AD/BAL/13 Amdt 1 - Portable Fire Extinguisher

The instrument rests on a small set of interlocking concepts stated in the body and the background notes. These are the applicable fleet, the technical requirement, standards compliance, timing for compliance, and the allocation of maintenance responsibility to the civil aviation regulatory framework.

Applicability and scope: The AD is addressed to "All Hot Air Balloons" (Applicability: All Hot Air Balloons). That phrase is literal in the source; there are no listed exemptions or subcategories within the source text. The legal reach is therefore to any aircraft that falls within the regulatory category of a hot air balloon wherever the AD applies.

Technical requirement: The content prescribes two acceptable technical types of portable fire extinguisher: a dry powder type, and a BCF vapourising‑liquid type. The minimum capacity is 1 kg (Requirement: "install a dry powder type or a BCF vaporising‑liquid type portable fire extinguisher of at least 1 kg capacity"). The instrument explicitly states a preference: "Note: A dry powder type extinguisher is the preferred type."

Standards and equivalence: The extinguisher must comply with Australian Standard AS 1841 or an equivalent standard (Requirement: "...complying with Australian Standard AS 1841 or equivalent."). The AD therefore prescribes a specific standards benchmark but allows for an unspecified "equivalent" to satisfy the requirement. The text does not define how "equivalent" is to be assessed; the background does recommend that manufacturer's maintenance and overhaul requirements be nominated as approved maintenance data, but the equivalence for the extinguisher standard itself is left open in the AD text.

Timing and effect: The compliance timing has two formulations in the table: compliance "Before issue of a certificate of airworthiness or before 10 May 1995." Separately, the amendment has an effectiveness date "6 August 2010." The AD also records that the original AD became effective on 8 December 1994. The juxtaposition of those dates is notable and appears in the source as written; the instrument does not elaborate on the interaction of those particular dates.

Maintenance and regulatory placement: The amendment removes maintenance requirements from the AD, describing them as duplicative of Maintenance regulations. The background points to specific regulatory provisions,CAR 2 (definition of Fire Extinguisher as an aircraft component), CAR 41(2) (requirement for the balloon maintenance schedule to include maintenance of all aircraft components), and CAR 2A (definition of Approved Maintenance Data). CASA's recommendation is that the manufacturer's maintenance and overhaul requirements be nominated as the approved maintenance data for the extinguisher (Background: "CASA recommends the Fire Extinguisher Manufacturer’s Maintenance and Overhaul requirements be nominated as the approved maintenance data..."). The AD leaves the installation requirement in place while removing the AD's internal maintenance regime in favour of the CAR‑based maintenance framework.

Document identity and provenance: The instrument identifies itself as AD/BAL/13 Amdt 1, dated 16/2010 in the header. It is signed by a CASA delegate (Mike Higgins), dated 2 August 2010, and explicitly records that the amendment becomes effective on 6 August 2010.

In sum, the main concepts are a mandatory installation of a specified minimum extinguisher type and capacity, compliance with AS 1841 or an equivalent standard, a preference for dry powder types, timing tied to COA issuance (and an earlier date), and a reallocation of maintenance obligations to the CAR definitions and maintenance scheduling regime.

The source explicitly applies to "All Hot Air Balloons" (Applicability: All Hot Air Balloons). From that starting point, the concrete actors affected by the instrument, as shown in the text, include:

• Balloon owners and operators: They are the entities that must ensure a compliant extinguisher is installed "if not already accomplished" and that compliance occurs "before issue of a certificate of airworthiness or before 10 May 1995." Because the AD ties compliance to issuance of a certificate of airworthiness, an owner or operator seeking to obtain or renew a COA for a hot air balloon will need to satisfy the installation requirement.

• Maintenance organisations and maintainers: The amendment removes AD maintenance requirements as duplicative and points to CAR 41(2) for maintenance scheduling of aircraft components (Background: "CAR 41(2) requires the Balloon maintenance schedule to include provision for the maintenance of all aircraft components."). That reallocation means that maintenance organisations responsible for balloon maintenance schedules must account for the fire extinguisher as an aircraft component and include its maintenance requirements in the schedule. CASA's recommendation that the manufacturer's maintenance and overhaul requirements be nominated as the approved maintenance data (Background: "CASA recommends the Fire Extinguisher Manufacturer’s Maintenance and Overhaul requirements be nominated as the approved maintenance data for the Fire Extinguisher.") affects how maintainers prepare and justify their maintenance data.

• Certifying authorities and delegates: The AD is an airworthiness directive, signed by a CASA delegate; the COA issuance process is implicated directly by the compliance timing. Certifying staff within CASA or authorised personnel will need to check the presence and standard compliance of the extinguisher when evaluating COA applications.

• Manufacturers and suppliers of extinguishers: The requirement to meet AS 1841 or an equivalent standard creates a standards demand for portable extinguishers of the specified types and capacity. Suppliers will be influenced by the explicit capacity (at least 1 kg) and by the preference note for dry powder types ("Note: A dry powder type extinguisher is the preferred type.").

• Certificated engineers and organisations that prepare Approved Maintenance Data: The reference to CAR 2A and the recommendation that manufacturer's maintenance and overhaul be nominated as approved maintenance data means engineers and organisations preparing maintenance schedules and data must consider the extinguisher's manufacturer's instructions as the likely approved standard.

The source does not explicitly state who bears the purchase, installation and maintenance costs. The operative phrase "If not already accomplished install ..." and the tie to COA issuance implies those responsible for achieving and maintaining airworthiness - typically the owner or operator - must procure and fit the extinguisher and incorporate its maintenance into the maintenance schedule. The AD text does not allocate costs or funding.

Other potentially affected parties not named in the source but implicated by its mechanics include insurers (who may need evidence of compliance for underwriting), certificated maintenance data approvers (who must accept nominated manufacturer's maintenance), and inspectors who verify compliance at COA issue. The source does not identify exemptions, alternative compliance pathways beyond "equivalent" standards, or transitional arrangements beyond the dates cited.

The AD imposes a small number of clear duties and records a recommendation concerning maintenance data. The source text is the authority for these duties.

Duties

• Installation duty: The primary duty is to install a specified portable fire extinguisher on each hot air balloon if such installation has not already been accomplished. The AD requires "install a dry powder type or a BCF vaporising‑liquid type portable fire extinguisher of at least 1 kg capacity, complying with Australian Standard AS 1841 or equivalent." This is a pre‑condition of compliance tied to certificate of airworthiness issuance ("Before issue of a certificate of airworthiness or before 10 May 1995.").

• Standards compliance duty: The extinguisher must comply with AS 1841 or an equivalent standard. The AD does not define who determines equivalence in the text; that determination will sit with the regulator and certifiers in practice.

• Maintenance scheduling duty under the CARs: The AD removes maintenance requirements from the AD itself and points practitioners to the regulatory maintenance regime. Backgroundly, the AD notes "CAR 41(2) requires the Balloon maintenance schedule to include provision for the maintenance of all aircraft components" and "CAR 2 defines a Fire Extinguisher is an aircraft component." Therefore maintainers must include the extinguisher in the maintenance schedule for the balloon in compliance with CAR 41(2).

• Approved maintenance data duty: CAR 2A is referenced as defining what can constitute Approved Maintenance Data, and CASA "recommends the Fire Extinguisher Manufacturer’s Maintenance and Overhaul requirements be nominated as the approved maintenance data for the Fire Extinguisher." The AD itself is a recommendation in this respect; it leaves the formal adoption of approved maintenance data to the processes of CAR 2A.

Rights and discretion noted in the source

• Choice of "equivalent" standards: The text allows AS 1841 or an "equivalent" standard to be used, which grants a degree of flexibility to operators and regulators regarding compliance means. The source does not specify the method of approval for equivalents.

• Preference but not prohibition on types: The AD expresses a preference for dry powder types ("A dry powder type extinguisher is the preferred type."), but it does not prohibit the BCF vapourising‑liquid type that the instrument also accepts, provided it meets the standard.

• Maintenance approach discretion: By removing maintenance detail from the AD and pointing to CARs and "Approved Maintenance Data", the instrument cedes detailed maintenance rules to CAR processes and the approval pathway for maintenance data under CAR 2A. CASA's text recommends nomination of manufacturer's maintenance and overhaul requirements as the approved data, but that is presented as a recommendation rather than a mandatory content of the AD.

What the AD does not specify

• The AD text does not identify a detailed inspection, installation method, mounting, or placement specification. It states the installation requirement remains unchanged from the original AD, but does not reproduce those installation details in the amendment text that appears in the source.

• The AD does not state explicit enforcement penalties or sanctions in this text, nor does it specify which party is financially responsible, although the tie to COA issuance implies non‑compliance will affect the legal ability to have a certificate of airworthiness issued.

In short, the duties are: fit a compliant extinguisher of specified type and capacity and ensure its maintenance is included in the maintenance schedule under CAR 41(2); recommended action is to adopt manufacturer's maintenance data as approved maintenance data under CAR 2A. Rights include a limited equivalence pathway and a choice between two extinguisher types, with a stated preference.

The source text of AD/BAL/13 Amdt 1 (16/2010) does not set out explicit penalty provisions or a detailed enforcement regime within the AD itself. It records timing for compliance tied to certificate of airworthiness issuance ("Before issue of a certificate of airworthiness or before 10 May 1995.") and identifies CASA as the issuing authority by inclusion of the CASA delegate's signature (Mike Higgins) and dates (2 August 2010). Beyond that, the AD does not include clauses specifying fines, sanctions, or criminal penalties.

From the document itself, the concrete enforcement mechanism evident in the AD is procedural: compliance is a pre‑condition to COA issuance. The AD's instruction that the extinguisher be installed "Before issue of a certificate of airworthiness" makes the presence of a compliant extinguisher an enforceable item in the COA assessment and issuance process. In practice, that means certifiers and regulatory staff will require demonstration of compliance as part of COA certification activities. The AD text provides no further enforcement details.

The background explains a reallocation of maintenance requirements to the Maintenance regulations (CARs). The AD refers to CAR 41(2) and CAR 2A regarding component definition and approved maintenance data. Enforcement of maintenance obligations therefore becomes a matter within the CAR framework rather than the AD itself. The AD explicitly removes maintenance requirements from the Airworthiness Directive as duplicative (Background: "This amendment removes the maintenance requirements for the Airworthiness Directive as it is duplicative to the Maintenance regulation requirements.").

Because the instrument is silent on penalties, users of the AD should note two practical points derived from the text:

• Administrative enforcement via certificate issuance: The AD ties compliance to a regulatory administrative step , the COA. Failure to comply will, on the face of the AD, prevent lawful COA issuance for a balloon subject to the AD.

• Regulatory maintenance oversight: Maintenance obligations are to be discharged under the CAR provisions referenced. Any enforcement action for maintenance failures would be pursued under the CAR regime rather than under this AD's text. The AD itself recommends nomination of manufacturer's maintenance and overhaul requirements as approved maintenance data, but does not specify sanctions.

The AD does not, in this text, provide guidance on the procedure for demonstrating conformity with "equivalent" standards, nor does it set out an appeals or variation process for the AD itself. Those procedural matters would be expected to exist in the broader regulatory framework (the Civil Aviation Regulations and CASA administrative procedures), but they are not referenced beyond the CAR citations in the AD. The source does not provide case law, penalty schedules, or enforcement examples.

Therefore, the AD's enforcement mechanics, as stated in the source, are limited to the condition that the extinguisher must be installed in order for a certificate of airworthiness to be issued; maintenance requirements are to be managed under CAR provisions. Any specific penalties or formal enforcement steps are not included in the provided text.

The instrument expressly situates installation and maintenance obligations within the Civil Aviation Regulations (CARs) framework. The background text identifies three specific CAR provisions that interact with this AD:

• CAR 2: the AD notes "CAR 2 defines a Fire Extinguisher is an aircraft component." By identifying the fire extinguisher as an aircraft component under CAR 2, the AD connects the extinguisher to the body of regulation that applies to aircraft components generally.

• CAR 41(2): the AD states "CAR 41(2) requires the Balloon maintenance schedule to include provision for the maintenance of all aircraft components." This places the extinguisher within the maintenance scheduling duties for balloons; maintenance records and scheduled maintenance obligations that apply to components under CAR 41(2) become the vehicle for ensuring continued airworthiness of the extinguisher.

• CAR 2A: the AD indicates "CAR 2A defines what can constitute Approved Maintenance Data." CAR 2A therefore governs what maintenance instructions and sources can be relied upon as approved maintenance data for the extinguisher. The AD goes further to recommend that the manufacturer's maintenance and overhaul requirements be nominated as the approved maintenance data for the extinguisher.

The AD explicitly removes maintenance requirements from the Airworthiness Directive because those requirements are "duplicative to the Maintenance regulation requirements." That language indicates an intent to avoid regulatory overlap: the AD retains only the installation requirement and defers maintenance obligations to the established CAR mechanisms.

Practical interaction consequences evident in the source:

• Maintenance enforcement under CARs: Any regulatory oversight or action concerning the maintenance of the fire extinguisher will be taken under the CAR framework rather than under supplementary maintenance provisions in the AD. The AD is therefore not a stand‑alone maintenance prescription; it is a directive about installation with a pointer to the CARs for maintenance.

• Approval of maintenance data: The AD recommends nomination of the manufacturer's maintenance and overhaul requirements as approved maintenance data, which aligns the AD with the CAR 2A approval pathway. That recommendation influences how organisations will document, seek approval for, and defend their maintenance practices concerning the extinguisher.

• Certificate of airworthiness process: The AD imposes the installation obligation as a condition for COA issuance. This creates an operational intersection between the AD and COA regulatory procedures. The AD’s compliance timing and the COA process will therefore be integrated during certification inspections and documentation reviews.

What the source does not show about legal interaction

• The AD does not reproduce the text of CAR 2, CAR 41(2) or CAR 2A, nor does it provide procedural details on how equivalence to AS 1841 is to be assessed. Any concrete procedural rules for how to nominate and obtain approval for maintenance data are not included in the AD text and must be sought in the CARs or CASA guidance.

• The AD does not specify how disputes over equivalence, maintenance data approval, or COA decisions would be adjudicated; such mechanisms exist elsewhere in the broader regulatory framework but are not part of the instrument as supplied.

Therefore, the AD operates as a focused rule that intersects with the CARs by: (1) mandating installation prior to COA issuance, (2) categorising the extinguisher as an aircraft component under CAR 2, and (3) directing maintenance responsibilities into the CAR 41(2) schedule and CAR 2A approved maintenance data processes. The AD's own maintenance content has been removed to avoid duplicative regulatory prescription.

The document provided contains a short amendment trail and provenance notes. The history stated in the source is as follows:

• Original AD: The source records that "The original issue of this Airworthiness Directive became effective on 8 December 1994." That establishes the original AD's effective date.

• Amendment identification: The current instrument is titled "AD/BAL/13 Amdt 1" and is also referenced as "16/2010" in the header. The header repeats these identifiers multiple times (AD/BAL/13 Amdt 1 AD/BAL/13 Amdt 1; AD/BAL/13 Amdt 1; Portable Fire Extinguisher; 16/2010).

• Amendment effective date and signature: The AD states "This Amendment becomes effective on 6 August 2010." It is signed by a CASA delegate, Mike Higgins, and dated 2 August 2010 in the signature block (Mike Higgins; Delegate of the Civil Aviation Safety Authority; 2 August 2010). The apparent order is: signed on 2 August 2010, with a recorded effective date of 6 August 2010. The header also includes the 2010 label (16/2010).

• Compliance timing reference to an earlier date: The table places a compliance obligation "Before issue of a certificate of airworthiness or before 10 May 1995." The presence of the 10 May 1995 date alongside an amendment effective in 2010 is recorded in the source as written; the instrument does not include an explanatory note within the supplied text explaining how to treat the 1995 date in relation to the 2010 amendment.

• Removal of maintenance requirements: The background notes that this amendment "removes the maintenance requirements for the Airworthiness Directive as it is duplicative to the Maintenance regulation requirements." That is the functional change effected by Amdt 1; installation requirements "remain unchanged" (Background: "The requirements for installation of a Fire Extinguisher remain unchanged.").

The amendment history recorded in the source is minimal: original AD in 1994, an amendment labelled Amdt 1 recorded and effective in August 2010, and an internal change to remove maintenance requirements while retaining installation requirements. The AD does not list any intermediate amendments, consultation steps, or public comment periods in the provided text. It also does not set out transitional arrangements beyond the compliance deadline clauses that accompany the requirement.

Readers should note that the AD text includes dates that pre‑date the amendment, and the instrument as provided does not explain the operational effect of the 10 May 1995 compliance date in relation to the 2010 amendment. The only recorded procedural detail for the amendment itself is the delegate's signature and the effective date.

The source provided contains no litigation history. It names no cases, no proceedings, and provides no references to judicial or administrative decisions interpreting or applying the AD. The document is an Airworthiness Directive and background note signed by a CASA delegate; it does not include references to any legal challenges, appeals, enforcement actions, or adjudications.

Because the supplied text does not mention litigation, there is no case law to draw upon from the instrument itself. Any disputes about the AD's interpretation, equivalence determinations under AS 1841, or maintenance data approval would, if they occurred, be handled through the wider administrative and judicial systems set out in the Civil Aviation Regulations and the relevant administrative law framework; however, none of those matters appear in the provided text.

For practitioners, that means the AD must be read and applied on its face, and any necessary enquiries about precedent, appeals, or enforcement practice must be made to CASA, the CARs, or legal databases external to this document. No litigation examples, outcomes, or citations are included in the source.

The text contains several features that can create practical ambiguity or trap unwary practitioners. These features are present in the source and should be noted for operational and compliance planning.

1. Dating incongruity and practical compliance window: The AD requires installation "Before issue of a certificate of airworthiness or before 10 May 1995," yet the amendment's effective date is 6 August 2010 and the delegate signed on 2 August 2010. The AD also notes the original AD became effective on 8 December 1994. The presence of a 1995 compliance date in a 2010 amendment may cause confusion about whether the obligation is historic only, or whether it continues to apply to COA issuance after 2010. The source does not explain this date‑relationship or specify transitional arrangements beyond the clause as printed.

2. "If not already accomplished" language: The requirement is framed as "If not already accomplished install..." That phrasing presumes existing balloons may already have compliant extinguishers installed. For second‑hand balloons, or balloons where records are incomplete, evidence that the extinguisher was installed "already" may be required for COA issuance. The source does not prescribe acceptable evidence of prior compliance.

3. "Equivalent" standard left undefined: The AD allows compliance with AS 1841 or an "equivalent" standard. The instrument does not specify the process for approving an equivalent. Practitioners should not presume what counts as equivalent without confirming with the certifying authority. The AD text itself leaves the equivalence determination to the regulatory and certifying bodies.

4. Preference vs permitted type: The AD expressly notes "A dry powder type extinguisher is the preferred type." That is a preference, not a prohibition. The BCF vapourising‑liquid type remains explicitly permitted. In contexts where particular operational environments may favour one type over another, the declared preference is not an absolute bar but could influence certifier decisions.

5. Removal of maintenance detail from the AD: The amendment removes maintenance requirements from the AD and points to CAR 41(2) and CAR 2A for maintenance scheduling and approved maintenance data. Practically, this means the AD itself will not state inspection intervals, maintenance tasks, or recordkeeping specific to the extinguisher. Operators must therefore ensure their maintenance schedule complies with the CARs and that approved maintenance data is in place. The AD recommends nomination of the manufacturer's maintenance and overhaul requirements as the approved maintenance data, but this recommendation is not itself a formal approval; approval must proceed through CAR 2A pathways.

6. Lack of installation detail in the amendment text: The AD says "The requirements for installation of a Fire Extinguisher remain unchanged," but the amendment text does not reproduce those installation requirements. Anyone relying on the amendment alone will need to consult the original AD or other installation guidance to know where and how the extinguisher must be mounted and secured.

7. No penalties listed: The AD does not specify penalties. That leaves operators to rely on the COA process and the CARs for enforcement consequences. Practitioners should not assume the absence of penalty language means non‑compliance carries no regulatory consequence; the AD ties compliance to COA issuance.

8. Manufacturer maintenance nomination is a recommendation: Although CASA "recommends the Fire Extinguisher Manufacturer’s Maintenance and Overhaul requirements be nominated as the approved maintenance data," the AD does not mandate that posture as the only acceptable approach. However, nomination of manufacturer data is likely to be the simplest and most defensible path to approval under CAR 2A.

9. Recordkeeping and proof for COA: While the AD ties installation to COA issuance, it does not set out what documentary proof is required. Operators should expect to demonstrate the extinguisher's compliance with AS 1841 or an equivalent and to show maintenance scheduling consistent with CAR 41(2).

10. Potential supplier and compatibility issues: The AD specifies a minimum capacity (1 kg) and two types. The market for small extinguishers that meet AS 1841 or acceptable equivalents will determine availability and prices. The AD itself does not address compatibility with balloon basket fittings, mounting hardware, or other installation accessories.

These "gotchas" flow directly from the AD's text as provided: the dates stated, the choices left open by "equivalent" and "preferred," the removal of maintenance specifics, and the lack of penalty wording. Practitioners should plan for these practical uncertainties by consulting the original AD for installation details, liaising with CASA on equivalence and approved maintenance data, and ensuring documentary proof for COA processes.

The source establishes a narrow compliance path. The steps below are drawn strictly from the AD text and background notes and describe concrete actions an operator, owner, or maintainer should take to align with the instrument.

1. Identify applicability: Confirm the aircraft is a "Hot Air Balloon" as described in the AD (Applicability: All Hot Air Balloons). If so, the AD applies.

2. Verify current equipment: Check whether a compliant portable fire extinguisher is already installed. The AD’s operative clause begins "If not already accomplished install..." so if an extinguisher matching the requirements is already present, the installation duty will be satisfied. However, retain documentary evidence (photos, maintenance records, serial numbers, compliance certificates) that the extinguisher was installed and meets the standard, because the AD ties compliance to COA issuance.

3. Acquire a compliant extinguisher where needed: If there is no compliant extinguisher, install a portable fire extinguisher meeting the AD's specification: either a dry powder type or a BCF vapourising‑liquid type; minimum capacity at least 1 kg; complying with Australian Standard AS 1841 or an equivalent standard ("install a dry powder type or a BCF vaporising‑liquid type portable fire extinguisher of at least 1 kg capacity, complying with Australian Standard AS 1841 or equivalent. Note: A dry powder type extinguisher is the preferred type."). The AD identifies a preference for dry powder types; that preference should be considered where practical.

4. Ensure standard compliance or obtain equivalence approval: The extinguisher must comply with AS 1841 or an "equivalent" standard. The AD does not explain the process for establishing equivalence; therefore seek formal acceptance from CASA or the relevant certifying authority for any non‑AS 1841 product relied upon as "equivalent." Keep records of any approval correspondence.

5. Install in accordance with required installation practices: The AD states "The requirements for installation of a Fire Extinguisher remain unchanged." The amendment text does not reproduce installation specifications; therefore consult the original AD (the text notes the original AD became effective on 8 December 1994) or CASA installation guidance to confirm mounting location, fittings, and securing methods. Document the installation with photographs, placards, and installation reports.

6. Include extinguisher in maintenance schedule: Because the amendment removes maintenance requirements from the AD as duplicative, incorporate the extinguisher into the balloon maintenance schedule in accordance with CAR 41(2) which "requires the Balloon maintenance schedule to include provision for the maintenance of all aircraft components." Ensure intervals, checks, and tasks are captured in the maintenance schedule.

7. Nominate approved maintenance data: CAR 2A defines what can constitute Approved Maintenance Data. The AD "recommends the Fire Extinguisher Manufacturer’s Maintenance and Overhaul requirements be nominated as the approved maintenance data for the Fire Extinguisher." Follow the CAR 2A pathway to nominate the manufacturer's maintenance and overhaul requirements as the approved maintenance data, and obtain the necessary approvals or endorsements.

8. Retain records for COA issuance and audits: Because compliance is tied to "Before issue of a certificate of airworthiness," compile and retain records demonstrating the extinguisher's type, capacity, standards compliance (AS 1841 or accepted equivalent), installation reports, and evidence that maintenance scheduling and approved maintenance data have been established for the extinguisher. Present these documents during COA inspections.

9. Seek clarification on historical compliance date if necessary: If your situation involves interpreting the AD’s "or before 10 May 1995" clause in the context of the 2010 amendment, seek clarification from CASA or the certifying authority as to how that date affects current COA issuance and compliance obligations. The AD as presented does not explain the relation of the 1995 deadline to the 2010 amendment.

10. Monitor CAS A guidance and CAR processes: Because maintenance, approved data, and equivalence determinations are handled in the CAR framework rather than within the AD text, monitor CASA guidance and the CAR procedures for any updates or formal approval steps that pertain to extinguisher selection, maintenance, and data approval.

These steps flow from the AD's explicit text: installation requirement, type and capacity limitation, AS 1841 or equivalent standard, tie to COA issuance, and redirection of maintenance requirements to CAR 2, CAR 41(2), and CAR 2A with CASA's recommendation for manufacturer's maintenance data. The AD itself does not set out forms, paperwork templates, or the equivalence approval process; those administrative steps must be completed under CASA's established processes.