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

The French Military Airworthiness System Lt-Col Richard Duriez - State Aviation Safety Authority. Turkish Military Airworthiness Seminar - 18 Sep 2013. CIVIL-MIL AVIATION: SAFETY IN COMMON. CIVIL AGENCIES CANNOT REGULATE STATE AVIATION

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

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  1. The French Military Airworthiness SystemLt-Col Richard Duriez - State Aviation Safety Authority Turkish Military Airworthiness Seminar - 18 Sep 2013

  2. CIVIL-MIL AVIATION: SAFETY IN COMMON • 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 FR military airworthiness system

  3. First airworthiness regulation and organisation Interdepartmental level Decree 2006-1551 Order « Duties » Order « Conditions » Order « Registration » • The first regulation was focused on aircraft only • TC, PtF, CoA, CoR… • The stakeholders were : • One Technical Authority • 7 Air Operating Authorities (AOA) FR military airworthiness system

  4. First airworthiness organisation Military aviation Civil aviation Current situation Former situation Presentsituation Technical authority Continuing airworthiness authorities State Aviation Safety Authority 7 AOAs End users (incl. CAMO) May grant exemption, by a justified decision and for a limited period, with the requirements of the CoA in the event of exceptional circumstances or of urgent operational needs Operators FR military airworthiness system

  5. 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 FR military airworthiness system

  6. DSAÉ : a political decision Military aviation Civil aviation Current situation Former situation Presentsituation Technical authority Continuing airworthiness authorities State Aviation Safety Authority 7 AOAs End users (incl. CAMO) 7 AOAs May grant exemption, by a justified decision and for a limited period, with the requirements of the CoA in the event of exceptional circumstances or of urgent operational needs Operators FR military airworthiness system

  7. Civil stakeholders Rulemaking and executive functions Military stakeholders European Commission • Establishes the essential requirements • Conduct Type certification • Approve flight test conditions • Ensure Continued airworthiness • Approves Design organisations Technical Authority EASA Aviation Safety Authority • Establish the rules for continuing airworthiness • Issues permit to fly (flight tests) • Registration of flight test aircraft • Approves Production organisations • Appreciates the compliance of new products to the type design Technical Authority National authorities • Approves organisations (maintenance, continuing airworthiness management, training) • Issues maintenance personnel licences • Issues Individual CoAs • Registration of aircraft in service Aviation Safety Authority End Users / CAMOs Operators • Apply the rules • Manages Continuing airworthiness • Can grant exemptions for urgent operational needs • Issue permit to fly Civil vs military : who does what ? FR military airworthiness system

  8. DSAÉ governance structure Minister of the Interior Minister of Budget and Finance Minister of Defence Executive Committee Chaired by Chief of Defence DGA SGA Defence Staff Functional authority DSAÉ DGA Technical Authority Defence Staff responsibility DGA MoI MoB&F Industry Design Organisations = Type Certificate Holder Each Air Operating Authority (CGS, CNS, CAS, Director) appoints one Accountable Manager for each domain AM FRA M AM FRA 145 AM FRA 147 Initial certification Continued airworthiness Continuing airworthiness FR military airworthiness system

  9. SQ (Quality Service) Programme managers DGA Technical Authority FR military airworthiness system

  10. DGAorganisation for airworthiness decisions Deputy : C. GAUTIE Airworthiness cell: Th LOUDES Technical manager for air systems expertiseR.CORNEN (GR ASA) Technical director for aircraft:P. HADOU RP.ASA Director of DGA Flight testing(permit to fly for test bed aircraft) DGA Aeronautical Systems (airdrop, fast roping, airlift, airframe structure and systems) Technical manager for airframes & aircraft systems expertiseO DUGAST RM PSA Technical manager for propulsion expertiseR. HEILIGENSTEIN RM PRA About ASA 130 specialists Project Manager 1 Project axis : DO Management unit x Technical authority axis: DT Specialists for airframes and aircraft systems Project Manager 2 Experts propulsion ….. Project Manager n People authorized to sign airworthiness decisions FR military airworthiness system

  11. DSAE PILARS & MISSIONS Central DSAÉ : 106 Outpost DSAÉ : 130 Total DSAÉ : 236 TRAINING& OPERATIONS MISSIONS: REGULATION MONITIRING HARMONISATION CONTINUING AIRWORTHINESS MISSIONS: REGULATION CERTIFICATION ATM/ASM AIRPORTS CNS MISSIONS: REGULATION AIRSPACE MGT CERTIFICATION INITIAL CERTIFICATION (TC) CONTINUED AIRWORTHINESS SEVEN AVIATION OPERATING AUTHORITIES (AOA) FR military airworthiness system

  12. Airworthiness directorate organisation Airworthiness Director Secretariat Rulemaking Department Airworthiness Oversight Department Initial Airworthiness Advisor Rulemaking Division Reference Manuals& Guides Division Management Division Organisations Oversight Division AircraftOversight Division Production Planning Section RegistrationSection Training & LicencesSection Skill Management & System Tools Section Technical AssessmentSection Certificates of Airworthiness & Approved Maintenance PlansSection UCN marine n° 1 – Lann-Bihoué UCN air n° 1 – Villacoublay UCN Terre UCN air n° 2 – Saint-Dizier UCN marine n° 2 – Landivisiau UCN Gendarmerie UCN air n° 3 – Nancy UCN marine n° 3 – Lanvéoc UCN DGA – Istres UCN air n° 4 – Istres UCN marine n° 4 – Hyères UCN air n° 6 – Orléans UCN : Unité de contrôle de la navigabilité = AOU : Airworthiness Oversight Unit UCN air n° 7 – Mont-de-Marsan UCN air n° 8 – Cazaux DSAÉ Villacoublay UCN air n° 9 – Tours Outposts FR military airworthiness system

  13. Airworthiness oversight units locations UCN-air Villacoublay UCN : Unité de contrôle de la navigabilité = AOU : Airworthiness Oversight Unit UCN-terre Villacoublay UCN-air Saint-Dizier UCN-gendarmerie Villacoublay UCN-marine Landivisiau UCN-air Nancy UCN-marine Lanvéoc UCN-marine Lann-Bihoué UCN-air Tours UCN-air Orléans UCN-DGA Istres UCN-air Cazaux UCN-air Mont de Marsan UCN-air Istres UCN-marine Hyères FR military airworthiness system

  14. French airworthiness regulation structure Interdepartmental level Decree 2006-1551 superseded by decree 2013-367 Order « Duties » Order « Conditions » Order « Registration » Order« Continuing airworthiness » Order« UAS » Authorities level documents : - applicable to State organisations and personnel - applicable to industry through contracts Instruction« Initial airworthiness » Instruction« Continuing airworthiness » Instruction« Report oftechnical occurrences » • 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 Instruction« Civil ADs and TCH technical directives » Instruction« Stores and equipment excluded from continuing airworthiness » DGA Technical Authority DSAÉ State Aviation Safety Authority AMC & GM for all FRA Internal documents Mementos and procedures FR military airworthiness system

  15. 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 FR military airworthiness system

  16. 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 FR military airworthiness system

  17. The Airworthiness ControlledEnvironment The Design Organisation (DO) has a FRA-21 J approval, The Production Organisation (DO) has a FRA-21 G approval A Type Certificate (TC) is issued by DGA Technical Authority DESIGN & PRODUCTION A Certificate of Airworthiness (CoA) is issued for each individual aircraft. The Type Certificate Holder (TCH) is the Design Organisation 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) FR military airworthiness system

  18. Challenge of certifying all aircraft in service • Different options were available : • 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 • 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 • 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 FR military airworthiness system

  19. 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) FR military airworthiness system

  20. Ambitious implementation schedulewith transitional provisions OK 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 Controlled environment : Late 2016 D G A Legacy aircraft TCs New aircraft TCs 100% TCs (Sustainable fleets) Late 2009 TCs 2007 2008 2009 100% CoAs (Sustainable fleets) Late 2014 D S A É 2009 2010 2011 2012 2013 2014 CoAs 100% FRA M, FRA 147 Late 2014 CAMOs, MTOs 2011 2012 2013 2014 100% FRA 145 (Ops) 2016 Operational MOs 2011 2012 2013 2014 2015 2016 100% FRA 145 (Industry) 2016 Industrial MOs 2011 2012 2013 2014 2015 2016 D G A 2011 2012 2013 2014 2015 2016 FRA 21 G 2016 POs (*) (*) FRA 21 J Design : no real timeframe constraint as, in the absence of DOA,any airworthiness approval is done by DGA Technical Authority FR military airworthiness system

  21. Challenge of certifying all aircraft in service • 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 FR military airworthiness system

  22. From TC to CoA Individual aircraft level (applied configuration) Aircraft type level (applicable configuration) aircraft TC TCDS Baseline Engine TC Airworthiness review TCDS • 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? • …. Supplementary information clarifying the past STC 1 STCDS 1 Airworthiness reference data sheet STC 2 STCDS 2 Frozen approved configuration FR military airworthiness system 18 Sep 2013 22

  23. Challenge of certifying all aircraft in service • 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 FR military airworthiness system

  24. 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 FR military airworthiness system

  25. 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 FR military airworthiness system

  26. 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 FR military airworthiness system

  27. FRA 66 Maintenance staff licences • 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 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 FR military airworthiness system

  28. 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 airworthyby recognizing the responsible MAA or CAA • A400 M CAF (Continuing Airworthiness Forum) • Drafting a principles document to allow in service support cooperation FR military airworthiness system

  29. 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 FR military airworthiness system

  30. 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 FR military airworthiness system

  31. Thank you for your attention! Any questions? FR military airworthiness system

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