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RPAS Airworthiness - An Overview of the Process and the Benefits of Being Able to Demonstrate it RAeS Conference – London 7th May 2015
Michael Gadd – Policy Specialist, UAS & Spaceplanes
UK CAA Safety and Airspace Regulation Group
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Introduction
RPAS - Basic Objectives & Principles for CAA
The Concept of Safety
The Aviation Frameworks
International / European
National
The Airworthiness Processes –
Organisation Approvals
Certification and Validation
Summary & Questions
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RPAS Context – Vision and Scale
CAA Vision is “to enable full and safe integration of
all UAS operations into the total aviation system”
RPAS must be….
Safe to be flown AND Flown safely
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Fundamental Principles
They are Aircraft
They are Piloted – albeit remotely
No ‘automatic rights’ - to airspace or special privileges
Regulations must be proportionate to the potential
risk
Protect those not involved in the activity
Equivalence – to similar risk picture to manned aviation
Visual Line of Sight (VLOS) ‘See and Avoid’ responsibilities through direct visual observation
Limited range - 400ft vertical, 500m horizontal – basic limits
Beyond Visual Line of Sight (BVLOS) Detect and Avoid Capability
Segregated Airspace (if no DAA system fitted)
ICAO definition: Aircraft - Any machine that can derive support in the atmosphere from the reactions of the air other than the reactions of the air against the earth’s surface.
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The Concept of Safety ICAO Circular 328 –
(UAS) must not present a hazard to persons or property on the ground or in the air that is any greater than that attributable to the operation of manned aircraft of equivalent class or category
ICAO Manual on Remotely Piloted Aircraft Systems - (Doc. Ref. 10019 / AN/507)
“… an RPA shall be operated in such a manner as to minimise hazards to persons, property or other aircraft …”
What does this mean and how do we do it?
Airworthiness Limitations
Operational Limitations
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The International Civil Aviation Framework
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The International Civil Aviation Framework
Borne out of the United Nations 191 Member States International Convention for Civil Aviation (The Chicago Convention) 19 Annexes & Various Guidance Manuals & Documents
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Annex 19 SMS
Annex 17 SECURITY Annex 16
ENVIRONMENTAL PROTECTION
Annex 15 AERO INFO SERVICES
Annex 14 AERODROMES
Annex 13 ACCIDENT
INVESTIGATION
Annex 9 FACILITATION
Annex 5 UNITS OFMEASURE
Annex 4 AERO CHARTS
Annex 3 METROLOGY
Annex 2 RULES OF THE
AIR
The Annexes Annex 18
DANGEROUS GOODS
Annex 12 SEARCH & RESCUE
Annex 11 AIR TRAFIC SERVICES
Annex 10 TELECOM & RADIO NAV
Annex 7 NATIONALITY & REGISTRATION
Annex 6 OPERATIONS
Annex 8 AIRWORTHINESS
Annex 1 LICENSING
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The International Civil Aviation Framework
Annex 1 - Licensing
Guidance Manuals & Documents
Annex 6 - Operations
Annex 8 - Airworthiness
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The European Aviation Framework
European Aviation Safety Agency
Regulation (EC) No. 216/2008 of 20/02/2008 – The “Basic Regulation”
Certification Specifications
Advisory/Guidance Material
Web: www.easa.europa.eu
Initial Airworthiness Regulation(EU) No 748/2012 of 03/08/2012
Continuing Airworthiness Regulation(EC) No 2042/2003
Aircrew Regulation(EU) No 1178/2011 of 3 November 2011
Air Operations Regulation(EU) No 965/2012 of 5 October 2012
Third Country Operators Regulation (EU) No 452/2014 of 29 April 2014
ATM/ANS Implementing Regulation (EU) No 1034/2011 of 17 October 2011 & Implementing Regulation (EU) No 1035/2011 of 17 October 2011
ATCO Regulation (EU) No 805/2011 of 10/08/2011
AUR Implementing Regulation(EU) No 1332/2011 of 16 September 2011
SERA Implementing Regulation(EU) No 923/2012 of 26/09/2012
AERODROMES
FEES & CHARGES Regulation (EU) No 319/2014 of 27 March 2014
CS-36 – Noise CS-31 – Balloons CS-29 – Large Helicopters CS-27 – Small Helicopters CS-25 – Large Aeroplanes CS-23 – Small/Commuter Aeroplanes CS- 22 – Sailplanes & Powered Sailplanes CS-VLA – Very Light Aeroplanes CS-E – Engines CS-FSTD – Simulated Training Devices ….
AMC-20 – General Acceptable Means of Compliance for Airworthiness of Products, Parts and Appliances
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The National Civil Aviation Framework
UK – Civil Aviation Act
Air Navigation Order (CAP 393)
British Civil Airworthiness Requirements (CAP 553 & 554)
Web: www.caa.co.uk
Specific Guidance (CAP 722, Edn. 6)
Information & Procedures (CAP 562)
Civil Aviation Authority
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Air Navigation Order 2009 - Key Articles
138 – Endangerment ‘A person shall not recklessly or negligently permit an aircraft to
endanger persons or property’
166 – Small Unmanned Aircraft (20kg or less)
Articles or animals must not be dropped ……so as to endanger
persons or property.
The ‘person in charge’ may only fly the aircraft if reasonably
satisfied that the flight can safely be made.
(NOTE: No specific requirements for ‘airworthiness’)
Person in charge must maintain ‘Direct unaided visual contact’ –
for the purpose of avoiding collisions (ie. VLOS flights only)
>7kg ATC permission for A,C,D,E airspace, ATZ’s, >400ft.
Flights for the purpose of aerial work require specific permission
to be granted by the CAA.
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167 – Small Unmanned Surveillance Aircraft ‘SUSA’ is a small unmanned aircraft equipped to
undertake any form of surveillance or data acquisition.
Unless in accordance with a permission from the CAA, a SUSA must not be flown: Over or within 150m of congested area or assembly of >1000
people
Within 50m of vessels, vehicles or structures (not under the control of the person in charge of the aircraft)
Within 50m of any person (exceptions exist for take-off/landing (30m) and persons under the control of the person in charge of the aircraft)
Art 167 ‘covers off’ flights which are not aerial work
Air Navigation Order 2009 - Key Articles
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RPAS over 20kg mass
All elements of the ANO apply (Registration, Equipment, Crew Licensing, Rules of the Air etc)
Airworthiness – based on principles of the
EASA ‘Basic’ Regulation (Reg. (EU) No.
216/2008) (>150kg mass , State a/c, research, experimental, scientific)
Segregated airspace (until DAA ‘arrives’) UK uses Danger Areas as prime tool for UA segregation purposes
Short term needs may be catered for through temporary airspace
restrictions – TDA
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Airspace
Wilts/Salisbury – EGD120, 122 A/B/C
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Airworthiness – CAA look to EASA (under Reg. (EU) No 216/2008) for
Initial Airworthiness (Type Certification) and Continuing Airworthiness of these aircraft, unless conditions specified in Annex II are met.
For 216/2008 Annex II aircraft, (>150kg mass, State a/c, research, experimental, scientific,…), then National Regulations apply. (CAA use EASA requirements and processes, supplemented where necessary by British Civil Airworthiness Requirements, e.g. CAP 553 “Section A” - UK products or CAP 554 “Section B” – Non-UK products).
Operations – Again, CAA look to EASA regulations/requirements.
The Airworthiness Processes RPAS over 150 kg
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The Airworthiness Process - Certificates
Objective: To establish compliance to the applicable
requirements and grant the appropriate certificate.
INTERNATIONAL
Operating Certificate
Certificate of Airworthiness
Aircraft Type Certificate
Engine Type Certificate
Propeller Type
Certificate
Flight Crew Licensing
NATIONAL Operating Certificate
Certificate of Airworthiness
Aircraft Type Certificate
Engine Type Certificate
Propeller Type
Certificate
Flight Crew Licensing
Permit to Fly INTERNATIONAL
or NATIONAL
Flight Crew Licensing
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The Type Certification Process
Applicant Process
Pre-application
Application
Certification Basis Agreed
Demonstration of Compliance
Type Certification
Date of Application
Initial Certification Basis Agreed
Final Certification Basis Agreed
Compliance Review Complete
Type Certificate Issued
Regulator Process
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Type Certification and Validation
Primary Certification & Validation Authorities
Bi-Lateral Agreements & Working Arrangements
The Certification Processes RPAS over 150 kg
Design Organisation Approval EASA - Part 21 subpart J UK Nat’l –(CAP 553) BCAR Section A Chapter A8-21
POA Organisation Approval EASA - Part 21 subpart G UK Nat’l – (CAP 553) BCAR Section A Chapter A8-21
Continuing Airworthiness EASA - Part M & Part 145 UK Nat’l – (CAP 553) BCAR Section A Chapter A8-23, 24 & 25
Qualified Entities EASA – Reg. No. (EU) 216/2008 (Basic Reg’n) Annex 5 UK Nat’l – (CAP 553) BCAR Section A Chapter A8-22 & CAP 722 Edn. 6 Appendix E (Information Notice 2015/005 (Small UAS))
Organisation Approvals
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Certification Requirements
The Certification Processes RPAS over 150 kg
Noise Balloons Large Helicopters Small Helicopters Large Aeroplanes Small/Commuter Aeroplanes Sailplanes & Powered Sailplanes Very Light Aeroplanes Engines Simulated Training Devices
CS-36 CS-31 CS-29 CS-27 CS-25 CS-23 CS- 22 CS-VLA CS-E CS-FSTD
Small Light Aeroplanes Light Gyroplanes Non-rigid Airships
(CAP 482) BCAR Section S (CAP 643) BCAR Section T (CAP 471) BCAR Section Q
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Certification Requirement
CS-25 - Large Aeroplanes
CS-29 - Large Helicopters
CS-23 - Small/Commuter Aeroplanes
CS-27 - Small Helicopters
Requirement - 1309
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Certification Basis: Defined in Certification Review Item (CRI) A-01
1. Statement of Issue
2. High level project description
3. Date of Application / Reference Date / Baseline Requirement Amendment
4. List of applicable requirements
I. Basic requirements, e.g. ICAO Annex 16 Vol I, Vol 2, CS/BCAR …
II. Requirements not considered applicable and (if necessary) why not
5. List of Certification Review Items:
I. Special Conditions
II. Elect to Comply
III. Equivalent Safety Findings
IV. Deviations
V. Reversions
VI. Interpretative Material and Means of Compliance
6. Requirements for optional equipment/operations, e.g. ETOPS
The Airworthiness Processes RPAS over 150 kg
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The Airworthiness Processes RPAS between 20kg and 150 kg
No mandated airworthiness requirements.
CAP 772 (Edition 6) uses a CONOPS approach, based
on a Safety Case.
An operator will need to justify the overall risk from their
activity is adequately recognised and mitigated - for
normal operations AND under failure or problem
situations.
WHAT, WHERE, WHEN AND HOW
A balance of Airworthiness and/or Operational Limitations
Airworthiness Limitations
Operational Limitations
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Operational Safety Case (CAP 722 App. B, C and D)
Volume 1 – Operations Manual
Safety Policy
Organisation
Operations
Volume 2 – Systems
Technical system(s) descriptions
Volume 3 – Safety Assessment
Hazard and Risk assessment
Self Assessment
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Small Unmanned Aircraft (SUA)
“Any unmanned aircraft, other than a balloon or a kite,
having a mass of not more than 20kg without its fuel but
including any articles or equipment installed or attached at
the commencement of its flight”
Note - this does not differentiate between model/recreational or other
uses
SUA are exempted from the majority of the UK Air Navigation
Order (UK Air Law), but 3 specific articles apply: Arts 138, 166 &
167
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Small RPAS Operations
Commercial Use (Aerial work):
CAA Permission is required.
Aerial work – if ‘valuable consideration’ is given/promised for purpose of the flight.
Requests for flight closer to people/property/in congested areas, is growing.
(150m of congested areas or large assemblies, 50m of ‘PVVS’ not under control of RP)
CAP 722 CONOPS Safety Case supports this.
For safety purposes only;
Privacy aspects are covered by the data protection regulations (managed by the Information Commissioners Office)
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Small RPAS Leisure Use
Recreational Use:
Basic responsibility on ‘person in charge’
Simple and very light touch – no licensing, no
registration, no ‘airworthiness’ requirements.
VLOS only
Privacy aspects are covered by
the data protection regulations
(managed by the Information
Commissioners Office)
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UK Publicity campaign leaflet
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New Aviation Sectors
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www.hover-bike.com
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Thank You
