aerospace- harmonising military airworthiness - feb 2015

7/24/2019 Aerospace- Harmonising Military Airworthiness - Feb 2015

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DEFENCEHarmonising airworthiness

In his September 2014AEROSPACEarticle,Howard Wheeldon described how the MilitaryAviation Authority (MAA) had grown anddeveloped since its creation in April 2010. Aspart of its drive to re-establish the importance of

managing military airworthiness effectively, the UKMAA has continued to support, and often lead, theextension of this work into Europe and beyond toimprove understanding and consistency in approachfor this critical area among our international allies.Other benefits are anticipated through creatingthe opportunity to share work done by the militaryairworthiness community to help reduce the costof procurement and support activity for both theparticipating nations and national industries.

This work has its origins in the early 2000s,when it became clear that international militaryaircraft projects were being managed in a variety ofdifferent ways. Each nation had developed its ownsovereign regulations or laws governing militaryaviation, often informed by lessons learned fromthe national perspective, and there seemed littleappetite to change. However, as defence spendingreduced, the cost of these international programmescame increasingly under the spotlight. It was in

this context that the UK championed a proposal

to harmonise military airworthiness arrangementsacross Europe. This gathered broad support andwork was initiated formally by the 26 participatingmember states (pMS) of the European DefenceAgency (EDA) who, on 10 November 2008, agreedto the formation of the Military AirworthinessAuthorities (MAWA) Forum. In addition to thepMS, observers from the AeroSpace and DefenceIndustries Association of Europe (ASD), theEuropean Aviation Safety Agency (EASA) and otherinterested organisations were invited to participatein the MAWA Forum.

The Forum was tasked to harmonise militaryairworthiness requirements across Europe. Toachieve this goal, the pMS set down a Ministerially-approved roadmap of objectives in a BasicFramework Document (BFD). The objectives wereto achieve:

Common regulatory frameworkCommon certification processesCommon approach to organisational approvalsCommon certification/design codesCommon approach to preservation of

airworthiness

Arrangements for mutual recognition

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In a time of extreme pressure on defence budgets,

harmonising military airworthiness among allies can bring

big benefits. Air Vice-Marshal MARTIN CLARK FRAeS,

Director (Technical), Military Aviation Authority, reviews

recent progress.

Harmonisingairworthiness


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Formation of a European Military JointAirworthiness Authorities Organisation (EMJAAO)

The concept of the EMJAAO was that the pMSwould come together as a club of like-mindednations, comparable to the original Joint AviationAuthoritiess approach within civil aviation. Therewas no intention to create a central or over-archingregulator. Indeed, from a sovereignty perspectivethis would have been wholly inappropriate. Hencethe EMJAAO would fulfill a co-ordinating functionunder the auspices of the EDA, a role nowbetter articulated by the new description of theproposed organisation as the Permanent MilitaryAirworthiness Co-ordination Cell.

Military airworthiness framework

To achieve the BFD objectives, the MAWA Forumelected to draw heavily upon the civil regulatory

framework created by EASA. This provided themodel on which the harmonised European MilitaryAirworthiness Requirements (EMARs) would bebased. In this way EMARs would be as militaryas necessary but as civil as practicable. Thenomenclature for the EASA airworthiness modelhas been retained, hence the EMAR frameworkcomprises:

EMAR 21 Certification of Military Aircraft andRelated Products, Parts and Appliances, andDesign and Production Organisations

EMAR M Requirements for ContinuingAirworthiness Organisations

EMAR 145 Requirements for MaintenanceOrganisations

EMAR 66 Military Aircraft MaintenanceLicensing

EMAR 147 Aircraft Maintenance TrainingOrganisations

The drafting of EMARs has been undertaken byfour Task Forces (primarily made up of SubjectMatter Experts from the pMS), two of which havebeen chaired by the UK.

In addition a handbook was constructed, initiallybased on the US MIL-HDBK-516 Airworthiness

Certification Criteria, to address the objectiveof common certification and design codes. Thenew European Military Aircraft CertificationCriteria (EMACC) handbook contains harmonisedcertification criteria developed to address Europeanrequirements. Against each of these harmonisedcriteria, the relevant US and European airworthinessrequirements from the military and civil domainshave been identified, covering manned andunmanned, fixed and rotary wing aircraft. Theintention is that the EMACC handbook will be usedto build a tailored set of certification criteria for theprocurement, or major change, of a specific aircrafttype, for example, a manned large aircraft, that willthen allow detailed airworthiness requirements to bedetermined.

Within the UK, military airworthinessrequirements will continue to be drawn fromDef Stan 00-970 Design and AirworthinessRequirements for Service Aircraft, which has evolvedfrom its first formal appearance in February 1918 asthe Handbook of Aircraft Strength Calculations. TheMAA is now re-writing and re-structuring the DefStan to separate out those requirements that aremilitary specific and those that are the same as civilstandards; where appropriate, the civil standardswill simply be sign-posted, not duplicated. The first

element of the Def Stan to be re-written in this

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Airbus Defence and Space A400MAtlas. The UK, France and Spain arealready taking steps to harmoniseA400M continuing airworthiness

assurance.

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(EDA)


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way (Part 5 Large Fixed Wing Aircraft) has beenpublished. The remainder of this task is a significantbody of work that is likely to take up to four years tocomplete.

EMAR implementation

Once approved by the MAWA Forum, the intentis for National Military Airworthiness Authorities(NMAAs) of the pMS to implement the EMARs(in part or in full) into national regulations, therebymaintaining sovereignty but driving towards the goalof a harmonised approach to airworthiness. With acommon regulatory baseline, the pMS will be ableto co-operate more easily and fully with each otherin both Type (or Initial/Continued) and ContinuingAirworthiness for collaborative projects, such asAirbus A400M, or where one pMS is buying aproduct from another.

Since the BFD roadmap was issued in 2009much progress has been made by the pMS todevelop the EMARs. As the work of the TaskForces has come to fruition, the pMS have beenconsulted on the content of the draft EMARs.These have then been approved by the MAWAForum for implementation. To date, the EMACChandbook and EMARs 21, 145, 66 and 147 haveall been approved1, along with accompanyingAcceptable Means of Compliance and GuidanceMaterial. EMAR M remains under developmentand is likely to be approved by the MAWA Forum

in late 2015. With approval of the EMARs, workhas been undertaken by the pMS to considerimplementation into national regulation, either byadopting the requirement directly or by claimingcompliance based on the national approach thathas been taken. To support this work, several pMS,typically those with more mature NMAAs, haveformed the EMAR Implementation Group to bothshare experiences of integrating the EMARs intotheir national regulations and to provide a forum forencouraging, guiding and sustaining the momentumfor the implementation of EMARs.

Within the UK, EMAR 145 is alreadyencompassed in the Continuing AirworthinessEngineering series of the MAA RegulatoryPublications (MRP), as MRP Part 145, andhas replaced the UKs previous approach toMaintenance Organisation Approvals that wasset down in Def Stan 05-130. Known as theMaintenance Approved Organisation Scheme,there are currently 34 Approved MaintenanceOrganisations across 64 sites in the DefenceAviation Environment (DAE).

Although EMAR M is not yet approved by theMAWA Forum, the UK has already published its ownapproach to the requirements likely to be containedin the draft being developed. These requirements

were implemented to allow the MAA to address

key recommendations from the Nimrod Reviewtoimprove Continuing Airworthiness Management ofindividual aircraft across the RN, Army and RAFfleets. The MRP Part M regulations were publishedin June 2012 and have led to the establishment ofsome 42 Continuing Airworthiness ManagementOrganisations, 17 of which have so far been

approved. The MAA is using the experience of thiswork to inform the development of EMAR M.

The next significant step for the UK will bethe integration of EMAR 21 into the MRP. Thedevelopment work is currently underway and willlead to formal consultation and engagement withMoD stakeholders and industry at the end of thefirst quarter of 2015. Among other importantchanges, a review of current regulation on MilitaryType Certification and the UKs Design ApprovedOrganisation Scheme (which has been in placesince 1928 and currently has 92 Design ApprovedOrganisations across the DAE) will be included inthis work.

Work is also underway, in conjunction withstakeholders, including industry partners, on theapproach to be taken to address the intent ofEMARs 66 and 147. Licensing of military andcivilian technicians undertaking military aircraftmaintenance, and approval of the associatedtechnician training organisations, represents anatural evolution of the MAAs regulatory work todate, and would further enhance the delivery ofContinuing Airworthiness. However, implementationof these requirements in the UK needs to beframed carefully to recognise existing militarytrade structures and current military technician

training policies, and to minimise any associated

Implementation ofEMAR 21 offersthe potentialto reduce timeand cost ofEurofighterTyphoonupgrades.


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@aerosociety Find us on LinkedIn Find us on Facebookk www.aerosociety.com 39FEBRUARY 2015

administrative activity. Implementation planningmust also take account of the way in whichEASA might adjust its training requirements fortechnicians undertaking civil aircraft maintenancein the future. The MAAs approach is likely to bedefined by mid-2015 and all stakeholders will beconsulted fully. In this training and licensing domain,

the early indications are that benefits are morelikely to be realised in collaborative projects wheresignificant leverage is available through poolingof spares, underpinned by nations confidencein the competence and training of each othersmaintenance technicians.

Towards recognition

Based on the foundation provided by harmonisingairworthiness requirements and driving towards acommon regulatory baseline across the EDA pMS,the MAWA Forum has developed an approach todetermining whether NMAAs in themselves workin an acceptable and recognisable manner. Thiswork, which can lead to pMS recognising formallythe acceptability of other NMAAs, has beenapproved and published as the European MilitaryAirworthiness Document Recognition (EMAD R).To help standardise the process, the documentcontains the Military Authorities RecognitionQuestionsets (MARQ) to assist NMAAs goingthrough Recognition to explain their regulatoryapproach. This is made up of four subsets ofquestions based on the ICAOs airworthiness safetygoals2.

The benefits that can accrue from recognition

revolve around the potential for one NMAA to use

artefacts (such as Organisational Approvals orMilitary Type Certificates) that have been grantedby another NMAA and, thereby, reduce or avoid theneed for duplicating the work. Not only does this

benefit the NMAA but also industry, in the sensethat only one Organisational Approval or MilitaryType Certificate may need to be held or developedfor a particular aircraft being operated by severalnations. Since EMAR 145 has been approved,the UK, France and Spain have implemented theEMAR into their national regulations and haveengaged in recognition activity in the scope ofContinuing Airworthiness assurance to support theA400M programme. This will lead in due courseto the NMAAs being able to adopt MaintenanceOrganisation Approvals granted by another nation,either in full or with limited further checking.

Although less advanced, the implementationof EMAR 21, coupled with recognition, offers thepotential to considerably reduce time and cost inthe certification of modifications on EurofighterTyphoon. Early work to address the use of DesignOrganisation Privileges is underway to allow, forexample, Eurofighter partner companies (onceapproved) to self-certify the design of minormodifications and repairs. The UK has already putregulations in place to facilitate this ahead of thefull UK implementation of the EMAR. Realisationof the full scope of the benefits from this workis dependent on recognition covering TypeAirworthiness assurance between the UK, Germany,

Italy and Spain being completed, as well as all thenations addressing EMAR implementation. Plansare being developed to achieve the recognitioncomponent of this challenge before the end of2015 but the individual national challenges ofimplementing EMAR 21 into regulation are likelyto be considerable due to the broad nature of thisparticular set of requirements.

Recognition further afield

The UK is in a unique position as it is the only nationto be a participating member of the EDA MAWAForum, the NATO Airworthiness Committee andthe Air and Space Interoperability Council (ASIC),the latter being a military community comprisingthe UK, US, Canada, Australia and New Zealand.Having led on the development of EMAD R withinEurope, the UK has been able to take the ideaof recognition to both ASIC and NATO, wherethe benefits of adopting such an approach havebeen acknowledged clearly. For the TechnicalAirworthiness Authorities (TAAs) of the US Army,Navy and Air Force, recognition helps them tocomply with US DoD policy that requires themto assure the airworthiness of foreign-owned orforeign-leased aircraft that their personnel fly in. For

the UK and other ASIC nations the benefit lies in

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potentially being able to use the military certificationand Type Airworthiness artefacts produced foraircraft that are being procured from the US.Although NATOs approach to implementing itsairworthiness policy is still evolving, it seems likelythat it will wish to be assured of the airworthiness ofaircraft being operated under its banner directly and,potentially, as part of a NATO operation; recognitionwill help build confidence in these areas. Unlikewith the EDA MAWA pMS, there is not a commonregulatory baseline developed from the EMARs

on which recognition within ASIC and NATO canbe founded, but nonetheless the use of the EMADR process provides sound evidence on which todetermine the acceptability of the respective NMAA.

Having embraced the European approach, theUS National Airworthiness Council (NAC)3hasnow developed its own detailed procedures basedon EMAD R and agreed that recognition of othernations will typically be carried out by a lead TAA.The UK MAA has recently been recognised by theUSAF TAA, taking the lead on behalf of the Armyand Navy. In parallel, the MAA has completed itsown recognition of the US Army, Navy and AirForce TAAs, with work carried out independentlydue to the different airworthiness regulations andprocesses that each uses. Through this recognitionwork, the UK MAA has been able to look in detailat how each of the US TAAs works, identifyingthe processes that they use for certification andmapping the outputs (the artefacts) to the UKmilitary certification process. This provides thepotential for the UK to obtain these artefacts anduse them as evidence of compliance for certificationof new aircraft or upgrades procured from the US,where the underlying airworthiness requirementsare acceptable to the UK and there is no significantdifference in the planned usage or operating

environment. While this will not remove the need to

address differences in UK configuration, inherentshortfalls in the US evidence or UK specific designsafety requirements, the opportunity providedthrough this work should deliver benefits in reduced

cost and time for the core certification activity.Future work on C-17, C-130J, Rivet Joint, LightningII, Chinook and Apache will allow this potential to betested.

Summary

Since the goal of harmonising airworthinessrequirements across Europe was set down in2008 much has been achieved, with all but one ofthe EMARs approved by the EDA MAWA Forum,and the last scheduled to be approved by theend of 2015. This wil l deliver a common baselinefor the EDA pMS to use in the developmentand modification of their national airworthinessregulations, and pave the way for recognition amongthe NMAAs to leverage the potential benefits thatthis harmonised approach offers. A recent EDApamphlet noted that cost savings in the order of10% for industry and government could be realisedby using harmonised certification procedures forthe development phase of multinational militaryaircraft projects, along with up to 50% reductionin programme duration. This is a prize that is worthstriving for.

Outside of Europe, the benefits of recognitionbetween NMAAs have been embraced by the

ASIC and NATO communities, although withoutthe advantage of a common regulatory baselineon which to build. From a national perspective,the recent recognition of the US Army, Navy andAir Force TAAs by the UK MAA paves the wayfor more efficient procurement of US-sourcedaircraft and major changes, for example, baselineor block upgrades. While this needs to be steppedthrough carefully to ensure we do not lose focuson the important aspects of UK airworthinessrequirements, there is clear potential to deliverbenefit through this route.

There is still much to do in the realm of militaryairworthiness, but the work that the UK MAAhas been involved in across Europe and beyondoffers the opportunity to deliver tangible benefitsand the promise of a much better understandingbetween nations of the importance of managingthe airworthiness of military aircraft and workingtogether to improve air safety.

REFERENCES

1. Full details can be found on the EDA website at http://www.

eda.europa.eu/certification/mawa-documents.

2. ICAO Document 9760 Airwor thiness Manual.

3. The NAC comprises the Technical Airworthiness Authorities of

the US Army, US Navy, USAF, US Coastguard, Department for

Homeland Security, NASA and FAA.

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Recognition ofUS TAAs pavesthe way formore efficientprocurementof US blockupgrades suchas the BoeingAH-64E ApacheGuardian.

Furtherinformation can

be found atwww.gov.uk/maa

aerospace- harmonising military airworthiness - feb 2015

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