AD/PA-34/51 Amdt 1 - Combustion Heater Fuel Pumps

The directive revolves around several defined concepts. Group 1 aeroplanes refer to the original population of PA-34-200T (serials 34-7570002 through 34-8170092) and PA-34-220T (serials 34-8133002 through 3449278) aeroplanes that were subject to the original AD/PA-34/51. Group 2 aeroplanes are the newly added PA-34-220T aeroplanes with serial numbers 3449279 through 3449309. The distinction matters because the service bulletin version and compliance timing differ.

The heater fuel pump is the component of interest, specifically models 91E92-1 and 91E93-1. These are part of the combustion heater system, which supplies fuel to the cabin heater. The directive does not define the pump’s normal service life or failure modes; it simply mandates a one-time visual inspection plus any necessary follow-up.

Visual inspection for leakage is the primary required action. The procedure must be done in accordance with two documents: The New Piper Aircraft, Inc. Service Bulletin No. 1127 (or 1127B for Group 2) and Kelly Aerospace Power Systems Service Information Letter Bulletin No. A-110A (or A-110B for Group 2). These documents are incorporated by reference; the operator must obtain and follow them. The source does not reproduce their content, but they presumably outline the specific inspection points, leak criteria, and any disassembly steps.

If a leak is found, the concept of abnormality inspection is triggered. The operator must examine the pump sealing surface for nicks, gouges, warping, or similar defects. The directive does not specify acceptable limits for these abnormalities; it says “correct any abnormality found.” That gives the maintainer discretion, but also imposes a duty to remediate. Only if the abnormality cannot be corrected must the pump be replaced. Replacement must also follow the same service bulletins.

The concept of time in service (TIS) is critical for compliance timing. TIS is the total time the aircraft has been operated since new, not since the last inspection. The initial inspection for Group 1 must be done within the first 10 hours TIS after 27 June 2003. For Group 2, it is within the first 10 hours TIS after 29 September 2005. Because the original directive was issued in 2003, many Group 1 aircraft would have accumulated far more than 10 hours by 2005. The directive says the compliance for Group 1(a) “remains unchanged as Within the next 10 hours time in service (TIS) after 27 June 2003.” This wording is odd; it suggests that if the inspection was not done at the original effective date, it must be done within the next 10 hours from that past date. In practice, that would mean the inspection was already overdue if not performed within 10 hours of 27 June 2003. The amendment does not reset the clock for Group 1; it just adds Group 2 with a new deadline.

Before further flight is a stricter compliance category: if a leak is found, the aircraft cannot fly again until the abnormality is corrected or the pump replaced. This imposes a potential grounding cost if the inspection reveals a problem.

Finally, the effective date of this Directive is 29 September 2005. That date triggers the installation prohibition for both groups and the inspection deadline for Group 2. For Group 1, the installation prohibition also runs from that date, which is a novel requirement not explicitly stated in the original directive’s residual text. The original directive likely had its own installation prohibition from 27 June 2003; the amendment reaffirms it.

The primary affected parties are the registered owners and operators of the listed Piper PA-34-200T and PA-34-220T aeroplanes. According to the serial number ranges, the total population is not large. Group 1 spans thousands of serials but only two models; Group 2 adds only 31 aircraft. The compliance burden falls on individual owners or commercial operators, who must schedule the inspection, procure the service bulletins, and potentially pay for repairs or replacement. There is no state subsidy; the cost is private.

Maintenance organisations and licensed aircraft maintenance engineers (LAME) are also affected. They must be familiar with the service bulletins and the AD text to perform the inspection correctly. The visual inspection likely requires access to the heater fuel pump, which may involve removing panels or internal components. The labour cost is non-trivial. If a leak is found, further work is required. Replacement pumps (models 91E92-1 or 91E93-1) are subject to the same inspection prohibition, so even new pumps cannot be installed without first being inspected. That applies to parts suppliers and distributors, who must ensure their inventory is not sold as un-inspected unless the purchaser is aware of the AD. The directive does not mandate a marking or certification for inspected pumps; it just prohibits installation. That puts the onus on the installing maintainer.

The original equipment manufacturer (OEM), The New Piper Aircraft, Inc., and the pump supplier, Kelly Aerospace Power Systems, are affected in the sense that they issued the service bulletins referenced by the AD. Their bulletins become mandatory through this regulatory action. The AD does not direct them to do anything, but it relies on their technical data.

The Civil Aviation Safety Authority is the regulator issuing and enforcing the AD. CASA has an interest in ensuring compliance to manage safety risk. However, the AD also imposes an indirect burden on CASA resources for oversight and potential enforcement.

Insurance companies and financiers may also be indirectly affected. If the AD is not complied with, the aircraft’s airworthiness certificate may be at risk, affecting insurability and asset value. A buyer of a used PA-34 would want to check AD compliance records.

Potentially, passengers and third parties are the intended beneficiaries of the reduced fire risk, but they bear no direct cost. The cost is externalised to owners and operators.

The AD does not affect aircraft outside the listed serial numbers. For example, PA-34-200T serials outside the range are not subject. But careful attention to serial number boundaries is needed, as the source lists a hyphen range for Group 2 with an en dash, which may be read as inclusive.

The central duty is to perform the visual inspection of any installed heater fuel pump (model 91E92-1 or 91E93-1) within the prescribed time. For Group 1 aeroplanes, that duty was originally due within 10 hours TIS after 27 June 2003; by the time of this amendment (2005), that duty was likely already overdue for many aircraft. The amendment does not create a new grace period for Group 1; it simply notes that the requirement “remains unchanged.” In practical terms, the operator of a Group 1 aircraft that never complied with the original directive would be in violation from the outset. The amendment might provide an opportunity for voluntary compliance, but the legal duty is retroactive.

For Group 2 aeroplanes, the duty arises upon the effective date: the inspection must be accomplished within 10 hours TIS after 29 September 2005. That is a forward-looking duty.

If a leak is found, a secondary duty arises: inspect the pump sealing surface for abnormalities. Then a tertiary duty: correct any abnormality found. If correction is impossible, the duty escalates to replacement. All these actions must be done before further flight.

A further duty applies to any person installing a heater fuel pump of the listed models: they must not install it unless it has passed the visual inspection and any necessary corrective actions. This duty is broad: it does not distinguish between new, overhauled, or used pumps. It effectively requires every pump of that model to undergo the inspection before installation, regardless of its history. That creates a compliance burden for parts suppliers and maintenance organisations.

The rights are implicit. Operators have the right to use alternative means of compliance if approved by CASA (though not mentioned, such rights exist under the Civil Aviation Safety Regulations). They have the right to rely on the approved data in the service bulletins. They have the right to challenge the AD through judicial review, but that is costly and unlikely for a limited population. They also have the right to sell or dispose of the aircraft, but the AD duty attaches to the aircraft, not the person, so it runs with the registration. An operator can also elect to remove the heater fuel pump and render the combustion heater inoperative, if that is permissible under other rules. The AD does not require the pump to be installed; it only mandates inspection if it is installed. Removing the pump and capping the fuel line might avoid the AD, but that could affect the aircraft’s type design and require an approved modification.

The directive does not confer any rights to compensation for costs incurred. It is a pure regulatory mandate.

The source does not list specific penalties, but under the Civil Aviation Act 1988 and the Civil Aviation Safety Regulations 1998, non-compliance with an airworthiness directive is a serious breach. The Civil Aviation Safety Authority can suspend or cancel the aircraft’s certificate of airworthiness, effectively grounding the aircraft until compliance is achieved. That is the most immediate enforcement lever. Operating an aircraft not in compliance with an AD is an offence. Under CASR Part 42, the registered operator is primarily responsible for maintaining the aircraft in an airworthy condition, which includes compliance with ADs. Failure could lead to civil penalties under the Act, which for corporations can be significant.

Beyond CASA action, the Australian Transport Safety Bureau may investigate incidents related to heater fuel pump failures, and non-compliance would be a factor. There is also the risk of voiding insurance coverage if an accident occurs during non-compliant operation.

The directive itself is a legislative instrument. It does not create a criminal penalty on its face, but it is enforced through the broader regulatory framework. CASA’s enforcement policy typically escalates from education and warning letters to enforceable voluntary undertakings, infringement notices, and court proceedings. For a limited-population AD like this, CASA might rely on targeted inspections and requests for records.

The enforcement burden is asymmetric. CASA bears the cost of monitoring compliance, but individual operators bear the cost of proving compliance through logbook entries and maintenance records. If an operator fails to comply and is caught, the penalty could be significant relative to the minor cost of the inspection. But many operators might simply overlook the AD, especially if the original 2003 compliance window has passed.

There is no mention of criminal liability for individuals or strict liability. Under CASR, the operator must take reasonable steps; but an inadvertent failure might still attract a penalty.

The AD is effective 29 September 2005. From that date, any Group 2 aircraft that has not been inspected is non-compliant. For Group 1, the effective date does not create a new compliance deadline for the inspection itself, but the installation prohibition from that date could be enforced.

This Airworthiness Directive is issued under the Civil Aviation Act 1988 and the Civil Aviation Safety Regulations 1998. It is a standalone regulatory instrument that modifies the aircraft’s type certificate or certificate of airworthiness. Under CASR Part 21 (Certification of aircraft) and Part 42 (Continuing airworthiness), compliance with ADs is mandatory. The directive does not interact with criminal law, tax law, or contract law directly, but it can affect commercial contracts for sale or lease of the aircraft, where the seller warrants compliance with all applicable ADs.

Coordination with foreign airworthiness authorities is relevant. The note in the source says: “FAA AD 2005-15-10 Amdt 39-14199 refers.” That suggests this CASA AD is harmonised with or derived from a corresponding US Federal Aviation Administration airworthiness directive. In practice, an aircraft imported from the US may have been subject to the FAA AD. The CASA AD may adopt the same requirements or differ. Operators must check whether compliance with the FAA AD satisfies the CASA AD, or whether additional steps are needed. The source does not specify the relationship, but the note implies a reference. This means that if an aircraft already complied with the FAA AD using the same service bulletins, it might still need to show compliance with the CASA AD, which has its own compliance paragraphs. The effective dates may differ.

The directive also interacts with other CASA requirements for maintenance records. Under CASR Part 42, maintenance actions must be recorded in the aircraft logbook or component history. Compliance with this AD must be properly documented. The directive does not specify record-keeping, but standard practice requires entry of the AD number, compliance method, date, and signature.

If the heater fuel pump is removed and replaced, the installation prohibition in the AD means that the replacement pump must be inspected before installation. That could interact with rules on approved parts (CASR Part 21) and the requirement to use only FAA-approved or CASA-approved parts. The service bulletins are issued by the OEM, so their use is typically accepted as an approved method.

The AD does not interact with state or territory laws unless it involves workplace health and safety for maintenance personnel.

There is no indication of interaction with privacy law, environmental law, or consumer law.

This document is Amendment 1 to AD/PA-34/51. The original AD/PA-34/51 was issued with an effective date of 27 June 2003. That original directive required a one-time visual inspection of combustion heater fuel pumps for leakage, with corrective action if needed. The amendment was issued on 18 August 2005 by James Coyne, Delegate of CASA, and becomes effective on 29 September 2005.

The scope of the amendment is limited. It adds a new group of aeroplanes (Group 2) to the applicability: PA-34-220T serial numbers 3449279 through 3449309, covering 31 aircraft. It also introduces updated service bulletin references for Group 2: Service Bulletin No. 1127B (dated 18 April 2005) and Kelly Aerospace Letter No. A-110B (dated 20 December 2004). For Group 1, the original service bulletin references (No. 1127 of 26 February 2003 and A-110A of 6 March 2003) are retained.

The compliance table in the source shows that for Group 1 (a), compliance “remains unchanged” - i.e., within 10 hours TIS after 27 June 2003. This is significant because it means that the original obligation is not extended or forgiven for Group 1. If an operator of a Group 1 aircraft failed to comply within 10 hours of the original effective date, they remain in breach. The amendment does not create a new compliance opportunity for those aircraft; it merely adds new aircraft.

For Group 2, the compliance times are triggered by the amendment’s effective date (29 September 2005). The installation prohibition for both groups runs from that date, which is a new requirement for Group 2 and a reaffirmation for Group 1.

There is no mention of any intervening amendments between the original and this amendment. The background states that the amendment results from further investigation that concluded additional fuel pumps not meeting quality control requirements had been installed in PA-34-220T aircraft. This suggests that the original AD’s applicability was too narrow, and the regulator expanded it based on new information. No cost-benefit analysis is provided.

The document does not indicate whether there have been any subsequent amendments. The AD number (AD/PA-34/51 Amdt 1) implies that future amendments could follow.

The source does not mention any litigation. Airworthiness directives are generally not challenged in court because the cost of litigation outweighs the compliance cost, and because the regulator has broad discretionary powers under the Civil Aviation Act. Moreover, the population of affected aircraft is small, and the operators are likely to comply rather than litigate.

However, it is possible that an owner of a Group 1 aircraft that missed the original compliance window might argue that the AD is invalid for imposing a retroactive requirement. The original AD required inspection within 10 hours TIS after 27 June 2003. By 2005, that time has passed. An owner who acquired the aircraft after 2003 might not have known about the AD. The amendment does not address that; it simply says compliance “remains unchanged.” A court might consider whether the operator had a reasonable opportunity to comply. But given that the AD was published, the onus would be on the operator to perform the inspection when the aircraft was first operated after the effective date. The passage of time does not extinguish the obligation.

For Group 2, the compliance time is forward-looking and less likely to be challenged.

There is no record of any administrative review or merits review of this particular AD within CASA. Under the Administrative Appeals Tribunal Act 1975, a person affected by a decision of a CASA delegate may seek review. That would be an option if CASA takes enforcement action based on non-compliance. But no such cases are cited in the source.

The note referencing FAA AD 2005-15-10 suggests that the US equivalent may have been the subject of litigation in US courts, but that is not covered here.

Given the age of the directive (2005), any litigation would have likely occurred years ago. The reader should treat the absence of litigation as notable: it either indicates broad acceptance or that the costs of compliance were low enough to avoid court. But the lack of litigation does not validate the regulatory approach.

Several aspects of this directive may trap the unwary.

Compliance timing confusion for Group 1. The compliance table says Group 1(a) “Remains unchanged as Within the next 10 hours time in service (TIS) after 27 June 2003.” That wording suggests that if the inspection was not done within 10 hours of that date, it is overdue and cannot be caught up. An operator who acquires a Group 1 aircraft in 2005 must check the logbook. If the inspection was never performed, the aircraft is non-compliant and must be grounded immediately. There is no grace period in the amendment. The only viable action is to perform the inspection as soon as possible, and then document that it was done, even though late. But the legal breach remains.

Serial number ranges may not be obvious. The Group 2 serial numbers are listed as “3449279 through 3449309.” The Group 1 PA-34-220T range ends at 3449278. So the break is clear, but an operator with a PA-34-220T serial 3449278 is Group 1, while 3449279 is Group 2. That requires careful reading.

Service bulletin version matters. For Group 1, the directive references Service Bulletin No. 1127 and Kelly Letter A-110A. For Group 2, it references 1127B and A-110B. Using the wrong version could result in non-compliance even if the inspection is performed. The documents are not reproduced in the directive, so the operator must obtain the correct version.

The installation prohibition is absolute. The directive says: “Do not install any heater fuel pump (model 91E92-1 or model 91E93-1) unless you have visually inspected the pump for leakage and corrected any abnormalities …” This applies regardless of whether the pump is new from the factory. It means that even a brand-new replacement pump must be inspected before installation. That could cause delays and extra cost if the pump arrives sealed and the distributor is not aware of the AD.

Potential for subtle wording on Group 1(c) and Group 2(c). Both say the installation prohibition runs “from the effective date of this Directive.” For Group 1, the original directive already had an installation prohibition from 27 June 2003. This amendment does not override that; it reasserts it from a later date. Arguably, an installation prohibition that started earlier and continues is stricter. But an operator might mistakenly think that because the amendment says “from the effective date”, the original prohibition is replaced. It is not; it is cumulative.

No exemption for aircraft that have already complied. If a Group 1 aircraft performed the inspection under the original AD, does the amendment require any new action? No, because the requirement for Group 1 is unchanged. But if a Group 2 aircraft already complied with the original AD (which did not apply to it, since it was not listed), the owner might think it is safe. However, the original AD did not cover those serial numbers, so no compliance action could have been taken under it. The amendment now imposes a duty. The owner must now perform the inspection within 10 hours after 29 September 2005, even if the aircraft has been flying without incident.

Background risk claim is unquantified. The source says “Quality control problems with the heater fuel pump could result in failure of the heater fuel pump. Such failure could lead to fire or explosion in the cockpit.” That is a generic statement. There is no data on failure rates, number of incidents, or probability. The regulator’s stated purpose is to address that risk, but the reader cannot assess whether the cost of inspection is proportionate.

First, determine whether the aircraft is subject to this directive. Check the model and serial number against the tables. PA-34-200T serials 34-7570002 through 34-8170092 are Group 1. PA-34-220T serials 34-8133002 through 3449278 are Group 1. PA-34-220T serials 3449279 through 3449309 are Group 2. If the aircraft is not in these ranges, no action is required under this AD.

If the aircraft is Group 1 and the original inspection (per Requirement 1(a)) was performed within 10 hours TIS after 27 June 2003, and no leak was found, no further action is needed under this amendment. However, if the inspection was not done, the aircraft is currently non-compliant. The only way to comply is to perform the inspection immediately, using Service Bulletin No. 1127 (dated 26 February 2003) and Kelly Aerospace Letter A-110A (dated 6 March 2003). The inspection must be visual, looking for fuel leakage. Document the inspection in the aircraft logbook, noting the AD number, the compliance method, and the result.

If a leak is found on a Group 1 aircraft, do not fly the aircraft again until the pump sealing surface is inspected for abnormalities (nicks, gouges, warping). Correct any abnormality. If correction is impossible, replace the heater fuel pump with a serviceable unit, but note that the replacement pump must also be inspected before installation.

For Group 2 aircraft, the compliance clock starts on 29 September 2005. Arrange for the visual inspection within 10 hours TIS after that date, using Service Bulletin No. 1127B (dated 18 April 2005) and Kelly Aerospace Letter A-110B (dated 20 December 2004). If a leak is found, follow the same corrective steps as for Group 1, using the Group 2 service bulletins. The prohibition on installing un-inspected pumps applies from 29 September 2005.

The practical steps involve obtaining the required service bulletins and letters. These are proprietary documents from Piper and Kelly Aerospace. The operator or maintainer must source them, possibly from the manufacturer’s website or through a parts distributor. The directive does not make them publicly available. That is a compliance cost.

Next, schedule the aircraft for maintenance. The inspection is visual, but access to the heater fuel pump may require removing interior panels or engine cowlings. The time needed should be estimated by a LAME familiar with PA-34 aircraft. The 10-hour TIS window is generous, but if the aircraft is used frequently, the window could close quickly.

Maintain a clear record: logbook entry stating “Compliance with AD/PA-34/51 Amdt 1, Requirement 1/2 [as applicable], visual inspection performed [date]; no leakage found” or if corrective action was taken, detail the repair or replacement. Keep copies of the service bulletins used.

If the aircraft is sold, the seller should provide the AD compliance records to the buyer. The buyer should verify that the inspection was done and that the correct service bulletin version was used.

For parts suppliers and maintenance organisations, establish a procedure to ensure that any heater fuel pump model 91E92-1 or 91E93-1 is not installed until it has been inspected per the AD. That may involve setting up a quarantine area and inspection checklist.

Finally, monitor for future amendments. This is Amdt 1; there may be further changes. CASA’s website is the official source for current AD status.