MILITARY AIRWORTHINESS, M JANKOVIĆ, Z ILIĆ, M DRONJAK, V PAREZANOVIĆ

Tags: European Defence Agency, EMAR, airworthiness, European Military Airworthiness Requirements, Military Airworthiness Authorities, EASA, maintenance, European Military, military personnel, military aviation, Forum, Military Aviation Authority, MAWA Forum, maintenance organization, Member States, National Military Airworthiness Authority, military aircrafts, Ministry of Defence, certification, implementation, requirements, National Military Airworthiness Authorities, European Military Airworthiness Requirement, regulations, Mr Justice Haddon-Cave, national military, maintenance organizations, airworthiness requirements, European Military Airworthiness Certification Criteria, certification criteria, administrative procedures, the European Aviation Safety Agency, military aircraft, European Union, national level, Air Defence Command, MAWA, Air Safety, French Ministry of Defense, Aircraft Mechanics, RAF Nimrod MR2 Aircraft, Civil Aviation Authorities, EDA, Nimrod aircraft, French Aviation Safety Agency
Content: MILITARY AIRWORTHINESS MILUTIN JANKOVI Aeronautical Plant ,,Moma Stanojlovi", Batajnica, [email protected] ZORAN ILI Technical Test Center, Beograd, [email protected] MILAN DRONJAK Aeronautical Plant ,,Moma Stanojlovi", Batajnica, [email protected] VLADAN PAREZANOVI Air Force and Air Defence Command, Zemun, [email protected] STEVAN JOVICI Technical Test Center, Beograd, [email protected]
Abstract: In Europe, military and state operated aircraft are excluded from the scope of the European Aviation Safety Agency (EASA) legislation. As a result, military airworthiness is regulated only at national level. The need to improve European defence capabilities influenced decision of the European Defence Agency (EDA) to establish the Military Airworthiness Authorities (MAWA) Forum to develop, adopt and implement harmonized European Military Airworthiness Requirements (EMARs). Up to date, MAWA Forum has developed and approved three sets of EMARs that cover: Initial Aircraft Certification (EMAR 21), Aircraft Maintenance (EMAR 145) and Maintenance Training Organizations (EMAR 147). The issue of military airworthiness becomes more and more important because of the signing of the Administrative Arrangement with The Ministry of Defence of the Republic of Serbia in December 2013. In the years to come, it can be expected that the Republic of Serbia will implement those harmonized requirements into own national regulatory documentation. This paper shows the content of the approved EMARs and considers some important consequences of its implementation. Keywords: Military Airworthiness, EMAR, EDA, MAWA Forum, EASA.
1. INTRODUCTION The European Aviation Safety Agency (EASA) is a European Union (EU) agency with regulatory and executive tasks in the field of civilian aviation safety that ensures that all civil aircraft within Europe are airworthy and safe. Because of the national sovereignty reasons, military and state operated aircrafts are excluded from related legislation. Therefore, each member state is individually responsible to ensure that those aircrafts are airworthy and can be flown safely. A series of accidents and incidents throughout the 1990s, where participants were Military Aircrafts, had influence on the decision to pay more attention to questions related to the military airworthiness. According to [1], airworthiness is defined as ability of an aircraft, or other airborne equipment or system, to operate in flight and on ground without significant hazard to aircrew, groundcrew, passengers (where relevant) or to other third parties. In November 2008, the EDA Steering Board entrusted the EDA (European Defence Agency) with the establishment
of a Military Airworthiness Authorities (MAWA) Forum and approved the associated military airworthiness roadmap for achieving common harmonization and certification processes [2]. The goal of MAWA Forum is to complete full set of European Military Airworthiness Requirements (EMARs) until 2015. It is important to emphasize that the EMARs are not mandatory, and each country has a possibility to decide whether to implement them or not. The growing importance of this issue can be viewed through the signing of an arrangement regarding enhanced cooperation between EDA and EASA in June 2013. This arrangement specifically covers the harmonization of military aviation safety requirements with a primary focus on airworthiness [3]. The aim of this paper is to show the potential impact of adopted EMARs on the defence system of the Republic of Serbia. Accordingly, a comparative review of airworthiness regulations and activities that are performing by EASA and MAWA Forum is given.
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Also, the issues of military airworthiness in some European countries are presented. It is stated that the Serbian Ministry of Defence should start with implementation of EMARs in order to comply with the military aviation standards that have been adopted in other European countries. 2. MAWA FORUM The aim of MAWA Forum is harmonization of the national legislation related to military airworthiness. Factor that considerably complicates the achievement of this objective is a complexity of the aviation sector, and this complexity makes it too difficult to regulate, and requires the existence of different level regulation. In some situations, it is necessary to use binding rules, while in other situations it is desirable to provide a certain level of flexibility, which can be achieved through the adoption of non-binding standards. This need for a balanced approach is universally recognized and implemented by all International Organizations and national regulatory bodies. Picture 1: EASA regulatory system In the EASA system, three main levels of Regulatory material exist (Picture 1) [4]: - The Basic Regulation itself, adopted by the European Parliament and the Council, binding in all its elements, - Implementing Rules to the Basic Regulation, adopted by the European Commission; and - Soft law, adopted by EASA. This level consists of non- binding standards: Certification Specifications (CS), Acceptable Means of Compliance (AMC) and Guidance Material (GM). MAWA Forum accepted analogy with adopted EASA regulations, so the future structure of harmonized requirements for military airworthiness is represented in Picture 2.
MAWA Forum. This document is adopted by EDA, approved nationally by 22 Member States, and it is not equivalent to the EASA Basic Regulation. It clarifies the principles of a common approach to military airworthiness and addresses issues such as the mutual recognition between National Military Airworthiness Authorities which is essential to realize the expected benefits from regulatory harmonization. On the basis of this document, to date, the MAWA Forum has developed and approved three sets of European Military Airworthiness Requirements (EMARs) that cover: EMAR 21 for the initial and continued certification of military aircraft ­ including the approval of the design and production organizations, EMAR 145 covering the approval of maintenance organizations and the activities they undertake and EMAR 147 detailing the responsibilities of organizations responsible for the training of maintenance personnel. Beside these EMARs, MAWA Forum has also approved the following supporting documents: European Military Airworthiness Document 1 (EMAD-1), European Military Airworthiness Document ­ Recognition (EMAD-R) and European Military Airworthiness Certification Criteria (EMACC). EMAD-1 provides definitions and explanations for those words, terms and phrases, in the whole EMAR/EMAD document set, which could otherwise be considered ambiguous, confusing or unclear. EMAD-R deals with the recognition of certificates and organizational approvals issued by any of the Authorities amongst participating Member States (pMS). EMACC contains a framework of certification criteria to assist in the determination of airworthiness for all manned and unmanned, fixed and rotary wing air systems [5]. The complete set of EMARs is planned to be approved by the end of 2015 [6]. Furthermore, the implementation of the EMARs will be on a voluntary basis, with each European Military Airworthiness Requirement being transcribed into national regulations. It should be stressed that the MAWA Forum does not have the authority to impose airworthiness regulations on individual nations who retain their sovereignty for military airworthiness. Member States in the work of the EDA MAWA Forum participate through four working groups: 1) for basic framework (definitions, membership, organization etc.), 2) for EMAR Certification (type certification, design approvals, issue of airworthiness certificates etc.), 3) for EMAR maintenance (maintenance organization, certification, housing, equipment etc.) and 4) for military certification criteria (define the new air systems airworthiness basis).
3. EMARS
Picture 2: Future structure of harmonized requirements Basic regulation of MAWA Forum is "European Harmonized Military Airworthiness Basic Framework Document" which defines the role and functions of the
The aim of the EMARs is to provide each National Military Airworthiness Authority (NMAA) with a set of harmonized requirements that can be implemented into their own national regulatory documentation. This could result in that the EMARs become the uniform standard for all European States, thus avoiding national regulatory differences. It should be stressed that the EMARs are not mandatory documents. This means that each European Military
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Airworthiness Authority can decide if they will deviate from EMARs with specific national requirements. There are many benefits for the Military Authorities and Industry in case of the implementation of standardized airworthiness requirements into national military regulations, particularly when it comes to the certification of products and the approval of organizations across Europe. The adoption of common rules and procedures between the European Military Airworthiness Authorities will facilitate the recognition of certificates and approvals issued by any of the Military Airworthiness Authorities amongst participating Member States. [2]. A good example of the possible positive effects of joint cooperation can be a usage of a diplomatic clearance Web portal, which started to work in June 2013. This portal implements a technical arrangement signed by 13 EU countries (Belgium, Bulgaria, Cyprus, Czech Republic, Germany, Greece, Italy, Lithuania, the Netherlands, Romania, Slovakia, Sweden and Norway) for common provisions and harmonized procedures for over-flights and landings. Its main purpose is granting diplomatic clearances for military transport aircrafts [7]. Under a new arrangement, EDA members do not need to submit a diplomatic clearance request for each flight that transits the territory of another member. Instead, annual clearances are issued. The accord also harmonizes the requirements for requests and notifications of clearances and uses a common diplomatic clearance form. EMAR 145 The requirements that must be met by the Maintenance Organizations for the maintenance of aircraft and aircraft components are specified in EMAR 145. This requirement contains two sections. Section A establishes the requirements to be met by an organization to qualify for the issue or continuation of an approval for the maintenance of aircraft and components. Section B establishes the administrative procedures which the National Military Airworthiness Authority shall follow when exercising its tasks and responsibilities regarding issuance, continuation, change, suspension or revocation of maintenance organization approvals in accordance with the requirements of EMAR 145. According to EMAR 145 requirement [8], the organization shall appoint an Accountable Manager who has corporate authority for ensuring that all maintenance can be carried out to the standard required by EMAR 145. The Accountable Manager shall appoint a person with responsibility for monitoring the quality system, including the associated Feedback System, and other personnel. In order to ensure the achievement of certain operations of maintenance, such as the maintenance and operations of laying and removal of armaments, the organization must have sufficient staff possessing the class B mil or national equivalent qualification. The organization shall have a maintenance man-hour plan showing that the organization has sufficient staff to plan, perform, supervise, inspect and quality monitor the organization in accordance with the approval. In addition the organization shall have a procedure to reassess work
intended to be carried out when actual staff availability is less than the planned staffing level for any particular work shift or period. The organization shall establish and control the competence of personnel involved in any maintenance, management and/or quality audits in accordance with a procedure and to a standard defined through the Maintenance Organization Exposition and approved by the NMAA. Organization maintaining aircraft, shall in the case of aircraft line maintenance, have appropriate aircraft type rated certifying staff, qualified as category B1, B2 and B mil or national equivalent qualification in accordance with EMAR 66 and EMAR 145.A.35. In the case of base maintenance of aircraft, organization shall have appropriate aircraft type rated certifying staff qualified as category C or national equivalent qualification in accordance with EMAR 66 or equivalent and EMAR 145.A.35. Additionally, organization shall ensure that certifying and category B1, B2 and B mil support staffs have an adequate understanding of the relevant aircraft and/or components to be maintained together with the associated organization procedures. In the case of certifying staff, this must be accomplished before the issue or re-issue of the certification authorization. The organization shall maintain records of all certifying staff and support staff containing details of any aircraft maintenance licence held under EMAR 66 or national equivalent requirement, all relevant training completed, the scope of the certification authorizations issued (where relevant) and particulars of staff with limited or one-off certification authorizations. The organization shall retain the record for at least three years after the certifying staff or B1, B2 or B mil or national equivalent qualification or support staffs have ceased employment with the organization or as soon as the authorization has been withdrawn. EMAR 145 also defines a set of requirements related to equipment, tools, material, facilities, workshops, production of spare parts, and certification of maintenance. EMAR 21 The requirement EMAR 21 is organized in two sections with the subparts and paragraphs numeration corresponding to Implementing Rules Part 21 annex to EC regulation 1702/2003 regarding certification of aircraft and related products, parts and appliances, and of design and production organizations. According to EMAR 21 requirement [9], Section A establishes general provisions governing the obligations and privileges of the applicant for, and holder of, any certificate issued or to be issued in accordance with EMAR 21. Section B establishes the procedures for the Authorities when exercising their tasks and responsibilities concerned with the issuance, maintenance, amendment, suspension and revocation of certificates, approvals and authorizations referred to in this EMAR. This requirement enforces collaboration between the design organization and the production organization as
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necessary to achieve the proper support of the continued airworthiness of the product, part or appliance and also to achieve the satisfactory coordination of design and production. Further, it establishes the procedure for issuing Type-Certificates (TCs) for products and Restricted Type-Certificates (RTCs) for aircraft, and establishes the rights and obligations of the applicants for, and holders of, those certificates. EMAR 21 establishes the procedure for the approval of changes to type designs and type-certificates, and establishes the obligations and privileges of the applicants for, and holders of, those approvals. The procedure for the issuance of a military production organization approval (MPOA) is established. Also, procedure for the approval of major changes to the type design under supplemental type-certificate procedures is defined, and the obligations and privileges of the applicants for, and holders of, those certificates are established. This EMAR makes a distinction between continued and continuing airworthiness. In this document, the term ,,continued (design) airworthiness" means all tasks to be carried out to verify that the conditions under which a type-certificate or a supplemental type-certificate has been granted continue to be fulfilled at any time during its period of validity (Type Design). Term ,,continuing (preservation of) airworthiness" means all of the processes ensuring that, at any time in its operating life, the aircraft complies with the airworthiness requirements in force and is in a condition for safe operation (Maintenance). Permits to fly shall also be issued in accordance with the EMAR 21 to aircraft that do not meet, or have not been shown to meet, applicable airworthiness requirements but are capable of safe flight under defined conditions. EMAR 147 Requirements that must be met by the Maintenance Training Organizations (MTO) seeking approval to conduct training and examination are specified in EMAR 147. This EMAR, in a kind of introduction, stressed that the Task Force 3 has tried to maintain a clear link to the principles of EASA Part 147 (amendment M5), making changes where necessary for use within a military airworthiness context. Also, this document notes that EMAR 147 cannot be adopted/implemented in isolation from EMAR 66 (which is currently being developed by Task Force 3) or by a pMS that does not have a national Military Licensing Scheme for their maintenance personnel. It is pointed out that current form of EMAR 147 Edition 1.0 provides a framework within which pMS can work towards adopting/implementing the harmonized Requirements for Aircraft Maintenance Training Organizations [10]. This requirement contains two sections. Section A establishes the requirements to be met by organizations seeking approval to conduct training and examination as specified in EMAR 66. Special attention in this Section is paid to requirements related to facilities, personnel, and records of all instructors, knowledge examiners and
practical assessors. Also, training procedures and quality system are considered. Section B establishes the administrative procedures which the NMAA shall follow when exercising its tasks and responsibilities regarding issuance, continuation, change, suspension or revocation of MTO approvals in accordance with the requirements of EMAR 147. 4. REGULATION OF MILITARY AIRWORTHINESS In the United Kingdom, as a part of the Ministry of Defence (MOD), the Military Aviation Authority (MAA) was established in 2010. The MAA is an independent and autonomous organization responsible for the regulation, surveillance, inspection and assurance of the Defence Air operating and technical domains. It ensures the safe design and use of military air systems. As the single regulatory authority responsible for regulating all aspects of Air Safety across Defence, the MAA has full oversight of all Defence aviation activity. The MAA was established in response to the recommendations made by Mr Justice Haddon-Cave in his Nimrod Review, which called for a radical overhaul of military airworthiness regulation. The Nimrod Review is an independent review into the broader issues surrounding the loss of the RAF Nimrod MR2 Aircraft XV230 in Afghanistan in 2006, killing 14 military personnel in Britain's biggest single loss since the Falklands War. Mr Haddon-Cave condemned the change of organisational culture within the MoD between 1998 and 2006, when financial targets came to distract from safety. As well as attributing blame over the safety case, the review also strongly criticises a wider culture around safety and risk in defence that was created by politicians and senior commanders. He said that the Afghanistan crash occurred because of a ,,systemic breach" of the military covenant. In March 2009 in response to the Review, the Ministry of Defence admitted responsibility for the deaths of 14 servicemen aboard Nimrod aircraft XV230. Now, the MAA is taking a more active role in the MAWA Forum [11]. In France, Decree N° 2006 ­ 1551 was released on December 07, 2006, and it integrates and adapts to the French State aircraft (military or used by the State) the principles of airworthiness, regulations and authorities introduced by the Chicago convention. This decree was superseded by Decree N° 2013-367 of April 29, 2013 which regulates the same topic. Following the release of this Decree, the French Ministry of Defense had begun drafting standards for the State aircrafts. Basing on the appropriate EASA documents, in order to apply best practices in terms of air safety, the Ministry of Defence has developed specific regulations for State aircrafts. There are five FRAs (France): FRA 21 is related to design and manufacturing, FRA 145 is related to maintenance organizations, FRA M is related to airworthiness issues, FRA 66 is related to individual Aircraft Mechanics licensing and FRA 147 is related to Maintenance Training Organizations. The purpose of these regulations is to make a controlled environment for the State aircrafts, recognized by other European organizations, such as EASA and EDA.
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The French Aviation Safety Agency was created in 2010 to oversee the safety of the French government (Air Force, Army, Navy, DGA, Gendarmerie, Civil Security and Customs) for three Ministries (Defense, Interior and Budget), which represents in a total a fleet of 1,600 airplanes and helicopters. In October 2012, UK and France signed an agreement to launch a mutual recognition process around continuing airworthiness based on the draft of EMAD-R, which was approved in the meantime by MAWA Forum [12]. In February 2014, The Federal Ministry of Defence of Germany formed the Military Aviation Authority (Luftfahrtamt der Bundeswehr) tasked to concern itself with all aviation affairs of the German Armed Forces. This body will oversight over all military aviation assets, the certification of civil contractors and military personnel as well as setting rules and writing manuals for all military aviation procedures. The first staff element started to work in April 2014. Complete operational capability for the Military Aviation Authority was expected until the end of 2017 [13]. The Serbian Ministry of Defence and EDA signed an Administrative Arrangement in December 2013. This arrangement enables Serbia to participate in EDA's projects and programmes. EDA has previously signed an Administrative Arrangement with Norway (in 2006) and Switzerland (2012). This enables these countries to participate in EDA's projects and programmes. Representatives of these countries can participate in the EDA Steering Boards as observers. 5. CONCLUSION Recent common European dual-use aircrafts projects forced EDA's participating Member Countries to establish National Military Airworthiness Authorities, with similiar tasks like civil aviation Authorities. This leaded to close cooperation between military and civil authorities. Good example of cooperation is A400M aircraft which required more than 5,000 flight-hours test and certification programme to meet both civil and military airworthiness standards before the initial delivery, which was received by the French Air Force in August 2013 [14]. An agreement signed in June 2013, between EDA and EASA, enhancing their civil-military cooperation in the harmonization of military aviation safety requirements and airworthiness in areas of ,,dual use" aircraft and the Remotely Piloted Aircraft Systems (RPAS) can be viewed as a confirmation of this conclusion. Also, three approved EMARs are similiar to related EASA documents. Aircraft airworthiness must be considered as a coherent process running from the design of the aircraft to the monitoring of its technical condition in airline service. It should be noted that, in Europe, there is a tendency to harmonize requirements related to the military airworthiness. This harmonization can be viewed as a process with duration similar to the extension of EASA competences during the last decade. Experiences that many European countries have in the area of military airworthiness obtrude a need for the Serbian Ministry of Defence to review the existing
system of aircraft spare parts production, military aircraft maintenance and training of military personnel in accordance with adopted harmonized requirements. After a comprehensive analysis, it should start with implementation of EMARs in order to comply with the military aviation standards that have been adopted in other European countries. All this will result in an increase of safety and compatibility of military aircraft. REFERENCES [1] European Defence Agency, MAWA Forum, European Military Airworthiness Document ­ EMAD 1 ­ Definition and acronyms document, Ed. 1.1., 2013. [2] MAWA Forum, Frequently Asked Questions (FAQs), Ed. 1.0., 2011. [3] http://easa.europa.eu/system/files/dfu/2013-0618%20 Press%20release_EDA%20EASA%20cooperation% 20agreement_final.pdf, retrieved May 13, 2014. [4] https://www.easa.europa.eu/document-library/ acceptable-means-compliance-amcs-and-alternativemeans-compliance-altmocs, retrieved May 11, 2014. [5] "Europe - RP Defense", available from: http://rpdefense.over-blog.com/tag/Europe/108, retrieved April 16, 2014. [6] "Aйronautique - RP Defense", available from: http://rpdefense.over-blog.com/tag/Aйronautique/33, retrieved April 16, 2014. [7] "EDA simplifies military air transport clearances", available from: http://www.spa.gov.sa/english/print. php?id=1117241, retrieved May 13, 2014. [8] European Military Airworthiness Requirements (EMAR) ­ EMAR 145 ­ Requirements for Maintenance Organisations. European Defence Agency (EDA). Military Airworthiness Authorities (MAWA) Forum. Ed. 1.1. 25/09/2012. [9] European Military Airworthiness Requirements (EMAR) ­ EMAR 21 ­ Certification of military aircrafts and related products, parts and appliances, and design and product organisations. European Defence Agency (EDA). Military Airworthiness Authorities (MAWA) Forum. Ed. 1.0. 23/01/2013. [10] European Military Airworthiness Requirements (EMAR) ­ EMAR 147 ­ Requirements for Maintenance Training Organisations. European Defence Agency (EDA). Military Airworthiness Authorities (MAWA) Forum. Ed. 1.0. 14/06/2012. [11] The Nimrod Review: an independent review into the broader issues surrounding the loss of the RAF Nimrod MR2 aircraft XV230 in Afghanistan in 2006. [12] report, available at https://www.gov.uk/government/ uploads/system/uploads/attachment_data/file/229037 /1025.pdf, retrieved May 13, 2014. [13] http://rpdefense.over-blog.com/tag/Airworthiness/, retrieved June 2, 2014. [14] http://www.bmvg.de, retrieved June 2, 2014. [15] http://www.airbus.com/aircraftfamilies/militaryaircraft/a400m/, retrieved June 2, 2014.
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M JANKOVIĆ, Z ILIĆ, M DRONJAK, V PAREZANOVIĆ

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