The French Military Airworthiness System Lt-Col Richard Duriez - State Aviation Safety Authority
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Transcript of 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
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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
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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
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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
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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
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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
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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
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DGA Technical AuthorityProgramme managersSQ (Quality Service)
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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
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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
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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
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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
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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 »
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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
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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
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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
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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
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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)
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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?