AD/B717/31 - Elevator Standby Cable

The instrument is concise and built around a narrow airworthiness concern. The central mechanical risk identified is binding of the bolt that connects cable 264A clevis to the bellcrank assembly against the adjacent (upper) clevis of the pull‑pull cable assembly. The AD identifies three inspection focal points: (a) interference between the clevis and bolt of the bellcrank assembly, (b) the orientation of the pull‑pull cable clevis bolt, and (c) excessive freeplay of the bellcrank assembly bearing. These three items form the checklist for the required general visual inspection mandated for all aeroplanes within the AD’s applicability.

The AD tokenises compliance into two layers. Requirement 1 is a universal inspection plus any corrective actions discovered, to be completed within a fixed flight‑hours/elapsed‑time window relative to the AD’s effective date (3,000 flight hours or 27 months, whichever later). Requirement 2 applies only to the subset of aeroplanes classified as Group 1, Configuration 1 in Boeing ASB 717-27A0039 and demands a modification to the pull‑pull cable clevis in the drive assembly of the aft elevator standby loop at the Boeing‑specified compliance time. The AD ties both requirements to the Boeing ASB as the procedural and technical source: the AD states "Do the applicable actions specified in Requirements 1 and 2 of this AD in accordance with Boeing Alert Service Bulletin (ASB) 717-27A0039 dated 6 December 2007."

The AD also incorporates a cross‑jurisdictional acceptance mechanism. It permits later revisions of the Boeing ASB to be used for compliance, but only where those later revisions have been approved by the FAA as an AMOC to FAA AD 2008‑18‑05. In other words, CASA conditions acceptance of subsequent service bulletin revisions on FAA AMOC approval for the corresponding FAA AD. The AD expressly refers to FAA AD 2008‑18‑05 (Amdt 39‑15662 dated 18 August 2008) as related material.

The safety logic articulated in the AD is causal: the identified mechanical interference can bind the clevis/bolt and thereby either slow rotation (reduced takeoff performance) or cause a control column disconnect, which in turn could lead to an aborted takeoff followed by a runway excursion. The AD therefore links a discrete inspection and a discrete modification to an operational harm scenario and prescribes immediate corrective actions "before further flight" if non‑conformities are found.

The instrument’s applicability is narrow and clearly specified: McDonnell Douglas Model 717‑200 aeroplanes that appear in Boeing Alert Service Bulletin 717‑27A0039 dated 6 December 2007. The AD therefore affects owners and operators of those specific 717‑200 aeroplanes whose serial numbers or configurations are identified in the Boeing ASB. The AD further divides affected aeroplanes into at least one subgroup: Group 1, Configuration 1 aircraft to which the modification requirement (Requirement 2) applies. Operators must consult the Boeing ASB to determine whether a particular aeroplane is within the AD’s scope and whether it falls into Group 1, Configuration 1.

Who pays: the costs of compliance fall to the operators/owners of the affected aeroplanes. The AD prescribes a visual inspection and possible corrective actions, and for some aeroplanes a modification of the pull‑pull cable clevis. Those inspections, corrective repairs and modifications require labour time, replacement components if parts are unserviceable, maintenance planning, and aircraft downtime. The AD’s compliance times (see Requirement 1: "Within 3,000 flight hours or 27 months after the effective date of this AD, whichever occurs later" and Requirement 2: at the time specified in paragraph 1.E of the ASB subject to the AD’s caveat) influence operators’ maintenance scheduling and commercial availability of aircraft.

Who decides operational impact: maintenance control and the operator must implement the inspection and corrective actions as specified in the Boeing ASB. The AD ties the technical work to Boeing’s ASB procedures, so the operator decides how to schedule and fund the work, but must do so using the ASB instructions or FAA‑approved AMOC versions. CASA (the Civil Aviation Safety Authority) made the AD effective in Australia on 20 November 2008 by issuing the instrument; the AD is signed by a CASA delegate (Charles Lenarcic, dated 22 September 2008). The AD therefore directs Australian operators to follow the stated requirements; any operator intending to use a revised ASB must ensure that revision has FAA AMOC approval to be considered acceptable under this AD.

Who executes the work: licensed maintenance organisations and appropriately authorised engineers or mechanics will carry out the inspections and modifications under the operator’s maintenance procedures using Boeing ASB instructions. The AD does not specify who must do the work beyond requiring compliance "in accordance with Boeing Alert Service Bulletin (ASB) 717‑27A0039 dated 6 December 2007" and that corrective actions must be completed "before further flight."

Key duties

• Determine applicability. Operators must check whether their Model 717‑200 aeroplane is identified in Boeing ASB 717‑27A0039 dated 6 December 2007. The applicability clause in the AD directs operators to the ASB for specific identification. If an aeroplane is identified, the operator must proceed with the actions required by this AD.

• Perform the inspection. For all aeroplanes in the AD’s applicability, perform a general visual inspection of the drive assembly of the aft elevator standby loop for: (1) interference between the clevis and bolt of the bellcrank assembly; (2) correct orientation of the pull‑pull cable clevis bolt; and (3) excessive freeplay of the bellcrank assembly bearing. This is set out as Requirement 1.

• Correct any defects before further flight. The AD instructs operators to "Do all applicable corrective actions before further flight." Thus, if the inspection reveals interference, incorrect bolt orientation, or excessive freeplay, the operator must correct those conditions and may not return the aeroplane to service until the applicable corrective actions are completed.

• Modify for Group 1, Configuration 1 aeroplanes. For aeroplanes identified in the Boeing ASB as Group 1, Configuration 1, complete the modification to the pull‑pull cable clevis in the drive assembly of the aft elevator standby loop as specified in Requirement 2.

• Follow Boeing ASB procedures. The AD requires that the applicable actions be accomplished "in accordance with Boeing Alert Service Bulletin (ASB) 717‑27A0039 dated 6 December 2007." That links the technical method, parts, and sequence to Boeing’s published procedure. Later revisions of the ASB are acceptable only if they have FAA AMOC approval to FAA AD 2008‑18‑05.

• Meet compliance times. For Requirement 1, comply "Within 3,000 flight hours or 27 months after the effective date of this AD, whichever occurs later." For Requirement 2, comply at the time specified in paragraph 1.E, "Compliance," of the Boeing service bulletin, with the AD’s caveat about service bulletin compliance times that run from the bulletin date.

Rights and procedural flexibilities

• Use of FAA‑approved AMOCs. The AD allows operators to use later revisions of Boeing ASB 717‑27A0039 if those later revisions have FAA AMOC approval to FAA AD 2008‑18‑05. That creates a procedural pathway to rely on updated Boeing service bulletin material, subject to FAA approval. The AD does not itself specify a CASA AMOC process in this text; it specifies FAA AMOC approval as the gateway for accepting later ASB revisions for compliance.

• Choice of corrective actions consistent with ASB. The AD requires "Do all applicable corrective actions" discovered during inspection but ties the method to the Boeing ASB. The operator has the right to rely on the ASB’s corrective action procedures or an FAA‑approved AMOC revision, rather than inventing alternative fixes.

• Timing flexibility within set limits. For Requirement 1 operators have a calendar or utilisation‑based window (3,000 flight hours or 27 months, whichever later) to plan the inspection. For Requirement 2 the timing follows the Boeing ASB’s paragraph 1.E, subject to the AD’s caveat converting some service‑bulletin‑dated timings to run from the AD’s effective date.

Limitations the AD imposes

• Work must be done before further flight where corrective action is required. This limits operators’ ability to defer fixes discovered through inspection while continuing operations.

• Use of non‑ASB procedures is not authorised by the AD text except insofar as later ASB revisions have FAA AMOC approval. The AD does not provide CASA‑level AMOCs in the instrument text itself, nor does it list alternative approved methods.

All duties and rights in the AD are framed by the specific language used in the instrument: inspection requirements, corrective actions before further flight, modification for a specified subgroup, reliance on the Boeing ASB dated 6 December 2007 and FAA‑approved subsequent revisions, and the stated compliance times.

The AD text itself does not enumerate monetary penalties, administrative fines, or criminal sanctions. What the AD does do, in concrete terms, is set technical and timing obligations and impose an operational constraint by requiring that applicable corrective actions discovered during inspection be completed "before further flight." That requirement has direct operational consequences: an aeroplane with an unresolved applicable defect discovered under Requirement 1 cannot be returned to service until the defect is addressed in accordance with the AD and the linked Boeing ASB.

Enforcement mechanics implicit in the instrument

• AD as an operational requirement. The AD makes the inspections and modifications mandatory for aeroplanes that fall within its stated applicability. The effective date is 20 November 2008. The obligations are therefore time‑bound and become operational duties from that effective date. For Requirement 1 the compliance deadline is a maximum of 3,000 flight hours or 27 months after the effective date, whichever occurs later. For Requirement 2 the timing follows paragraph 1.E of the Boeing ASB subject to the AD’s conversion rule.

• Immediate operational constraint on return to service. The AD’s instruction to "Do all applicable corrective actions before further flight" is a clear operational instruction; it means that if the inspection reveals a disqualifying condition, the operator must take corrective action,using the Boeing ASB procedure or an acceptable FAA‑AMOC revision,before the aircraft flies again.

• Reliance on Boeing ASB and FAA AMOCs. The AD ties the method of compliance to Boeing ASB 717‑27A0039 dated 6 December 2007, and accepts later revisions only where those revisions have FAA AMOC approval to FAA AD 2008‑18‑05. That creates a compliance pathway whose acceptability is gated by FAA action. For enforcement purposes, CASA will evaluate compliance against the AD and the technical documentation specified in it, specifically the Boeing ASB or an FAA‑approved AMOC revision.

What the text does not state

• The AD does not specify civil penalty amounts, demerit point regimes, or a schedule of fines for non‑compliance within the instrument text provided. It does not set out an administrative enforcement procedure or a prosecution pathway in the text supplied. It likewise does not provide particulars on who is authorised to accept deviations or to grant relief from the AD’s requirements within CASA. The AD instead prescribes the technical requirements, compliance timing and the procedural dependence on Boeing ASB and FAA AMOC approvals.

Practical enforcement implication

• The most immediate practical enforcement lever embedded in the AD language is the operational prohibition implicit in the "before further flight" clause. That clause functions to remove aircraft with unresolved applicable defects from service until correction occurs according to the AD’s specified methods. For operators, that means scheduling and funding repairs promptly if the inspection reveals an issue. The AD’s cross‑reference to FAA AMOCs also shapes enforcement: to rely on a later ASB revision, operators must ensure the revision carries FAA AMOC approval to be considered an acceptable compliance route under this AD.

The AD explicitly references and interacts with US regulatory material and Boeing service instructions. The AD states that later revisions of Boeing ASB 717‑27A0039 are acceptable for compliance "where the service bulletin" revision has been approved by the United States Federal Aviation Administration (FAA) as an Alternate Method of Compliance (AMOC) to FAA AD 2008‑18‑05. The AD also includes a note that FAA AD 2008‑18‑05 Amdt 39‑15662 dated 18 August 2008 is referred to. Those references create cross‑jurisdictional interoperability: the AD requires adherence to Boeing’s ASB procedures while treating FAA AMOC approval as the gateway for CASA acceptance of later technical revisions.

Specific interactions stated in the instrument

• Boeing ASB as the technical standard. The AD requires actions be done "in accordance with Boeing Alert Service Bulletin (ASB) 717‑27A0039 dated 6 December 2007." The AD therefore imports the technical methods, part numbers, and compliance mechanisms contained in that ASB into Australian regulatory compliance for the relevant aircraft. Operationally, the ASB becomes the technical baseline against which compliance is judged.

• FAA AD and FAA AMOC approvals. The AD directly references FAA AD 2008‑18‑05 and makes FAA AMOC approvals relevant to Australian compliance. That creates a specific interface: later ASB revisions approved by the FAA as AMOCs for FAA AD 2008‑18‑05 are treated as acceptable compliance material for CASA’s AD. The AD does not state a parallel CASA AMOC process in the text provided; instead it defers to FAA AMOC approvals for later ASB revisions to be deemed acceptable.

What is not in the instrument

• The AD does not recite other Australian statutes, regulations or regulatory manuals; the text does not identify specific sections of Australian aviation law under which the AD is promulgated. It does not list CASA enforcement powers, penalty schedules, or administrative processes in the text provided.

Operational implication of the cross‑references

• Operators must consult Boeing ASB 717‑27A0039 for specific identification of affected aircraft, compliance steps and any specified parts or kits. Where an operator seeks to use a later revision of the ASB, that revision is only acceptable for compliance if it has received FAA AMOC approval to FAA AD 2008‑18‑05. Thus compliance with the CASA AD implicitly requires monitoring FAA actions and Boeing ASB revisions that are specifically approved by the FAA as AMOCs to the relevant FAA AD.

• Given those links, the AD effectively binds Australian compliance to a chain: CASA AD instructs operators to follow Boeing ASB dated 6 December 2007 or later ASB revisions only with FAA AMOC approval to FAA AD 2008‑18‑05, and it refers to FAA AD 2008‑18‑05 as relevant material.

The AD text as supplied contains limited amendment history. What is recorded in the instrument is:

• Issue date and delegate signature. The AD is signed by Charles Lenarcic as Delegate of the Civil Aviation Safety Authority, dated 22 September 2008. The instrument states that it "becomes effective on 20 November 2008."

• Cross‑reference to FAA AD. It refers to FAA AD 2008‑18‑05 (Amdt 39‑15662 dated 18 August 2008). That cross‑reference indicates contemporaneous action by the FAA relevant to the same technical issue.

• Acceptance of later ASB revisions subject to FAA AMOC approval. The AD specifically permits later revisions of Boeing ASB 717‑27A0039 to be used for compliance if those later revisions have been approved by the FAA as AMOCs to FAA AD 2008‑18‑05. That clause functions as an openness to future technical updates but conditions their acceptability on FAA approval.

What the AD does not contain in the supplied text

• The AD text does not list prior versions of CASA's AD/B717/31 or any prior amendments to this Australian AD. The instrument appears to be a standalone issuance with an effective date rather than an amendment of an earlier CASA AD. No subsequent CASA amendments, supersessions, or revocations are listed in the supplied text.

• The AD does not identify a CASA internal amendment or an earlier emergency AD; it only gives the AD number (AD/B717/31), the problem statement, the required actions, the Boeing ASB reference and the FAA cross‑references.

Operational takeaway on amendment tracking

• Operators should note that the AD explicitly permits later Boeing ASB revisions for compliance only where those revisions have FAA AMOC approval to FAA AD 2008‑18‑05. Consequently, tracking the amendment history for purposes of compliance requires monitoring FAA AD 2008‑18‑05 updates and any FAA AMOC approvals related to Boeing ASB 717‑27A0039. The AD itself does not list or commit to CASA amendments; therefore, to establish whether the AD has been amended since the effective date supplied (20 November 2008), operators would need to consult CASA’s official AD database or formal amendment notices beyond the text provided here.

The supplied AD text contains no litigation history. It does not list any court cases, appeals, administrative reviews, or other contested proceedings either challenging the AD or interpreting its requirements. The instrument contains only the directive text, its effective date, its signature, and the cross‑reference to the FAA AD and the Boeing ASB.

What the absence of litigation references implies for a practitioner reading this AD

• There are no recorded judicial or administrative decisions referenced in the text to interpret ambiguity in the AD’s wording, to establish precedential points on how CASA will apply the "before further flight" requirement, or to constrain the meaning of "applicable corrective actions." In the absence of decisions cited in the AD, operators and counsel must rely on the plain AD language and any CASA guidance outside the instrument for interpretive clarity.

• The AD does reference FAA material (FAA AD 2008‑18‑05 and FAA AMOC approvals). If disputes arise concerning the acceptability of later Boeing ASB revisions, the FAA’s AD, AMOC decisions, and FAA administrative records would likely be relevant. The supplied AD text indicates CASA’s acceptance of FAA AMOCs for later ASB revisions, but it does not supply CASA’s own administrative practice notes or adjudicated interpretations.

Practical steps for operators and advisers

• Because the AD text provides no litigation history, practitioners should treat the document as a primary regulatory directive and, where necessary, seek contemporaneous records from CASA and FAA about AMOC approvals, service bulletin revisions, and any subsequent CASA AD amendments. Any legal contestation or interpretation not reflected in the AD text would need to be researched through external CASA and FAA records and, where relevant, judicial or administrative filings outside the AD instrument.

Several practical pitfalls and potential sources of compliance error are embedded in the AD’s text and structure. These are matters to check and confirm rather than speculative critique.

1. Applicability depends on Boeing ASB identification. The AD’s applicability clause points to Boeing ASB 717‑27A0039 dated 6 December 2007 for identification of affected Model 717‑200 aeroplanes. An operator who relies only on general Model 717‑200 type identification without checking the ASB’s serial‑number or configuration lists risks missing whether their aeroplane falls into the AD’s scope, and whether it is specifically within Group 1, Configuration 1 (which triggers Requirement 2). In short, do not assume all 717‑200s are covered without consulting the Boeing ASB.

2. Two different timing regimes; the "whichever occurs later" trap. Requirement 1 requires the inspection "Within 3,000 flight hours or 27 months after the effective date of this AD, whichever occurs later." That phrasing can extend the compliance deadline for low‑utilisation aircraft beyond 27 months. Operators must compute the later of the two measures, not the earlier, to avoid mis-timing the inspection.

3. Requirement 2 timing depends on paragraph 1.E of the ASB and the AD’s caveat. Requirement 2 directs operators to perform the modification "At the applicable time specified in paragraph 1.E., 'Compliance,' of the service bulletin; except, where the service bulletin specifies a compliance time after the date on the service bulletin, this AD requires compliance within the specified compliance time after the effective date of this AD." That requires careful translation: if the ASB sets a countdown from the ASB date, the AD converts that countdown to start from the AD’s effective date. Operators must therefore carefully read paragraph 1.E of the Boeing ASB and apply the AD’s conversion rule to yield the correct deadline.

4. Corrective actions must be done before further flight. The AD’s instruction to "Do all applicable corrective actions before further flight" is absolute in its phrasing. If the inspection finds a condition the ASB or AD deems corrective, the aeroplane must be kept out of service until corrected. Failure to follow that operational constraint is a direct non‑compliance risk.

5. Acceptance of later ASB revisions is conditional on FAA AMOC approval. The AD permits later revisions of Boeing ASB 717‑27A0039 to be acceptable only where the FAA has approved them as an AMOC to FAA AD 2008‑18‑05. If an operator attempts to follow a later Boeing ASB revision that has not received FAA AMOC approval for FAA AD 2008‑18‑05, the AD does not accept that revision for compliance in Australia under the text provided.

6. Reliance on Boeing ASB for technical detail. The AD references Boeing ASB 717‑27A0039 for the procedural mechanics. The AD itself does not reproduce the detail of how to perform inspections, how to make the modification, or what part numbers to use. Operators must obtain and follow the Boeing ASB to execute compliant work. Missing or misreading ASB paragraph references (for instance, an error in applying paragraph 1.E) creates a compliance risk.

7. Limited remedy language in the AD. The AD provides no CASA AMOC pathway or local deviations in the text supplied. If an operator needs a deviation or a different repair method, the AD text does not specify CASA processes or whether CASA will accept alternative methods without FAA AMOC approval; therefore, operators should assume that deviations require prior approval that is not described in this AD text.

8. Narrow safety rationale tied to a particular failure mode. The AD is framed to address a specific mechanical interference that could cause a control column disconnect or slow rotation. If an operator finds other unrelated defects during inspection, the AD does not prescribe outcomes for those defects beyond the general "Do all applicable corrective actions" phrasing; operators must interpret applicability of corrective measures to other findings and, where needed, apply standard maintenance and airworthiness judgement.

9. Timing of effective date versus ASB dates. The Boeing ASB is dated 6 December 2007; the AD is effective 20 November 2008. Where the ASB sets compliance timing relative to its own date, the AD requires that timing be converted to run from the AD’s effective date. Confusion between ASB date‑based timing and AD effective‑date based timing is a common source of error unless the operator explicitly applies the AD’s conversion rule.

10. Documentation and records. The AD requires actions in accordance with the Boeing ASB; although the AD does not expressly spell out record‑keeping requirements in the excerpt presented, operators should ensure they document that inspections, corrective actions and modifications were accomplished per the ASB and the AD to evidence compliance and to enable regulatory review.

Step‑by‑step actions an operator should take, strictly following the language and cross‑references of the AD as supplied:

1. Obtain the Boeing ASB. Acquire Boeing Alert Service Bulletin (ASB) 717‑27A0039 dated 6 December 2007. The AD mandates compliance "in accordance with Boeing Alert Service Bulletin (ASB) 717‑27A0039 dated 6 December 2007." The ASB contains the aircraft identification (to determine applicability), the subgroup classification (for Group 1, Configuration 1), the detailed inspection and modification methods, and paragraph 1.E, "Compliance," which the AD references for Requirement 2.

2. Confirm applicability. Using the Boeing ASB, confirm that the specific Model 717‑200 serial number and configuration of the aeroplane are listed in the ASB’s applicability. Confirm whether the aeroplane is within Group 1, Configuration 1 (this determines whether Requirement 2 applies).

3. Schedule Requirement 1 inspection within the AD timetable. For all aeroplanes identified as applicable, schedule a general visual inspection of the drive assembly of the aft elevator standby loop. Requirement 1 must be performed "Within 3,000 flight hours or 27 months after the effective date of this AD, whichever occurs later." Calculate the later of the two thresholds from the effective date (20 November 2008) to determine the deadline for each aeroplane.

4. Conduct the inspection exactly as per the ASB. Inspect the drive assembly of the aft elevator standby loop for: (a) interference between the clevis and bolt of the bellcrank assembly, (b) correct orientation of the pull‑pull cable clevis bolt, and (c) excessive freeplay of the bellcrank assembly bearing. Use the inspection method, tools, and acceptance criteria set out in the Boeing ASB. Record findings contemporaneously in the aeroplane’s maintenance records.

5. If defects are found, perform corrective actions before further flight. The AD states "Do all applicable corrective actions before further flight." Apply the corrective procedures specified in the Boeing ASB for any non‑conforming condition found during the inspection. Do not return the aeroplane to service until the corrective action(s) have been completed and verified in accordance with the ASB.

6. For Group 1, Configuration 1 aeroplanes, plan and perform the modification. If the aeroplane is identified in the Boeing ASB as Group 1, Configuration 1, schedule and perform the specified modification to the pull‑pull cable clevis in the drive assembly of the aft elevator standby loop at the time specified in paragraph 1.E of the Boeing ASB. Where the ASB’s paragraph 1.E specifies compliance time relative to the ASB date, apply the AD’s rule converting such timings to be relative to the AD’s effective date: "except, where the service bulletin specifies a compliance time after the date on the service bulletin, this AD requires compliance within the specified compliance time after the effective date of this AD."

7. Where using a later Boeing ASB revision, verify FAA AMOC approval. If relying on a Boeing ASB revision later than the 6 December 2007 edition, ensure that the later revision has been approved by the FAA as an AMOC to FAA AD 2008‑18‑05. The AD accepts later revisions only "where the service bulletin" revision has FAA AMOC approval. If no FAA AMOC approval exists, do not rely on the later revision for compliance; instead use the Boeing ASB dated 6 December 2007 as mandated.

8. Record compliance and retain documentation. Maintain maintenance log entries and records demonstrating: (a) how applicability was established via the Boeing ASB; (b) dates and results of the inspections required by Requirement 1; (c) any corrective actions taken, including parts and work orders; (d) if applicable, the modification performed under Requirement 2; and (e) the specific Boeing ASB revision used for the work or the FAA AMOC approval reference if a later revision was used. The AD requires actions in accordance with the Boeing ASB, so contemporaneous records that tie the work to the ASB procedures are the practical evidence of compliance.

9. Plan for aircraft downtime. Because the AD requires corrective actions to be completed before further flight if defects are found, plan maintenance windows and possible spare aircraft to cover any resulting out‑of‑service time. For Group 1, Configuration 1 aeroplanes, plan time and parts procurement for the modification.

10. Monitor FAA AD/AMOC activity. Since the AD accepts later Boeing ASB revisions only where the FAA approves them as AMOCs to FAA AD 2008‑18‑05, maintain awareness of FAA AD 2008‑18‑05 developments and any FAA AMOC approvals that authorise revised Boeing ASBs. If a later ASB revision receives FAA AMOC approval, obtain the revision and the FAA approval reference to document the basis for using that later revision for compliance.

11. If clarification or deviation is needed, contact CASA or an authorised delegate. The AD text does not set out CASA’s local AMOC or deviation process in the excerpt provided, and it conditions acceptance of ASB revisions on FAA AMOC approval. If an operator requires alternative means of compliance or has questions about the AD’s application, engage CASA through its normal channels to seek clarification or authorisation prior to deviating from the AD or the Boeing ASB procedures.

Following these steps aligns an operator’s maintenance programme to the explicit requirements and cross‑references contained in the AD/B717/31 text as supplied.