Airworthiness Directives 2004 - Revocation and Remaking - Piper PA-32 (Cherokee Six) Series Aeroplanes

The instrument rests on three tightly confined legal concepts, each present in the text.

1. Delegated power to make and revoke ADs. The instrument is made by a delegate of the Civil Aviation Safety Authority under subregulation 39.001(1) of the Civil Aviation Safety Regulations 1998 (instrument, first paragraph). That single citation is the only statutory source cited in the text provided; the instrument therefore exercises a regulation-granted administrative power to manage airworthiness directives.

2. Revocation. Paragraph (a) of the operative part states the delegate “revoke[s] the Airworthiness Directives mentioned in Schedule 1.” That is an explicit, instrument-level revocation of those listed ADs as they previously existed. The effect of revocation is to cancel the prior instrument form under which the ADs were recorded; the legal consequences of revocation for compliance history, record-keeping and any continuing obligations depend on the text of the replaced ADs and on the enabling regulation (the instrument itself does not restate those consequences).

3. Re-making as separate instruments. Paragraph (b) states the delegate “make[s], as separate instruments, each Airworthiness Directive mentioned in Schedule 1 and attached.” The instrument therefore performs an administrative conversion: it removes the listed ADs from whatever prior collective instrument they were in and issues them individually as separate instruments. The Note clarifies that the re-made ADs are identical to the latest published edition of each Directive: “in exactly the same form as appears in the latest published edition of the Directive.”

Schedule 1 operationalises those concepts by enumerating each AD to be revoked and re-made. The Schedule lists many ADs by title and AD number, and records amendment statuses (for example “Amdt 1”, “Amdt 2”, etc.), cancellations and a supersession reference (“Superseded by AD/GENERAL/45 - CANCELLED AD/PA-32/14”). The AD titles in the Schedule show the technical scope of the instruments concerned: examples include structural items (outer wing spar, wing rear spar attach bolts, wing rear spar inspection), systems (fuel system, fuel selector valve, engine air inlet duct, air conditioning), flight controls (stabilator, aileron, rudder), landing gear (main and nose landing gear inspections and modifications), and cabin/crew safety items (seat frame modification, seat belt attachment, front seat restraint installations).

Two additional practical concepts follow from the instrument as written. First, the instrument functions as a housekeeping device that clarifies the instrument identity and standalone status of a set of ADs. Second, where the Schedule records “CANCELLED” or “Superseded”, the instrument records those administrative outcomes in the list to ensure the revocation/remaking covers the full set of historical instrument variants relevant to the PA-32 series in the regulator’s published record.

The text does not include the operative text of the separate ADs, does not itself specify compliance actions or effective dates for the re-made instruments, and does not specify enforcement or sanction mechanisms in this instrument. Those matters will be governed by the separate AD instruments and by the enabling regulations cited.

The text does not attach express definitions of ‘who’ within this instrument, but the Schedule and the nature of airworthiness directives make the affected parties identifiable from the content provided.

• Owners and registered operators of Piper PA-32 (Cherokee Six) series aeroplanes: The Schedule specifically targets ADs titled and numbered for the PA-32 series. Any person who owns or operates an aircraft of that series will be affected to the extent the separate ADs prescribe inspections, modifications, replacements or other mandatory actions. The instrument’s revocation and re-making act changes the administrative identity of the AD instruments that define those mandatory actions, rather than altering the substantive content of the AD requirements (Note).

• Maintenance organisations and certificated maintenance personnel: The AD titles in the Schedule are heavily maintenance- and inspection-focused (for example, “Fuel Tanks - Inspection AD/PA-32/4 Amdt 1”; “Wing Rear Spar Attach Bolts - Inspection AD/PA-32/11”; “Main Landing Gear Torque Links - Inspection AD/PA-32/24 Amdt 1”). Those entries indicate the tasks required by the ADs are typically performed by maintenance organisations or licensed maintenance personnel. Those entities will need to locate the re-made separate AD instruments to know the exact procedural requirements.

• Aircraft engineers, technical records keepers and continuing airworthiness managers: Re-making ADs as separate instruments changes how ADs will be cited and located in the legislative and regulatory record. That affects technical records, logbook entries, and continuing airworthiness documentation, which must reference the correct instrument identifiers.

• Registrars, auditors and compliance officers: Where ADs are re-issued as separate instruments, compliance auditing, safety assurance and regulatory oversight functions will need to track the re-issued instrument identifiers. The Schedule includes entries already marked “CANCELLED” or “Superseded”, which may require auditors to reconcile historical compliance actions against the correct authoritative instrument text.

• Potentially affected service suppliers: Items in the Schedule requiring modification (for example “Fuel System Improvements - Modification AD/PA-32/10”; “Air Conditioning System - Modification AD/PA-32/33”) create demand for parts and technical services. Suppliers of parts and modification kits will be affected insofar as operators comply with the re-made AD instruments.

Who does not appear affected by the instrument, from the text: the instrument contains no new obligations for persons not connected to the PA-32 ADs listed, and it does not purport to change policy across other aircraft types. It also does not itself create novel offences or penalties; those are governed by the enabling regulation cited (subregulation 39.001(1)) and by the separate AD instruments, which are attached but not reproduced in the text supplied.

The instrument’s administrative action will therefore be directly relevant to PA-32 owners/operators and indirectly relevant to maintenance providers, parts suppliers and compliance personnel. The instrument’s Note instructs that the attached separate ADs are identical to the latest published editions, which focuses affected parties on locating those latest published AD editions to determine exact obligations and compliance timelines.

The instrument itself is narrow in form: it revokes and re-makes instruments listed in Schedule 1. It does not, on its face, restate the operative duties (inspect, modify, replace, etc.) that apply to aircraft; those duties will remain contained in the separate Airworthiness Directives that are attached and re-made in this instrument.

Duties, as can be inferred from the Schedule titles and the Note:

• Locate and apply the re-made ADs. The Note specifies that each attached AD is being re-made in exactly the same form as the latest published edition of the Directive. Therefore the proximate duty for affected parties is to obtain the attached re-made AD instruments (or the latest published editions) and comply with the substantive requirements contained there.

• Perform mandatory inspections, replacements or modifications specified in the ADs. The Schedule titles indicate the types of mandatory actions that appear in the ADs themselves: inspections (for example AD/PA-32/4 “Fuel Tanks - Inspection”; AD/PA-32/11 “Wing Rear Spar Attach Bolts - Inspection”), replacements (for example AD/PA-32/12 “Brake Disc - Replacement”), modifications (for example AD/PA-32/10 “Fuel System Improvements - Modification”), and combinations of inspection and modification (for example AD/PA-32/29 “Rudder Bar Assembly - Inspection and Modification”).

• Maintain regulatory records referencing the correct instrument. Because the ADs are being re-issued as separate instruments, those responsible for continuing airworthiness will need to ensure that compliance entries, logbooks and maintenance records cite the correct re-made AD instrument identifiers from Schedule 1.

Rights and procedural signals visible in the instrument:

• Administrator’s authority and limitation. The instrument records the delegate’s exercise of power under subregulation 39.001(1). That identifies the statutory channel through which the ADs are administered.

• No new substantive content. The Note’s statement that the re-made ADs are identical to the latest published editions signals that the instrument does not alter the substantive duties embedded in the ADs; it merely re-issues them as separate instruments. Affected parties therefore retain the same substantive rights and obligations as those set out in the latest published editions of the directives.

• Record of cancellation and supersession. The Schedule records where AD numbers have been cancelled or superseded (for example AD/PA-32/14 superseded by AD/GENERAL/45 and cancelled). That function informs affected parties of the current administrative status of particular ADs, which affects whether any duty arises from them.

What the instrument does not do, per its text:

• It does not create new rights of appeal, dispute resolution provisions, or new relief mechanisms within its own text. Any rights to challenge, appeal or seek relief in relation to ADs would need to be pursued under the Civil Aviation Safety Regulations or other applicable statutory or administrative review processes (not reproduced in this text).

• It does not specify compliance deadlines, methods, or acceptable means of compliance; those specifics reside in the attached AD texts stated to be identical to the latest published editions.

For practitioners: the operative duty placed on affected entities is to consult the attached re-made ADs and the latest published editions and to ensure compliance records correctly cite the standalone AD instrument numbers in Schedule 1. The instrument, by re-making ADs as separate instruments, changes the administrative citation and documentary context in which those duties are discharged.

This instrument does not include an enforcement or penalties section in the text provided. The instrument’s sole cited statutory authority is subregulation 39.001(1) of the Civil Aviation Safety Regulations 1998, which is the enabling norm relied on by the delegate to revoke and re-issue the ADs (instrument, first paragraph). The text does not itself restate, modify or prescribe penalty provisions or enforcement procedures.

The implication, drawn from the instrument’s form, is administrative: the re-made ADs are standalone instruments that will carry whatever compliance obligations and enforcement consequences their substantive texts provide. Those enforcement mechanisms,civil sanctions, administrative directions, suspension of certificates, criminal penalties or infringement provisions, if any,would be specified elsewhere, either in the separate AD instruments (which are attached but not reproduced here) or in the empowering Civil Aviation Safety Regulations and other applicable law. The instrument itself neither adds to nor diminishes the visible enforcement regime in express terms.

Two points for readers and compliance officers to note from the text:

• The instrument makes a record of revocation and re-making. Where enforcement actions, audits or prosecutions rely on precise citation of the applicable AD instrument, the change in instrument form may be material to procedural compliance and to any enforcement action that references the instrument identifier. Practitioners should ensure enforcement actions cite the correct version of the AD as it exists following this revocation/remaking exercise.

• Cancellations and supersessions are recorded in Schedule 1. The Schedule shows some ADs are already marked “CANCELLED” or “Superseded by AD/GENERAL/45 - CANCELLED AD/PA-32/14”. That administrative information can affect whether any enforcement or compliance obligation remains in place for particular AD numbers. Enforcement in respect of cancelled ADs depends on the content and effective dates in the attached instruments and the broader regulatory scheme.

Because the instrument provides no express penalty provisions, practitioners must look to the Civil Aviation Safety Regulations 1998 and the re-made AD texts themselves to identify sanctioning powers, timelines for compliance, and the consequences of non-compliance. The instrument’s role is to reorganise instrument identity and publication form; it does not itself introduce new enforcement mechanics.

The instrument explicitly situates its legal authority in another statutory instrument: it is made by a delegate of the Civil Aviation Safety Authority under subregulation 39.001(1) of the Civil Aviation Safety Regulations 1998 (instrument, first paragraph). That citation establishes a direct link between this instrument and the Civil Aviation Safety Regulations 1998 as the empowering framework. The instrument does not reproduce or summarise the content of subregulation 39.001(1) itself, and therefore does not recast or reinterpret the enabling regulation within its own text.

The Schedule contains an explicit cross-reference to another airworthiness directive: “Superseded by AD/GENERAL/45 - CANCELLED AD/PA-32/14.” That entry records an interaction between the PA-32-specific AD number and a general AD (AD/GENERAL/45), indicating that the regulatory record recognises supersession relations among ADs. This instrument, by revoking and re-making the ADs, continues that administrative record of how ADs interrelate.

What the instrument does not do, per its text:

• It does not purport to modify or displace other legislation beyond its exercise of power under subregulation 39.001(1). Any effect on other laws (for example, obligations under the Civil Aviation Regulations, safety management system requirements, or state aviation legislation) must be understood through the enabling regulatory framework and through the text of the re-made ADs themselves.

• It does not create cross-jurisdictional rules. The instrument is an administrative act of the Civil Aviation Safety Authority’s delegate and therefore operates within the regulatory architecture of civil aviation in the Commonwealth framework. There is no express interaction with state or territory laws recorded in the text provided.

Administrative and documentary interactions practitioners should note:

• Citation and record-keeping. By converting ADs into separate instruments, the instrument influences how those ADs will be cited in internal compliance documents, audit reports and in any legal proceedings. Any interactions with other laws that require reference to ADs (for example, insurance policy conditions, maintenance contracts, airworthiness certificate conditions) will need to cite the correct re-made AD instrument.

• Supersession and cancellation. The Schedule’s recording of cancelled or superseded ADs is an interaction point: when an AD has been superseded by a more general directive, as recorded for AD/PA-32/14, the legal obligations may have shifted to a different instrument. Practitioners must reconcile historical compliance with the current legal instrument relied upon by the regulator.

• Missing substantive enforcement text. Because the instrument does not recite enforcement or penalties, interactions with enforcement law, administrative law remedies, and procedural rights under the Civil Aviation Safety Regulations remain governed by those other instruments. Practitioners will need to consult the enabling regulations and the re-made AD texts to assess interactions with administrative law remedies, judicial review or appeal routes.

In short, this instrument is a procedural administrative link in the broader legal architecture of aviation safety. Its principal interaction is with the Civil Aviation Safety Regulations 1998 (via the cited subregulation) and with other ADs that supersede or cancel PA-32 ADs (as recorded in Schedule 1). For further legal effects beyond re-issuing instruments, the re-made ADs and the enabling regulations must be consulted.

The instrument itself is dated and signed on 20 December 2004 by the delegate of the Civil Aviation Safety Authority (instrument signature block). Within the Schedule 1 list, many AD entries include amendment markers, cancellation notes and a supersession entry, which together form the amendment history record that this instrument seeks to consolidate administratively.

Key points from the Schedule that represent amendment history elements:

• Explicit amendment notations: Several ADs in the Schedule are listed with “Amdt” numbers indicating prior amendments to those directives. Examples are: “Fuel Tanks - Inspection AD/PA-32/4 Amdt 1”; “Aileron and Stabilator Balance Weight Assembly and Rudder Horn Assembly - AD/PA-32/5 Amdt 3”; “Control Wheel - Inspection AD/PA-32/17 Amdt 4”; “Stabilator Balance Weight Tube Assembly AD/PA-32/19 Amdt 3”; “Wing Rear Spar Inspection AD/PA-32/27 Amdt 2”; “Main Landing Gear Torque Links - Inspection AD/PA-32/24 Amdt 1”; “Oil Coolers - Inspection and Replacement AD/PA-32/54 Amdt 2”; and numerous others. These amendment markers are an integral part of the record of changes to the substantive ADs over time.

• Cancellation markers: The Schedule contains items explicitly labelled “CANCELLED” (for example the entries at the top and others such as “CANCELLED AD/PA-32/6 Amdt 3”; “CANCELLED AD/PA-32/7”; “Ammeter Installation Modification - CANCELLED AD/PA-32/70 Amdt 1”; “Crossover Exhaust Assembly - CANCELLED AD/PA-32/76”). The presence of these entries reflects that the Schedule incorporates historical cancellations.

• Supersession notation: The Schedule records at least one supersession example: “Superseded by AD/GENERAL/45 - CANCELLED AD/PA-32/14.” That records a prior legal step where a PA-32-specific AD was superseded by a general AD, and then cancelled.

• Range and vintage of ADs: The Schedule shows a broad sweep of AD topics (fuel systems, structural parts, landing gear components, control surfaces, seating, etc.). The presence of high amendment counts for some ADs (up to Amdt 4 in one example) indicates iterative changes to certain directives over time. This instrument consolidates that amendment history by revoking and re-issuing the ADs as separate instruments in their latest published forms, per the Note.

What the instrument itself does not do in amendment-history terms:

• The instrument does not itself record earlier dates, versions or textual changes beyond the shorthand amendment markers in the Schedule. It does not provide a change log or redline showing what changed between amendment versions. It states only that each attached AD is being re-made in exactly the same form as the latest published edition.

• The instrument does not purport to be an amendment to any AD; rather it revokes prior instrument forms and re-makes each AD as a separate instrument identical to the latest published edition. That means this instruments functions as an administrative consolidation event rather than as a substantive amendment.

For record-keeping and legal tracing, practitioners should treat this instrument as a node in the chain of custody of the AD instruments: it formalises that, as at 20 December 2004, the listed ADs are revoked in their previous formatting and are re-issued as standalone instruments identical to the then-latest published editions. To reconstruct the full amendment history of any particular AD, one must consult the earlier AD versions and the amendment markers recorded in the Schedule together with the separate attached AD texts and any previous instruments in the public record.

The text supplied contains no information about litigation. There are no references to court decisions, tribunal determinations, judicial review proceedings, or administrative appeals in the instrument itself. The instrument is an administrative act of revocation and remaking; the provided material contains only the delegation, the operative revocation/remaking paragraphs, the Note about identical re-issue, and Schedule 1 listing the ADs.

Consequently, the instrument’s text does not record:

• Any past litigation challenging the ADs listed in Schedule 1, their content, their amending instruments, or the process by which they were issued.

• Any ongoing litigation or court orders affecting the legal status of the ADs, nor any settlements or consent orders.

• Any practitioner-level guidance arising from case law interpreting the legal effect of revoking and re-making ADs.

For users who require a litigation record or precedential guidance about how courts have treated similar revocations/remakings or the content of ADs, the instrument provides no material. Any search for litigation outcomes, judicial interpretations of the enabling regulation (subregulation 39.001(1)), or disputes concerning the substantive AD requirements must therefore be conducted outside this instrument by consulting court records and other legal databases; that material is not reproduced or summarised here.

The absence of litigation references in the instrument should not be taken as an indication that litigation is impossible or irrelevant; it only records that this instrument does not itself note any litigation history. Practitioners who need to advise on legal risk in respect of compliance or enforcement should therefore look to the Civil Aviation Safety Regulations, the full texts of the separate attached ADs, and external legal sources for any judicial commentary or precedent.

The instrument is concise, but its brevity creates a set of practical pitfalls and possible points of confusion that practitioners should note, grounded in the instrument’s text.

1. Administrative re-issue, not substantive change. The instrument revokes the ADs listed in Schedule 1 and re-makes them “as separate instruments” identical to the latest published editions (Note). A potential gotcha is mistaking this administrative act for a substantive amendment. The re-making is expressly identical in form to the latest published editions; therefore, any change in obligations will not generally arise from this instrument itself but from the content of the separate ADs and their effective dates.

2. Presence of CANCELLED items in the Schedule. Several Schedule entries are marked “CANCELLED” or “Superseded” (for example “CANCELLED AD/PA-32/6 Amdt 3”, “CANCELLED AD/PA-32/7”, and “Superseded by AD/GENERAL/45 - CANCELLED AD/PA-32/14”). This raises two practical traps: first, a reader might assume that because an item is listed it remains operative; second, a reader might assume that everything listed has a current attached text. The instrument revokes the ADs mentioned in the Schedule and re-makes “each Airworthiness Directive mentioned in Schedule 1 and attached.” If an entry is labelled CANCELLED, the intended attached instrument relevant to that entry may be that cancellation record rather than an operative AD requiring action. Practitioners must not assume uniform operative effect across all listed entries; they must check the attached AD texts and the published record.

3. Lack of effective date language. The instrument is dated 20 December 2004, but it does not state explicit effective dates for the re-made ADs within the text provided. Practitioners should not assume that compliance deadlines or effective dates are uniformly the instrument date; those operative timings will be in the separate attached AD texts or in the latest published editions referenced in the Note.

4. Citation and record-keeping discontinuity. By making each AD a separate instrument, previous collective citations or references may no longer be straightforward. Maintenance records, logbook entries, continuing airworthiness documentation and audit trails must reference the correct re-made AD identifiers. Failure to adjust citations may create evidentiary difficulties in audits or enforcement actions.

5. No penalties or enforcement restated. The instrument does not describe enforcement mechanisms or penalties. Parties looking for sanction details must consult the enabling regulation (subregulation 39.001(1) and related Civil Aviation Safety Regulations) and the separate AD texts. Assuming that the revocation/remaking affects enforcement thresholds or penalties is unsupported by the instrument.

6. Attached ADs not reproduced here. The instrument states that the ADs are attached and re-made in identical form, but the provided text does not include those attachments. Practitioners must obtain the attached ADs or the latest published editions to determine the operative technical requirements, including the methods of compliance, specified parts, and any allowable modifications or alternative means of compliance.

7. Supersession by a general AD. The Schedule records at least one supersession by a general AD (AD/GENERAL/45). Where a specific PA-32 AD has been superseded by a general AD, compliance obligations may now be found in that general AD, not the PA-32-specific AD number. This can create confusion if systems, parts or maintenance contracts refer to the old PA-32 AD number.

8. Amendment numbering differences. The Schedule records amendment numbers for many ADs (e.g., “Amdt 3”, “Amdt 4”). Practitioners must ensure that the edition they use corresponds to the latest published amendment referenced by the Note. Misreading an amendment number or using an earlier amendment edition can result in non-compliance.

In short, the administrative act performed by this instrument creates several documentary and procedural tasks for affected parties, and omitting any of those checks can create operational or compliance risk. The correct operational step is to obtain the attached ADs or the latest published editions and confirm the effective dates, compliance actions and whether any item is in fact cancelled or superseded.

Because this instrument itself is administrative and does not restate substantive AD requirements, compliance in practice requires the following steps, which are grounded in the instrument’s terms and the Schedule content.

1. Identify whether you operate, own, maintain or supply parts for a Piper PA-32 (Cherokee Six) series aeroplane. The Schedule’s title and each AD title identify the PA-32 series as the scope. If your aircraft or operation includes PA-32 types, proceed to step 2.

2. Obtain the attached re-made Airworthiness Directives or the latest published editions. The instrument states each attached AD is being re-made “in exactly the same form as appears in the latest published edition of the Directive” (Note). The text provided here does not include the attachments; compliance depends on consulting those attached AD instruments or the published repository where the latest editions were published.

3. Match AD numbers and amendment markers. The Schedule lists AD titles with AD numbers and amendment designators (for example “AD/PA-32/4 Amdt 1”, “AD/PA-32/17 Amdt 4”, “AD/PA-32/19 Amdt 3”). Ensure you consult the AD instrument that corresponds precisely to the AD number and amendment label that applies to your aircraft and to the compliance history you maintain.

4. Confirm operative dates and compliance windows in the separate AD text. The re-made ADs will contain the deadlines, required workscope, acceptable means of compliance and any serial-number applicability. The instrument here does not provide those specifics; they are in the attached ADs. Do not assume the instrument date (20 December 2004) as the compliance deadline without checking the AD text.

5. Determine who must perform the work and who bears the cost. The substance of the ADs will indicate whether work must be performed by licensed maintenance organisations or whether owner-operators may perform certain tasks, and will typically determine parts and labour responsibilities. The Schedule titles (inspections, modifications, replacements) indicate the kinds of work likely required; the separate ADs will specify technical qualifications and methods of compliance.

6. Record compliance accurately, citing the re-made instrument identifier. Because the ADs have been re-made as separate instruments, maintenance records, logbooks and continuing airworthiness documentation should reference the correct AD number from Schedule 1 to show that the obligation has been discharged under the correct instrument.

7. Reconcile cancelled and superseded entries. The Schedule contains entries labelled “CANCELLED” and at least one entry noting supersession by AD/GENERAL/45. Where an AD is listed as cancelled or superseded, cross-check the attached AD text and the public AD repository to determine whether the cancellation removes any duty or whether the duty has moved to another AD (for example a general AD). Ensure historical compliance is reconciled against the currently operative AD.

8. Evaluate parts and modification availability. Many ADs in the Schedule relate to structural components, fuel systems and landing gear. Compliance may require obtaining parts, kits or specialised labour. Early procurement planning reduces aircraft downtime and cost uncertainty.

9. Maintain a compliance audit trail. Because the instrument changes the administrative identity of the ADs, maintain copies of the re-made ADs, proof of compliance work (work orders, invoices, sign-offs), and updated logbook entries that specifically reference the re-made AD instrument identifiers.

10. Consult the enabling regulations for enforcement consequences. The instrument cites subregulation 39.001(1) as authority. If there is any doubt as to enforcement obligations, sanctions or record-keeping requirements, consult the Civil Aviation Safety Regulations 1998 and any associated guidance materials or notices issued by the Civil Aviation Safety Authority.

In short, compliance with the effects of this instrument is procedural: obtain and follow the separate AD instruments that have been re-made. The substantive work and technical compliance obligations are contained in those AD instruments, which this instrument confirms are identical to the latest published editions. Failure to source and implement the instructions in those separate ADs will be the primary route to non-compliance, not the administrative act of revocation and re-issue itself.