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 Post subject: Piper PA32 Drivers take note- Basic Med and your aircraft
PostPosted: 19 Mar 2017, 21:19 
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Location: Brunswick, Ga
Aircraft: PA32RT-300T
I have been on a quest to find out if I still need a Med cert or if I can "Basic Med" my ticket and still drive my Lance.

Nowhere in my books, certs or otherwise could I find how MY Lance was certified; with 6 seats or 7 seats. If it is 7 seats, I will have to get a 3rd class still, even though the 7th seat is completely useless. Now, my Lance does not have a 7th seat installed, but in theory (Or certified as) it can.

I dug into Pipers own docs filed with the DOT and FAA and located the attached PDF. My Lance is a PA32RT-300T of 1979 vintage WITH factory club seating. If I am reading this correctly, the planes could have been shipped with all facing front and the middle row 3 across. If it was club seating, it was certified as a 6 place.

The info is derivated from two separate CG limits used by Piper to build the planes. One is for a 7 seat config, the other the 6. 6 being the Club seating option. If you look at Note 11 all the way at the end of the doc, it breaks this out a bit clearer.

Based on the "Official specs" filed with FAA, I feel pretty confident my factory CLUB seating Lance is indeed certified as a 6 place plane. :werd:

Someone care to tell me I'm wrong, and if so why? :popcorn: :scratch:


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 Post subject: Re: Piper PA32 Drivers take note- Basic Med and your aircraf
PostPosted: 19 Mar 2017, 21:38 
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Joined: 04/28/12
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Location: Kansas City, MO (KMKC)
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Username Protected wrote:
I have been on a quest to find out if I still need a Med cert or if I can "Basic Med" my ticket and still drive my Lance.

Nowhere in my books, certs or otherwise could I find how MY Lance was certified; with 6 seats or 7 seats. If it is 7 seats, I will have to get a 3rd class still, even though the 7th seat is completely useless. Now, my Lance does not have a 7th seat installed, but in theory (Or certified as) it can.

I dug into Pipers own docs filed with the DOT and FAA and located the attached PDF. My Lance is a PA32RT-300T of 1979 vintage WITH factory club seating. If I am reading this correctly, the planes could have been shipped with all facing front and the middle row 3 across. If it was club seating, it was certified as a 6 place.

The info is derivated from two separate CG limits used by Piper to build the planes. One is for a 7 seat config, the other the 6. 6 being the Club seating option. If you look at Note 11 all the way at the end of the doc, it breaks this out a bit clearer.

Based on the "Official specs" filed with FAA, I feel pretty confident my factory CLUB seating Lance is indeed certified as a 6 place plane. :werd:

Someone care to tell me I'm wrong, and if so why? :popcorn: :scratch:


Based on the TCDS, your airplane is certified for up to 7 seats; it's currently configured for only 6. With the appropriate parts, you can, with only an A&P signature, install 7 seats.

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 Post subject: Re: Piper PA32 Drivers take note- Basic Med and your aircraf
PostPosted: 20 Mar 2017, 02:45 
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Company: Golden Arrow Properties Inc.
Location: Vancouver, BC
Aircraft: PA34, C172, PA18
Intersting question. I see most of the Cherokee 6's were certified as 6PCLM or 7 PCLM. Then from the Lance onwards - 7PCLM.

But the information (not the regulations) state:

>>Basic Aircraft Requirements:
Any aircraft authorized under federal law to carry not more than 6 occupants
Has a maximum certificated takeoff weight of not more than 6,000 pounds

A Cessna 208 can be certified as a 2PCLM or an 11 PCLM. I doubt the intent is/was that you could remove 5 seats from the 11PCLM and then say it is authorized as a 6 occupant? (ignoring the weight limitation).

Similarly you can't just revise a weight and balance to show 6000lb.

But I think you are on the right track. A Seneca II can be certified at a gross weight of 4570 or, by installation of a service kit for 4406lb (1999kg). Once the kit is installed, it is legally limited to 1999kg, and recognized by authorities as such (else what's the point). The kit instructions say it can be converted back to 4570 by the reverse procedure.

So, look for the 'service kit' or instructions for installing club seating, use that as 'proof' that it is only authorized for 6 seats.

Hopefully the regulations when published will be more detailed?

Don


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 Post subject: Re: Piper PA32 Drivers take note- Basic Med and your aircraf
PostPosted: 20 Mar 2017, 06:09 
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I wonder if Piper will need to make a service kit, perhaps a placard and a set of instructions to check for and remove any 7th seat floor anchors, to solve this issue for those who want Basic Med. Wonder what cost they will set for the kit?


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 Post subject: Re: Piper PA32 Drivers take note- Basic Med and your aircraf
PostPosted: 20 Mar 2017, 07:21 
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Location: Brunswick, Ga
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In the Lance, the 7th seat is in the center row. It would take a complete rearrangement of the interior to make it a 7 seater.

My argument right now is that the plane was delivered as a 6 seat configuration with no 7th seat installed or supplied.


Or in other words, the planes delivery as a 6 seat plane would prima facie be it's limitations.


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 Post subject: Re: Piper PA32 Drivers take note- Basic Med and your aircraf
PostPosted: 20 Mar 2017, 09:22 
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There's a grammar problem with the reg as shown above...

"Authorized ...to carry not more than 6 occupants"

Is logically the same as...

"Authorized ...to carry less than or equal to 6 occupants"

Which includes a King Air, a 747, etc.
....

I think they meant to say "Any aircraft not authorized under federal law to carry more then 6 occupants ", which is a different thing altogether.


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 Post subject: Re: Piper PA32 Drivers take note- Basic Med and your aircraf
PostPosted: 20 Mar 2017, 09:38 
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An airplane with 6 seats installed may not legally carry more than 6 occupants, regardless of how many seats may be installed at another time. Don't overthink this.


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 Post subject: Re: Piper PA32 Drivers take note- Basic Med and your aircraf
PostPosted: 20 Mar 2017, 09:44 
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Username Protected wrote:
In the Lance, the 7th seat is in the center row. It would take a complete rearrangement of the interior to make it a 7 seater.

My argument right now is that the plane was delivered as a 6 seat configuration with no 7th seat installed or supplied.


Or in other words, the planes delivery as a 6 seat plane would prima facie be it's limitations.


You're conflating "configured" and "certified." The fact it was delivered as a 6 seat airplane does not change the fact that it is, in fact, certified to carry 7 people. It's irrelevant to the certification question that the interior would need to be reconfigured.

It's a very, very poorly written reg (the result of the FAA adopting Congress' language without revision). The reg itself uses the term "authorized," and the FAA, in its guidance, says that "authorized" means "certified." I disagree with that entirely. As your airplane sits, it is only authorized to carry 6 people because of how it's configured (you're not authorized to carry more people than you have seats/seatbelts for). I imagine the FAA is going to get enough questions about this from owners of PA32/PA34 owners, and some questions from Twin Bonanza owners (we have the same issue, being "certified" to carry up to 8, but with 6 as a fairly normal configuration) that hopefully they'll change their "interpretation" of the term "authorized" to make it essentially "configured."

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 Post subject: Re: Piper PA32 Drivers take note- Basic Med and your aircraf
PostPosted: 20 Mar 2017, 22:32 
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Username Protected wrote:
An airplane with 6 seats installed may not legally carry more than 6 occupants, regardless of how many seats may be installed at another time. Don't overthink this.


That's what I was going to say.

But Jeff, To be on the safe side and for the correct answer I would put up a poll here on BT. Then if the Feds say anything you will be covered :cheers:

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 Post subject: Re: Piper PA32 Drivers take note- Basic Med and your aircraf
PostPosted: 21 Mar 2017, 18:35 
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The Type cert for the Aerostar shows 6 seats, with an *

The * says that if you limit the total weight to 380lbs you can put three people in the
bench seat. So is it 6 or 7? My aerostar came from the factory with
Bench seat and three other seats for a total of 6 ;-( How hard is it to get an STC approved changing that number?


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 Post subject: Re: Piper PA32 Drivers take note- Basic Med and your aircraf
PostPosted: 21 Mar 2017, 18:53 
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Username Protected wrote:
The Type cert for the Aerostar shows 6 seats, with an *

The * says that if you limit the total weight to 380lbs you can put three people in the
bench seat. So is it 6 or 7? My aerostar came from the factory with
Bench seat and three other seats for a total of 6 ;-( How hard is it to get an STC approved changing that number?

Wouldn't being pressurized and/or gross over 6,000 disqualify the A* (601P) from basic med anyway?

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 Post subject: Re: Piper PA32 Drivers take note- Basic Med and your aircraf
PostPosted: 21 Mar 2017, 21:35 
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Location: Brunswick, Ga
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I've read the legislation and proposed rule. FAA has proposed that the type cert is what drives the train and no accommodations for actual configuration were made. That's not what the law says, its what FAA thinks it says because that's whet they think it should be. I submitted a public comment, albeit I have little hope they will change anything. See below:

Quote:
In the case of The Piper Aircraft PA-32 and Piper Aircraft PA-34 series aircraft,per Type Certificate No. A3SO, several of these aircraft are certified to carry either 6 persons or 7 persons(6PCLM or 7PCLM). Many of these aircraft left the Piper factory brand new and configured per Type Certificate No. A3SO as 6PCLM, 6 passenger aircraft(Club Seating)and have been in service as 6 passenger aircraft for the past 30 plus years with no modification to a 7 seat configuration. This demonstrates owners are not interested in or willing to bear the expense of conversion.

As written, the Rule does not take into consideration the actual factory delivered occupant capacity of the aircraft, the condition in which Airworthiness Certification occurred, the historically operated occupant capacity, nor provide any reasonable language to provide relief to owners who are legally configured under the BasicMed requirements. Due to ambiguous language in Type Certificate No. A3SO, it leaves these aircraft owners unable to fly what would otherwise be a conforming and lawful aircraft under FESSA for the mere fact the plane could have been a 7 passenger aircraft when assembled new.

Section 2307(j) of FESSA defines a covered aircraft as an aircraft that (1) is authorized under Federal law to carry not more than 6 occupants; and (2) has a maximum certificated takeoff weight of not more than 6,000 pounds. As configured, these Piper aircraft cannot legally carry more than 6 passengers and are under 6,000 pounds gross weight. Under H.R. 636 Section 2307 (8)(A) as passed, The Congressional intent was to limit the covered aircraft to carrying not more than 5 passengers and one pilot. As configured, these aircraft are in compliance with FESSA. The Rule as proposed is based on what an aircraft could have been configured as, not what it is configured as. This is tantamount to being guilty until proven innocent.

Piper PA-32's and PA-34's configured from the factory as 6 passenger aircraft are not readily converted to 7 passenger aircraft, nor was the required seating, seat belts and other hardware delivered with the aircraft to make a conversion to a 7 passenger configuration. Thus, it is unreasonable to assume all PA-32 and PS-34 aircraft are 7 passenger aircraft for the purpose of this legislation.

Congress intended to restrict the total capacity to 6 occupants and as published, the FAA Rule runs afoul of the legislative intent by unreasonably restricting the Rule without consideration for any aircraft that is legally configured for no more than 6 total passengers, e.g. a PA32 configured as 6PCLM (Club Seating)

The current Rule as proposed unfairly penalizes owners and operators of PA-32 and PA-34 aircraft who have never been configured for, do not desire to, or are not legally authorized to carry more than 6 passengers as configure from Factory Piper.

Additionally, the Rule has not provided consideration for other aircraft owners and operators who desire to comply with the FESSA by removing unused passenger seats with the associated logbook entry and Weight and Balance revision, which may legally be done without an STC, ATC or other Certificate modification to comply with FESSA per the Pilots Operating Handbook or Aircraft Limitations manuals.

I request the FAA draft reasonable and common sense verbiage in the Rule that meets the legislative intent without arbitrarily penalizing Piper aircraft owners, or other affected make and model aircraft who operate their airplanes solely as 6 passenger-configured aircraft and have not, or do not, convert the air frame to accommodate a 7th passenger (7PCLM) configuration.

This proposal to amend the Rule is reasonable, fair and in line with Public Law 114-190 as passed by the 114th Congress July 15th, 2016


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 Post subject: Re: Piper PA32 Drivers take note- Basic Med and your aircraf
PostPosted: 21 Mar 2017, 21:43 
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Aircraft: 1969 Bonanza V35A
Many cargo airplanes, such as the Metroliner and the Beech 1900 have an STC that limits the aircraft to nine seats for maintenance reasons.

My money says that you will see (or develop) the STC to limit the aircraft to six seats in short order..

Jason


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 Post subject: Re: Piper PA32 Drivers take note- Basic Med and your aircraf
PostPosted: 22 Mar 2017, 07:17 
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>Wouldn't being pressurized and/or gross over 6,000 disqualify the A* (601P) from basic med anyway?

The stock 601P and 602P are 6K gross.
The 700 or 700 STC's give you more gross (6300 or 6800 with mods)

Its pressurized, but 17.5K ft is a great cruising altitude!
You don't have to fly it above 18K.


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 Post subject: Re: Piper PA32 Drivers take note- Basic Med and your aircraf
PostPosted: 30 Dec 2017, 02:48 
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Joined: 07/27/13
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Does anyone have an update on this topic? I am considering a Seneca III, but would like to use Basic Med. Doesnt look like that is possible given the 7 passenger certification that the airplanes currently have.


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