airworthiness in the military aviation in the eu. « the emars · 2017. 12. 23. · based on civil...
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Airworthiness in the military aviation in the EU.
« The EMARs »
66th EAMTC, Lulea, 13th & 14th March 2017 Colonel Stéphane Copéret.
Chairman Continuing Airworthiness Advisory Group MAWA Forum
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www.eda.europa.eu 2
Topics / Briefing plan • Background & General context:
- Early impulses.
- Political decision: EU military airworthiness Policy.
- The MAWA Forum approach.
• The EMARs.
- Common principles.
- Focus on Training : EMAR 147 & 66.
• Current situation, challenges & progress achieved.
- Implementation current status.
- Comparison: Civil Military.
- Recognition.
• Way forward & future EDA activities.
- EMAR update.
- SMS implementation.
- Specific rules for RPAS
• General review
- Learning's & obstacles
- Results, achievements & benefits
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Airworthiness in the military aviation, why? Background & General context:
Early impulses:
• A fundamental consideration.
- Civil agencies cannot regulate military aviation.
- Military aviation does not have to comply with civil regulation.
• Several dramatic accidents.
- MIRAGE F1
- CAP 232
- NIMROD
- US C130
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Background & General context:
Early impulses:
A political will : following the civil trend.
Creation of the EASA
Single European Sky
Civil aviation recognized the need for harmonization much earlier than the
military (sovereignty, competition, defense issues etc)
However, military in Europe recognized that there were drawbacks to the
existing fragmented approach to airworthiness management
First steps were made when nations started common multinational
programmes ( Typhoon, NH90, A400M….) and also with the increased
integration of aerospace industry in military aircraft ‘total-support’ contracts.
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Background & General context:
Political Decisions : EU military airworthiness Policy.
• Nov 2008 – EDA’s Steering Board (in Defence Ministers’ formation)
decided to establish the Military Airworthiness
• Authorities (MAWA) Forum with a view to developing an EU-wide military
airworthiness regulatory framework
• Nov 2009 - Defence Ministers’ Political Declaration for the ‘timely
development and early implementation’ of the harmonised European
Military Airworthiness Requirements (EMARs) into national regulations
• Defence Minister’s Political Declaration on Certification and
Airworthiness of 19 Nov 2013.
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Background & General context:
MAWA Forum approach & the EMARs strategy :
MAWA Forum is made up of representatives from European National Military
Airworthiness Authorities (or equivalent)
MAWA Forum has the mandate, responsibility and authority to develop the
harmonised EMARs
Important Note:
Implementation of the EMARs into national regulations remains a sovereign national
decision, noting the political declarations made in Nov 2009 and 2013.
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MAWA
Forum
ARAG
Airworthiness Regulation Advisory Group
Policy:
BFD
EMAD 1
EMAD R
DPAG
Design & Production Advisory Group
Initial Airworthiness:
EMAR 21 update
EMAD MFTP
CAWAG
Continuing Airworthiness Advisory Group
Continuing Airworthiness
EMAR 145 update
EMAR M update
EMAR 147 update
EMAR 66 update
RPAS
Remotely Piloted Aircraft System Advisory Group
RPAS airworthiness policy
EMAR “RPAS”
Background & General context:
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09/03/2016 DSAÉ
FI
IS
GE
AM
AZ
EE
UA
MD
TR
CY
FR
LV
LT
BE
NL
DE
UK
IE BY
RO
AL
BG
GR
CH
IT
AT HU
ES PT
DK
NO SE
PL
CZ
MT
BA
MA
DZ
TN
SY IQ
IR
KZ
RU
LU SK
SI HR
RU
27 EDA pMS
(participating Member States)
= 27 EU States – DK
ME KO
RS
FYROM
pMS having approved the BFD
pMS having not approved the BFD
8
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Background & General context:
MAWA Forum
none MAWA members
EMAR implemented or process in work
EMAR envisaged (to be confirmed)
EMAR compliant
observers
participating Member States
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The EMARs
Common principles. Based on Civil rules. PART (currently amendment M7 2012)
Follow civil changes & stay as close as possible to the civil.
Same philosophy.
Exactly same structure: 21, 145, 147, 66, M
AMC & GM…
Section A & Section B…
Same type of Forms….
EMARs = standards ≠ PART = law
Few differences: mainly wording militarisation Use of military terminology where appropriate.
Civil approvals or certification recognized the military recognise what is done and certified in
the civil.
All military aircraft considered as complex motor powered (Group 1).
Summer 2017 EMAR framework completed
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The EMARs
MILITARY AIRWORTHINESS
AUTHORITIES FORUM
EMAR 145
MILITARY AIRWORTHINESS
AUTHORITIES FORUM
EMAR M
MILITARY AIRWORTHINESS
AUTHORITIES FORUM
EMAR 147
MILITARY AIRWORTHINESS
AUTHORITIES FORUM
EMAR 66
MILITARY AIRWORTHINESS
AUTHORITIES FORUM
EMAR 145
AMC + GM
MILITARY AIRWORTHINESS
AUTHORITIES FORUM
EMAR M
AMC + GM
MILITARY AIRWORTHINESS
AUTHORITIES FORUM
EMAR 147
AMC + GM
MILITARY AIRWORTHINESS
AUTHORITIES FORUM
EMAR 66
AMC + GM
MILITARY AIRWORTHINESS
AUTHORITIES FORUM
EMAR 21
MILITARY AIRWORTHINESS
AUTHORITIES FORUM
EMAR 21
AMC + GM MILITARY AIRWORTHINESS AUTHORITIES FORUM
EMAD 1
MILITARY AIRWORTHINESS
AUTHORITIES FORUM
EMAD R
MILITARY AIRWORTHINESS
AUTHORITIES FORUM
EMAD
MFTP
MILITARY AIRWORTHINESS
AUTHORITIES FORUM
EMACC
MILITARY AIRWORTHINESS
AUTHORITIES FORUM
EMAR
FORM
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PART
Civil aircraft Military aircraft Military aircraft
EU Regulation law pMS Regulations law EU Requirements standard
Main differences and main similarities The EMARs
EASA & CAAs
EMAR
EDA & MAWA FORUM
EMAR FR
DSAE / DGA
PERAM
DGAM
DEMAR
LUFABW
MRP
MAA UK
PMAR
AAN
BMAR
MAA BE
DAAA
MAA NLD ……
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EU Rulemaking Structure for civil aviation : “the PART System”
Council Regulation (EC) 216/2008
“Basic Regulation”
Annex I – Essential Requirements
Annex II – Excluded Aircraft
Annex III – Pilot Licensing
Annex IV – Air Operations
Annex V – Qualified Entities
Annex VI – Correlation Table
Commission Regulation (EU) 748/2012
“Initial & continued Airworthiness”
Annex I – Part 21
AMC & GM
Approved Means of Compliants & Guidance Material
“Certification”
AMC & GM
Approved Means of Compliants & Guidance Material
“Continuing Airworthiness”
Commission Regulation (EU) 1321/2014
“Continuing Airworthiness”
Annex I – Part M
Annex II – Part 145
Annex III – Part 66
Annex IV – Part 147
Annex V – Part T
RE
GU
LA
TIO
NS
AGENCY MEASURES
Military aviation regulation
As a mirror to
Civil regulation
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French Rulemaking Structure for State’s aviation : “the EMAR FR System”
Decree 2013 367
Order – “Duties”
Order – “Conditions”
Order – “Registration”
Order – “Continuing Airworthiness”
Order – “Remotely Piloted Aircraft System”
Instruction
“Initial Airworthiness”
FRA 21
AMC & GM
Approved Means of Compliants & Guidance Material
“Certification”
AMC & GM
Approved Means of Compliants & Guidance Material
“Continuing Airworthiness”
Instruction
“Continuing Airworthiness”
EMAR FR M
EMAR FR 145
EMAR FR 66
EMAR FR 147
RE
GU
LA
TIO
NS
In
terd
epart
menta
l level
Authorities Level
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DESIGN ORGANISATION PRODUCTION
ORGANISATION
TRAINING
TECHNICIAN
AIRCRAFT
A/W MANAGEMENT ORGANISATION
TYPE CERTIFICATE
MAINTENANCE ORGANISATION
OPERATOR AERONAUTICAL COMPANY
General overview of airworthiness organization in Europe.
TRAINING ORGANISATION
AIRWORTHINESS FRAMEWORK
INITIAL AIRWORTHINESS
CONTINUED AIRWORTHINESS
CONTINUING AIRWORTHINESS
AERONAUTICAL ACTIVITY
OPERATIONS
AV
IAT
ION
AU
TH
OR
ITY
APPROVAL / OVERSIGHT
APPROVAL / OVERSIGHT
CERTIFICATION / REVIEW
OVERSIGHT / AIRWORTHINESS DIRECTIVES
CERTIFICATION
LICENSING
« DO » « PO »
« MTO »
« MO » « CAMO »
CAA’s
The EMARs
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DESIGN ORGANISATION PRODUCTION
ORGANISATION
TRAINING
TECHNICIAN
AIRCRAFT
A/W MANAGEMENT ORGANISATION
TYPE CERTIFICATE
MAINTENANCE ORGANISATION
OPERATOR COMPANY
AIR FORCE
AV
IAT
ION
AU
TH
OR
ITY
General overview of airworthiness organization in Europe in the civil.
TRAINING ORGANISATION
AIRWORTHINESS FRAMEWORK
INITIAL AIRWORTHINESS
CONTINUING AIRWORTHINESS
AERONAUTICAL ACTIVITY
OPERATIONS
PART 21 J PART 21 G
PART 145 PART 147 PART 66
PART M
CAA’s
The EMARs
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DESIGN ORGANISATION PRODUCTION
ORGANISATION
TRAINING
TECHNICIAN
AIRCRAFT
A/W MANAGEMENT ORGANISATION
TYPE CERTIFICATE
MAINTENANCE ORGANISATION
OPERATOR
AIR
FORCES
AV
IAT
ION
AU
TH
OR
ITY
General overview of airworthiness organization in Europe in the military in France.
TRAINING ORGANISATION
AIRWORTHINESS FRAMEWORK
INITIAL AIRWORTHINESS
CONTINUING AIRWORTHINESS
AERONAUTICAL ACTIVITY
OPERATIONS
FRA 21 J FRA 21 G
EMAR FR 145
EMAR FR
147 EMAR FR
66
EMAR FR M
The EMARs
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The EMARs
EMAR 147 (Aircraft Maintenance Training Organisations) Ed 1.0 approved by MAWA Forum on 14th June 2012, Ed 1.1, together with its associated AMC & GM, was approved by the MAWA Forum
on 23rd September 2014.
EMAR 147 / PART 147 Key differences :
A number of “small” differences exist between EMAR 147 and EASA
Part 147 to better suit the military environment:
• Use of military terminology where appropriate.
• Parts of an organisation's EASA exposition that are equally
applicable to satisfy EMAR requirements will generally be accepted
as equivalent in respect of the EMAR MTO exposition.
• Appendix III contains examples of certificates – MTO’s may use
their own certificates provided that all the information is included
• Appendix I has been rewritten:
• No basic course durations (theory or practical) are detailed
(although an NMAA may decide to do this at a national level if
required). gives more flexibility to NMAAs.
• minimum practical training hours required for an individual to be
able to claim reductions in the experience requirements as
detailed in EMAR 66.A.30(a)1(iii) and EMAR 66.A.30(a)2(iii) are
given.
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EMAR 66 (Certifying Staff): Ed 1.0 together with its associated AMC & GM, was approved by the MAWA Forum on 23rd September 2014
A number of differences exist between EMAR 66 and EASA Part 66 to better suit the military environment:
• Use of military terminology where appropriate
• Military Aircraft Maintenance Licence (MAML) is non-expiring
• MAML introduces ‘extensions’.
• All military aircraft considered ‘complex motor-powered’ (~Group 1)
• Type Ratings will be determined nationally by each NMAA
• Module 10 (Aviation Legislation) re-written for military environment
• All course durations have been removed (Basic and Type)
• 6 x Military specific modules introduced:
• 50 Essential Principles of Armament
• 51 Weapon Stores System
• 52 Operational Attack Systems
• 53 Surveillance and Electronic Warfare
• 54 Crew Safety
• 55 Military Communications and Navigation Systems
The EMARs
Especially true for
combat aircraft…
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The EMARs
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For B1/B2, additional paragraphs have been added to
enable reductions in the practical maintenance experience
required to allow for the practical training received during a
basic training course that does not provide the minimum
practical training hours:
“…..practical maintenance experience can be reduced by
the duration of the practical training given during the basic
training course with a maximum reduction of 1 year. (Note:
as a reference 20 hours of practical training will be
considered as being equivalent to a duration of 1 week.”
The EMARs
New paragraph 66.A.30(a)5(ii) added:
To reduce time of practical experience
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1350 Aircraft of 70 different types (including RPAS): 1200 in the military and 150 in other services or
administrations. 50 engine & 20 propeller Types.
420 Organizations:
60 « CAMO ». Continuing Airworthiness Management Organizations.
100 « ATO ». Aircraft Training Organizations.
260 « MO ». Maintenance Organizations.
Technician Licenses
10000 to manage
Continuing Airworthiness in the Military in France : Current Situation
Current situation: challenges & progress achieved.
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EMAR FR 145, 66, 147, M
COMPLETE FRAMEWORK PUBLICATION
2000 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018
AIRWORTHINESS REGULATION
DECREE & ORDERS PUBLICATION
FRENCH STATE AVIATION SAFETY AUTHORITY
CREATION
21 J : TYPE CERTIFICATION TCs
M : AIRCRAFT AIRWORTHINESS CERTIFICATION CoAs
M : CAMOs ORGANISATION APPROVAL
147 : MTOs TRAINING ORGANISATION APPROVAL
145: MOs MAINTENANCE ORGANISATION APPROVAL
21G: Pos PRODUCTION ORGANISATION APPROVAL
PREPARATORY PHASE IMPLEMENTATION & RISE PHASE CRUISING SPEED PHASE
66 : LICENCE DELIVERY
FRA 145, 66, 147, M
RULES PUBLICATION EMAR FR 145 PIBLICATION
RPAS ORDER PUBLICATION
An ambitious
implementation schedule
First focuse on A/C & AW management
FRA 21
RULES
PUBLICATION
100%
100%
36%
93%
60%
The strategic approach
100%
Current situation: challenges & progress achieved.
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CIVIL
MILITARY
Rules : PART Standards : EMAR
CAA FR
CAA SP
CAA PT CAA IT
CAA GE
CAA UK
CAA PL
CAA GE
CAA CY
CAA ML
CAA BE
CAA NL
CAA IR
CAA SW
CAA FI
EASA
CAA MA
CAA RO
CAA HU CAA AU
CAA CZ
CAA SLO
CAA LA
CAA ES
CAA
MAA SP
MAA PT
MAA FR
MAA UK
MAA IT
MAA GE
MAA NL
MAA BE
Current situation: challenges & progress achieved.
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DSAÉ & DGA
“EMAR FR”
MAA UK
“MRP”
LufABw
“DEMAR”
DGAM
“PERAM”
BMAA
“BMAR”
DAAA
“AER.P”
AAN
“PMAR”
NDMA
“EMAR”
RSAF AELD
“AFLO”
DASA
“DASR”
USAF &
NAVY
& ARMY
MAA NLD
“MAR”
MAA TR
“TMAR”
MAA ML
EASA
“PART”
21J
21G
145
147
21J
21G
145
147
21J
21G
145
147
145
145
145
145
21J
om
Potential mutual
interests with FR
A400M
REAPER
C130J
A400M
TIGER
NH90
C130J
A400M
TIGER
MRTT
REAPER
A400M
NH90
MRTT
A400M
NH90
REAPER
C130J
C130 NH90
MRTT
MRTT
TIGER
NH90
MRTT
C130J
C135
REAPER
MRTT A400M A400M A400M
Recognized Process to launch To be studied
MRTT
A400M
C130J
NH90
TIGER
REAPER
Cooperation Pooling & sharing
Spare parts
Common maintenance
Mutual support / operations
Mutual training
Costs benefits
……
The recognition process: interests & potential benefits. Current situation:Recognition
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MRTT User’s & Airworthiness issues.
manufacturer AUSTRALIA EAU SAUDI
ARABIA
UK FRANCE SINGAPORE SOUTH
KOREA
MMF GERMANY CANADA
A/C A330
MRTT
A330
MRTT
A330
MRTT
A330
MRTT
FSTA
A330
MRTT
A330
MRTT
A330
MRTT
A330
MRTT
A310
MRTT
A310
MRTT
Number
Regulation
EMAR ? ? PART EMAR ? EMAR EMAR ?
Recognition
Current situation: Recognition The MRTT case
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Recognition Activities:
Mutual recognition between FR & UK (in March 2013, FR & UK became first EDA
nations to recognise each others’ activities, in the field of continuing
airworthiness primarily focused on the A400M In-Service Support)
Both FR & UK have recognised ES activities in support of A400M In-Service
Support.
FR recognised DE activities of A400M maintenance and training.
Mutual recognition between UK/DE/IT/ES on design and production on Typhoon.
DE recognised ES on design and production for A400M
Soon global recognition on continuing airworthiness between FR/DE/UK/ES/IT….
Soon NATO recognition process will be launched.
Current situation: Recognition
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Way forward & future EDA activities.
EU global policy : EUGS.
Strengthen the ties between EDA/EASA & EDA/NATO
Support & train pMS
Support implementation process of pMS
Support recognition.
EMAR update : DPAG, CAWAG & RPAS Wg core activity.
SMS study & implementation.
Militarization of some AMC 20.
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Learning's & obstacles :
A long , hard & ambitious process…. That needs to be accompanied.
Meanings & goals of airworthiness have to be trained both on base and directional levels
A deep cultural & organizational change…. Especially for the CAMO’s activities.
The need for a change management strategy.
Difficulties to cope with: legacy A/C.
Efficiency of quality systems …… a new challenge.
General review.
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Results, achievements & benefits of Harmonised Military
• More control, oversight & global rigor.
• A unique regulation adapted to the Military specificities and close to the Civil.
• Safety within Civil & Military aviation is paramount
• ‘Key Enabler’ for ‘Pooling & Sharing’ activities
• Enhanced Military-Military & Civil-Military cooperation Synergy improvement between Civil
& Military.
• Facilitates a common approach to maintenance and repair / Better possibility for military
outsourcing of maintenance and repair
• Cross border maintenance + training
• Improved cooperation on military operations
• Similar licensing and educational schemes for military and civilian maintenance personnel
utilising accepted best practice.
• Next step: enlarge to European level through MAA recognition.
• A consolidated & homogenate situation in Europe: A unique and harmonized way to manage
safety in all the military as well as in the industry.
• General improvement in safety, in maintenance, in logistics, in training, in joint operations, in
budget efficiency, in international cooperation, in aeronautical exports opportunities.
A safer, clearer and more controlled situation
today than yesterday.
General review.
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www.eda.europa.eu
Thankyou for your attention!