AD/AE 3007/4 Amdt 1 - Starter Adapter Drain

The directive rests on three principal concepts embedded in its text: incorporation by reference of a foreign airworthiness directive, approval of a limited alternative means of compliance, and a time-limited approval tied to a arriving terminating action.

1. Incorporation by reference: The directive does not reproduce the FAA AD text. Instead, under "Requirement" and "Compliance", it directs action "in accordance with FAA AD 2007-24-05" and states compliance is "As detailed in FAA AD 2007-24-05 with a revised effective date of 31 July 2008." The practical effect is that the FAA AD supplies the substantive tasks, inspection intervals, and terminating action requirements; the Australian instrument makes that FAA AD the operative standard for Australian operators for the purposes stated.

2. Alternative means of compliance (AMOC): The directive authorises an AMOC consisting of installation of a single or multi orifice restrictor replacing the starter adapter drain cap assembly. The directive lists specific approved part numbers by engine model: AE3007A engines P/N 23074840, 23074537 and 23075806; AE3007C engines P/N 23074840 and 23076015. The instrument explicitly states that this AMOC is "approved as an alternative means of compliance" to the FAA AD requirements, signalling regulatory recognition that a part replacement can satisfy the safety issue addressed by the FAA AD.

3. Time-limited approval and terminating action: The AMOC approval is explicitly temporary. The directive states the AMOC "is approved until the terminating action detailed in paragraph (g) of FAA AD 2007-24-05 is required to be incorporated" and notes that the compliance time for that paragraph is 30 September 2009. The directive therefore sets a two-stage compliance pathway: (a) immediate adoption of the FAA AD measures or the AMOC restrictor as an interim solution; and (b) incorporation of the FAA AD terminating modification by the stated deadline.

Other supporting concepts in the text are scope and applicability, and the stated causal safety concern. Under "Applicability" the directive identifies the affected engines as Rolls Royce (formerly Allison Engine Company, Inc.) AE 3007A and AE 3007C series turbofan engines and adds that "These engines are installed on but not limited to Embraer EMB-135 and EMB-145 and Cessna 750 series aeroplanes." Under "Background" the directive states it was prompted by "reports of in-flight engine shutdowns" attributed to "loss of engine oil from the starter shaft seal" and that the measures are "intended to prevent an in-flight engine shutdown due to loss of engine oil."

Mechanically, therefore, the directive binds Australian operators to FAA AD 2007-24-05, permits a specifically enumerated parts-based AMOC for an interim period, and mandates eventual incorporation of the FAA AD terminating action by a stated date.

The instrument identifies its primary targets plainly: operators, owners, and maintenance organisations responsible for Rolls Royce (Allison) AE 3007A and AE 3007C series turbofan engines. The "Applicability" clause reads: "These engines are installed on but not limited to Embraer EMB-135 and EMB-145 and Cessna 750 series aeroplanes." That phrasing indicates the directive is intended to apply to all installations of AE 3007A and AE 3007C engines in Australian-registered aircraft, not only the named airframes.

Who pays: The document does not set out an express cost recovery mechanism. The operational implication is that the aircraft operator or owner generally bears the direct costs of compliance: obtaining and installing the approved restrictor P/Ns and/or carrying out the terminating action specified in paragraph (g) of FAA AD 2007-24-05. The directive specifies the parts by part number for the AMOC, which creates a procurement obligation for the party responsible for maintenance. The directive does not provide parts or funding, nor does it mention alternative funding routes.

Who decides: The directive was issued under the authority of the Civil Aviation Safety Authority and signed by James Coyne, "Delegate of the Civil Aviation Safety Authority" on 13 June 2008. That indicates CASA exercised regulatory authority to accept FAA AD 2007-24-05 as the compliance instrument for Australian operators and to approve the specific AMOC. The FAA AD remains the source of the detailed tasks and the terminating action in paragraph (g), which the directive imports; therefore both CASA (for the Australian directive and AMOC approval) and the FAA (as author of FAA AD 2007-24-05 and its terminating action) are relevant decision nodes in practice.

What must change in behaviour: Operators must act in accordance with FAA AD 2007-24-05 or adopt the AMOC restrictor listed in this directive. Where the AMOC is chosen, operators must install one of the approved restrictor P/Ns appropriate to their engine model. Eventually, before or by 30 September 2009, operators must incorporate the terminating action specified in paragraph (g) of FAA AD 2007-24-05, at which point the AMOC approval ceases. Maintenance organisations and licensed engineers will be responsible for fitting, paperwork, and ensuring compliance.

Scope limits: The directive names specific engine series and gives examples of airframes but states "not limited to", so any aircraft fitted with AE3007A or AE3007C engines fall within scope, irrespective of make or type beyond those examples. The directive does not list exemptions or carve-outs.

The directive creates a discrete set of duties and a limited right to use an alternative means of compliance. The operative duties are stated in the "Requirement" and "Compliance" entries.

Primary duties:

• Comply with FAA AD 2007-24-05. The directive expressly instructs: "Action in accordance with FAA AD 2007-24-05." That means the substantive tasks, inspections, compliance times and the terminating action set out in the FAA AD are required under Australian regulation as of the revised effective date of 31 July 2008.
• Incorporate the terminating action in paragraph (g) of FAA AD 2007-24-05 by the compliance time specified. Note 2 states the compliance time for paragraph (g) is 30 September 2009, and the directive reiterates that the AMOC approval remains only until that terminating action is required to be incorporated.

Alternative means of compliance:

• The directive grants an explicit AMOC option: "Installation of a single orifice or multi orifice restrictor which replaces the starter adapter drain cap assembly is approved as an alternative means of compliance to the requirements detailed in FAA AD 2007-24-05."
• The right to use that AMOC is defined narrowly by engine model and approved part numbers. For AE3007A engines the approved P/Ns are 23074840, 23074537 and 23075806. For AE3007C engines the approved P/Ns are 23074840 and 23076015.
• The AMOC approval is time-limited: it is "approved until the terminating action detailed in paragraph (g) of FAA AD 2007-24-05 is required to be incorporated." Practically, Note 2 fixes that date as 30 September 2009.

Procedural duty timing:

• The directive's "Compliance" entry notes that compliance follows FAA AD 2007-24-05 "with a revised effective date of 31 July 2008." The amendment itself becomes effective on 31 July 2008. Operators therefore had a specific revised effective date to align their actions with.

Rights or entitlements:

• Operators have the right to use the specified AMOC in place of the FAA AD measures, up to the terminating action deadline. The directive does not state a right to payment, waiver, or reimbursement.
• The directive does not grant discretion to individual operators to choose an unlisted alternative means of compliance; only the listed restrictor P/Ns are "approved" as an AMOC in this instrument.

Record keeping and certification: The directive does not explicitly prescribe paperwork or the method of recording compliance. However, by requiring actions "in accordance with FAA AD 2007-24-05", operators will need to follow any recording, logbook or certification steps which the FAA AD demands. The Australian directive does not itself spell out those administrative duties; it imports them by reference.

Limits and conditions: The AMOC is not an indefinite substitute. The duty to incorporate the terminating action by the stated time places a future compulsory modification obligation on operators regardless of whether the restrictor is installed in the interim.

The text of the directive itself does not specify civil or criminal penalties, fines, or particular enforcement procedures. The instrument is an airworthiness directive; it prescribes mandatory action and an effective date, but it does not enumerate sanctions within the document.

What the source says:

• The directive contains "Requirement" and "Compliance" instructions and an effective date. It was issued by an authorised CASA delegate, James Coyne, which indicates it is a binding regulatory instrument within the aviation safety framework. The directive does not include a penalties section or reference to enforcement measures.

Consequences implied by regulatory context in the instrument:

• Because the directive requires compliance "in accordance with FAA AD 2007-24-05", failure to comply would leave the aircraft non-compliant with the delegated airworthiness obligations imposed by CASA. The directive does not itself list the consequence mechanism, but mandatory compliance obligations typically mean the affected aircraft are not airworthy for regulated operations until compliance is demonstrated. The document does not state how CASA will verify compliance, conduct audits, or impose remedial measures.

Enforcement actors and authority:

• The directive was signed by a CASA delegate. That signals CASA as the regulatory authority responsible for issuance. The FAA is the source of the incorporated AD and the terminating action, but the Australian instrument is the legal vehicle for Australian enforcement. The text does not describe enforcement delegation mechanisms, inspectors’ powers, or administrative procedures.

Limits on AMOC enforcement:

• The AMOC is approved until the terminating action is required to be incorporated. The document does not specify enforcement steps to ensure removal or replacement of the AMOC after that date; it only sets the deadline. Responsibility for incorporation by that date rests with operators.

In sum, the directive imposes mandatory compliance obligations but does not, within its own text, specify penalties or enforcement processes. Any sanctions or enforcement procedures would arise from the broader statutory and regulatory framework within which CASA operates; none of those measures are described in the instrument supplied.

The directive explicitly integrates and references foreign regulatory material and earlier directives, creating cross-references that determine applicable tasks and timelines.

Incorporation of FAA AD:

• The instrument requires action "in accordance with FAA AD 2007-24-05." That means the FAA AD supplies the detailed requirements, and the Australian directive operates by importing those requirements into the Australian regulatory setting. The "Compliance" entry restates this by noting compliance is "As detailed in FAA AD 2007-24-05 with a revised effective date of 31 July 2008."

Supersession history:

• The directive records that "FAA AD 2007-24-05 amendment 39-15271 dated 14 November 2007 supersedes FAA AD 99-02-51." The instrument therefore relies on the most recent FAA AD and acknowledges the prior FAA AD as superseded. For Australian compliance purposes the current FAA AD is the operative text to be followed.

AMOC relationship to FAA AD:

• The directive both requires the FAA AD and simultaneously approves a particular AMOC as an alternative means of compliance to the FAA AD requirements. That creates a conditional relationship: the FAA AD remains the baseline regulation, but the Australian directive authorises a specific substitution until the FAA AD terminating action becomes mandatory. The instrument therefore creates a bridge between Australian regulatory authority and the FAA AD compliance pathway.

Interaction with Australian aviation law:

• The directive itself is issued by CASA and becomes effective in Australia. It does not quote specific sections of Australian aviation statutes or regulations, but by being issued by CASA it exists within the Australian airworthiness regulatory framework. The directive does not amend Australian primary legislation. Rather, it is an instrument in the body of airworthiness directives which operators must follow to maintain compliance with Australian airworthiness obligations. The directive does not specify how it affects related Australian instruments, approvals, or certificates.

Cross-jurisdictional dependence:

• Because the directive imports FAA AD 2007-24-05 and references FAA amendment numbers, Australian compliance is functionally dependent on an FAA text for substantive detail. The Australian instrument provides a limited, specified AMOC and sets Australian effective dates and a terminating action deadline, but the substantive work (inspection intervals, detailed steps and the terminating action described in paragraph (g)) is sourced from an FAA document. Operators therefore must consult both instruments to be fully compliant.

No mention of other laws or acts:

• The directive does not reference or interact directly with other Australian laws, such as statutes governing administrative review, penalties, or aviation safety regulation, within its text. It also does not refer to any exemption mechanisms, compensatory schemes, or civil liability provisions. Its interactions are confined to FAA ADs and the Australian instrument itself.

In sum, the directive operates by importing an FAA AD, authorising a narrow AMOC, recording supersession of an earlier FAA AD, and setting an Australian effective date and deadline for the FAA AD terminating action. The document thereby creates an interlocking compliance obligation that requires operators to work with both the FAA AD text and the Australian amendment.

The instrument contains a concise internal amendment history within its text. The key dates and changes stated are:

• Original issue: The "Background" notes "The original issue of this Directive became effective on 14 April 2005." That identifies the directive's first appearance in Australian records as 14 April 2005.

• FAA AD supersession: The directive records that "FAA AD 2007-24-05 amendment 39-15271 dated 14 November 2007 supersedes FAA AD 99-02-51." That provides a chain of FAA AD amendments that the Australian instrument follows.

• Present amendment effective date: The amendment currently under review, AD/AE 3007/4 Amdt 1, "becomes effective on 31 July 2008." The "Compliance" entry mirrors this by noting compliance is to be as detailed in FAA AD 2007-24-05 "with a revised effective date of 31 July 2008."

• Approval of AMOC in this amendment: The present amendment explicitly provides that installation of specific restrictor part numbers is "approved as an alternative means of compliance." It lists the P/Ns applicable to AE3007A and AE3007C engines. The amendment also provides that the AMOC is approved only until the FAA AD terminating action must be incorporated.

• Terminating action deadline: The amendment notes (Note 2) that the compliance time for paragraph (g) of FAA AD 2007-24-05 is 30 September 2009, and the amendment states that the AMOC is approved until that terminating action is required to be incorporated.

• Signing and date of issue: The amendment bears the signature line "James Coyne, Delegate of the Civil Aviation Safety Authority" dated 13 June 2008. That shows the administrative act occurred on 13 June 2008, with the effective date set later on 31 July 2008.

The amendment therefore represents a mid-course adjustment in a longer-running airworthiness monitoring and corrective action process that began at least with the original directive effective 14 April 2005 and reflects updated FAA AD material from November 2007. Its key functional change is to grant a specific parts-based AMOC for a limited period and to fix a firm deadline for the FAA AD terminating action. The amendment text does not include any other revisions, rescissions, or broader regulatory restructuring, nor does it set out procedures for future amendments beyond the terminating action date imposed by the FAA AD.

The supplied instrument contains no reference to litigation, judicial review, administrative appeals, or court decisions. The text includes no citations of cases, no mention of court challenges to the original directive or this amendment, and no record of contested proceedings. The "Background" recounts safety incidents that prompted the directive but does not reference any legal proceedings arising from those incidents.

What the source shows:

• The directive documents administrative steps: original issue effective 14 April 2005; FAA AD 2007-24-05 amendment 39-15271 dated 14 November 2007 superseding an earlier FAA AD; and this amendment effective 31 July 2008 signed by a CASA delegate on 13 June 2008. There is no material in the text suggesting any litigation or legal contestation of the directive or its predecessor instruments.

Implication for researchers:

• If litigation or administrative review existed, it is not recorded in this instrument. Any enquiry into litigation would require consultation beyond this document. The instrument itself supplies no grounds, parties, filings, outcomes or procedural history to analyse or cite.

Therefore, on the basis of the supplied text alone, there is no litigation history to record.

This directive contains several textually explicit features that create operational traps if overlooked. The following are concrete pitfalls drawn from the instrument’s wording.

1. Temporary AMOC approval. The AMOC is explicitly time-limited. The directive states the restrictor installation "is approved as an alternative means of compliance" but only "until the terminating action detailed in paragraph (g) of FAA AD 2007-24-05 is required to be incorporated." Note 2 fixes that compliance time as 30 September 2009. Operators who treat the restrictor installation as a permanent fix may be non-compliant after the terminating action date. The instrument does not provide a mechanism in this text to renew or extend the AMOC.

2. Dual-document compliance requirement. The directive does not restate the FAA AD in full. It requires action "in accordance with FAA AD 2007-24-05." That means operators must consult the FAA AD to know the detailed tasks, intervals and the content of paragraph (g). Failure to consult the FAA AD or to follow its detailed instructions could result in incomplete compliance. The Australian instrument’s brevity may lead to misreading if one treats only this text as sufficient.

3. Part numbers differ by engine model. The approved restrictor P/N lists are engine-specific: AE3007A and AE3007C have overlapping but not identical approved P/Ns. Installing an incorrect part number for a given engine model could be an invalid AMOC. The directive lists P/Ns precisely: AE3007A P/Ns 23074840, 23074537 and 23075806; AE3007C P/Ns 23074840 and 23076015. The presence of one P/N (23074840) on both lists suggests potential confusion; operators must check engine model fitment carefully.

4. Applicability language "not limited to". The instrument names Embraer EMB-135, EMB-145 and Cessna 750 as examples but adds "not limited to". Operators of other airframes with AE3007 engines may fail to recognise they are affected if they rely on examples rather than engine fitment. The correct test is engine model, not airframe make/model examples.

5. Effective and compliance dates. The amendment "becomes effective on 31 July 2008." The AMOC approval is tied to that effective date and the FAA AD terminating action deadline of 30 September 2009. Operators must ensure scheduling of maintenance to both meet immediate requirements and to plan for the terminating action deadline. The directive does not specify lead-in windows or grace periods beyond these dates.

6. No penalties described. The instrument does not state penalties. Absence of penalties in the text does not mean failure to comply is without consequence, but the instrument itself provides no enforcement mechanics. Operators cannot rely on lack of explicit sanctions as a defence to non-compliance.

7. Reliance on FAA materials. Because the directive imports FAA AD 2007-24-05 and references FAA amendment numbers, any updates, clarifications or revisions to the FAA AD after the effective date may be relevant. The Australian directive does not itself commit to automatically adopt future FAA changes; it binds operators to follow the specified FAA AD with the Australian effective date. This creates a potential source of confusion about whether subsequent FAA guidance affects Australian obligations unless CASA issues further amendments.

8. Terminology and documentation. The directive refers to "starter adapter drain cap assembly" and to "starter drive adaptor pad drain" in the Background clause that allows modification with an orifice. Differences in terminology across maintenance manuals, parts catalogues and FAA AD language could produce misinterpretation; maintenance organisations must reconcile the terms with the FAA AD and parts catalogues to ensure correct installations.

These are concrete operational "gotchas" flowing from the precise textual provisions of the directive; they do not invoke matters outside the supplied instrument.

The directive provides a clear, two-step compliance pathway that operators should follow precisely and document. Below are the action steps grounded in the instrument’s wording.

1. Identify applicability. Confirm whether the aircraft is fitted with Rolls Royce (Allison) AE3007A or AE3007C series turbofan engines. The directive’s "Applicability" states these engine series are affected and notes they are installed on, but not limited to, Embraer EMB-135/145 and Cessna 750 series aeroplanes. The correct trigger for compliance is engine model, not airframe examples.

2. Obtain and review FAA AD 2007-24-05. The directive requires action "in accordance with FAA AD 2007-24-05." Operators must obtain the full FAA AD text, including paragraph (g) which contains the terminating action, and follow its inspection schedules, procedures and any documentation requirements. The Australian directive sets a revised effective date of 31 July 2008 for that FAA AD in Australia.

3. Choose compliance route: FAA AD actions or AMOC restrictor. The directive expressly authorises an AMOC consisting of installing a single or multi orifice restrictor which replaces the starter adapter drain cap assembly. If electing the AMOC, ensure you install an approved part number appropriate to the engine:

   • AE3007A engines: P/N 23074840, 23074537, or 23075806.
   • AE3007C engines: P/N 23074840 or 23076015. Only these P/Ns are "approved" as set out in the directive.

4. Time-limit planning. If using the AMOC, track the terminating action deadline. The directive states the AMOC "is approved until the terminating action detailed in paragraph (g) of FAA AD 2007-24-05 is required to be incorporated." Note 2 sets the compliance time for paragraph (g) as 30 September 2009. Plan maintenance schedules and parts procurement so that the terminating action is incorporated by that date.

5. Document installations and compliance actions. The directive does not prescribe exact paperwork, but because the FAA AD is the operative compliance instrument and because regulatory records will be needed to demonstrate airworthiness, record:

   • Engine serial numbers and airframe registration.
   • Part numbers installed and source documentation.
   • Maintenance release entries, certificates of conformity or maintenance releases as required under applicable maintenance regulations.
   • Dates of installation and any inspections performed in accordance with FAA AD 2007-24-05.

6. Coordinate with maintenance organisations and parts suppliers. Ensure the approved P/Ns are procured and that the maintenance organisation understands the AMOC is a temporary compliance route. Confirm fitment instructions with engine manufacturer documentation and the FAA AD text to avoid installing an incorrect component for a given engine model.

7. Prepare for terminating action. The directive requires incorporation of the terminating action in paragraph (g) of the FAA AD by 30 September 2009. Determine whether the terminating action is a replacement, modification, or other hardware change, and budget time and resources for its implementation. Because the directive imports paragraph (g) from the FAA AD without reproducing it, operators must ensure they adhere to the FAA AD’s specific technical steps for the terminating action.

8. Monitor for further CASA guidance. Although the directive sets the Australian effective date and AMOC terms, CASA may issue future amendments, clarifications or directives. Maintain a process to check CASA publications for any updates.

9. Avoid assumptions about enforcement. The instrument does not list penalties. Do not interpret that as permissiveness. Treat compliance as mandatory and maintain records to demonstrate it.

Following these steps aligns operational practice with the directive’s requirements: consult and follow FAA AD 2007-24-05, or install one of the approved restrictor P/Ns as an AMOC until the terminating action is required to be incorporated by 30 September 2009, and maintain appropriate maintenance and compliance records to substantiate conformity with the directive and the imported FAA AD.