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

[Sinistar]

So lets say you have a 6 seater and never intended to haul more than 4. Will a insurance company lower the premiums if you have 2 seats removed and signed off by IA?

Maybe stick to piston single GA planes such as 206, 210, 6/260, 6/300, Lance, Bonanza, etc.

You would think they would treat it like a 4place then??

 

[Pilawt]

I inquired about that when I was shopping for a PA-32. With some companies there was a small discount, I'm thinking about $125 or so - not really enough to make the reduced utility worthwhile.

 

[luvflyin]

I inquired about that when I was shopping for a PA-32. With some companies there was a small discount, I'm thinking about $125 or so - not really enough to make the reduced utility worthwhile.

What would happen if you put the seats back in. Took 5 people and then crashed and hurt everybody. Would the insurance company pick 3 to settle with and not the other 2?

 

[Pilawt]

What would happen if you put the seats back in. Took 5 people and then crashed and hurt everybody. Would the insurance company pick 3 to settle with and not the other 2?

They might claim it was a material misrepresentation on the part of the insured and deny coverage altogether.

 

[hindsight2020]

They might claim it was a material misrepresentation on the part of the insured and deny coverage altogether.

Bingo. No different than auto claims when the vehicle is occupied by more than the listed occupancy per the manufacturer.

 

[Albany Tom]

Keep in mind that if you pull the back seat, you need a clean, dry, mouse-free place to store the seat until you sell the plane again. Otherwise you'll likely lose whatever amount you saved in insurance in the weird configuration. I don't think I'd remove the seat unless I had a reason to want the extra cargo space, and a cheap place to store the seat climate-controlled and pest free.

 

[Archer Jack]

On this subject, does anyone know much weight would I save by removing back seats from my PA28-181. I was thinking about removing them for trips to higher elevations during warm weather.

 

[texasclouds]

Yes, but you have to pinky swear to not put it back in. Or send pictures of the seats cut in half.

 

[Pilawt]

There has been a discussion on the PA-32 Facebook page recently, to the effect that one FSDO claims that you need an STC - not just a revised W&B - in order to take seats out of a PA-32. That FSDO is trying to push a violation against a PA-32 owner, and FAA counsel is deciding whether or not to pursue it.

It's nonsense, of course (Piper has been touting the easily-removable seats and various seating arrangements in the PA-32 since day one), but the owner has an attorney defending this FSDO action.

 

[Archer Jack]

Was the FAA out doing random ramp checks looking for unapproved seat removals and other egregious acts? Looks like a little extra nose up trim would take care of any potential problems with back seat removal (unless the owner's seats weighed 200 lbs. each). Just saying. I'm guessing the FAA would not be mollified if the weight of the removed seats was replaced by an equivalent amount of cargo, assuming, of course, that the guilty party did the necessary w&b.

 

[Bell206]

to the effect that one FSDO claims that you need an STC - not just a revised W&B - in order to take seats out of a PA-32.

FYI: to make the aircraft a "true" 4 seater from it's certified 6 seater designation (TCDS) it requires a major change to type design, i.e., an STC. Other wise the aircraft is still a legal 6 seater with 2 seats removed. Years ago some operators tried to beat the FAR seat based requirements (mx, attendants, etc) by simply removing a seat. At the old day job we had several STCs that would reduce a 13 pax helicopter down to 9 pax or 6 pax legally to streamline the mx requirements for certain operations.

 

[Stewartb]

My Cessna is a 6 seat airplane. I insure 4 seats. No big deal.

 

[SoonerAviator]

The bulk of the insurance cost is in the hull value. There isn't much of anything to be saved in insurance premiums by removing 2 seats of "potential liability".

 

[Pilawt]

I don't think Piper contemplated that an STC would be necessary to take advantage of these loading options.

 

[Archer Jack]

I'm not trying to get a discount on my insurance. Just wondered if anybody knew how much Piper Cherokee back seats weigh. Doesn't look like they should be more than 15-20 lbs. each but on a hot day at altitude that extra 40 lbs. or so might be nice to have removed.

 

[Archer Jack]

Sadly, mine is only a 181 so only 4 seats.

 

[luvflyin]

Bingo. No different than auto claims when the vehicle is occupied by more than the listed occupancy per the manufacturer.

Why am I having visions of a clown car? Anyway, I wonder if behind closed doors the insurance companies are going yeah, overload that car. Put those seats back in that plane. It would be like the Jackpot for them.

 

[Bell206]

I don't think Piper contemplated that an STC would be necessary to take advantage of these loading options.

And one is not needed per your loading schedule. In the context of the OP an STC would be needed to make it a permanent 4 seater. Nothing more.

 

[Bell206]

Just wondered if anybody knew how much Piper Cherokee back seats weigh.

Take one out and weigh it for an accurate weight. If you decide to pursue the seat removal route ask your local FSDO if you can get an LOA to perform the seat removal and EWB corrections. The LOA is more for the EWB side as its a minor alteration and normally requires an AP sign off. The LOA will allow you to sign it.

 

[schmookeeg]

My third row seats are 25.4lbs. I weighed them with a fish scale. I generated multiple "scenario" W/B documents for my plane using those and other numbers.

My insurer only offered like $110 discount (~4%?) for removal so I kept the 6 seat policy.

I did this with no STC. Can't wait for them to come revoke my A&P and Pilot certs. Also glad the FAA has fixed all other problems and has the bandwidth and resources to skewer a PA32 pilot over seat installations. Eesh.

 

[Pilawt]

And one is not needed per your loading schedule.

I agree with you. FSDO 19 apparently disagrees. From the Facebook posts by the attorney for the pilot against whom action is being taken:

The aviation safety inspector who started this whole thing has said that, in FSDO 19, they will enforce this policy against aircraft like the PA32 that can be used for charter of cargo, whenever they find them with the seats removed as they come in through Customs. I am not sure that this was an authorized statement of official FSDO policy.

The FAA attorney seems to have adopted the position that, unless there is an FAA approved “seating configuration” for every possible combination of seats being removed, it would require an STC (a 337 field approval will not do) to fly the aircraft without any of the seats in place (except the 7th seat which is an option in some models). We do not believe this to be an accurate statement of the law. We believe that all that is required, in an aircraft where the seats are designed to be removed easily, without tools, and where the manufacturer has provided the weight and moment arm for each seat and directed the pilots to make weight and balance calculations for seats removed, is that such weight and balance calculations actually be made by the pilot prior to flight. Of course, Part 91 does not require that the physical calculations be recorded and kept. But, in an abundance of caution, it would seem to be a very good idea to keep a written copy of the actual calculations you make for flight with whatever seats you have removed.

The owner of the aircraft has a house and a business in the Bahamas (the house was badly damaged in the last Hurricane). He takes supplies and materials with him in his aircraft. No compensation or hire at all. But the complainant thought that the aircraft, being loaded (in his words “to the gills”) “must” be being used for charter. The ASI put the N number on a watch list with Customs to try to catch the aircraft doing illegal charter. But there was no evidence of charter at all. So the ASI decided that the absence of the rear seats was an Airworthiness violation, even though there were two W&B forms in the aircraft — one for all seats installed; and the other with just the two front seats installed.​

 

[Archer Jack]

My third row seats are 25.4lbs. I weighed them with a fish scale. I generated multiple "scenario" W/B documents for my plane using those and other numbers.

My insurer only offered like $110 discount (~4%?) for removal so I kept the 6 seat policy.

I did this with no STC. Can't wait for them to come revoke my A&P and Pilot certs. Also glad the FAA has fixed all other problems and has the bandwidth and resources to skewer a PA32 pilot over seat installations. Eesh.

Thanks kindly for that information. Removing the back seats will be almost as good as removing one of my wife's suitcases on a high DA day. Cheers.

 

[tawood]

On this subject, does anyone know much weight would I save by removing back seats from my PA28-181. I was thinking about removing them for trips to higher elevations during warm weather.

Bench seat, or individual seats? On my PA28-140, they were individual seats. Removing them saved 17 lbs. I had multiple W&B made by my mechanic, because I also removed the wheel pants in the winter (so that total I was saving like 35 lbs). It does take a log book entry when they are removed/re-installed. I removed the seats more for cargo room than for weight (and the pants for snow covered runways)...fuel reductions saved much more weight than seats/wheel pants.

 

[schmookeeg]

Thanks kindly for that information. Removing the back seats will be almost as good as removing one of my wife's suitcases on a high DA day. Cheers.

Sorry, for context, this was the third row seats in my D55 -- but I suspect your PA28 seats are in that ballpark

 

[Sam D]

There has been a discussion on the PA-32 Facebook page recently, to the effect that one FSDO claims that you need an STC - not just a revised W&B - in order to take seats out of a PA-32. That FSDO is trying to push a violation against a PA-32 owner, and FAA counsel is deciding whether or not to pursue it.

It's nonsense, of course (Piper has been touting the easily-removable seats and various seating arrangements in the PA-32 since day one), but the owner has an attorney defending this FSDO action.

Was this just for taking the seats out or for flying under Basic Med? I think the latter has been more problematic because there is some language about "originally certified for 6 seats or less" or something along those lines. Apparently, just removing the 7th seat doesn't cut it.

 

[schmookeeg]

Was this just for taking the seats out or for flying under Basic Med? I think the latter has been more problematic because there is some language about "originally certified for 6 seats or less" or something along those lines. Apparently, just removing the 7th seat doesn't cut it.

Which is so weird, since I can think of very few aircraft that came with > 6 seats, are under 6000# MGW, and make sense to fly under 18000 MSL.

I think its the PA32 and the C207? I suppose there are oddballs, but I'd also expect that removing the 7th seat meets the spirit of Basic Med. I have no idea why they felt the need to add the "originally certified" language, but they clearly had these two in mind.

 

[Bell206]

FSDO 19 apparently disagrees.

Sounds more like a charter or a combination of issues than a simple seat issue. Regardless, the “approved” seating configuration debate has been going on for 20+ years with the cause mostly internal FAA issues and conflicting guidance. Long story short, at one time operators blocked available seats by seat uphostery color, placards, simple removal, removal by 337, and other similar methods to meet the lower maintenance requirements in Part 135 9 pax or less. Each previous method being “approved” by their local FSDO. Eventually, due to FAA personnel changes or aircraft movements into different areas, questions were being raised on these various enforcement differences. So the FAA head shed put out new guidance to quell all seat issues. Well that led to a whole new group of issues and as I recall after the 5th revision of that policy it was canceled. The current guidance is found in 8900.1 and states in order to change the type-certificate seating number an STC is required. Last I heard there was a proposed NPRM to remove the “type-certicate” from the seating number so that operators can use less stringent methods to meet any seat requirement for maintenance, etc.

 

[BryanAV8R]

Was this just for taking the seats out or for flying under Basic Med? I think the latter has been more problematic because there is some language about "originally certified for 6 seats or less" or something along those lines. Apparently, just removing the 7th seat doesn't cut it.

IIRC, AOPA (and maybe others) had a nominal cost STC that called for the removal of the 7th seat so that a basic med holder could legally fly, say, the Saratoga that had been originally certificated as a 7-place plane. Some may have more/more correct insight into whether this is real or my failing memory.

Found it:
https://www.aopa.org/news-and-media...stc-makes-more-piper-pa32s-basicmed-compliant

 

[Skyrys62]

The ASI put the N number on a watch list with Customs to try to catch the aircraft doing illegal charter. But there was no evidence of charter at all. So the ASI decided that the absence of the rear seats was an Airworthiness violation, even though there were two W&B forms in the aircraft — one for all seats installed; and the other with just the two front seats installed.

Sounds like a power trip..

 

[Archer Jack]

I believe Basic Med rules state that removal of a 7th seat does not qualify a plane. If the AC is capable of carrying 7 passengers in 7 seats it does not qualify under Basic Med.

 

[flyingron]

I don't think the insurance company is going to buy it. THey're going to base the premium based on what the aircraft is certified for.

 

[schmookeeg]

Sounds like a power trip..

Sigh. Contempt of Cop, but an ASI in this case. Where's our resident FAA apologist to explain this sort of thing?

 

[Htaylor]

I agree with you. FSDO 19 apparently disagrees.

Let's hope that FSDO 19 inspector doesn't get to Alaska anytime soon. All the 207, Cherokee 6 and Caravan Part 135 operators there R&R seats nearly every flight. We have a seat removal chart that shows the new W&B for each seat configuration that gets filled out each time that changes. Caravan seats are a PITA to R&R, but to get 3000 lbs of fish onboard, you need to do it.

 

[Pilawt]

IIRC, AOPA (and maybe others) had a nominal cost STC that called for the removal of the 7th seat so that a basic med holder could legally fly, say, the Saratoga that had been originally certificated as a 7-place plane. Some may have more/more correct insight into whether this is real or my failing memory.

Found it:
https://www.aopa.org/news-and-media...stc-makes-more-piper-pa32s-basicmed-compliant

I believe Basic Med rules state that removal of a 7th seat does not qualify a plane. If the AC is capable of carrying 7 passengers in 7 seats it does not qualify under Basic Med.

From the horse's mouth -- FAA's FAQs on Basic Med (question #33):

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). ​

 

[Archer Jack]

From the horse's mouth -- FAA's FAQs on Basic Med (question #33):

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). ​

 

[Clip4]

There has been a discussion on the PA-32 Facebook page recently, to the effect that one FSDO claims that you need an STC - not just a revised W&B - in order to take seats out of a PA-32. That FSDO is trying to push a violation against a PA-32 owner, and FAA counsel is deciding whether or not to pursue it.

It's nonsense, of course (Piper has been touting the easily-removable seats and various seating arrangements in the PA-32 since day one), but the owner has an attorney defending this FSDO action.

I suspect there is more to this story.

 

[Sluggo63]

I suspect there is more to this story.

I do too. There has to be. Either from the owner side or the FAA side.

In my Seneca POH, I have these paragraphs/instructions:


This isn't the Maintenance Manual, this is the PILOT Operating Handbook. It tells me how to operate and use my aircraft, and in that manual it tells me how to remove my seats (and refreshment console). As long as I do a weight and balance before my flight to account for the weight not being there, how am I operating beyond the scope of the rules?

I know this is for a Seneca, but I had a Cherokee 6 before and the exact same verbiage is in that POH (well, AFM since it was pre-POH).

 

[Fearless Tower]

I agree with you. FSDO 19 apparently disagrees. From the Facebook posts by the attorney for the pilot against whom action is being taken:

The aviation safety inspector who started this whole thing has said that, in FSDO 19, they will enforce this policy against aircraft like the PA32 that can be used for charter of cargo, whenever they find them with the seats removed as they come in through Customs. I am not sure that this was an authorized statement of official FSDO policy.

The FAA attorney seems to have adopted the position that, unless there is an FAA approved “seating configuration” for every possible combination of seats being removed, it would require an STC (a 337 field approval will not do) to fly the aircraft without any of the seats in place (except the 7th seat which is an option in some models). We do not believe this to be an accurate statement of the law. We believe that all that is required, in an aircraft where the seats are designed to be removed easily, without tools, and where the manufacturer has provided the weight and moment arm for each seat and directed the pilots to make weight and balance calculations for seats removed, is that such weight and balance calculations actually be made by the pilot prior to flight. Of course, Part 91 does not require that the physical calculations be recorded and kept. But, in an abundance of caution, it would seem to be a very good idea to keep a written copy of the actual calculations you make for flight with whatever seats you have removed.

The owner of the aircraft has a house and a business in the Bahamas (the house was badly damaged in the last Hurricane). He takes supplies and materials with him in his aircraft. No compensation or hire at all. But the complainant thought that the aircraft, being loaded (in his words “to the gills”) “must” be being used for charter. The ASI put the N number on a watch list with Customs to try to catch the aircraft doing illegal charter. But there was no evidence of charter at all. So the ASI decided that the absence of the rear seats was an Airworthiness violation, even though there were two W&B forms in the aircraft — one for all seats installed; and the other with just the two front seats installed.​

Truly sad that said FSDO apparently has the time to go after shady PA32 operators while they continue to look the other way at all the illegal 135 turbine operators in that part of the country….

 

[k9medic]

I suspect there is more to this story.

I messaged the pilot's lawyer yesterday and got some more details as I have been in similar circumstances myself. All I can say is that if the FAA thinks you are doing something wrong and you are not, be prepared for some of them to try to find something you ARE doing wrong. In this case the pilot/owner is doing everything right.

If you fly out of country be prepared to have CBP acting as the eyes and ears of the CDC and the FAA.

 

[Clip4]

I messaged the pilot's lawyer yesterday and got some more details as I have been in similar circumstances myself. All I can say is that if the FAA thinks you are doing something wrong and you are not, be prepared for some of them to try to find something you ARE doing wrong. In this case the pilot/owner is doing everything right.

If you fly out of country be prepared to have CBP acting as the eyes and ears of the CDC and the FAA.

There used to be smaller ports of entry that were used by the tourist pilots. As those were closed everyone got treated as a commercial operation. Thank the small govt crowd.