Basic Med and the Cherokee Six and Lance aircraft

Basic Med and the Cherokee Six and Lance aircraft

After reading the new rule for Basic Med, it has become apparent that the Cherokee Six and the Lance models do not qualify to be flown by a pilot holding only a Basic Med authorization.  The Type Certificate allows for a seating of 7, even though I have never seen that configuration in real life, it is authorized therefore not eligible under Basic Med rules.
The AOPA lawyers seem to think that the only way to get these airplanes covered is to do a STC or ATC to permanently limit the aircraft seating in these aircraft (even though six is all that is installed in many).

I have posed the question to Piper and am awaiting their answer.  If they decline to do an STC, then I would hope an organization would sponsor developing  an STC to avoid individual operators from having to do their own.  Each operator paying a DER to develop an STC would certainly be a deterrent to bothering with Basic Med. 
What are others thoughts on this wrinkle in the rule?

Doug Lesh
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Re: Basic Med and the Cherokee Six and Lance aircraft

Only ONE STC is needed (1 for Lance, 1 for Six, but really it should only be 1 for both in my book). EAA might be interested in being the holder.

My thinking is, since the optional seat does not change the W/B values, it should not be difficult to do an STC. Field approval should be simple. The STC should follow as fast as the FAA can rubber stamp it.

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Re: Basic Med and the Cherokee Six and Lance aircraft

RE: Basic Med and the Cherokee Six and Lance Aircraft
Doug,
I have also spoken to the AOPA lawyers and have received the same response in that an STC or ATC is needed. I have been a Cherokee 6 owner for 35 years and have never had the 7th (jump) seat installed. As many others, I have been following the 3rd Class Medical reform for a few years and thought that the new BasicMed would be of value to me. However at this time, it seems to be a stumbling block for a Cherokee 6 and Lance to comply with the 6 occupant requirement. In my opinion, this seems to be a relatively minor issue in that the PIC can ensure that there are no more than 5 passengers in the plane, especially if the plane only has 6 total seats installed.

I have spoken with my aircraft mechanic, and he suggested that Form FAA 337, Major Repair & Alteration, may be a possible option. Using FAA 337, the aircraft could be altered by removing the jump seat (if installed), seat attachments, and 7th seat belt which, in my opinion, would satisfy the 6 occupant requirement. I am not aware of any legal issues, but I am soliciting comments or remarks from others on the merits of a possible 337 alternative.

Hopefully, Piper (per Doug action) or another organization will do an STC if that is the only option.

Bob Joseph

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Re: Basic Med and the Cherokee Six and Lance aircraft

Interesting thoughts on how to apply a fix for this.   Keep in mind, it's the Cherokee 6 series and the Seneca, which uses the identical fuselage and was also marketed as seating 7.  Any chance the AOPA can convince the authors of BasicMed to include our airplanes since they clearly never carry more than 6?  I've never seen one with more than 6 seats - including a 7th was clearly a marketing stunt done by Piper in the 70's.  This year, I can't do basic med and have my fingers crossed that my special issuance will be extended again.

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Re: Basic Med and the Cherokee Six and Lance aircraft

I've been thinking about your message the last day or so as I own a Seneca.  Even though my airplane has five seats it's still certificated for 7 seats, unfortunately.  I don't think the AOPA is going to try and convince anybody of anything at this point as the bill has been signed into law.  A change to the bill would require an act of congress and a presidential signature.  If we could amend the type certificate to limit these airplanes to six seats we'd be in business.  That would be a big expense and who's going to pay the bill?  My guess is that Piper will turn their back on it as will EAA and AOPA.  There are just too few of our airplanes to warrant the cost, unfortunately.  Do you know any rich benefactors?

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Re: Basic Med and the Cherokee Six and Lance aircraft

3/24/2017

One solution may be in the FAA's Type Data Certification Sheet A3SO for PA-32.  My PA-32RT-300T is on pages 10-11 of 31 pages.  Page 11 shows this airplane is certified for 7 OR 6 seats as follows:

Number of Seats:
7 (2 at +85.3, 3 at +118.1, 2 at +157.6)
6 (2 at +85.5, *2 at 119.1, 2 at +157.6)
* - Optional Club Seats

I have the Club Seats option.  I went to my POH Section 6.9 "Weight and Balance Determination For Flight" on page 6-10 and verified the Arm Aft Datum (inches) for my airplane matched the 6 seat datum numbers in the Type Certification Data Sheet.  It appears my airplane with the Club Seat Option is only certified for 6 seats.  At least, this would be my argument to qualify for Basic Med.  I put a copy of this Type Data Certification Sheet in Section 6 of the POH.

I found the Type Data Certification Data Sheet as follows:
1.  Go to faa.gov.
2.  In the search box type in:  FAA-CT-8080-8D
3.  Search result:  "Computer Testing Supplement for Inspection Authorization (PDF)"
4.  Scroll down.  My airplane is at page 645-646/675 of this PDF.  (Note:  it is page 10-11/31 of Type Certification Data Sheet A3SO).

I look forward to comments about this approach to the 6 seat limitation in the Basic Med rules.  Lawyers my still say an STC is the best option.

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Re: Basic Med and the Cherokee Six and Lance aircraft

Hi, thanks for your research.  I'm going to look on the FAA website as soon as I'm done writing this message and see how my Seneca fits into this picture.  Back to you soon on this forum.

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Re: Basic Med and the Cherokee Six and Lance aircraft

Either Piper did not understand the situation or they are not interested.  Their response was that they build airplanes according to the type certificate, what happens after that is your business.

I have spoke with a couple of IAs,  in general, they also suggest the field approval on a 337 form.    While Advisory Circulars are not regulatory, it is unfortunate that their only indication is to do an STC or ATC.  It is likely a Fed will want to hang their hat on that.

Reading Mike Busch's article in AOPA,  it would appear that a DER would not be necessary as all engineering data exists since that configuration is how most of us are flying the aircraft.
More research to do.


I would think a simple statement in the AFM/POH in the limitations section:  This aircraft is limited to a maximum of 6 installed seats.  Perhaps a placard on the panel stating the same thing. 
Mine also came from the factory with the club seating and that is indicated in the equipment list.

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Re: Basic Med and the Cherokee Six and Lance aircraft

Since this is primarily a Piper aircraft issue, what role might the Piper Owner Society play in doing some of the foot work on getting an STC for Piper Six, Lance, Seneca owners?
The field office where I live is not known to be particularly friendly in regards to field approvals.

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Re: Basic Med and the Cherokee Six and Lance aircraft

Hi and thanks for writing.  I've been looking at the PA-32 and PA-34 type certificates.  To get a field approval for a 337, go to your FSDO.  To get an STC or an amended type certificate: forget about it.  That's a very big deal and very expensive.  However, if you look at the PA-32/34 type certificates, they say the following:
No. of Seats   7 (2 at +85.5, 3 at +118.1, 2 at +155.7)   
                       7 (2 at +85.5, 3 at +118.1, 2 at +157.6)     
                       6 (2 at +85.5, *2 at +119.1, 2 at +157.6)
     * - Optional Club Seat


So here's my advice, which I'm going to take myself.  Turn those middle seats around and you have club seating, hence six seats certified. Problem solved!  I'm going to check with our association A&P, Erich Rempert on this.  The question for him is:  Since the weight and balance don't change, can we reverse the middle row of seats with a log book entry?  My guess, "yes".  Stay tuned.

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Re: Basic Med and the Cherokee Six and Lance aircraft

Our A&P, Erich Rempert, has responded to my question "Since the pa32/34 is type certificated with standard and club seating, can we convert to club from standard with just a log book entry.  His response:

I would think so. It's not a major alteration as its on the TC.  Similar to wheel pants vs no pants.

~Erich

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Re: Basic Med and the Cherokee Six and Lance aircraft

I did call the local ACO and asked them.  He was going to research it and talk to the FSDO about their understanding.  He was hoping to go the 337 route by specifying what you stated, the three stations where the seats are located.  Mine already has the club seating, so maybe it will be easy.  His emphasis was for an IA to be able to verify the configuration meets the 337 form specifications during an annual. 
So I will post what they come back with.

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Re: Basic Med and the Cherokee Six and Lance aircraft

This e-mail address is being protected from spambots. You need JavaScript enabled to view it wrote:

Hi and thanks for writing.  I've been looking at the PA-32 and PA-34 type certificates.  To get a field approval for a 337, go to your FSDO.  To get an STC or an amended type certificate: forget about it.  That's a very big deal and very expensive.  However, if you look at the PA-32/34 type certificates, they say the following:
No. of Seats   7 (2 at +85.5, 3 at +118.1, 2 at +155.7)   
                       7 (2 at +85.5, 3 at +118.1, 2 at +157.6)     
                       6 (2 at +85.5, *2 at +119.1, 2 at +157.6)
     * - Optional Club Seat


So here's my advice, which I'm going to take myself.  Turn those middle seats around and you have club seating, hence six seats certified. Problem solved!  I'm going to check with our association A&P, Erich Rempert on this.  The question for him is:  Since the weight and balance don't change, can we reverse the middle row of seats with a log book entry?  My guess, "yes".  Stay tuned.

Well it looks like the center seats move 1 inch so the Weight and balance would change slightly, but that shouldn't be a big deal.

Doug Lesh
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Re: Basic Med and the Cherokee Six and Lance aircraft

Thanks for the update:  This could be a big reprieve for us PA32/34 owners.  Thanks for taking the lead on this.

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Re: Basic Med and the Cherokee Six and Lance aircraft

I just spoke with the Denver ACO  about this issue.  After doing research and taking the question through the Northwest Mountain Region up to AFS 230, they maintain that as long as the airplane is equipped with 6 seats as specified in the Type Certificate Data Sheet that there is no further action required in order to fly the airplane under basic med.
It would be up to the operator to maintain that seating configuration for the applicable type of operator or operation. 

Hard to believe in the end, the answer is pretty simple and straightforward.

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Re: Basic Med and the Cherokee Six and Lance aircraft

Awesome, Dude!  You just saved us all a lot of money and aggravation.  Perchance, do you have that approval in writing?

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Re: Basic Med and the Cherokee Six and Lance aircraft

No, I don't have it in writing.  I haven't decided yet whether to press my luck on that or not.  I am thinking that what really should happen is the folks that wrote the basic med rule in AFS 230 should put something out, at least through the alphabet groups.  Mainly AOPA.
I can try to get like an email from my contact stating that, but really how far will that go if there is a major challenge.
Doug

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Re: Basic Med and the Cherokee Six and Lance aircraft

Very good point.  The bottom line is that the message that you received isn't worth anything, unfortunately, unless it's written.  So we're back to having club seating as the only way out.  That's what I'm going to look into tomorrow with my A&P.  Thanks for the great conversation.

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Re: Basic Med and the Cherokee Six and Lance aircraft

I had another conversation with my contact and he had no problem putting his name here to contact if anyone ran into a problem.
Since the answer did come from AFS 230 in Washington, he said that anyone should be able to contact their FSDO, have them coordinate up through their region to get the same answer.  He said that AFS 230 felt that the preamble and rule were clear enough to probably not put out any additional guidance.  I did mention that it must not be as clear as they think if people in the field still have the question.  Maybe if they get more people calling them, that might come across.  But for the moment, he did not foresee any policy letter being issued.
The Denver ACO contact is Greg Johnson  303 342-1083. 

AFS 230 should be reachable through the number below.

Federal Aviation Administration
Flight Standards Service
Room 821
800 Independence Avenue, SW
Washington, DC 20591

Phone: (202) 267-8237
Fax: (202) 267-5230

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Re: Basic Med and the Cherokee Six and Lance aircraft

Thanks for the update.  I just took a screen print to save with my log.  Thanks so much.

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Re: Basic Med and the Cherokee Six and Lance aircraft

Hi Doug, I just received an FAA News and Update entitled "Basic Med Begins", which I posted under the FAA news section of this forum.  In it I quote the FAA:

"General aviation pilots may take advantage of the regulatory relief in the BasicMed rule or opt to continue to use their FAA medical certificate. Under BasicMed, a pilot will be required to complete a medical education course every two years, undergo a medical examination every four years, and comply with aircraft and operating restrictions. For example, pilots using BasicMed cannot operate an aircraft with more than six people onboard and the aircraft must not weigh more than 6,000 pounds."

I think we're good! smile  Do you concur?

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Re: Basic Med and the Cherokee Six and Lance aircraft

Scott,  I recently reviewed the FAQ at the FAA site for basic med dated 5/19/2017, actually after reading one of the most recent articles in the magazine.  No mention was made of the Seneca, however I have strong suspicions that it will fall into the same category as the Lance.  It appears that legal has determined that the Cherokee six requires an SB modification to put 7 seats in, therefore if you have not done the SB, you are good,  It appears the Lance and probably the Seneca do not require a SB, all you have to do is buy the seat and put it in, no structural modification required therefore it is a 7 place airplane and does not qualify unless a STC is acquired to limit the seating.
I guess back to square one on doing an STC.

Doug

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Re: Basic Med and the Cherokee Six and Lance aircraft

Hi Doug and thanks for writing.  Have a great weekend.

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