Brian Sponcil wrote:

There's an auto upholstery shop in town that is very well regarded and while
talking with him regarding my car I got to wondering if I could pull out my
Cherokee seats and have him leatherize them. FAR 43.100 states pilots can:

(11) Repair upholstery and decorative furnishings of the cabin, cockpit
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.

Hmmmm. Does "repair upholstery" cover "replace with leather" (or pleather
for that matter)? Does taking out a seat constitute "disassembly of a
primary structure"? I'm pretty sure other people have done this but I was
just wondering how "legal" it is.

How convenient....I was on the phone with the Denver FSDO/Airworthy
Specialist this morning for this exact same topic.

Key words -- "replace v repair" as you've already noted. If it's
just a repair then there's no issue IF (please note the emphasis)
you use the EXACT same hardware(screws or attaching hardware) to
re-install into the EXACT same location. This means you may NOT
drill new holes to attach the interior panels, you may NOT change
the materials (plastic - leather). If any of this is a replacement
then it becomes an A&P signoff to remain airworthy AND the materials
(fabric, leather, etc) must satisfy the burn requirements.

You may remove anything and everything. But there's a limit on
what you can re-install yourself without the A&P signoff.

If the automotive shop uses materials that satisfy the burn rqmt
and can provide documentation, that's one issue out of the way.
Only thing that's left is for an A&P to bless it. Then you can
put the seats back in.

Call your local FSDO and get their official position and/or the
AOPA legal office for peace of mind.