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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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  • 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

  • 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

  • www.eda.europa.eu 3

    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

  • www.eda.europa.eu 4

    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.

  • www.eda.europa.eu 5

    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.

  • www.eda.europa.eu 6

    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.

  • www.eda.europa.eu 7

    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:

  • www.eda.europa.eu 8

    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

  • www.eda.europa.eu 9

    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

  • www.eda.europa.eu 10

    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

  • www.eda.europa.eu 11

    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

  • www.eda.europa.eu 12

    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 ……

  • www.eda.europa.eu 13

    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

  • www.eda.europa.eu 14

    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

  • www.eda.europa.eu 15

    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

  • www.eda.europa.eu 16

    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

  • www.eda.europa.eu 17

    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

  • www.eda.europa.eu 18

    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.

  • www.eda.europa.eu 19

    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…

  • www.eda.europa.eu 20

    The EMARs

  • www.eda.europa.eu 21

    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

  • www.eda.europa.eu 22

    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.

  • www.eda.europa.eu 23

    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.

  • www.eda.europa.eu 26

    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.

  • www.eda.europa.eu 27

    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

  • www.eda.europa.eu 28

    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

  • www.eda.europa.eu 29

    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

  • www.eda.europa.eu 30

    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.

  • www.eda.europa.eu 31

    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.

  • www.eda.europa.eu 32

    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.

  • www.eda.europa.eu

    Thankyou for your attention!