AD/CF6/78 - State of Design Airworthiness Directives

The Directive deploys a short list of core regulatory mechanics and concepts that determine obligations and permissible compliance methods.

• Applicability determination. The Directive’s first operative step is an applicability test: operators must determine whether the FAA ADs listed in Table 1 apply to their specific CF6 engines and aircraft configuration. The text places this initial investigatory burden on the responsible party, not on CASA. The Directive recognises that applicability may vary with manufacture date, aircraft configuration and modification status, explicitly noting that some ADs "may not be applicable" for those reasons.

• Importation of State-of-Design ADs. The instrument treats the FAA ADs in Table 1 as the State-of-Design requirements that CASA wishes to secure compliance with for Australian-registered aircraft. The background statement frames the Directive as a mechanism to "ensure compliance with all State of Design ADs," and the operative requirement directs the reader to perform the actions required by those FAA ADs where applicable.

• Acceptance of FAA-approved AMOCs. The Directive allows Service Bulletins that the FAA has approved as Alternative Methods of Compliance to stand in for the corresponding FAA AD actions. That means CASA, by the terms of this Directive, accepts an FAA decision granting an AMOC as an acceptable compliance route for the equivalent CASA requirement created by the Directive.

• Once-only ADs with past compliance dates. The background indicates that the listed FAA ADs "require once-only actions for which the compliance date has passed." That framing affects the nature of compliance: these are not recurrent tasks with new intervals but single-occurrence modifications, inspections or replacements that, per the FAA ADs, should already have been done for engines already in service.

• Timing rules for compliance relative to certification. The Directive contains two timing branches: compliance before issue of a certificate of airworthiness if one has not yet been issued; and, if the certificate has been issued, compliance before further flight after 8 November 2010. This creates a hard scheduling constraint tied to either the certification milestone or the effective date and next flight.

• Reference to definitive FAA source. The Directive includes Note 1 directing readers to the FAA’s AD repository at http://rgl.faa.gov for the authoritative FAA AD texts. The Directive therefore imports the FAA AD prescriptions by reference rather than reproducing their full content.

• Engine and AD identifiers. The Directive is explicitly limited to "General Electric CF6 engines," and Table 1 lists four FAA ADs by number, effective date and short title. Those identifiers are how an operator maps the CASA Directive to the specific FAA AD text they must examine.

Together, these concepts create a concise legal mechanism: identify whether the listed State-of-Design ADs apply to the specific engine/aircraft; if they do and if the actions have not already been done, comply with the FAA AD’s required actions or with an FAA-approved AMOC; and do so within the specified timetable before certification or before further flight. The Directive includes an express recognition that applicability can vary, which both limits and clarifies the scope of the imported FAA requirements.

The Directive affects a narrow and well-defined set of actors, as indicated by its text.

• Aircraft operators and owners with General Electric CF6 series engines on aircraft on, or seeking entry to, the Australian register. The applicability line reads "General Electric CF6 engines," which delimits the equipment to which the Directive applies.

• Organisations responsible for determining and performing airworthiness actions. The Directive commands that the applicability of specific FAA ADs be determined and, if necessary, the FAA-required actions be carried out. That duty will typically sit with the aircraft owner, the aircraft’s operator, the approved maintenance organisation or the accountable manager responsible for continuing airworthiness and certification activities.

• The Civil Aviation Safety Authority (CASA) as regulator. CASA is the issuer of the Directive and sets the compliance timetable and acceptance of FAA-approved AMOCs. The Directive is signed by a CASA delegate, showing CASA’s administrative role in issuing the importation of State-of-Design ADs for Australian-registered aircraft. CASA is also the entity that has "determined that these ADs may be applicable when an aircraft enters the Australian register," as stated in the background.

• Persons involved in certification processes. The Directive creates a pre-condition for issue of a certificate of airworthiness where the aircraft has not yet been certified; the actors involved in issuing or applying for that certificate must ensure the required determinations and actions have been completed before CASAs certification milestone.

• Maintenance and engineering staff responsible for implementing the FAA AD actions or AMOCs accepted under the Directive. Those persons must obtain the FAA AD texts (the Directive points to rgl.faa.gov) and either implement the FAA-prescribed remedial actions or implement FAA-approved AMOCs where applicable.

The Directive’s wording places the practical burden , both investigatory and execution , on the party responsible for the aircraft’s airworthiness and certification. The timing provisions mean an owner or operator seeking to import or certify an aircraft with CF6 engines into the Australian register must incorporate the applicability check and any required FAA AD actions into the pre-certification workplan. For already-certified Australian aircraft, the requirement to comply "before further flight after 8 November 2010" imposes an immediate short-term operational constraint that the operator must satisfy before the aircraft next departs.

The Directive does not itself allocate monetary responsibility or identify who pays directly. The obligation to perform the actions required by applicable FAA ADs logically falls on the party required to maintain the aircraft in an airworthy condition and to comply with CASA ADs, which in practice will be the aircraft owner or operator and their maintenance provider, but the instrument does not spell out cost allocation or reimbursement mechanisms.

The Directive creates a small set of explicit duties and confers implicit compliance options.

Duties

• Determine applicability (explicit duty). The first legal duty in the Directive is to "Determine the applicability of the United States Federal Aviation Administration (FAA) Airworthiness Directives (ADs) listed in Table 1." That is an affirmative investigatory duty requiring review of the FAA AD texts and mapping them to the specific aircraft/engine configuration.

• Implement FAA AD actions if applicable and not previously accomplished (explicit duty). The Directive states: "If it is determined that an FAA AD listed in Table 1 is applicable and has not been previously accomplished, perform the actions required by that AD." This is a conditional operational duty: where the FAA AD applies and the AD’s remedial or modification actions remain outstanding, those actions must be performed.

• Use FAA-approved AMOCs as acceptable alternatives where relevant (explicit right/option). The Directive allows Service Bulletins approved by the FAA as Alternative Methods of Compliance to be "considered acceptable for compliance with the equivalent requirements of this Directive." That language affords the regulated party a compliance option where the FAA has already approved an AMOC for the relevant AD.

• Meet compliance timing (explicit duty). Compliance timing is explicit: for uncertificated aircraft, compliance must occur "before issue of the certificate of airworthiness"; for certificated aircraft, compliance must be performed "before further flight after 8 November 2010." These deadlines operate as definitive temporal limits on completing the duties.

Rights and compliance choices

• Right to rely on FAA-approved AMOCs for equivalence. The Directive explicitly recognises FAA-approved AMOCs as acceptable compliance methods. That is a right to use a foreign authority’s alternative compliance decision rather than performing the exact actions originally prescribed in the FAA AD, provided the AMOC is FAA-approved.

• Right to consider non-applicability where justified by manufacture date, configuration or modification status. The Directive’s background acknowledges that "due to date of aircraft manufacture or aircraft configuration and modification status, some of the ADs listed in Table 1 may not be applicable to aircraft registered in Australia." That framing gives the person performing the applicability determination a factual basis to conclude non-applicability where supported by the aircraft’s history and configuration.

• Duty to consult FAA AD authoritative source. Note 1 directs the reader to the FAA ADs at http://rgl.faa.gov, which is the source material against which applicability and action obligations must be judged.

Operational consequences of duties

• The duty to determine applicability requires access to the FAA AD content and sufficient technical knowledge to map FAA AD applicability criteria (for example, serial numbers, serial ranges, identified configurations or affected parts) to a given engine/airframe combination. The Directive does not supply the technical thresholds; it imports them by reference to each FAA AD.

• The duty to implement FAA AD actions, when they remain outstanding, requires the regulated party to engineer, schedule and fund the actions called for by the FAA AD unless an FAA AMOC is used. The Directive does not prescribe who funds those actions.

• The timing duty can create immediate operational constraints for certificated aircraft: the aircraft cannot undertake further flight after 8 November 2010 until compliance is demonstrated.

Limits and absences

• The Directive does not specify penalty provisions, compliance-monitoring mechanisms or a formal CASA approval process for evidence of compliance within the text provided. It also does not prescribe documentation requirements beyond the operative instruction to carry out the FAA AD actions or use FAA-approved AMOCs.

• The instrument accepts FAA AMOCs but does not mention CASA-approved AMOCs or specify whether CASA would independently accept other alternative methods. The only explicit recognition is of FAA-approved AMOCs.

Collectively, the Directive imposes a clear investigatory duty and a contingent performance duty, while providing a procedural option to use FAA-approved AMOCs. Timing constraints are explicit and tied to certification and the effective date.

The Directive text does not include express penalty provisions or describe the detailed enforcement process. The document is an Airworthiness Directive issued by the Civil Aviation Safety Authority (CASA), signed by a CASA delegate, and contains clear compliance requirements and timelines; however, the instrument itself does not specify the sanctioning regime, investigative powers, or administrative procedures for enforcement.

What the Directive does provide that is relevant to enforcement and operational control

• Mandatory nature implied through prescriptive wording. The Directive uses mandatory phrasing: "Determine the applicability" and "perform the actions required by that AD" where applicable. Such language in an AD context typically signals an enforceable obligation, but the Directive text does not specify the legal penalties for failing to meet it.

• Timing constraints that condition airworthiness certification and further flight. The Directive imposes timing conditions: compliance must occur "before issue of the certificate of airworthiness" if one has not been issued, and otherwise before further flight after 8 November 2010. Those timing constraints are concrete operational limits, and non-compliance with those limits would have immediate consequences for an operator’s ability to lawfully operate an aircraft, since an aircraft not in compliance with an applicable AD will not meet the regulatory standard for airworthiness.

• Authority and signature. The Directive is issued by CASA and signed by a CASA delegate, Mike Higgins, on 8 October 2010. That signatory element identifies the issuing authority responsible for the Directive and provides administrative provenance relevant to enforcement procedures that CASA would use under its broader statutory powers, though those powers are not detailed in this instrument.

What is absent from the text

• No explicit fines, criminal penalties, or civil sanctioning structure are set out in the Directive itself. The text does not describe infringement notices, penalty units, licence suspensions, or other specific punitive measures.

• No description of compliance documentation or audit processes. The Directive does not state what documentary evidence must be lodged with CASA, nor does it identify how CASA will verify that the applicability assessment or the required FAA AD actions have been completed.

• No express process for CASA acceptance of non-FAA AMOCs or CASA-made AMOCs is described. The Directive only recognises FAA-approved AMOCs as acceptable means of compliance.

Implication for regulated parties

• Given the Directive’s mandatory language and its conditioning of certification and flight, the practical enforcement mechanism likely stems from existing regulatory regimes governing airworthiness and the administrative powers of CASA rather than from this document’s text. Operators and maintainers should therefore treat the Directive as a binding airworthiness direction that must be complied with in order to maintain lawful airworthiness certification status and to avoid operational prohibition, and they should expect CASA to rely on its general enforcement powers where the Directive is not followed. The Directive itself, however, does not specify penalty amounts, escalation processes, or dispute-resolution steps.

The Directive primarily operates as a mechanism by which CASA imports State-of-Design airworthiness requirements (FAA ADs) into the Australian airworthiness regime for CF6 engines. The text sets up a direct reference relationship to FAA material and establishes limited cross-recognition of FAA determinations.

Interaction features evident from the Directive text

• Reference to State-of-Design ADs. The background explicitly frames the Directive as a response to FAA ADs and states that CASA "has determined that these ADs may be applicable when an aircraft enters the Australian register." The Directive therefore functions as an instrument for aligning Australian airworthiness compliance with State-of-Design mandates in particular cases, integrating foreign-design authority decisions into the national regulatory framework for aircraft on the Australian register.

• Import by reference to FAA ADs. The operative requirement directs the regulated party to determine the applicability of the FAA ADs listed in Table 1 and to perform actions required by those FAA ADs where applicable. The Directive therefore makes FAA AD content a source of the practical obligations that an Australian operator must obey for the covered equipment. Note 1 points operators to the FAA AD repository at http://rgl.faa.gov, making the FAA AD text the technical substance of the obligation.

• Recognition of FAA AMOCs as acceptable. The Directive identifies Service Bulletins that have been approved by the FAA as Alternative Methods of Compliance to the listed FAA ADs as acceptable for compliance with the "equivalent requirements of this Directive." This creates a regulatory bridge where a foreign authority’s assessment of alternative compliance is expressly accepted in lieu of the precise AD-prescribed corrective action.

Implications for domestic regulatory coherence

• The Directive does not repeal or amend Australian statutory instruments; rather, it creates an obligation under CASA’s airworthiness-directive authority to ensure compliance with State-of-Design ADs. The instrument is a tool to achieve conformity between Australian-registered aircraft and the design authority’s mandatory corrective actions.

• The Directive leaves open the interaction with CASA’s broader administrative processes. It does not specify whether CASA will accept other alternative methods of compliance or what CASA’s own approval process for AMOCs might be. The only attested cross-acceptance in the text is of FAA-approved AMOCs.

• The Directive does not specify how evidence of compliance is to be recorded on Australian maintenance release documentation or logbooks, nor does it address the interplay with Australian certification requirements beyond the timing constraints for certificate issue and further flight. Operators must therefore rely on their existing regulatory knowledge and CASA practice to properly document or notify CASA of compliance.

Potential points of legal interface not specified in the text

• The Directive does not address whether an FAA AD that has been superseded or revised is treated as superseded under CASA’s Directive; the Directive lists specific FAA AD numbers and their effective dates, so the operator must refer to the FAA source to determine whether AMOCs or later FAA actions supersede or alter the listed ADs.

• The Directive does not mention interaction with commercial contract rights, warranties, insurance coverage, or liability regimes. Any cost allocation or contractual claims arising from implementing these FAA AD actions would be governed by separate agreements and legal instruments outside the Directive.

In short, the Directive is a targeted regulatory vehicle that imports and cross-recognises specific FAA AD requirements for CF6 engines into the Australian airworthiness framework, while leaving the broader administrative, evidentiary and legal interactions to the existing CASA and operator processes and to the underlying FAA AD texts referenced.

The text supplied contains limited material on amendment history. What is present in the instrument allows a concise statement of its provenance and effective chronology.

• Instrument identity and issuance. The instrument is titled AD/CF6/78 and shows the reference 21/2010. The document is signed by Mike Higgins, as a "Delegate of the Civil Aviation Safety Authority," with the signature dated 8 October 2010. The Directive states it "becomes effective on 8 November 2010."

• Table 1 provenance. The Directive reproduces a table of FAA ADs (Table 1) listing four FAA ADs, each with its FAA AD number, an "Effective Date" and a short title. The Table 1 entries include FAA ADs with their own historical effective dates spanning from 1990 through 2007 (90-12-06 effective 25/06/1990; 96-16-07 effective 28/08/1996; 2005-26-06 effective 26/01/2006; 2007-21-06 effective 15/11/2007). The Directive therefore imports ADs whose compliance dates precede the issuance of this CASA Directive.

• Background context indicating once-only ADs with past compliance dates. The background paragraph states that "the FAA ADs listed in Table 1 of this Directive require once-only actions for which the compliance date has passed" and that CASA "has determined that these ADs may be applicable when an aircraft enters the Australian register." That language explains why CASA is issuing a contemporaneous Directive in 2010 that references older FAA ADs.

• No recorded amendments in the supplied text. The document does not list any prior or subsequent amendments to AD/CF6/78 itself within the supplied text. There is no schedule of revisions, dates of amendment, revocation clauses, or references to superseding CASA ADs in the material provided.

What cannot be inferred from the provided text

• The Directive text does not indicate whether AD/CF6/78 has been superseded, amended or revoked after 8 November 2010. No later amendment entries are present.

• The instrument does not detail any changes made from previous CASA directives concerning CF6 engines or whether this AD follows prior CASA action on the same subject.

For historical research or compliance confirmation beyond the scope of the supplied text, one would need to consult CASA’s public AD register or other official CASA records to determine whether this instrument has been amended, superseded or otherwise changed since issuance. The present document itself records only issuance on 8 October 2010 and effectiveness on 8 November 2010 and reproduces the FAA AD entries with their own historical effective dates.

The supplied Directive text contains no information about litigation, disputes, appeals, judicial review, or administrative proceedings related to AD/CF6/78. There are no case names, court decisions, tribunal determinations or references to challenges recorded in the material provided.

Consequently, based solely on the text in this Directive:

• No litigation is reported or referenced. The instrument does not recount any litigation either by CASA or against CASA concerning its issuance, nor does it note any appeals or administrative review processes that have been invoked in relation to this specific Directive.

• No precedent or judicial interpretation of the Directive is supplied. The text does not include citations to judicial authorities or earlier CASA decisions that would illuminate how its provisions have been interpreted or enforced in practice.

If a practitioner needs to know whether this Directive has been the subject of litigation, or whether relevant judicial or administrative rulings have affected its interpretation, they must search external legal and administrative databases, court records, or CASA’s own records. The Directive itself provides no litigation history to inform legal risk assessment or precedent analysis.

The Directive’s brevity and its method of importing FAA ADs create a number of practical pitfalls and risk points that appear in the text.

• Applicability is factual and can vary by aircraft. The Directive explicitly recognises that "due to date of aircraft manufacture or aircraft configuration and modification status, some of the ADs listed in Table 1 may not be applicable to aircraft registered in Australia." The gotcha is that a superficial reading that treats all listed FAA ADs as automatically applicable would be wrong. The operator must perform a careful mapping exercise against the FAA AD texts to ascertain applicability. Mischaracterising applicability can lead either to unnecessary work or to non-compliance if an applicable AD is overlooked.

• Once-only ADs with past compliance dates. The background states the FAA ADs "require once-only actions for which the compliance date has passed." The implication is that many aircraft already in service likely have had the FAA actions performed, while aircraft entering the Australian register might not. The risk is assuming compliance status without documentary evidence; absent proof, CASA’s timing condition means the actions must be performed before certification or further flight.

• Acceptance limited to FAA-approved AMOCs. The Directive expressly accepts Service Bulletins approved by the FAA as AMOCs for the FAA ADs in Table 1. The gotcha is that AMOCs approved by other authorities or AMOCs approved directly by CASA are not mentioned; the Directive does not state whether those would be acceptable. Regulated parties should not assume that non-FAA approvals are automatically acceptable for the purposes of this Directive.

• Timing conditions can interrupt operations. For aircraft already on the Australian register, the Directive requires compliance "before further flight after 8 November 2010." That is a binary operational constraint: the aircraft cannot be operated again until the requirements are satisfied. Failure to plan for this could ground an aircraft unexpectedly.

• Reliance on external source documents. The Directive imports the FAA ADs by reference and directs operators to http://rgl.faa.gov. The gotcha is that the FAA AD texts themselves contain the technical applicability criteria, required actions, and any AMOC information. Operators who do not retrieve and read the FAA AD text in full risk misapplying the Directive’s obligations.

• No explicit documentation procedure provided. The Directive requires actions but does not lay out how compliance must be recorded, what evidence must be held or submitted to CASA, or what forms are required. That absence means that operators must rely on standard airworthiness recordkeeping practice to create defensible audit trails, but the operator may not know whether CASA expects any specific notification or evidence filing for this Directive.

• Specificity of listed FAA ADs. The Directive lists four FAA ADs by number and effective date. A practical pitfall is working with the wrong FAA AD edition. Since ADs may be revised, the regulated party must confirm that the relevant FAA AD version corresponds to the Table 1 entry or determine whether later FAA actions affect the requirement.

• No penalties or enforcement steps in the text. The Directive contains no explicit penalty structure, but the timing constraints linked to certification and flight suggest operational enforcement. The gotcha is that the regulated party cannot read the absence of penalty terms as freedom to defer compliance; CASA’s general enforcement powers, not cited here, would be the relevant mechanism.

• The Directive is equipment-limited. It applies to "General Electric CF6 engines" only. An operator with mixed engine types might accidentally apply requirements to non-covered engines if they do not check the equipment identification carefully.

• Administrative provenance but limited procedural guidance. Signed by a CASA delegate, the Directive has clear authority, but it gives little procedural guidance. The gotcha is assuming this document provides all process steps necessary to demonstrate compliance to CASA.

Careful attention to the FAA AD texts, strict documentary evidence of previous accomplishment where claimed, and early scheduling of any required work will mitigate many of these risks. Operators should not assume equivalence of non-FAA AMOC approvals or informal technical deviations without explicit FAA or CASA approval as permitted by the Directive.

The Directive gives a compact compliance recipe; follow these discrete steps to meet the textual requirements exactly.

1. Identify affected engines. Confirm which aircraft on the register have General Electric CF6 series engines as specified in the Directive. The Directive’s applicability line reads "General Electric CF6 engines." Do not extend compliance steps to other engine types.

2. Retrieve the authoritative FAA AD texts. The Directive provides Note 1 stating "FAA ADs may be accessed via the internet at the following URL: http://rgl.faa.gov." Use that site to obtain the full FAA AD texts for the specific AD numbers listed in Table 1: 90-12-06, 96-16-07, 2005-26-06 and 2007-21-06. Use the FAA AD texts to determine technical applicability criteria, required actions, and any AMOC information.

3. Determine applicability for each FAA AD in Table 1, against each engine/aircraft. The Directive’s first operative requirement is to "Determine the applicability of the ... FAA Airworthiness Directives (ADs) listed in Table 1." Compare the FAA AD’s applicability criteria (for example, serial number ranges, affected part numbers, installation indices, or configuration limitations) with the aircraft’s and engine’s manufacture data, modification status, logbooks and maintenance records. Where the background notes that manufacture date, configuration and modification status can affect applicability, document the facts for each AD’s applicability determination.

4. Check previous accomplishment status. For each FAA AD that your applicability analysis shows is applicable, confirm whether the required FAA AD actions have "previously been accomplished." Locate maintenance records, logbook entries, SB compliance statements or other documentary evidence that the FAA AD action was completed. If there is credible documentary proof that the FAA AD actions were already performed, no further action for that AD may be required under the Directive.

5. If applicable and not previously accomplished, implement required FAA AD actions. The Directive states: "If it is determined that an FAA AD listed in Table 1 is applicable and has not been previously accomplished, perform the actions required by that AD." Implement the specific remedial actions, inspections or modifications exactly as prescribed in the FAA AD text, unless you will use an FAA-approved AMOC as below.

6. Consider FAA-approved AMOCs. The Directive states that "Service Bulletins approved by the FAA as Alternative Methods of Compliance (AMOC) to the FAA ADs listed in the Table 1 are considered acceptable for compliance with the equivalent requirements of this Directive." If the FAA has approved a Service Bulletin as an AMOC for the listed FAA AD, you may implement that AMOC instead of the FAA AD’s specific action. Ensure you have the FAA approval documentation for the AMOC and retain it in records as evidence of compliance.

7. Meet the timing requirements. The Directive prescribes two timing pathways. If the aircraft does not yet have a certificate of airworthiness, complete the applicability determination and any required FAA AD actions before issuance of the certificate. If the aircraft already has a certificate of airworthiness, ensure the applicability determinations and any required actions are completed before further flight after 8 November 2010. Plan maintenance scheduling accordingly and avoid operating the aircraft until compliance is demonstrably complete.

8. Document compliance. Although the Directive does not specify the format of evidence, good regulatory practice is to create an auditable record for each AD considered: the FAA AD title and number, the retrieved FAA AD text version, the technical basis for applicability determination, documentary evidence of prior accomplishment where claimed (logbook entries, SB compliance reports), details of corrective actions performed or AMOCs implemented, dates of completion and the signatures of the responsible certifying maintenance release authority. Retain any FAA AMOC approval documentation if applicable.

9. Retain and present evidence for certification. If you are seeking issuance of a certificate of airworthiness, present the documented applicability determination and evidence of completed actions or valid FAA AMOC acceptance as part of the certification package to demonstrate compliance "before issue of the certificate of airworthiness" as required.

10. Reconcile with maintenance and operational planning. Because the Directive imports once-only FAA ADs with past compliance dates, incorporate the applicability checks into acceptance inspections for imported or newly-registered aircraft so that gaps are identified early and scheduled works can be completed without disrupting operations.

11. Seek clarification from CASA only if necessary. The Directive is precise in what it requires and points to FAA AD texts for the technical substance. If an unusual factual situation arises where applicability is ambiguous or where an AMOC is not FAA-approved but arguably equivalent, document your reasoning and, where necessary, approach CASA with the facts and proposed method of compliance, noting that the Directive explicitly recognises FAA-approved AMOCs.

12. Keep version control of FAA ADs. Because Table 1 lists FAA AD numbers and their effective dates, make sure to implement the FAA AD text corresponding to the Table 1 entry. If the FAA has since revised or superseded an AD, consult the FAA text to confirm whether the revision affects the AD listed in Table 1 or the availability of AMOCs.

By following these steps, an operator will meet the specific textual obligations set out in AD/CF6/78: perform a careful applicability analysis, execute outstanding FAA AD actions where needed, use FAA-approved AMOCs where available and comply within the timing constraints tied to certification and further flight after the effective date.