Several aspects of this AD are easy to overlook or misinterpret. The first is the measurement of compliance times from the effective date of Amendment 1 (30 September 2004), not from Amendment 3 effective date (15 July 2005). An operator reading Amendment 3 in isolation might mistakenly calculate deadlines from mid‑2005. For example, the 24‑month deadline for option 1.a would fall on 30 September 2006, not 15 July 2007. By the time Amendment 3 took effect (July 2005), those deadlines might be less than 15 months away. If an operator acquired an aeroplane after the original AD, they need to back‑calculate from September 2004.
The second gotcha is the interplay between option 1.b and the compliance times. If an operator selects 1.b, they must perform the wire termination change (1.b.(i)) within 18 months of 30 September 2004 (i.e., by 30 March 2006) and the full air data system modification (1.b.(ii)) within 72 months (i.e., by 30 September 2010). But if an operator fails to do the wire termination by March 2006, does the option become invalid? The AD does not explicitly state. However, logically, if the wire termination is late, the operator cannot claim the benefit of the extended 72‑month period because the condition precedent was not met. They would then revert to the 24‑month deadline for 1.a, which would already have passed. This could leave the operator in a position of having no legal compliance path without seeking individual relief from CASA.
The third gotcha is Requirement 2: “For aeroplanes that are identified in ASB 767-34A0332, Revision 2 and also identified in any of the Boeing service bulletins listed below.” The cross‑reference is cumulative. Not every aeroplane subject to the AD needs the EICAS replacement. An operator must check both lists carefully. The five service bulletins listed have different revisions and dates; some are original issues, others are revisions. If the aeroplane appears only in the ASB but not in any of those five SBs, Requirement 2 does not apply. Conversely, if the aeroplane appears in one of the five SBs but not in the ASB, the AD does not apply at all. Operators must verify based on their specific serial numbers.
The fourth gotcha is Note 1: it says “if Requirement 1.b. is selected the compliance date for the modification of the air data switching system (ASB 767-34A0332 Revision 1 or Revision 2) is extended from 24 months to 72 months.” This is counterintuitive: the wire termination change under 1.b.(i) has a shorter deadline (18 months), yet the full modification gets a much longer extension. The rationale may be that the wire termination itself solves the immediate safety risk, so the physical modification can wait. But the AD does not explain. An operator might mistakenly think that selecting 1.b allows them to defer the wire termination as well; it does not.
The fifth gotcha is the prohibition in Requirement 3: parts in the “Existing Part Number” column are prohibited from installation as replacement parts “as of the effective date of the original issue of this Directive.” That date is 5 August 2004. This means any installation of those part numbers after that date is a continuing breach. If an operator discovers they have a prohibited part installed now (in real time), they must remove it and replace it with an improved part, even if the original installation was lawful before the AD. This can create significant maintenance events.
The sixth gotcha is the effective date of Amendment 3: 15 July 2005, but the delegate signed on 8 July 2005. There is a gap of seven days. The AD is likely gazetted on 15 July. Operators must comply from the effective date, not the signature date. If a maintenance action occurred between 8 July and 15 July using SB 767-31-0149 Revision 2, it would be acceptable under the AD only from 15 July, meaning that work done in that window may be technically non‑compliant under the earlier version of the AD. However, as a practical matter, CASA might accept it if the work is otherwise correct and the operator can show good faith.
The seventh gotcha is that the AD refers to multiple service bulletins by number and revision, but does not reproduce their contents. The operator must purchase or have access to these Boeing documents. If the documents are not available, compliance is impossible. The AD does not provide a grace period for obtaining documents. This dependence on proprietary data creates a barrier to entry for smaller operators with limited budgets. It also means that any error in the service bulletin (e.g., mis‑identified part numbers) could cause a ripple effect of non‑compliance even if the operator followed the text.
Eighth, the AD grandfathers modifications done “before the effective date of the original issue of this Directive in accordance with Boeing ASB 767-34A0332 dated 10 January 2002.” That means any operator who modified the air data system per that early ASB before 5 August 2004 is compliant with Requirement 1.a. But if the modification was done after 5 August 2004 but before the original AD’s effective date (which is the same day? Actually original effective date is 5 August 2004, so “before the effective date” means before 5 August 2004. Very tight. Grandfathering only applies to modifications done before that date.
Finally, the interpretation of “concurrently with” in Requirement 2: “Prior to, or concurrently with, SB 767-34A0332, Revision 1 or Revision 2.” This means the EICAS replacement must be done at the same time as the air data system modification or earlier. It cannot be done later. If an operator does the air data modification first, they cannot defer the EICAS work to a subsequent maintenance check without being in breach. The AD gives no flexibility on this ordering.