responsible for w/b before flight and will probably want the convenience of the post-it as a starting point.

Removal of the rear seat cannot be considered "preventive maintenance". It will require a logbook entry by an appropriately rated person (A&P) and a recalculation of the W&B also entered by the A&P.

If you need clarification contact your local FSDO.

 

[RotorAndWing]

Well, if it's illegal to pull and replace the seat as required for various missions, there's a heck of a lot of people breaking the law on a regular basis.

As long as the proper entries are made by the required person there's no issue.

No doubt some people see this as no big deal and just do it. Until they get a ramp inspection.

 

[Henning]

As long as the proper entries are made by the required person there's no issue.

No doubt some people see this as no big deal and just do it. Until they get a ramp inspection.

I'm talking about people pulling and replacing as needed with nothing but a simple W&B calculation change for that flight. If a pilot cant make that calculation, they wouldn't have been issued an Airman's Certificate of any level, it's completely basic stuff. Since it's not a permanent change, most people would not suspect it requires changing the W&B data sheet for the aircraft since after the weekend of hauling the camping gear and coolers in the back, they'll just bolt the back seats right back in again same as it ever was. Walk through the camping area at OSH and count how many 172s have the rear seat removed, then ask how many had it done by an A&P who filled a 337.... This is really kinda bordering on silly.

 

[SCCutler]

Well, I like the fact that my POH has calcs for W&B with one or both rear seats and third-row seats (if so-equipped) installed or removed. The seats remove without tools; one retaining pin holds in an aluminum limit on the seat track; remove each, and the seat slides right out, ba-da-boom.

 

[Yellowbird]

For what it's worth, the Cardinal owner's manual shows loading diagrams with CG arms for three configurations: front and back seats, front, back, and aux. (cargo area kiddy seat) seats, and front seats only.

The manual also states that the rear seat can be removed if desired, and gives loading limits and instructions on how to determine weight and balance for cargo carried in the aft cabin.

 

[RotorAndWing]

Well, I like the fact that my POH has calcs for W&B with one or both rear seats and third-row seats (if so-equipped) installed or removed. The seats remove without tools; one retaining pin holds in an aluminum limit on the seat track; remove each, and the seat slides right out, ba-da-boom.

As long as there is an approved procedure that can be referenced for that make/model aircraft you're good to go.

 

[RotorAndWing]

I'm talking about people pulling and replacing as needed with nothing but a simple W&B calculation change for that flight. If a pilot cant make that calculation, they wouldn't have been issued an Airman's Certificate of any level, it's completely basic stuff. Since it's not a permanent change, most people would not suspect it requires changing the W&B data sheet for the aircraft since after the weekend of hauling the camping gear and coolers in the back, they'll just bolt the back seats right back in again same as it ever was. Walk through the camping area at OSH and count how many 172s have the rear seat removed, then ask how many had it done by an A&P who filled a 337.... This is really kinda bordering on silly.

It maybe "silly and boring" to you,but during a ramp inspection if the FAA ASI sees a missing seat he may ask to see the approved documentation for performing the procedure. If you cannot produce this be prepared for the next step which may be very unpleasant.

 

[Bob Noel]

It maybe "silly and boring" to you,but during a ramp inspection if the FAA ASI sees a missing seat he may ask to see the approved documentation for performing the procedure. If you cannot produce this be prepared for the next step which may be very unpleasant.

I trust that the FAA ASI won't expect me to have the logs (with
the entries for seat removal and revised W & B in the aircraft.
And I trust that a valid W&B for the aircraft won't have to detail
all the stuff included/excluded from the W&B.