So I spoke to Phillip over at Webco and he suggested the nut plates and screws. When I asked about an STC or some type of FAA approval for this conversion he said I needed to read up on "owner supplied parts" and then call him back to order. I've heard of this more than once and in fact even my PMI at the FAA had mentioned it to me at one point. Any thoughts on this topic appreciated and specifically with regard to the nose fasteners.

- Charles

Jim

All the best!
Jim

- Charles

Jim

FYI,

Another approach you might look into is installing "Camlock" style fasteners. The later models have them as standard equipment. Hence, the paperwork shouldn't be that big of a deal. The physical installation process might be about the same cost as installing nut plates. It's worth looking into.

I am going to install them on my twin just before it goes into the paint shop. FWIW.

Jeff

- Charles

Back on the nose cowl... This morning I had a chat on this topic with my Principal Maintenance Inspector (PMI) at the local FSDO who oversees my 135 charter certificate (to be clear my PA-30 is not on that cert it is just Part 91 but I wanted his opinion). He said that changing out the SouthCo nose fasteners to nut plates and screws is a good idea but from a paperwork standpoint it's just "substitution of parts" under AC 43.13-1B. I pulled the entire AC down from the FAA website and chapter 7 is the part that deals with hardware. He said replacing using A/N counter-sunk pan-head screws and washers / nut plates would work well. He also said that in his mind this is a simple substitution of parts with no Weight & Balance impact so no 337 is required as it's not really a "major" alteration. He said a simple logbook entry should suffice citing substation of parts under AC 43.13-1B. He also said ultimately it's up to the mechanic installing to determine (major / minor) but in his opinion it's minor. He also said he'd be happy to grant a field approval if we wanted to call it major and do a 337.

We also talked about nut plates and screws vs newer style Cam Lock fasteners and he said either would be fine but he said he thought nut plates and screws would be better on a PA-30 nose for 3 reasons:

1) Easier and cheaper to find a replacement in the field if one is missing

2) He felt cam-locks could come loose more easily than a screw and could do more damage to a prop given the location

3) Given the way the cowl lifts off - nut plates and crews would mean the cowl does not have to be pulled out both sides to lift off the way it does with fasteners (my PMI used to work on PA-30s and is familiar). Pat also commented on another thread that with nut plates and screws she can take the cowl off by herself.

So I think I'll be calling Phillip over at Webco today to order stainless nut plates and screws today along with washers and rivets for install.

By the way... my PMI also said that the topic of "Owner Produced Parts" does not apply here because these are not parts I as the owner have produced. He said OPP comes into play when the owner manufacturers a part and has some original basis for doing so. For Example: The PA-30 battery box - I just ordered a Bogurt stainless steel box but had I decided to buy aircraft grade stainless steel and make my own battery box to the same specs as the original - that would be "Owner Produced". I could also enlist the help of a machine shop to do the actual metal work. But just buying screws and nut plates is not "producing" anything. But under substitution of parts AC 43.13-1B the nose hardware can be replaced legally with a simple logbook entry..

This is what I learned today on this topic...

- Charles