Harmonising Military Airworthiness - Feb 2015 V2

DEFENCEHarmonising airworthinessHarmonisingairworthinessIn a time of extreme pressure on defence budgets,harmonising military airworthiness among allies can bringbig benefits. Air Vice-Marshal MARTIN CLARK FRAeS,Director (Technical), Military Aviation Authority, reviewsrecent progress.n his September 2014 AEROSPACE article,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 ofmanaging 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 inthis context that the UK championed a proposalI36AEROSPACE / FEBRUARY 2015to 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 Ministeriallyapproved roadmap of objectives in a BasicFramework Document (BFD). The objectives wereto achieve: Common regulatory framework Common certification processes Common approach to organisational approvals Common certification/design codes Common approach to preservation ofairworthiness Arrangements for mutual recognitionIT ALSOBENEFITSINDUSTRY, INTHE SENSETHAT ONLY ONEORGANISATIONALAPPROVAL ORMILITARY TYPECERTIFICATEMAY NEED TOBE HELD ORDEVELOPED FORA PARTICULARAIRCRAFT BEINGOPERATEDBY SEVERALNATIONS

Airbus Defence and Space A400MAtlas. The UK, France and Spain arealready taking steps to harmoniseA400M continuing airworthinessassurance.The concept of the EMJAAO was that the pMSwould come together as a club of ‘like-minded’nations, comparable to the original Joint AviationAuthorities’s 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.10%Military airworthiness frameworkTo achieve the BFD objectives, the MAWA Forumelected to draw heavily upon the civil regulatoryframework 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:COST SAVINGSDURINGDEVELOPMENT50%REDUCTION INPROGRAMMEDURATION(EDA) 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 TrainingOrganisationsMoDMoD Formation of a European Military JointAirworthiness Authorities Organisation (EMJAAO)HARMONISATION@aerosocietyiFind us on LinkedInfFind us on Facebookwww.aerosociety.comThe 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 — AirworthinessCertification 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 firstelement of the Def Stan to be re-written in thisFEBRUARY 201537

DEFENCEHarmonising airworthinessway (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 implementationOnce 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 Forumin 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 UK’s 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 requirementswere implemented to allow the MAA to address38AEROSPACE / FEBRUARY 2015Implementation ofEMAR 21 offersthe potentialto reduce timeand cost ofEurofighterTyphoonupgrades.key recommendations from the Nimrod Review toimprove 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 beenapproved. 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 UK’s 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 MAA’s 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 techniciantraining policies, and to minimise any associated