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Thread: 22/20 conversion

  1. #1
    daveav8r Guest

    Default 22/20 conversion

    I have a PA22/20 with the Tri-Pacer lower cowl. I'd like to change to the Pacer style without the bowl. Is there an STC for this?

  2. #2
    Join Date
    Aug 2005


    i dont think you need an stc if its a univair conversion it saysin their catolog "the bottom cowl needs to be modified or replaced with a PA20 type cowl which univair can provide " part #L-1041-10

  3. #3
    daveav8r Guest


    I have 2 A&P's that say the paper work for the conversion only allows the 5"X9" patch over the nose gear opening. They say it does not cover removing the bowl and patching the cowl below. It is a Univair conversion, but the drawing included is for the small patch. They will indeed sell me a new lower cowl.....for $900.45.

  4. #4
    Join Date
    Aug 2005


    You could do what many other people have done in the past and that is to build a new one as an owner produced part.
    Ben V.

  5. #5
    daveav8r Guest


    Maybe a dumb question....doesn't this make the airplane experimental?

  6. #6
    Join Date
    Sep 2005
    Leeds, AL.


    No. and the cowling can be changed by the owner also since:
    (12) Making small simple repairs to fairings, nonstructural cover plates, cowlings, and small patches and reinforcements not changing the contour so as to interfere with proper air flow.
    The owner can remove the cowling and manufacture the part using the drawings from Piper as data to duplicate the Univair part. Since this is most particularly a modification to the original PA-20 the repair is to return it to the original condition?

    Failing in all that a good IA should be able to get a field approval with no real problems. If he has a relationship with the local FAA and asks the question the inspector may just tell you that it is a minor modification (which I think it is) and all that is necessary is a logbook entry.

  7. #7
    Join Date
    Dec 2005
    01TN Tennessee


    The following explains the owner produced parts rule by the Bill O'Brien who just retired from the FAA. Bill wrote the rule and explains it below.

    1. You can use parts produced under a type or production
    certificate such as a Piper, Cessna, or Mooney produced

    2. A owner or operator produced part to maintain or alter
    their own product;

    3. Parts produced under a Technical Standard Order (TSO)
    such as radios, life vests and rafts, and GPS; or,

    4. A standard aviation part such as fasteners, washers, or
    safety wire.

    Before I segue into the subject of "owner produced parts" as
    called out in section 21.303, which is the purpose of this
    article. I would like to create a small uproar with this
    statement: "FAA Airframe and Powerplant rated mechanics
    can maintain, repair, and modify parts, but they cannot make
    a brand new part and call it a repair." Before you accuse me
    of losing dendrites by the minute, check out section 65.81
    General privileges and limitations. The section talks about
    maintenance, preventive maintenance, and alterations, but
    not the manufacturing of parts. Nor is it an implied privilege
    in Part 65, because Part 21 section 21.303 says "no person"
    may make a replacement part for a type certificated (TC)
    product unless that person has a PMA, etc.

    While I write this I can remember 25 pounds ago and when I
    had hair, I worked in the real world and I specialized in
    making engine baffles for Lycoming engines. Before
    someone accuses me of bureaucratic ventriloquism which is
    roughly translated as "talking out of both sides of my
    mouth." My weak defense is, I made the parts because I
    thought I could." It never dawned on me that I could not
    legally make a part. Some of you may be astounded that I
    make this confession freely. It's no big thing because I know
    the statue of limitations has run out years ago and a jury of
    my peers would never look me in the eye and convict me.

    So here is our problem that we must solve. Since mechanics
    cannot legally make parts for aircraft and aircraft need
    replacement parts, how are we going to keep the fleet
    flying? If we cannot find PMA, TSO, standard, or
    production holder replacement parts, we are left to make the
    part under the owner-produced option under section
    21.303(b)(2). However, we must remember that the part is
    for the owner/operator's aircraft only and is not
    manufactured for sale to other TC aircraft.

    To get through confusing regulatory policy with our pride
    intact, let's try the question and answer routine. (Note: This
    policy is taken from FAA 's AGC-200 policy memorandum
    to AFS-300 on the definition of "Owner-Produced Parts"
    dated August 5, 1993)

    Question 1: Does the owner have to manufacture the part
    him or herself in order to meet the intent of the rule?

    Answer 1: No, the owner does not have to make the part him
    or herself. However to be considered a producer of the part
    he/she must have participated in controlling the design,
    manufacturer, or quality of the part such as:

    1. provide the manufacturer with the design or performance
    data from which to make the part, or

    2. provide the manufacturer with the materials to make the
    part, or

    3. provide the manufacturer with fabrication processes or
    assembly methods to make the part, or

    4. provide the quality control procedures to make the part,

    5. personally supervised the manufacturer of the part.

    Question 2: Can the owner contract out for the manufacture
    of the part and still have a part that is considered

    Answer 2: Yes, as long as the owner participated in one of
    the five functions listed in Answer 1.

    Question 3: Can the owner contract out the manufacture of
    the part to a non-certificated person and still have a part that
    is considered "owner-produced?"

    Answer 3: Yes, as long as the owner participated in one of
    the five functions listed in Answer 1.

    Question 4: If a mechanic manufactured parts for an owner,
    is he/she considered in violation of section 21.303(b)(2)?

    Answer 4: The answer would be no, if it was found that the
    owner participated in controlling the design, manufacture, or
    quality of the part. The mechanic would be considered the
    producer and would not be in violation of section 21.303(a).
    On the other hand, if the owner did not play a part in
    controlling the design, manufacture, or quality of the part,
    the mechanic runs a good chance of being in violation of
    section 21.303 (b)(2).

    Question 5: What kind of advice can you give on how a
    mechanic can avoid even the appearance of violating section

    Answer 5: First, a mechanic should never make a logbook or
    maintenance entry saying that he/she made a part under his
    certificate number. This foopah will send up a flare and get
    you undue attention from your local FAA inspector, which
    you could do without. However, the mechanic can say on the
    work order that he helped manufacture an owner-produced
    part under section 21.303 (b)(2).

    Second, the owner or operator should be encouraged to
    make a log book entry that is similar to section 43.9
    maintenance entry that states: The part is identified as an
    owner produced part under section 21.303 (b)(2). The part
    was manufactured in accordance with approved data. The
    owner/operator's participation in the manufacturer of the
    part is identified, such as quality control. The owner must
    declare that the part is airworthy and sign and date the entry.

    Question 6: Is there anything else a mechanic must do?

    Answer 6: The mechanic must ensure that the
    owner-produced part meets form, fit, and function, and,
    within reasonable limits, ensure that the part does meet its
    approved type design (e.g. like looking at the approved data
    used to make the part). Then the mechanic installs the part
    on the aircraft, makes an operational check if applicable,
    and signs off the required section 43.9 maintenance entry.

    Question 7: What is the owner responsible for and what is
    the mechanic responsible for concerning owner-produced

    Answer 7: The owner is responsible for the part meeting
    type design and being in a condition for safe operation. The
    mechanic is responsible for the installation of the
    owner-produced part being correct and airworthy and for a
    maintenance record of the installation of the part made.

    Question 8: How does the owner or operator get the
    approved data to make a part if the manufacturer and other
    sources are no longer in business?

    Answer 8: For aircraft that the manufacturer is no longer
    supporting the continuing airworthiness of, the owner or
    operator can petition the FAA Aircraft Certification
    Directorate under the Freedom of Information Act for the
    data on how the part was made. Or the owner or operator
    can reverse engineer the part and have the data approved
    under a FAA field approval or, if it is a really complicated
    part, have the data approved by a FAA engineer or FAA
    Designated Engineering Representative.

    Question 9: What happens to the owner-produced part on
    the aircraft if the original owner sells the aircraft?

    Answer 9: Unless the part is no longer airworthy, the
    original owner-produced part stays on the aircraft.

    I hope that I spread some light on the murky subject of
    owner-produced parts, so the next time instead of saying to
    the owner of an broke aircraft: "Sure, 'I' can make that part,"
    you will now say "Sure, 'WE' can make that part."

    Bill O'Brien is an Airworthiness Aviation Safety Inspector
    in FAA's Flight Standards Service. This article also
    appeared in the Aircraft Maintenance Technology

  8. #8
    Join Date
    Aug 2005


    im not to interested in arguing with you but if you read the installation instructions it tell you that you have 3 options 1 leave the cowling as is[ leave the tripacer cowling on it as is
    2 if you dont want to patch your old cowling put on a PA 20 styl cowling
    3 patch your old cowling in there the instructions are a bit vague but if you read the part where it says make sure you continue the flange accross the bottom of the cowling i think anyone could resonably assume that the bottom [tripacer]air scoop which includes this very flange needs to be removed NOT left inplace otherwise why are you going to make sure the flange [that is by the way already there] continues accross the bottom of the cowling??????????? and it kinda sounds like you think sure they will sell you a cowling for 900 bucks but the rest of the guys already covered the make it yourself for 10 dollars part and not that you would need instructions for that im sure your capable of "winging it" but here is a website with the directions for a bottom cowling on a pacer

  9. #9
    Join Date
    Oct 2005
    White City, Or.



    No STC needed. It is part of the conversion. Someone was just too lazy to finish it.
    I have a write-up on my web page that discribes how to do it. Just look for the icon that says "Pacer lower cowl"


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