The French Military Airworthiness System Lt-Col Richard Duriez - State Aviation Safety Authority...

The French Military Airworthiness SystemLt-Col Richard Duriez - State Aviation Safety Authority

Turkish Military Airworthiness Seminar - 18 Sep 2013

18 Sep 2013FR military airworthiness system 2

CIVIL-MIL AVIATION: SAFETY IN COMMON

ICAO*Chicago Convention

(1944)

q ART 3 - State aircraft

•« This convention shall be applicable only to civil aircraft, and shall not be applicable to state aircraft »

•« The contracting States undertake, when issuing regulations for their state aircraft, that they will have due regard for the safety of navigation of civil aircraft. »

EASA*EC 216/2008

•ART 1 – Scope of application

•« This Regulation shall not apply to….while carrying out military, customs, police, search and rescue, firefighting, coastguards or similar activities or services »

•« The Member states shall undertake to ensure that such activities or services have due regard as far as practicable to the objectives of this Regulation »

• CIVIL AGENCIES CANNOT REGULATE STATE AVIATION

• STATE AVIATION DOES NOT HAVE TO COMPLY WITH CIVIL REGULATIONS

• STATES UNDERTAKE TO HAVE DUE REGARD FOR CIVIL AIRCRAFT SAFETY


First airworthiness regulation and organisation

• The first regulation was focused on aircraft only• TC, PtF, CoA, CoR…

• The stakeholders were :• One Technical Authority• 7 Air Operating Authorities (AOA)

Decree 2006-1551

Order« Duties »

Order « Conditions »

Order « Registration »

Interdepartmental level


Technical authority

End users (incl. CAMO)

First airworthiness organisation

May grant exemption, by a justified decision and for a limited period, with the requirements of the CoA in the event of exceptionalcircumstances or of urgent operational needs

Civil aviationCurrent situationFormer

situationPresentsituation

State Aviation Safety Authority

Military aviation

Continuingairworthinessauthorities

Operators

7 AOAs


Report of MMAé (Jan 2009)

• Scattering of responsibilities in terms of aviation safety

• Duplication of responsibilities between « users » and « regulators »

• Need for coherence with respect to EASA and FR Civil Aviation Authority principles

Note from the minister’s cabinet dated 02 April 2009

determining the creation and objectives of DSAÉ Three fields of competence :

Aircraft airworthiness Air traffic, airspace and airport management Aircrew training and aircraft operating rules

Newly established principles:

Separation of responsibilities between “authorities” and “end users” Preserved responsibilities for « Operating Authorities » Interdepartmental scope of action (Ministries of Defence, Interior,

Budget)

DSAÉ : a political decision


Technical authority

End users (incl. CAMO)

DSAÉ : a political decision

May grant exemption, by a justified decision and for a limited period, with the requirements of the CoA in the event of exceptionalcircumstances or of urgent operational needs

Civil aviationCurrent situationFormer

situationPresentsituation

State Aviation Safety Authority

Military aviation

Continuingairworthinessauthorities

Operators

7 AOAs 7

AOAs


Civil vs military : who does what ?

Technical AuthorityTechnical Authority

Military stakeholders

OperatorsOperators

EASAEASA

Civil stakeholders Rulemaking and executive functions

• Establishes the essential requirements

• Conduct Type certification• Approve flight test conditions• Ensure Continued airworthiness• Approves Design organisations

National authoritiesNational authorities

• Establish the rules for continuing airworthiness

Aviation Safety AuthorityAviation Safety Authority

Technical AuthorityTechnical Authority

End Users / CAMOsEnd Users / CAMOs

• Issues permit to fly (flight tests)• Registration of flight test

aircraft• Approves Production

organisations• Appreciates the compliance of

new products to the type design• Approves organisations (maintenance, continuing airworthiness management, training)

• Issues maintenance personnel licences• Issues Individual CoAs• Registration of aircraft in service

Aviation Safety AuthorityAviation Safety Authority

• Apply the rules• Manages Continuing airworthiness

• Can grant exemptions for urgent operational needs

• Issue permit to fly

European CommissionEuropean Commission


DSAÉ governance structure

DSAÉ

Minister of DefenceMinister of the InteriorMinister of Budget and

Finance

Defence Staff

Functional

authority

DGA SGAExecutive Committee

Chaired by

Chief of Defence

Each Air Operating Authority (CGS, CNS, CAS, Director)

appoints one Accountable Manager for each domain

AMFRA M

AMFRA 145

AMFRA 147

Defence Staff responsibility DGA MoB&FMoIDGA Technical Authority

Continuing airworthinessInitial certification

Continued airworthiness

Industry Design Organisations= Type Certificate Holder


DGA Technical AuthorityProgramme managersSQ (Quality Service)


DGA organisation for airworthiness decisions

Project axis : DO

Management unit x

Tec

hnic

al a

utho

rity

axis

: D

T

Project Manager 2

Project Manager 1

Project Manager n

Technical director for aircraft: P. HADOU RP.ASA

Technical manager for airframes & aircraft systems expertiseO DUGAST RM PSA

Technical manager for propulsion expertiseR. HEILIGENSTEIN RM PRA

Technical manager for air systems

expertise R.CORNEN (GR ASA)

Spe

cial

ists

for

airf

ram

es

and

airc

raft

syst

ems

Exp

erts

pro

puls

ion

…..

Director of DGA Flight testing(permit to fly for test bed aircraft)

Airworthiness cell: Th LOUDES

People authorized to sign airworthiness decisions

About ASA 130 specialists

DGA Aeronautical Systems (airdrop, fast roping, airlift, airframe structure and systems)

Deputy : C. GAUTIE


DSAE PILARS & MISSIONS

CONTINUINGAIRWORTHINESS

MISSIONS:

REGULATIONCERTIFICATION

ATM/ASMAIRPORTS

CNS

MISSIONS:

REGULATIONAIRSPACE MGTCERTIFICATION

TRAINING&

OPERATIONS

MISSIONS:

REGULATION MONITIRING

HARMONISATION

INITIAL

CERTIFICATION (TC)

CONTINUED

AIRWORTHINESS

SEVEN AVIATION OPERATING AUTHORITIES (AOA)

Central DSAÉ : 106

Outpost DSAÉ : 130

Total DSAÉ : 236


Airworthiness directorate organisation

DSAÉ Villacoublay

Outposts

UCN : Unité de contrôle de la navigabilité

= AOU : Airworthiness Oversight Unit

Secretariat

Initial Airworthiness Advisor

Rulemaking Department

Airworthiness Director

Airworthiness Oversight Department

Rulemaking Division

Reference Manuals& GuidesDivision

Management Division

Production Planning Section

UCN air n° 6 – Orléans

UCN air n° 8 – Cazaux

UCN air n° 4 – Istres

UCN air n° 7 – Mont-de-Marsan

UCN air n° 3 – Nancy

UCN air n° 2 – Saint-Dizier

UCN air n° 9 – Tours

UCN air n° 1 – Villacoublay

UCN marine n° 4 – Hyères

UCN marine n° 3 – Lanvéoc

UCN marine n° 1 – Lann-Bihoué

UCN marine n° 2 – Landivisiau

UCN Gendarmerie

AircraftOversight Division

Certificates of Airworthiness & Approved Maintenance Plans

Section

RegistrationSection

Organisations Oversight Division

Technical AssessmentSection

Training & LicencesSection

UCN Terre

UCN DGA – Istres

Skill Management & System Tools Section


Airworthiness oversight units locations

UCN : Unité de contrôle de la navigabilité = AOU : Airworthiness Oversight Unit

UCN-marine Landivisiau

UCN-marine Lanvéoc

UCN-marine Lann-Bihoué

UCN-marine Hyères

UCN-air Villacoublay

UCN-air Orléans

UCN-air Tours

UCN-air Nancy

UCN-air Saint-Dizier

UCN-air IstresUCN-air Mont de Marsan

UCN-air Cazaux

UCN-terre VillacoublayUCN-gendarmerie

Villacoublay

UCN-DGA Istres


French airworthiness regulation structure

Decree 2006-1551 superseded by decree 2013-367

Order« Duties »

Order « Conditions »

Order « Registration »

Order« Continuing airworthiness »

Order« UAS »

Interdepartmental level

Authorities level

Instruction« Initial airworthiness »

Instruction« Continuing airworthiness »

- Essential airworthiness requirements- Regulations considered as acceptable means of compliance

- FRA 21- FRA Forms

- FRA M - EMAR(FR) M (provision)

- FRA 145 - EMAR(FR) 145- FRA 147 - EMAR(FR) 147- FRA 66 - EMAR(FR) 66

(provision)- FRA Forms - EMAR Forms

AMC & GM for all FRA

Mementos and procedures

Internal documents

documents : - applicable to State organisations and personnel - applicable to industry through contracts

DGA Technical Authority DSAÉ State Aviation Safety Authority

Instruction« Report of

technical occurrences »

Instruction« Civil ADs and TCH technical directives »

Instruction« Stores and equipment excluded from continuing

airworthiness »


Rulemaking

• Rulemaking based on consensus between :• DSAÉ• DGA Technical Authority• The 7 Air Operating Authorities

• Consensus also with industry :• Working groups with GIFAS, the French Aerospace Industries

Association

• Monitor the evolutions of EASA regulation to keep as close as practicable while preserving military specificities

• Benefit from the return of experience of the implementation of the regulation to improve it


Aircraft concerned by the Regulation

Military aircraft Aircraft belonging to the Ministry of Defence or to the Ministry of Interior for the

Gendarmerie

Aircraft used temporarily by a legal person for the purpose of the ministry of Defence or to the Ministry of Interior for the Gendarmerie in the frame of a contract or a convention (e.g. upgrade of an aircraft)

Aircraft not belonging to the State classified as armament (e.g. Aircraft under development or production)

Aircraft not belonging to the State, but used to carry out missions for the State and piloted by a Military crew

State aircraft : Aircraft belonging to the Ministry of Interior for the Public Safety Service or to the

Ministry of Budget & Finance for the Customs

Police should join to operate RPAS

Aircraft belonging to the Ministry of Transport are not in the scope


The Airworthiness The Airworthiness ControlledControlled EnvironmentEnvironment

The Type Certificate Holder (TCH) is the Design Organisation

DESIGN & PRODUCTION

A Certificate of Airworthiness (CoA) is issued for each individual aircraft.

AIRWORTHINESS MANAGEMENT

A Continuing Airworthiness Management Organisation (CAMO) holding a FRA-M approval is chosen

by the 7 Air Operating Authorities

MAINTENANCE

TRAINING The aircraft is maintained in a FRA-145

approved maintenance organisation (MO), manned by technicians holding a

FRA-66 licence

Technicians are trained in FRA-147 approved

Maintenance Training Organisation (MTO)

A Type Certificate (TC) is issued by DGA Technical

Authority

The Design Organisation (DO) has a FRA-21 J approval,

The Production Organisation (DO) has a FRA-21 G approval


Challenge of certifying all aircraft in service

• Different options were available :

1. The regulation is applicable to aircraft procured after the enforcement of the regulation

• New procurements are so few that the Nation credibility would be at stake

2. The regulation is applicable to all aircraft, including all legacy aircraft in service

• Transitional provisions are necessary in order not to ground some fleets just because of a legal constraint

3. Find some trade offs between the 2 :

• e.g. The regulation is applicable only to recent aircraft, which service life will last several decades

France decided to choose the very challenging but also very virtuous option 2


Challenge to implement a regulation

EASA : Basic regulation EC 216/2008 (replacing original EC 1592/2002)

Article 70 : Entry into force • Articles 5, 6, 7, 8, 9 and 10 shall apply as from the dates specified in their respective

implementing rules, but not later than 8 April 2012.

EASA established a 10-year transitional period to implement its regulation

FR : FR launched a WG to develop an airworthiness regulation for military and State

aircraft in early 2002

FR issued the airworthiness decree for military and State aircraft on 7 Dec 2006 after 5 years

The regulation had initially a 5-year transitional period to implement the regulation

This period was later extended to 10 years further to the difficulties encountered in its implementation (2006 to 2016 for a fleet of about 1500 aircraft)


Ambitious implementation schedulewith transitional provisions

66 aircraft TCs, 51 engine TCs, 22 propeller TCs, 4 UAS TCs ~ 1500 CoAs

~ 200 maintenance organisations to approve~ 70 design or production organisations to approve

~ 5000 licensed maintenance personnel

OKOK

2011 2012 2013 2014 2015 2016 2011 2012 2013 2014 2015 2016

Controlled environment : Late 2016

FRA 21 G

2016

FRA 21 G

2016

2009 2010 2011 2012 2013 20142009 2010 2011 2012 2013 2014

2011 2012 2013 2014 2011 2012 2013 2014

2011 2012 2013 2014 2015 2016 2011 2012 2013 2014 2015 2016

100% CoAs (Sustainable fleets)

Late 2014

100% CoAs (Sustainable fleets)

Late 2014

100% FRA M, FRA 147

Late 2014

100% FRA M, FRA 147

Late 2014

100% FRA 145 (Ops)

2016

100% FRA 145 (Ops)

2016

100% FRA 145 (Industry)

2016

100% FRA 145 (Industry)

2016

DGA

DSAÉ

(*) FRA 21 J Design : no real timeframe constraint as, in the absence of DOA,any airworthiness approval is done by DGA Technical Authority

2007 2008 20092007 2008 2009

100% TCs (Sustainable fleets)

Late 2009

100% TCs (Sustainable fleets)

Late 2009TCs

DGA

Legacy aircraft TCs New aircraft TCsLegacy aircraft TCs New aircraft TCs

2011 2012 2013 2014 2015 2016 2011 2012 2013 2014 2015 2016

CoAs

CAMOs, MTOs

Operational MOs

POs (*)

Industrial MOs



DGA Technical Authority had 3 years to issue all Type Certificates (TC) Grandfather law: the types of product in service before 9 December 2006

or already qualified by DGA before 9 December 2006 are considered type certified

DGA Technical Authority issues a TC for each type of product mentioned in the previous bullet with the associated Type design definition, and designates a Type Certificate Holder (TCH) TCH : what if the OEM refuses to be the TCH ? Type design definition :

Type Certificate Data Sheet (TCDS) For legacy products, an “Airworthiness Reference Data Sheet”

clarifying the past : modifications, ADs, documentation way to handle the future documents coming from TCH or

from of a Primary Authority (civil or military)

It may have to be refined further to the first airworthiness reviews Then it is to be managed by the CAMO


From TC to CoA

aircraft TC

STC 1

STC 2

TCDS

STCDS 1

STCDS 2

Frozen approved configuration

Aircraft type level (applicable configuration) Individual aircraft level(applied configuration)

Airworthiness review

Questions raised during the airworthiness review :- A change is not physically implemented : is it mandatory ?-A change is implemented but not covered by the TC (“State” mod)-Some documents are not mentioned in the TCDS ?-How to manage documents approved by another authority or through past process?….

Airworthinessreference data

sheet

Supplementary informationclarifying the past

BaselineEngine TC

TCDS



• Very tight schedule particularly for old legacy aircraft for which the Airworthiness Reference

Data Sheet takes time to be consolidated

• Technical and/or regulatory solutions must be found for aircraft which are forecast not to meet the objective of 31 Dec 2014

• Some sensitive aircraft

• e.g. VIP aircraft

• Aircraft in operations (e.g. Operation Serval in Mali)

• Anticipate Airworthiness Review by DSAÉ prior to sending aircraft on theatre

• DSAÉ started to carry out the Airworthiness Reviews for the first ARC renewals after 3 years To be anticipated into DSAÉ workload


Approvals for AOA organisations

The following choice was made :• AOAs (Air Operating Authorities) apply for :

• a single FRA M approval (CAMO)• a single FRA 145 approval (MO)• a single FRA 147 approval (MTO) The Accountable Manager can better meet the requirement of

corporate authority• Incremental process to meet the time plan :

• The AOA applies for an initial approval on the scope of the head office + one fleet

• When ready, the AOA applies for extensions to other fleets Single exposition documents : CAME, MOE and MTOE

• Harmonized working processes within an AOA


Audit challenge for FRA 21G and 145 approvals

• DGA Technical Authority : 1 auditor• DSAÉ : 4 auditors + 30 trained personnel from Aircraft Oversight Units• DGA/SQ (Quality Service)

• Protocols with DGA/SQ to provide auditors to carry out :• FRA 145 audits for DSAÉ

• as lead auditors for industrial MOs DSAÉ auditors may participate as backup, for training or as observers

• part of audit team lead by DSAÉ for operational MOs

• FRA 21 G audits for DGA Technical Authority Although the auditor is part time an airworthiness auditor and part time a

Government Quality Assurance (GQA), when acting as an airworthiness auditor, he is independent from the GQA team auditors of the organisation to be audited

• 2012 : 51 auditors• 2013 : 81 auditors representing 12 full time personnel

• 12 for FRA 21 G

• 25 for FRA 21 G and FRA 145

• 42 for FRA 145

• New auditors selected among experienced GQA auditors Initial training and periodic updating training for all auditors


Challenge of the cooperation with FR CAA

• DGAC, the French CAA, outsourced the airworthiness reviews and the audits to OSAC (Organisme pour la Sécurité de l’Aviation Civile)

• DSAÉ signed with OSAC (with the agreement from DGAC) a protocol for mutual support to exchange information on maintenance organisations audited both against EASA Part 145 and FRA 145 on a common scope• DSAÉ to have access to OSAC audit reports

• For Part 145 approved MOs, level 1 findings during the FRA 145 initial or renewal audit which may impact the Part 145 approval to be transmitted by DSAÉ to OSAC


FRA 66 Maintenance staff licences

FRA 66 EMAR 66 Part 66

basic operations AE A A

complex operations on airframe/engine, avionic, armament systems

BE1 B1 B1

BE2 B2 B2

BEArm

whole aircraft CE C C

AE1 & BE1.1 : aeroplanes turbine

AE2 & BE1.2 : aeroplanes piston

AE3 & BE1.3 : helicopters turbine

BEArm.1 : armament on aeroplanes

BEArm.3 : armament on helicopters

FRA-66 licence is necessary only for the aircraft certifying staff

3 options :Recognition of a Part 66 licence

Grandfather law

Training in FRA 147 approved MTO + experience

5 year validity

renewal of validity : if valid FRA 145 approval with relevant licence categories and type ratings

if contract for industrial MOs


Challenge of cooperation

• DSAÉ and/or DGA Technical Authority participate actively in several cooperation fora :

• EDA MAWA Forum and their Task Forces• Development of EMARs (European Military Airworthiness Requirements) :

• EMAR 145, 147 and 21 published and publicly available• Publication of EMAD R (European Military Airworthiness Document Recognition)

• Guide for recognition between MAAs

• NATO AwWG• NATO Airworthiness Policy approved on 18 July 2013

• With designation of a NATO Airworthiness Executive (NAE)• NAE to make sure aeronautical products are airworthy

by recognizing the responsible MAA or CAA

• A400 M CAF (Continuing Airworthiness Forum)• Drafting a principles document to allow in service support cooperation


Challenge of cooperation

• The principles shared by other EU nations are: • Step by step approach :

• Nations may implement EMARs on some programmes only (e.g. cooperation purposes : A400M)

• “Implement” means • either “adopt” (e.g. FR) • or “comply with” (e.g. UK)

• “do not duplicate the work” : • reuse the EMAD R

• for the recognition of MAAs by NATO• for mutual recognition between the MAAs of the A400M nations

• Need to maintain the coordination between the airworthiness fora

• The EMAD R is not limited to recognition of EU MAAs• It can be used for the recognition of any MAA• The recognition is facilitated if the regulation is compliant with the EMARs


A400M

• A400 M joint FR-UK In Service Support (ISS) contract• DSAÉ and MAA UK signed a Recognition Agreement as per EMAD-R

• Further to questionnaires (MARQs) and reciprocal assessment visits, a Recognition Certificate was signed in Mar 2013 to allow :

• the mutual recognition of EMAR 145 approvals• the possibility to carry out joint audits

• Other Recognition Agreements are planned with Spain, Germany and Italy• Draft Recognition Agreement recently sent to Spanish DGAM

The Recognition Certificates will allow the recognition of EMAR 145 or 147 approvals issued by the recognized MAA• Full benefit of a harmonized European set of airworthiness requirements

(EMARs)• Optimisation of the scarce human resources of each MAA

18 Sep 2013FR military airworthiness system 32Thank you for your attention! Any

questions?

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