Well I guess my FSDO had it right. As for the Pilot/Mechanic debate. It would take me an hour to write about the history of seat removal's for part 135 that took place in the 80's. But the fact of the matter under the more restritive part 135 a pilot after training can remove and install seats. So, you really think a 170 being operated part 91 needs to have an A&P???? See my post dated DEC 13, 2008.........
Last edited by mit on Fri May 31, 2013 2:57 am, edited 1 time in total.
Seeing as the FSDOs are allowing complete interior replacements by owner/operators I see no reason they would not allow the rear sear removal under this
FAR 43-A para c item 11
(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.
Question being, is the removal part of the repair?
I said an owner pilot could remove, repair and replace the seat. But they can not leave it out as that would be a minor alteration. You need to have at least an A&P to do a alteration of any kind to an airplane per FAR 43.
Yes i think it's stupid. And yes a under part 135 today on aircraft with 9 seats or less not including the pilot seat, with training, a pilot can remove, install or reconfigure seats.
I see no way to allow a owner operator with only a private rating the same privilege to make an alteration, even minor under FAr 43.
CAUTION - My forum posts may be worth what you paid for them!
Bruce Fenstermacher, Past President, TIC170A
Email: brucefenster at gmail.com
Bruce Fenstermacher wrote:I said an owner pilot could remove, repair and replace the seat. But they can not leave it out as that would be a minor alteration. You need to have at least an A&P to do a alteration of any kind to an airplane per FAR 43.
Yes i think it's stupid. And yes a under part 135 today on aircraft with 9 seats or less not including the pilot seat, with training, a pilot can remove, install or reconfigure seats.
I see no way to allow a owner operator with only a private rating the same privilege to make an alteration, even minor under FAr 43.
I would guess that if the FUZZ was the least bit concerned with removal of the rear seat in all kinds of airplanes, all they would have to do is visit some of the fly in camping places such as Johnson Creek Airport in Idaho. Almost everyone who goes airplane camping does it without a rear seat in their airplane.
T. C. Downey wrote:"The Letter" is the authorization
Tom, if your saying the letter is the authorization for a person who is not authorized to make this alteration I disagree. The letter clarifies that removal of the seat for operation is not a Major alteration and therefor a minor authorization.
Everyone is missing my point. Removing and reinstalling a seat is preventive maintenance. Removing a seat and leaving it out for operation is a minor alteration. You must be authorized to make an alteration per FAR 43:
§ 43.3 Persons authorized to perform maintenance, preventive maintenance, rebuilding, and alterations.
(b) The holder of a mechanic certificate may perform maintenance, preventive maintenance, and alterations as provided in Part 65 of this chapter.
(c) The holder of a repairman certificate may perform maintenance, preventive maintenance, and alterations as provided in part 65 of this chapter.
(d) A person working under the supervision of a holder of a mechanic or repairman certificate may perform the maintenance, preventive maintenance, and alterations that his supervisor is authorized to perform, if the supervisor personally observes the work being done to the extent necessary to ensure that it is being done properly and if the supervisor is readily available, in person, for consultation. However, this paragraph does not authorize the performance of any inspection required by Part 91 or Part 125 of this chapter or any inspection performed after a major repair or alteration.
(e) The holder of a repair station certificate may perform maintenance, preventive maintenance, and alterations as provided in Part 145 of this chapter.
(f) The holder of an air carrier operating certificate or an operating certificate issued under Part 121 or 135, may perform maintenance, preventive maintenance, and alterations as provided in Part 121 or 135.
(g) Except for holders of a sport pilot certificate, the holder of a pilot certificate issued under part 61 may perform preventive maintenance on any aircraft owned or operated by that pilot which is not used under part 121, 129, or 135 of this chapter. The holder of a sport pilot certificate may perform preventive maintenance on an aircraft owned or operated by that pilot and issued a special airworthiness certificate in the light-sport category.
Notice in (g) it does not authorize a owner operator to perform alterations. The best a Private pilot can do is remove the seat and leave it out under the supervision of someone authorized.
Bruce
CAUTION - My forum posts may be worth what you paid for them!
Bruce Fenstermacher, Past President, TIC170A
Email: brucefenster at gmail.com
I just talked to Inspector Kuttler @ 1-562-627-5340.
he is good with a owner pilot removing the seat, and doing the W&B calculations IAW the owners manual.
But he qualified that statement, that this was not the question directed to him.
My advise would be to make the entry as the owner
Using the arm, and actual weight of the seat, calculate the W&B change and enter that in the log book entry. and sign it with your Pilots number.
I can hardly believe this. Eighteen pages over a period of five years discussing the legality et al of removing the rear seat of a sixty five year old airplane. This is some really deep stuff!
The rear seat incorporates rear occupant seat-belt attachments and I believe that makes it "structural". (The rear seat belts do not attach directly to the airframe as many others do.)
'53 B-model N146YS SN:25713
50th Anniversary of Flight Model. Winner-Best Original 170B, 100th Anniversary of Flight Convention. An originality nut (mostly) for the right reasons.
'53 B-model N146YS SN:25713
50th Anniversary of Flight Model. Winner-Best Original 170B, 100th Anniversary of Flight Convention. An originality nut (mostly) for the right reasons.
As for the Pilot/Mechanic debate. It would take me an hour to write about the history of seat removal's for part 135 that took place in the 80's. But the fact of the matter under the more restritive part 135 a pilot after training can remove and install seats. So, you really think a 170 being operated part 91 needs to have an A&P???? 
See my post dated DEC 13, 2008......... 
Guess we'll have 36 pages before too long. 
I didn't want you to be disappointed! 
