The International Cessna^® 170 Association

Well, being the official bearer of bad news....(that was a joke).... I was doing some reading, and came across FAA Document 8130.2 which basically will cause an uproar. It tells us that if you decide to fly your airplane with one door removed....not only must you apply to your FSDO to do so, you must have an A&P perform the removal. And to remove/reinstall the seat under "preventive maintenance"... you will have to be NAMED in the letter of authorization/limitations, and may have to demonstrate your ability to do so. (Perhaps this relates also to the discussions we've had previously about who can remove/reinstall the rear seat also.)

"21. OPERATION OF CIVIL AIRCRAFT WITH DOOR OPEN OR REMOVED FOR PARACHUTING,
SKYDIVING, OR OTHER SPECIAL OPERATIONS.
a. Advisory Circular 105-2, Sport Parachute Jumping, lists aircraft that the FAA has determined can be safely flown with one door open or removed if operated in accordance with specified operating limitations.
b. Owners or operators using aircraft listed in appendix 2 of AC 105-2 interested in obtaining authorization with operating limitations for operation of such aircraft for parachuting or other special operations should forward a written request to the FSDO having jurisdiction over the area in which the operations are to be conducted.
The request should contain the following information:
(1) Name and address of the registered aircraft owner.
(2) Make, model, serial, and registration number of the aircraft.
(3) Location where aircraft is normally based.
(4) Reason for the aircraft to be operated with a door removed.
c. There are two avenues for operation with the door removed:
(1) If identified in AC 105-2 to operate with the door removed and no STC is installed, operating limitations will be issued by the FAA.
(2) Aircraft other than those listed in AC 105-2 will be modified in accordance with STC procedures in part 21, subpart E, Supplemental Type Certificates. If altered in accordance with an STC, no other limitations are required.
d. Sample operating limitations outlined in figure 2-3 may be issued by inspectors for any aircraft listed in AC 105-2. The inspector will note on the operating limitations the aircraft make, model, registration and serial number, type of operation authorized, date of issuance, inspector's name, and district office number. On an aircraft that requires removal or opening of a particular door, the inspector shall specify in the limitations which door may be removed or opened.
NOTE: A copy of the limitations will be forwarded to AFS-750.
e. Removal or installation of a cabin door for the specified aircraft is considered maintenance and as such must be accomplished by persons authorized under § 43.3......
g. Under part 43, appendix A, paragraph (c)(15), a pilot may be authorized to remove or reinstall passenger seats if specifically listed by name in the operating limitations for the aircraft. The issuing inspector may require the pilot to demonstrate ability in this preventative maintenance function.

Yea, and your issue is?......Brad

I don't understand your question, Brad.... I don't have a specific issue. It's just that it's been a discussion-topic previously and I was surprised to have run across such direct language in an FAA document that we can all read and probably agree to what it says.

gahorn wrote:I don't understand your question, Brad.... I don't have a specific issue. It's just that it's been a discussion-topic previously and I was surprised to have run across such direct language in an FAA document that we can all read and probably agree to what it says.

OH! OK, I just thought you had an answer the the obvious .....Brad

You guys are going to bug the fuzz to the point where you're interfering with their afternon naps and then they will be down on you all like flies on you-know-what. If you want to fly with your door off, just tke it off and go flying. There is no need to call a press confernce to announce the event!
Its just like annual inspections. If you keep having trouble with annual inpections from fussy A&P, AIs, get a little rubber stamp made and do your own annuals.

George, how might this apply to removing the rear seat? Can I claim "gray area" since I'm leaving my door on and NOT conducting parachute operations?

I would follow the FARs not an order meant for the administration of airworthiness certification for the Feds that I'm NOT required to even have knowledge off.

This is only interesting read because it is just another example of the left hand of the FAA doesn't jive with what the right hand has regulated.

I believe the owner/operator is allowed under the previsions of preventive maintenance and repair to remove and replace the doors and the seats in the case of our 170s. This does not allow me to fly with the doors removed.

To fly with the doors removed I'd have to apply to the local FSDO in which case they would most likely subject me to their guidance in the order because that is what they have to do. They are not allowed to think on their own which in many cases is a good thing and in just as many a bad thing.

The old adage about it being easier to obtain forgiveness than permission may or may not apply in such cases. It probably depends upon whether or not an incident/accident happens, and how lawyers and insurance companies get involved (separate actors than FAA.)

Can one claim "gray area?" One may claim anything one likes. Good luck. I believe a rear-seat is just as subject to the policy as any other seat.

The reason this applies to US, is because it is the guidance used by FAA, and is likely the policy to which any inspector will revert in the case of the aforementioned incident/accident. Just because one is ignorant of the policy is not likely a defense, and for that reason is why we should be aware of it, and why I posted it.

I thought removal of a rear seat or door change the weight and balance...for flying. If so, doesn't the w&b have to be recalculated by a A&P and entered in the aircraft log?

Just thinking...gets me in trouble at times.

Rookie J. Edmund

azmuth1 wrote:I thought removal of a rear seat or door change the weight and balance...for flying. If so, doesn't the w&b have to be recalculated by a A&P and entered in the aircraft log?

Just thinking...gets me in trouble at times.

Rookie J. Edmund

According to the FSDO in my region, you are correct.

The FAA document George references is FAA Order 8130.2F dated 4/18/2007 Airworthiness Certification of Aircraft and Related Products. It is National Policy by FAA Office AIR-200 for use by FAA employees when taking action regarding airworthiness of civil aircraft. It is not a regulation (nor is an advisory circular regulatory) because it has not been developed through the rulemaking process. This order and the policy on aircraft doors has been around for a long time. It is not new. Recent changes to this order involve light sport rules which have added a new level of complexity to an already complex set of issues (not going there right now). An FAA Inspector who follows the guidance and procedures in this document is considered to be working within the scope of his duties and responsibilities. An aircraft operator who complies with this guidance would be considered to be in compliance with airworthiness requirements. Pretty simple really and not a case of the right hand and the left hand not in communication.
The section George quotes is found on Page 15 under General Information and it gives FAA Airworthiness Inspectors guidance to approve applications to operate with doors removed which is a deviation from type design in most aircraft. If there is an aircraft who's TCDS allows for operation without a door installed, this section would not apply. The parachute community is the most likely group who will need to use this process and, as you can see, it is pretty straight forward and should not be difficult to obtain from an FAA office. Removal of seats and installation of floor belts are typically part of conversion to a parachute configuration. The discussion about removing seats is interesting but I do not believe mandatory in all cases for pilots and owners. Weight and balance changes must be calculated and entered into the aircraft records. Changes in maximum weights or cg limits require engineering and separate approval. Incidentally, Part 105 is a regulation that has been almost entirely "given over" to the US Parachute Assoc by the FAA and is a success story in self regulation.
I am sure that pilots may have occasional need to operate without a door say for hunting or carrying of cargo that won't fit with the door installed and some may not want to jump through hoops to get approval from the FAA. As someone pointed out, the chances of getting "caught" doing this are remote. You are, as they say, a test pilot if you do this and you should be carefull. If caught, you would likely get a warning letter or be asked to cease and desist. The chances of being involved in an accident are somewhat higher and the risk is loss of insurance coverage. An accident investigation will note if an aircraft is not in conformance with type design and many insurance policies exclude coverage for that condition.
Fly Safe Be Happy!