AD/S-PUMA/62 Amdt 1 - Landing Gear - Electro-Valve Power Supply

The AD rests on a small number of interconnected technical and regulatory concepts that determine its scope and practical effect.

Applicability by mod-status and part number: The affected fleet is defined narrowly. The table states applicability as "AS 332 C, C1, L and L1 helicopters, pre MOD 0723817" that either (a) do not have the helicopter wiring modified in accordance with MOD 0725670 or Eurocopter AS 332 Service Bulletin (SB) 32.00.12 dated 28 April 1999 or a later EASA-approved revision, and/or (b) are equipped with a 33G landing gear control unit having specific part numbers (PN 332A67-1623-00, 332A67-1623-06, 332A67-1623-0610 or 332A67-1623-0651) that have not been modified per MOD 0725670 or MOD references 332P083218 or 332A088381 or per AS 332 SB 32.00.12 or a later EASA-approved revision. The AD therefore targets airframes with a particular pre-MOD status and specific control unit PN cohorts that lack specified prior modifications.

Modification as the remedy: The AD prescribes physical modifications to wiring and to the 33G landing gear control units, using paragraph 2.B of ASB 32.00.18 as the implementing document. For the specific PN 332A67-1623-0610 the AD requires modification and subsequent functional testing as instructeds in the ASB. For helicopters already modified under the original AD and ASB Revision 0, the AD requires repetition of functional tests as specified in paragraph 2.B.3 of the ASB. Spares are caught by a separate obligation: units held as spares must be modified per paragraph 2.B.5 of the ASB before they are installed.

Reference to EASA approval: The AD conditions compliance on the referenced ASB being used in its form as approved by EASA; the AD expressly allows later revisions "approved by the EASA." The AD also notes that EASA AD 2006-0152 refers, signalling coordination between CASA and EASA instruments and anchoring the technical remedy to an EASA-approved service instruction.

Timing and retroactivity mechanics: The AD attaches precise compliance times to each requirement, some of which precede the amendment's effective date. Requirement 1 carries a compliance deadline prior to 31 December 2005, while Requirements 2 and 3 carry deadlines prior to 23 February 2007. Requirement 4 is prospective, tying modification of spares to the point of installation. The AD also contains the line "Compliance time for Requirement 1 remains unchanged from the original issue of this AD," which links the amendment to a prior instrument and preserves its earlier deadline.

Safety failure mode and corrective objective: The problem prompting the AD is described in the Background: reports of electro-valve power supply disruptions that have caused the landing gear to retract and the helicopter to drop, causing structural damage. The corrective objective as stated is to "prevent landing gear retraction whilst the helicopter is on the ground." The AD therefore links a specific component failure mode (electro-valve power supply disruption) to a concrete operational hazard (uncommanded gear retraction on ground) and prescribes hardware and wiring changes and tests to mitigate that hazard.

Prescriptive service-instruction linkage: Rather than setting out engineering detail in the directive text, the AD delegates technical specifics to Eurocopter ASB 32.00.18 paragraph 2.B and to earlier SBs and MODs for exclusion criteria. The operative directive mandates compliance with those paragraphs and their EASA-approved later revisions rather than reproducing the steps.

Administrative issuance: The AD is an amendment (Amdt 1) to AD/S-PUMA/62, signed by a CASA delegate and dated 29 September 2006 on the document, effective 23 November 2006; the amendment extends applicability and corrects the functional test definition. The document thereby functions as a regulatory update to a prior AD.

The AD explicitly affects a narrow set of stakeholders identified by airframe model, mod-status, and part number holdings. The parties and assets directly affected by the measures in the AD are as follows, as given in the "Applicability" text:

• Owners and operators of Eurocopter AS 332 C, C1, L, and L1 helicopters that are pre MOD 0723817 and either (a) do not have the helicopter wiring modified in accordance with MOD 0725670 or Eurocopter AS 332 SB 32.00.12 dated 28 April 1999 (or later EASA-approved revision), and/or (b) are equipped with a 33G landing gear control unit with Part Numbers PN 332A67-1623-00, 332A67-1623-06, 332A67-1623-0610 or 332A67-1623-0651 that have not been modified as specified. Those owners and operators must arrange the wiring and control-unit modifications per the ASB and, where required, perform functional tests.

• Maintenance organisations and certificated repair stations contracted by operators to perform the wiring and control-unit modifications and the functional tests specified in Eurocopter ASB 32.00.18 paragraph 2.B. These bodies will be responsible for performing the work to the technical standard invoked by the AD and for recording compliance.

• Entities holding spare 33G landing gear control units (the same PN range listed above). The AD imposes a duty to modify those spares per paragraph 2.B.5 of the ASB before installation on an affected helicopter. Holding spares thus triggers a forward-looking obligation at the point of installation.

• Eurocopter (as the original equipment manufacturer), insofar as the AD relies on Eurocopter ASB 32.00.18 paragraph 2.B and earlier SBs and MODs, and insofar as the AD extends applicability to an additional control unit PN. Eurocopter's service instructions and the MOD definitions anchor the technical remedy.

• Regulators and their delegates, primarily the Civil Aviation Safety Authority (CASA) by issuing the AD and the EASA by approving ASB revisions and by way of the cross-reference to EASA AD 2006-0152. The AD requires use of EASA-approved ASB revisions, linking operational compliance to EASA technical approvals.

Indirectly, the AD will affect scheduling and commercial operations: helicopters requiring the modifications may need maintenance downtime; operators reliant on those helicopter models for commercial services will need to plan around those aircraft being unavailable while modifications and tests are completed. The AD document does not quantify downtime, cost, parts lead times, or provide exemptions; those practical burdens fall to operators and their maintenance suppliers.

Exclusions and pre-modified aircraft: Aircraft that are post MOD 0723817, or that already have wiring modified per MOD 0725670 or SB 32.00.12 (or later EASA-approved revisions), or which have the listed PN control units already modified per the MODs and SBs referenced, appear not to be within the scope of the AD as written. The AD sets out these MODs and SBs explicitly in the Applicability text; operators should verify mod-status and any prior compliance to determine whether their helicopter is captured.

Geography and regulatory scope: The AD is a CASA instrument applying to Australian-registered operations; it also references and aligns with EASA material. The document does not purport to apply internationally but references EASA approvals and EASA AD 2006-0152.

The AD creates several positive obligations for affected parties, and it anchors those obligations to external service instructions. The instrument text itself specifies what must be done, how it must be done (by reference), and by when. The obligations and any implicit rights available to regulated parties under the AD are as follows, with direct textual grounding.

Primary duties

• Modify aircraft wiring and installed 33G landing gear control units in accordance with paragraph 2.B of Eurocopter AS 332 ASB 32.00.18 or later revision approved by the EASA (Requirement 1). The AD text states this duty explicitly: "Modify the helicopter wiring and installed 33G landing gear control units in accordance with paragraph 2.B. of Eurocopter AS 332 Alert Service Bulletin (ASB) 32.00.18 or later revision approved by the EASA."
• For aircraft equipped with 33G landing gear control unit PN 332A67-1623-0610, carry out the modifications specified in paragraph 2.B of the ASB and then perform functional tests to check these modifications "in compliance with the instructions specified in paragraph 2.B. of the referenced ASB" (Requirement 2).
• For helicopters previously modified in compliance with the AD/S-PUMA/62 original AD and AS 332 ASB 32.00.18 Revision 0, repeat the functional tests in compliance with instructions specified in paragraph 2.B.3. of the ASB (Requirement 3).
• Modify 33G landing gear control units held as spares in accordance with paragraph 2.B.5 of ASB 32.00.18 before installation on a helicopter (Requirement 4).

Timings as duties: The AD imposes strict compliance timeframes for each of the requirements: Requirement 1 "Prior to 31 December 2005"; Requirement 2 "Prior to 23 February 2007"; Requirement 3 "Prior to 23 February 2007"; Requirement 4 "Before installation on a helicopter." The document further states that "Compliance time for Requirement 1 remains unchanged from the original issue of this AD," thereby maintaining an earlier deadline.

Reference-based performance standard: The AD does not set out the technical steps itself; rather it requires adherence to paragraph 2.B of the ASB (and specified subparagraphs for functional tests and spares). This delegates the technical method to Eurocopter's ASB subject to EASA approval. The AD also permits later revisions of the ASB that have EASA approval.

Rights and compliance mechanics

• The AD allows use of later revisions of ASB 32.00.18 provided such revisions are approved by the EASA. The express allowance for "later revision approved by the EASA" is effectively a procedural right to use an updated ASB once EASA has approved it.
• For helicopters already modified to earlier standards (e.g. MOD 0725670 or SB 32.00.12) the Applicability text indicates these aircraft are outside the AD's scope. That functions as a de facto compliance credit: prior modification per the listed MODs/SBs means the AD's remedial actions are not required for that airframe under this AD, as stated in the Applicability: "Without the helicopter wiring modified in accordance with either MOD 0725670 or Eurocopter AS 332 Service Bulletin (SB) 32.00.12 ..."

Documentation and provenance: The AD names the specific ASB paragraphs to be followed; parties must therefore obtain and follow Eurocopter ASB 32.00.18 paragraph 2.B (or later EASA-approved revision) to satisfy the directive. The AD also references EASA AD 2006-0152; operators and maintenance organisations will likely need to demonstrate that they used the EASA-approved ASB revision referenced by CASA when performing modifications and testing.

No penalties or enforcement mechanisms within text: The AD does not itself include penalty provisions or specify the enforcement process; it is framed as a directive with compliance times. The AD is signed and issued by a CASA delegate, indicating it is an instrument of the regulator. The AD does not set out appeal pathways or waivers within the text provided; it does, however, preserve earlier compliance deadlines for Requirement 1 as noted.

Operational consequence duties: The AD's presence imposes ancillary duties on operators to schedule aircraft downtime for modification and testing, to source modified parts or to arrange modification of spares before installation, and to retain records sufficient to show that the modifications and tests were carried out in accordance with the specified ASB paragraph and within the specified timeframes.

The text of AD/S-PUMA/62 Amendment 1 does not specify penalties, enforcement mechanisms, or sanctions within the four corners of the printed directive. The instrument sets mandatory technical requirements and compliance times but contains no express provision detailing fines, certificates of airworthiness consequences, suspension mechanisms, or administrative processes for non-compliance. The AD was signed by James Coyne, Delegate of the Civil Aviation Safety Authority, and made effective 23 November 2006, which indicates it is an instrument issued by CASA, but the AD document as supplied does not include the regulatory or enforcement framework that gives operational effect to the AD.

Implications arising from the absence of expressed penalties in the text

• No immediate penalty text: Because the AD text does not state penalties, anyone seeking to determine consequences for non-compliance must look to the broader statutory and regulatory framework that empowers CASA to issue ADs and to enforce aviation safety requirements. That framework is not reproduced in the AD text provided; therefore the directive itself does not identify the enforcement steps or sanctions.
• Record and evidence obligations: The AD prescribes specific technical actions and timings; practical enforcement will turn on whether operators and maintainers can demonstrate compliance with the specified ASB paragraphs and the specified dates. The AD’s prescriptive references to particular paragraphs and to EASA approval create a recordable standard of performance for which documentary proof can be produced.
• Enforcement route likely external to the AD text: In practice, regulatory enforcement for non-compliance with an AD would sit within CASA’s regulatory powers and aviation safety enforcement procedures. Those powers and procedures are not contained or described in this AD text. The AD does not, for example, state that failing to comply will automatically ground aircraft; it simply mandates modifications and testing.

Testing and inspection as compliance evidence: The AD requires functional tests where applicable (notably for PN 332A67-1623-0610 and for helicopters previously modified per the original AD and ASB Revision 0). The outcome and documentation of those functional tests, performed "in compliance with the instructions specified in paragraph 2.B. of the referenced ASB" (Requirement 2) and with paragraph 2.B.3 for repeating tests (Requirement 3), will act as the most concrete evidence that the operator fulfilled the AD’s technical obligations.

Ambiguities that affect enforcement practicality: The AD contains timing anomalies,Requirement 1’s deadline is prior to the effective date of the amendment,which may complicate any enforcement action based solely on this instrument. The AD explicitly states that "Compliance time for Requirement 1 remains unchanged from the original issue of this AD." That preserves the earlier deadline from the original AD but also creates a temporal sequencing issue within the amendment text. How that sequencing affects enforcement would be resolved by reference to the original AD and to CASA’s enforcement policy and practice, none of which are present in the supplied AD text.

In short, the AD sets specific duties and deadlines but does not itself set out penalties or the exact enforcement machinery. Parties requiring detail on sanctions or enforcement procedures will need to consult the statutory and regulatory instruments that empower CASA and govern aviation safety enforcement; those instruments are outside the scope of the AD as supplied.

The AD explicitly cross-references, incorporates and preserves the effect of a number of external technical instruments. The directive therefore must be read alongside those documents to understand its full legal and technical effect.

Mandatory reference to Eurocopter ASB and EASA approval: The AD requires modifications and tests "in accordance with paragraph 2.B. of Eurocopter AS 332 Alert Service Bulletin (ASB) 32.00.18 or later revision approved by the EASA." By tying the required actions to an ASB and to EASA approval of later revisions, the AD imports the technical content of the ASB into its compliance standard and makes EASA approval a gating condition for acceptable later revisions. This creates an interaction where CASA’s AD references EASA-approved technical material; compliance thus depends on following the ASB as approved by EASA.

References to prior Eurocopter SBs and MODs as exclusion criteria: The Applicability clause excludes helicopters that already have wiring modified in accordance with MOD 0725670 or Eurocopter AS 332 SB 32.00.12 dated 28 April 1999 or later revisions approved by the EASA. It also references MOD numbers 332P083218 and 332A088381 for modified control units. Those MODs and SBs are imported as technical thresholds which, if met, remove an aircraft from the AD’s scope. That interaction requires operators to cross-check historical modification records against those MOD and SB identifiers to determine whether the AD applies.

Reference to EASA AD 2006-0152: The AD includes the note "EASA AD 2006-0152 refers." That signals regulatory alignment with an EASA airworthiness directive addressing the same technical issue. The interaction suggests coordination between CASA and EASA instruments and that the technical standards invoked in EASA AD 2006-0152 are relevant to compliance with AD/S-PUMA/62 Amdt 1.

Link to the original AD and preserved compliance times: The amendment states that "Compliance time for Requirement 1 remains unchanged from the original issue of this AD," thereby preserving the timing conditions imposed by the prior AD/S-PUMA/62. This creates an interaction between the amendment and the original instrument for which the original text and its compliance requirements are necessary to understand the full legal obligations. The amendment itself does not reproduce the original compliance time beyond the statement that Requirement 1 maintains its original deadline.

Installation of spares and procurement interactions: Requirement 4 requires modification of 33G landing gear control units held as spares "in accordance with paragraph 2.B.5. ASB 32.00.18 or later revision approved by the EASA" before installation. This imposes a compliance condition on procurement and logistics processes: any spare unit in inventory must be modified per the ASB before it is installed on an affected helicopter. The AD therefore interacts functionally with supply-chain practices and spare-parts management rules, which are part of operations and maintenance regulatory practice.

No express conflict clauses: The AD does not contain an express clause resolving conflicts between the AD and other rules (for example, differing local requirements). Where operators are subject to multiple jurisdictions or to international operation rules, they must reconcile this AD with those other requirements, but the AD text does not itself state how to resolve any conflicts.

Consequences for record-keeping and certification: The AD requires adherence to particular ASB paragraphs and tests; performing the required work in accordance with the ASB and retaining evidence of EASA-approved ASB revisions will be essential for demonstrating compliance, particularly where other regulatory instruments require demonstration of airworthiness directive compliance before returning aircraft to service. The AD itself does not set out record-keeping obligations, but the imported ASB and the broader aviation regulatory framework will typically require traceable maintenance records.

Overall, this AD is non-self-contained: it imports, references and preserves the effect of several external MODs, SBs, an ASB, and an EASA AD. To understand compliance fully, affected operators must consult and follow those documents as referenced.

The supplied document is AD/S-PUMA/62 Amendment 1, dated 12/2006, and bears an internal date line signed by James Coyne, Delegate of the Civil Aviation Safety Authority, dated 29 September 2006, with the amendment stated to become effective on 23 November 2006. The AD is labelled twice in the text: "AD/S-PUMA/62 Amdt 1" and "AD/S-PUMA/62 Amdt 1 AD/S-PUMA/62 Amdt 1." It refers to an original AD/S-PUMA/62 (the "original issue") rather than reproducing the original text in full.

What the amendment does relative to the original AD

• Extends applicability: The amendment "extends the applicability of the AD to a new control unit." The new control unit PN added to the applicability list is 332A67-1623-0610. The inclusion of that PN pulls into scope aircraft equipped with that part number unless the unit has been modified per the referenced MODs or SBs.
• Corrects functional test definition: The amendment "corrects the definition of the functional tests to be carried out" , it does so by specifying the ASB paragraphs (2.B, 2.B.3, 2.B.5) to govern the testing and spares modification steps. The AD thereby clarifies what tests must be performed and which ASB subparagraphs are to be used for spares and repeat testing.

Timing and effective dates

• The document contains the line "This Amendment becomes effective on 23 November 2006." It also records "This Amendment" with the code "12/2006" and repeats the effective date in the header region. The practical effect is that the amendment was signed in late September 2006 and scheduled to operate from 23 November 2006.

Preservation of original requirement timing

• The amendment explicitly preserves the original compliance time for Requirement 1 by stating "Compliance time for Requirement 1 remains unchanged from the original issue of this AD." Requirement 1’s compliance deadline is quoted in the table as "Prior to 31 December 2005." The amendment therefore references and preserves time-related obligations that predate the amendment itself.

Document provenance and cross-references

• The amendment references Eurocopter ASB 32.00.18 and allows later revisions approved by the EASA. It also refers to earlier MODs and SBs that act as exclusion criteria, specifically MOD 0725670, SB 32.00.12 dated 28 April 1999, and MOD identifiers 332P083218 and 332A088381. The amendment includes a note that "EASA AD 2006-0152 refers," indicating parallel or coordinating action by EASA.

Administrative sign-off

• The document is signed by James Coyne, Delegate of the Civil Aviation Safety Authority. The signature line includes the date 29 September 2006. The AD is presented as an amendment to AD/S-PUMA/62 with the amendment number Amdt 1.

Gaps in the amendment text

• The amendment does not reproduce the original AD in full, nor does it include a summary of that original AD. It therefore must be read in conjunction with AD/S-PUMA/62 original text and with Eurocopter ASB 32.00.18 paragraph 2.B to understand the full engineering and timing obligations. The amendment preserves certain elements of the original AD, notably the Requirement 1 compliance time.

In short, the supplied document is an explicit amendment to an earlier AD that adds a control unit PN to the applicability, clarifies the functional test requirements by reference to the ASB paragraphs, and preserves the original compliance timeframe for one requirement, while establishing new compliance times for other requirements.

The AD text supplied contains no references to litigation, legal proceedings, case law, or dispute resolution outcomes. It is an administrative instrument issued by the Civil Aviation Safety Authority (signed by a delegate) and the text does not disclose any judicial or administrative challenges to the AD, nor does it narrate any prior enforcement actions, appeals, or court decisions relating to AD/S-PUMA/62 or this amendment. The only external normative references are to Eurocopter service documents and to EASA AD 2006-0152; none are litigation references.

Practical observations relevant to potential litigation or disputes

• Absence of litigation history in the AD text: Because the instrument as supplied does not include litigation history, readers seeking precedent on enforcement disputes, judicial review of the AD, or case law interpreting the obligations must look beyond the supplied text to the courts and administrative records. This AD document provides the technical and timing obligations but not any record of contested enforcement or adjudicated legal disputes.
• Evidentiary and documentary focus in potential disputes: If a dispute were to arise about compliance, the AD’s reliance on ASB paragraph 2.B and on EASA-approved revisions means that documentary evidence of which ASB revision was used, the EASA approval status of that revision, installation and maintenance records, parts traceability for control unit PNs and MOD histories (e.g. MOD 0725670, MOD 0723817, 332P083218 and 332A088381), and the functional test records specified in paragraph 2.B of the ASB would be central to any contested enforcement action. The AD itself makes those documents central by naming them.
• Timing anomalies and potential dispute points: The AD preserves the original Requirement 1 deadline as "Prior to 31 December 2005" while the amendment becomes effective 23 November 2006. That temporal configuration could be a contested point in litigation or administrative review if enforcement were sought for work allegedly required by this amendment after the stated deadline. Any adjudication of non-compliance might therefore involve examining the original AD/S-PUMA/62 text to determine the provenance of the Requirement 1 deadline and whether the amendment or the original AD controls the enforcement timeline.
• No published cases named: The AD does not name any cases or decisions; it contains only technical, compliance and background material. Parties intending to litigate would need to rely on statutory instruments empowering CASA and on relevant aviation safety enforcement jurisprudence, none of which are reproduced in this AD.

Because the supplied instrument contains no litigation history or cases, practitioners must consult external legal databases, CASA enforcement records, and court or tribunal archives if they require precedents or records of legal challenge concerning AD/S-PUMA/62 or closely related airworthiness directives.

The AD contains several operational, timing and documentation pitfalls that affected parties should note. The following points are grounded directly in the AD text.

1. Applicability requires checking multiple mod-statuses and SB/MOD references

• The Applicability box captures AS 332 C, C1, L and L1 helicopters pre MOD 0723817 that either lack certain wiring modifications or are equipped with specific 33G landing gear control unit PNs not modified per certain MODs or SBs. Determining whether an aircraft is affected therefore requires cross-referencing the aircraft status against multiple MOD identifiers (MOD 0723817; MOD 0725670; 332P083218; 332A088381) and service bulletin SB 32.00.12 dated 28 April 1999, or later EASA-approved revisions. Failure to correctly verify an aircraft’s MOD history and parts modification status could lead to performing unnecessary work or, conversely, overlooking an obligation. The text states: "Applicability: AS 332 C, C1, L and L1 helicopters, pre MOD 0723817: a. Without the helicopter wiring modified in accordance with either MOD 0725670 or Eurocopter AS 332 Service Bulletin (SB) 32.00.12 ... and/or b. Equipped with a 33G landing gear control unit Part Number ... not modified per MOD 0725670 or 332P083218 or 332A088381 or per AS 332 SB 32.00.12 ..."

2. Control unit PNs are specific and an amendment adds a PN

• The AD lists PNs 332A67-1623-00, -06, -0610 and -0651. Amendment 1 explicitly extends applicability to PN 332A67-1623-0610. Operators must check serial and part-number records carefully. Parts with slightly different suffixes can be misconstrued; the AD uses exact PN strings.

3. Timing anomaly for Requirement 1

• Requirement 1 carries the compliance time "Prior to 31 December 2005" while the amendment becomes effective 23 November 2006 and is dated 29 September 2006. The AD also says "Compliance time for Requirement 1 remains unchanged from the original issue of this AD." Practically, this creates a temporal oddity: the amendment repeats or preserves an earlier deadline that predates the amendment’s effective date. Operators should not assume the amendment resets deadlines; instead they must consult the original AD/S-PUMA/62 to confirm what was required and when. This anomaly may complicate compliance proofs and risk assessments.

4. Functional test definitions fixed by reference

• The AD corrects the definition of functional tests and requires adherence to paragraph 2.B and paragraph 2.B.3 of ASB 32.00.18. The AD therefore depends on the exact wording of those ASB subparagraphs; if the ASB text is ambiguous or later revised, an operator must ensure the ASB revision used was EASA-approved, because the AD allows only "later revision approved by the EASA." The AD text states: "Modify the helicopter wiring and installed 33G landing gear control units, PN 332A67-1623-0610, in accordance with paragraph 2.B of AS 332 ASB 32.00.18 ... and then check these modifications by carrying out functional tests, in compliance with the instructions specified in paragraph 2.B."

5. Spares must be modified prior to installation

• Requirement 4 requires modification of spare 33G landing gear control units in accordance with paragraph 2.B.5 of ASB 32.00.18 "before installation on a helicopter." This places a compliance obligation on spare parts management and procurement. Holding a spare unmodified in inventory is permitted, but that unit cannot be installed without the ASB-specified modification. The AD text: "Modify the 33G landing gear control units, held as spares, in accordance with paragraph 2.B.5. ASB 32.00.18 or later revision approved by the EASA."

6. EASA approvals gate acceptable revisions

• The AD allows later ASB revisions only if EASA has approved them. Operators must therefore ensure that any ASB revision relied upon carries the relevant EASA approval. The AD repeats the approval condition for each invocation of the ASB: "or later revision approved by the EASA."

7. Coordination with EASA AD

• The AD includes the short note "EASA AD 2006-0152 refers." That suggests a coordinated regulatory approach; operators operating internationally or under multiple jurisdictions should check EASA AD 2006-0152 to ensure full alignment. The AD itself does not reproduce that EASA AD.

8. No explicit enforcement or penalty clauses in the AD text

• As noted in the Penalties and enforcement section, the AD does not itself set out penalties or the enforcement process. Parties should therefore not rely on the AD for a description of enforcement steps; they need to consult CASA’s broader enforcement framework to understand the regulatory consequences of non-compliance.

9. Repetition of prior testing may be required

• Requirement 3 mandates repeat functional tests for helicopters already modified in compliance with the original AD and ASB Revision 0. Operators who previously performed modifications under AD/S-PUMA/62 and ASB 32.00.18 Rev 0 should ensure they have performed the repeat tests specified in paragraph 2.B.3 of the ASB by the deadline "Prior to 23 February 2007." The AD states: "Repeat the functional tests to check the modifications, in compliance with the instructions specified in paragraph 2.B.3. of AS 332 ASB 32.00.18 or later revision approved by the EASA for helicopters that have already been modified in compliance with AD/S-PUMA/62 and AS 332 ASB 32.00.18 Revision 0."

10. Documentation burden for proof of compliance

• Because the technical steps are delegated to the ASB, the primary proof of compliance will be maintenance records showing that the specific ASB paragraph was followed and that the ASB revision used had EASA approval if it was a later revision. The AD’s reliance on external documents increases the need for precise documentation.

These items are directly traceable to the AD text. Operationally, the combination of part-number specificity, cross-references to MODs and SBs, the EASA approval gating, spares modification timing, and the preserved earlier compliance date together create precise but potentially procedurally intricate compliance obligations.

The AD prescribes specific technical and timing steps. The following checklist sets out a practical compliance plan, strictly based on the AD text and its referenced paragraphs, to be followed by operators, maintainers and spare-holders.

1. Determine applicability for each helicopter

• Confirm the helicopter model: AS 332 C, C1, L or L1.
• Confirm MOD status: check if the helicopter is pre MOD 0723817, as the Applicability states applicability for "AS 332 C, C1, L and L1 helicopters, pre MOD 0723817."
• Confirm wiring MOD status: verify whether the helicopter wiring has already been modified in accordance with MOD 0725670 or Eurocopter AS 332 SB 32.00.12 dated 28 April 1999 or a later revision approved by the EASA. The AD’s Applicability includes only helicopters "Without the helicopter wiring modified in accordance with either MOD 0725670 or Eurocopter AS 332 Service Bulletin (SB) 32.00.12 ... and/or" certain control-unit conditions. If the wiring was modified per those instruments, the AD does not apply to that aircraft per the text.
• Confirm landing-gear control unit part number: inspect installed 33G landing gear control units to determine if they are PN 332A67-1623-00, 332A67-1623-06, 332A67-1623-0610, or 332A67-1623-0651. The AD specifically targets these PNs when not modified per referenced MODs or SBs.

2. If the helicopter is within applicability, obtain the correct Eurocopter ASB

• Obtain Eurocopter AS 332 Alert Service Bulletin ASB 32.00.18 paragraph 2.B (and the subparagraphs 2.B.3 and 2.B.5 where relevant).
• If relying on any later revision of ASB 32.00.18, ensure that the later revision has been approved by the EASA (the AD allows only "later revision approved by the EASA").

3. Perform the modifications and tests required by the AD, following the ASB

• Requirement 1 (if captured by the AD): Modify the helicopter wiring and installed 33G landing gear control units in accordance with paragraph 2.B of ASB 32.00.18 or a later EASA-approved revision. The AD lists Requirement 1 compliance as "Prior to 31 December 2005" and preserves that deadline from the original AD; consult original AD/S-PUMA/62 for any additional context.
• Requirement 2 (for PN 332A67-1623-0610): Modify the wiring and installed PN 332A67-1623-0610 in accordance with paragraph 2.B of ASB 32.00.18 (or later EASA-approved revision) and then carry out functional tests to check these modifications "in compliance with the instructions specified in paragraph 2.B of the referenced ASB." Compliance time: "Prior to 23 February 2007."
• Requirement 3 (for helicopters previously modified under the original AD and ASB Revision 0): Repeat the functional tests specified in paragraph 2.B.3 of ASB 32.00.18, for helicopters already modified in compliance with AD/S-PUMA/62 and AS 332 ASB 32.00.18 Revision 0. Compliance time: "Prior to 23 February 2007."
• Requirement 4 (spares): Modify 33G landing gear control units held as spares per paragraph 2.B.5 of ASB 32.00.18 (or later EASA-approved revision) before they are installed on a helicopter. This is explicitly prospective: "Requirement 4: Before installation on a helicopter."

4. Ensure correct documentation and traceability

• Record the ASB revision used and confirm its EASA approval status where a later revision is invoked. The AD repeatedly conditions compliance on "or later revision approved by the EASA."
• For each modified airframe, record the PN and serial numbers of the replaced or modified control units, the MOD verification steps, the details of the wiring changes performed, the identity of the maintenance organisation or certifying engineer, and the dates on which the work and the functional tests were completed.
• Retain the functional test results where tests are required by the ASB paragraph 2.B or paragraph 2.B.3. The AD requires testing "in compliance with the instructions specified in paragraph 2.B" and "in compliance with the instructions specified in paragraph 2.B.3" respectively.

5. Coordinate spares and procurement processes

• Update spare-parts procurement and installation procedures to require that any 33G landing gear control unit PN subject to the AD be modified per paragraph 2.B.5 of ASB 32.00.18 before installation. The AD requires: "Modify the 33G landing gear control units, held as spares, in accordance with paragraph 2.B.5. ASB 32.00.18 ... Before installation on a helicopter."
• Where spares are being sourced from external vendors, confirm whether they are supplied already modified per the ASB paragraph and, if not, ensure a plan to have the spares modified before installation.

6. Verify deadlines and older compliance

• For Requirement 1, note the AD’s statement that the compliance time "remains unchanged from the original issue of this AD" and that the stated compliance time in the amendment is "Prior to 31 December 2005." Because that date precedes the amendment’s effective date, operators should locate and review the original AD/S-PUMA/62 to confirm what was required and whether the aircraft was already in compliance as of that original date. The AD does not itself reset Requirement 1’s deadline.

7. Liaise with regulator and OEM where uncertainty exists

• If ambiguity remains about whether a helicopter is within the Applicability criteria or about which ASB revision is acceptable, consult CASA and Eurocopter technical representatives, and ensure an EASA approval record is available for any ASB revision relied upon. The AD expressly invokes EASA approval as the standard for later ASB revisions.

8. Consider operational scheduling and risk mitigation

• Plan maintenance windows and aircraft scheduling to allow for the wiring and control-unit modifications and for required functional tests. The AD does not specify duration but does require the modifications and testing by the specified dates.
• If an aircraft is to be operated across jurisdictions, check EASA AD 2006-0152 (the AD notes "EASA AD 2006-0152 refers") to ensure any cross-jurisdictional requirements are aligned.

9. Maintain audit-ready records

• Retain copies of ASB 32.00.18 paragraph 2.B (and any EASA-approved later revision used), maintenance release documents showing that the specified work was completed in accordance with those paragraphs, functional test records, and parts-modification evidence for spares. The AD’s technical specificity makes such documentation the key evidence of compliance.

This compliance plan follows the AD’s text and the ASB paragraphs it references. Because the AD tightly couples compliance to an EASA-approved ASB revision, operators must ensure they use the correct ASB document and that the EASA approval status of any revision used is documented.