Airworthiness Directives 2004 - Revocation and Remaking - Electrical Equipment

The instrument deploys a small number of interlocking administrative concepts drawn from the civil aviation regulatory framework as expressed in the body of the instrument itself.

• Delegation and source of authority: the instrument is exercised by “David Alan Villiers, delegate of the Civil Aviation Safety Authority”, explicitly invoking subregulation 39.001(1) of the Civil Aviation Safety Regulations 1998 (the instrument texts that authority). That identifies the legal actor who makes the administrative decision and the regulatory power under which it is taken.

• Revocation: the instrument expressly revokes the Airworthiness Directives listed in Schedule 1 (operative paragraph (a)). Revocation here is an administrative act that removes the prior instrument(s) listed from the instrument record that the delegate controlled.

• Remaking as separate instruments: the instrument does not merely revoke; it simultaneously provides for each AD mentioned in the Schedule to be “made, as separate instruments” (operative paragraph (b)). The practical consequence is to replace whatever prior instrument form existed with standalone AD instruments for each listed entry.

• Reproduction of text: the Note specifies that “Each attached Airworthiness Directive is being re‑made in exactly the same form as appears in the latest published edition of the Directive.” That is a statement about fidelity: the remade instruments are intended to reproduce the existing published texts without substantive change.

• Administrative indexing / metadata: Schedule 1 lists AD names and numbers and includes annotations (for example, “CANCELLED”, “Amdt 1”, “Amdt 3”, “Superseded”). Those annotations capture prior administrative history captured in the latest published edition and are carried forward by the Note’s promise of identical reproduction.

• Subject domain: the Schedule’s heading “Electrical Equipment” and the AD names themselves identify the technical domain of the instruments being re‑made , magnetos, circuit breakers, batteries, alternator fans, fluorescent lighting system components, and similar electrical components or systems relevant to aircraft airworthiness.

These concepts combine into a single administrative operation: an authorised delegate is exercising a regulatory power to revoke a grouped set of ADs and to re‑issue them, one by one, as separate instruments reproducing their latest published texts. The instrument does not itself amend substantive requirement language, create new technical mandates, or specify enforcement mechanisms within its text; rather, it manipulates the statutory instrument record and the form in which these ADs will be held as instruments.

The instrument’s practical effects fall on persons and entities that are subject to the content of the ADs listed in Schedule 1. The Schedule identifies ADs by name and number; those ADs (by their titles) concern inspections, modifications, replacements, retirement lives and related actions for aircraft electrical equipment. Examples from the Schedule include ADs referencing magnetos (BTH, Bendix, Slick), circuit breakers (Wood Electric Corp., Texas Instruments, Mechanical Products Inc.), batteries (Nickel Cadmium, SAFT, Sealed Lead Acid, Exide types), ignition switches, alternator bearings and fans, starter modifications, fluorescent lighting ballasts and cabin lighting components, and galley equipment.

Primary affected parties will include:

• Aircraft owners and operators who have aircraft equipped with the specific components named in the AD titles (for example aircraft containing Slick magnetos, Bendix magnetos, particular battery types, alternator types). Those owners/operators are the parties that must comply with mandatorily framed AD requirements when the AD text imposes inspections, modifications, retirements, or replacements.

• Maintenance organisations and individual maintenance personnel who carry out inspections, modifications, replacements and retirement actions described in the ADs. The AD titles show the typical kinds of technical work involved in compliance (inspection, modification, lubrication, replacement, retirement life), so maintenance providers will be the executors of those tasks.

• Manufacturers, component suppliers and parts providers that produce, service or supply the specific components: for example makers of magnetos, batteries, circuit breakers, or ballasts named in AD titles may be practically affected because AD compliance will drive demand for parts, replacement components, or approved repair/modification kits when the ADs require such measures.

• Regulatory administrators and record‑keepers at the Civil Aviation Safety Authority. The instrument changes the administrative form of the ADs (revocation and re‑making as separate instruments), so CASA’s instrument registers, document indexes and the way ADs are cited will change accordingly.

• Legal and compliance advisers who must interpret the operative status of ADs for their clients. The instrument’s administrative act and the Note about exact re‑making mean practitioners must check the attached instruments to determine how prior references to an AD should be updated to new instrument citations.

The instrument itself does not create new substantive obligations beyond what the attached ADs specify. Its direct operational effect is to alter the instrument form , revoking older grouped instrument(s) and replacing them with separately numbered and attached instruments reproducing the published AD texts. Therefore, the parties who already were potentially affected by the AD content remain the main audience: those required by the AD texts to perform inspections, modifications, replacements, retirements or similar maintenance actions. The instrument does not record any new relief, exemptions, timing alterations, or financial support; costs of compliance therefore remain as created by the substantive ADs as re‑made.

The instrument’s own operative text imposes no new technical duties nor confers new rights beyond the administrative acts of revocation and re‑making and the delegation of authority. The substantive duties and rights that will govern behaviour are those contained in the attached Airworthiness Directives, which the instrument states are re‑made “in exactly the same form as appears in the latest published edition of the Directive” (Note). The instrument therefore operates as a conduit: it transfers the legal force and citation form of existing AD texts into separate instruments.

From the Schedule’s titles, the typical duties that are likely to be present within each attached AD (and therefore carried forward by this instrument) include:

• Inspection obligations: many AD titles specify “Inspection” (for example “Ignition Switches - Briggs and Stratton - Inspection - CANCELLED AD/ELECT/2”, “Circuit Breakers - Inspection - CANCELLED AD/ELECT/3”, “Magneto Bendix Scintilla - Inspection AD/ELECT/14”). Where an attached AD prescribes an inspection, the owner/operator or maintenance organisation will have a duty to carry out that inspection within any timeframes and to any standards specified in the AD text.

• Modification and replacement duties: ADs referencing “Modification”, “Replacement”, or “Modification and Replacement” indicate duties to carry out hardware modifications or part replacements described in the AD (examples: “Relay - Leach - Modification - CANCELLED AD/ELECT/1”, “Engine Starter - Bendix - Modification AD/ELECT/15”, “Slick Magneto Hub - Impulse Coupling Replacement - CANCELLED AD/ELECT/25 Amdt 1”).

• Retirement life and removal: some ADs indicate retirement lives or removal requirements (example: “Slick 4000/4100 Series Sealed Non-Repairable Magnetos - Retirement Life AD/ELECT/18 Amdt 3”).

• Lubrication, inspection/maintenance regimes: titles such as “Magneto Bendix Scintilla - Lubrication - CANCELLED AD/ELECT/9” indicate obligations that may be maintenance tasks rather than structural modifications.

• Component‑specific actions: many ADs are component‑specific (magneto coils, distributor gear, capacitors, bearings, battery connectors, alternator fans) and will impose duties targeted at those parts.

Rights and administrative features in this instrument:

• Reproduction fidelity: the Note articulates a declarative right of the regulated community to expect that the re‑made ADs will contain the same textual content as the latest published edition. That reduces legal uncertainty about changes in substantive wording as a result of the re‑issuance; the instrument itself promises identical form.

• Instrument citation and separability: by remaking each AD as a separate instrument, the instrument creates a new legal citation framework. Practitioners gain the right to cite and rely on each AD as a discrete instrument (the instrument itself effects that separability), but the instrument does not specify the new instrument numbers or separate instrument identifiers beyond its attachment of the ADs.

What the instrument does not do, within its own text:

• It does not itself set compliance dates, enforcement regimes, or penalties; it does not alter substantive AD content; and it does not grant exemptions or create transitional relief. Those matters, if present, would need to be read in the attached re‑made AD texts.

In short, the instrument alters how the ADs are recorded and cited while preserving the substantive duties contained in each AD through identical textual reproduction, and it therefore implicitly preserves existing compliance duties as expressed in those ADs.

The instrument does not contain express penalties, enforcement provisions, or sanctioning criteria. Its operative words are confined to revocation of listed ADs and the re‑making of those ADs as separate instruments, accompanied by a Note stating that the attached ADs are re‑made in exactly the same form as the latest published edition. There is no section, clause or annotation within the instrument text that prescribes fines, criminal liability, administrative penalties, or the mechanisms by which non‑compliance with any re‑made AD would be prosecuted or administratively enforced.

Because the instrument is executed under the authority of subregulation 39.001(1) of the Civil Aviation Safety Regulations 1998, enforcement and penalties relevant to non‑compliance with an Airworthiness Directive would, in practice, depend on the statutory and regulatory framework that governs ADs more generally. This instrument itself does not set out that framework, nor does it modify or annotate the enforcement mechanisms. Consequently, this instrument must be read as an administrative re‑issuance mechanism that leaves enforcement questions to the broader regulatory scheme under which the ADs operate. For any enforcement or penalty consequences arising from failure to comply with the substantive requirements of an attached AD, a reader of this instrument would need to consult the AD text itself and the Civil Aviation Safety Regulations 1998 and related enforcement provisions,that material is not included in, nor modified by, the text of this instrument.

Practically, the absence of penalties or enforcement language in this instrument means two things, within the instrument’s own terms: (1) there is no change recorded here to sanctioning or penalty processes by virtue of the revocation/remaking act; and (2) to determine enforcement consequences arising from the ADs, users must consult the re‑made AD instruments attached and the wider legislative/regulatory enforcement framework outside this instrument. The Schedule’s annotations (CANCELLED, Amdt numbers, Superseded) do not themselves indicate enforcement treatment in this instrument; they carry forward administrative history, and enforcement status must be checked against the attached individual AD instruments and the underlying civil aviation regulations.

The instrument explicitly identifies its statutory chain of command by stating that the delegate acts under subregulation 39.001(1) of the Civil Aviation Safety Regulations 1998 (operative text). That indicates the instrument is an exercise of a power provided by the Civil Aviation Safety Regulations 1998. The instrument itself does not quote or reproduce subregulation 39.001(1) or other provisions of the CASR, nor does it specify any amendments to the CASR. Its interaction with other laws, therefore, is primarily administrative: it implements the delegate’s power under the CASR to manage Airworthiness Directives by revocation and re‑issuance.

The instrument also affects the corpus of subordinate instruments that constitute Airworthiness Directives. By revoking the ADs listed in Schedule 1 and re‑making them as separate instruments, it alters the form, citation and possibly the instrument identifier that legal practitioners, operators and maintainers will use when referring to those ADs in compliance, record keeping, contractual clauses, and regulatory filings. For example, references in maintenance manuals, compliance records or contracts that pointed to an AD as previously published may need to be updated to the separate instrument citation once the attachments are issued.

Additionally, the Schedule demonstrates administrative interdependence with prior amendment history: multiple entries are annotated “Amdt [number]”, “CANCELLED” or “Superseded”. Those annotations manifest the ADs’ prior interactions with amendment and cancellation processes. The Note’s assurance that each attached AD is reproduced “in exactly the same form as appears in the latest published edition” indicates that the remade instrument will carry the ADs’ current legal state , including past amendments, cancellations or superseddings , into the new separate instruments.

The instrument does not expressly address interactions with other safety instruments, international agreements, aircraft registers, certification rules, air operator’s obligations, or third‑party contract rights. Any such intersections will be governed by the AD content and the wider statutory/regulatory landscape, which are not altered substantively by this revocation/remaking instrument. Thus the immediate legal interaction is: (1) with the CASR as the authority that empowers the delegate; and (2) with the body of AD instruments that constitute the applicable airworthiness requirements for the components named in the Schedule, now restated as separate instruments.

The instrument itself is an administrative step in the lifecycle of a collection of Airworthiness Directives and includes internal signposting to prior amendments and cancellations using the annotations included in Schedule 1. The Schedule contains numerous entries showing the AD number, a title, and one of the following annotations where applicable: “CANCELLED”, “Amdt [number]”, or “Superseded”. Examples include “Slick 4000/4100 Series Sealed Non-Repairable Magnetos - Retirement Life AD/ELECT/18 Amdt 3” (showing at least three prior amendments to that AD in its history), “Slick Magnetos - 447 and 600 Series - CANCELLED AD/ELECT/21 Amdt 6” (showing cancellation after a series of amendments), and entries labelled “Superseded AD/ELECT/29” or “Superseded AD/ELECT/32 Amdt 1”.

The presence of “Amdt” annotations indicates that many ADs have a documented amendment history prior to this revocation/remaking action. The instrument’s Note asserts that the attached re‑made ADs are stuck to the latest published edition’s form. That implies that the current instrument reflects the most recent amendment status for each AD as recorded in the published AD record. The instrument therefore functions as an administrative consolidation that captures the ADs’ cumulative amendment/cancellation history and migrates it into separately issued instruments that replicate their latest published texts.

The Schedule’s multiple “CANCELLED” annotations show that some ADs have previously been cancelled. Including cancelled ADs in the Schedule for revocation and re‑making suggests the delegate intends the separate instruments to reproduce the latest published state, including cancellations. The lack of additional commentary in the instrument about transitional or retrospective effects means that any historical amendment or cancellation consequences follow the textual content now being replicated.

This instrument does not itself provide an amendment log for the specific changes that led to each Amdt number; rather it operates at a meta level by reproducing the current text as published. To trace the full amendment genealogy of any particular listed AD (for example to see what Amdt 3 changed relative to the original AD), one would need to consult the earlier published editions and amendment records, which are not reproduced within this instrument. The instrument’s role is to freeze and replicate the current published state into discrete instrument form rather than to narrate the amendment process that produced the current state.

The instrument contains no mention of litigation, court decisions, administrative appeals, or contested proceedings related to the revocation and re‑making of the Airworthiness Directives listed in Schedule 1. The text of the instrument is limited to the administrative act of revocation and re‑making and a Note concerning textual fidelity; it does not record, recount, or reference any judicial or tribunal decisions, nor does it summarise disputes or appeals.

Given that absence, the instrument itself does not provide a litigation history. Practitioners seeking whether any of the ADs listed have been subject to legal challenge, appeal, or judicial review will not find that information in this instrument. Any litigation record would need to be sought in court records, tribunal records or in the administrative record maintained by the Civil Aviation Safety Authority; such records are not included in the instrument text provided here.

The Schedule’s annotations (CANCELLED, Superseded, Amdt numbers) reflect administrative action but do not reveal whether those actions prompted or were the subject of litigation. The instrument’s silence on litigation means that, within the instrument’s own terms, no litigation effects are being recognised, reported or altered. For legal practitioners, that absence is itself a datum: this instrument should not be relied upon as a source for litigation history; separate searches of judicial and administrative decision repositories will be necessary to establish whether any of the ADs have been litigated or otherwise judicially considered.

This instrument is short on substantive technical detail and long on administrative consequence. The following practical risks and traps for readers are identified directly from the instrument’s terms and from the Schedule’s annotations.

• Administrative citation change: the instrument revokes and re‑makes ADs “as separate instruments”. That will change how ADs are cited and referenced in manuals, maintenance records, engineering orders, certificates of release to service, and legal documents. If a compliance record or contract cites an old AD instrument number or the previous grouped instrument, that citation may be stale once the re‑made AD is issued. The instrument does not supply the new separate instrument citations in its body; users must obtain the attached instruments to discover the precise new citations.

• Identical text promise does not mean unchanged legal effect across contexts: the Note promises exact reproduction of the latest published edition. That eliminates textual change risk in principle, but does not negate practical differences arising from changing an AD from part of a grouped instrument to a separate instrument (for example, different publishing metadata, different instrument numbers, or differences in how a court or regulator might reference the AD). The instrument does not address those metadata or administrative consequences.

• CANCELLED entries are included: Schedule 1 includes ADs annotated “CANCELLED”. Including cancelled ADs among items to be revoked and re‑made could cause confusion. Practitioners must not assume that an entry labelled CANCELLED in the Schedule requires no action without checking the attached instrument, because the instrument promises to reproduce the latest published edition, which may itself indicate cancellation or reinstatement. The instrument gives no standalone statement about the operative force of entries labelled CANCELLED beyond replication.

• Amendment annotations without detail: many entries show amendment numbers (Amdt 1, Amdt 3, Amdt 6). The instrument does not list what those amendments changed. If a reader must know the substance of an amendment (for scheduling work or assessing liability), they must consult either the attached re‑made AD or the amendment records; the instrument does not provide a change log.

• No enforcement or transitional language: the instrument does not provide transitional rules, nor does it state effective dates for the re‑made ADs other than the instrument’s signature date (20 December 2004). Practitioners should not assume that the re‑making changes compliance timelines or enforcement treatment. To determine the operative compliance timing and enforcement posture, one must read the attached AD instruments themselves.

• Dependence on attachments: the instrument’s substantive work is done by the attached instruments. If a practitioner reads only this instrument without retrieving and reviewing the attached ADs, they will lack the operative technical requirements. The Note’s promise of identical reproduction reduces risk of substantive surprise, but operational compliance requires the actual attached text.

• Potential record‑keeping mismatch: organisations that maintain internal registers of ADs will need to update those registers to reflect the separate instrument format. Failure to synchronise internal records with the new instrument citations could create avoidable compliance reporting errors.

• Ambiguity over “make, as separate instruments”: the instrument does not specify whether the separate instruments are to be treated as newly commencing instruments for purposes of instrument numbering, gazettal, or publication date; practitioners should verify how the separate AD instruments are published and what their effective dates and references will be.

In short, the instrument is an administrative housekeeping measure that can create practical uncertainty if the regulated parties assume that nothing about citation, publication, or procedural handling will change. The cure is to obtain and review the attached re‑made AD instruments and to update internal registers and compliance procedures to match the newly issued separate instruments.

Follow these concrete steps, each grounded in the instrument’s text and the Schedule contents, to manage compliance risk arising from the revocation and re‑making of ADs.

1. Obtain the attached AD instruments: the instrument states each Airworthiness Directive mentioned in Schedule 1 is attached and re‑made in exactly the same form as appears in the latest published edition (Note). The attachments contain the operative technical requirements. Do not rely on this revocation/remaking instrument alone.

2. Confirm effective dates and citations: this instrument is signed on 20 December 2004, but it does not specify effective dates for the separate instruments it creates. When you obtain the attached ADs, check their individual effective dates, instrument numbers and publication data. Update your maintenance manuals, compliance registers, and contract references to the new citations if they differ from previous references.

3. Map AD obligations to fleets and components: review the titles in Schedule 1 to identify which ADs may apply to your aircraft or components. For example, ADs referencing “Slick 4000/4100 Series Sealed Non-Repairable Magnetos”, “SAFT 40AH Type 40976 Batteries”, “Wood Electric Corp. Circuit Breakers”, or “Cabin Fluorescent Lighting System Components” identify components to screen against the equipment lists on each affected aircraft. Compile a list of aircraft and serial numbers potentially impacted by each attached AD.

4. Read each attached AD for the precise duty: although Schedule 1 indicates whether an AD is about inspection, modification, replacement, lubrication or retirement life, the precise scope, required intervals, instructions, and compliance timeframes will be in the attached AD text. Execute the technical steps only after confirming the exact instructions in the attached instrument.

5. Check cancellation/ amendment status as reproduced: entries in Schedule 1 marked “CANCELLED”, “Superseded” or annotated with “Amdt” are being re‑made in their latest published form, as the Note states. That means the attached AD will replicate any cancellation or amendment state. If an entry is marked “CANCELLED” in the attachment, determine whether that means no current action is necessary, and retain documentation proving that review.

6. Schedule and document compliance tasks: for ADs requiring inspection, modification, replacement, retirement or lubrication, schedule the work in accordance with the attached AD’s timeframes. Ensure work is carried out by personnel and organisations who are authorised to perform the required maintenance tasks under the relevant regulatory framework (the instrument does not specify those authorisations; verify with applicable maintenance standards and regulatory requirements).

7. Retain evidence and update logs: maintain records that demonstrate timely compliance with the re‑made ADs. Record the date, personnel, parts used, serial numbers, and release documentation. Because the instrument changes AD citation form, retain cross‑references showing which old AD reference corresponds to the new separate instrument citation for audit trails.

8. Update supplier and parts ordering: if ADs require modifications or replacements, confirm parts compatibility and lead times. Where the AD identifies specific part numbers or modification kits (common in component ADs), ensure you source the authorised parts and keep purchase and installation invoices as part of the compliance record.

9. Reconcile manuals, procedures and contracts: update maintenance manuals, airworthiness logs, continuing airworthiness management arrangements, and any contractual clauses that reference AD instrument numbers or publication forms. Confirm with insurers or lessors whether the new instrument format requires any notice or documentation update.

10. Seek clarification where the attachment is ambiguous: if the attached AD replicates a cancelled or superseded state and that state is not clear in practical effect, seek written clarification from CASA or the delegate’s office. This instrument does not supply explanatory transition provisions; therefore, obtaining official confirmation will reduce regulatory risk.

In all these steps, the governing principle is that this instrument preserves the substantive AD texts by administrative replication (Note), but it changes their instrument form. Compliance therefore depends on acting according to the attached instrument texts, confirming their effective dates and citations, and updating administrative and operational records accordingly.