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
•
STATE AVIATION DOES NOT HAVE TO COMPLY WITH CIVIL REGULATIONS
•
STATES UNDERTAKE TO HAVE DUE REGARD FOR CIVIL AIRCRAFT SAFETY
ICAO*
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. »
Chicago Convention
(1944)
EASA*
•ART 1 – Scope of application
EC 216/2008
FR military airworthiness system
•« 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 »
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2
First airworthiness regulation and organisation
Interdepartmental level
Order
« Duties »
Decree 2006-1551
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
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First airworthiness organisation
Military aviation
Former
situation
Present
situation
Civil aviation
Current situation
Technical authority
Continuing
airworthiness
authorities
State Aviation Safety Authority
7 AOAs
End users
(incl. CAMO)
Operators
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
FR military airworthiness system
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DSAÉ : a political decision
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)
FR military airworthiness system
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DSAÉ : a political decision
Military aviation
Former
situation
Present
situation
Civil aviation
Current situation
Technical authority
Continuing
airworthiness
authorities
State Aviation Safety Authority
7 AOAs
End users
(incl. CAMO)
Operators
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
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Civil vs military : who does what ?
Civil stakeholders
Rulemaking and executive
functions
European Commission
Military stakeholders
• Establishes the essential
requirements
EASA
•
•
•
•
Technical Authority
Conduct Type certification
Approve flight test conditions
Ensure Continued airworthiness
Approves Design organisations
Aviation Safety Authority
• Establish the rules for continuing
airworthiness
National authorities
• 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
• Approves organisations (maintenance,
continuing airworthiness management, training)
Aviation Safety Authority
• Issues maintenance personnel licences
• Issues Individual CoAs
• Registration of aircraft in service
Operators
• Apply the rules
• Manages Continuing airworthiness
End Users / CAMOs
• Can grant exemptions for urgent
operational needs
• Issue permit to fly
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DSAÉ governance structure
Minister of the Interior
Minister of Budget and
Finance
Minister of Defence
Executive Committee
DGA
SGA
Chaired by
Chief of Defence
Defence Staff
Functional
DSAÉ
authority
DGA Technical Authority
Industry Design Organisations
= Type Certificate Holder
Initial certification
Continued airworthiness
FR military airworthiness system
Defence Staff responsibility
DGA
MoI
MoB&F
Each Air Operating Authority (CGS, CNS, CAS, Director)
appoints one Accountable Manager for each domain
AM
FRA M
AM
FRA 145
AM
FRA 147
Continuing airworthiness
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SQ (Quality Service)
Programme managers
FR military airworthiness system
DGA Technical Authority
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DGA organisation for airworthiness decisions
Deputy : C. GAUTIE
Project Manager 2
…..
Project Manager n
Airworthiness cell:
expertise R.CORNEN (GR ASA)
Th LOUDES
Technical manager for propulsion expertise
R. HEILIGENSTEIN RM PRA
About ASA 130 specialists
Project axis : DO
Management unit x
Specialists for airframes
and aircraft systems
Project Manager 1
Technical manager for air systems
Technical manager for airframes & aircraft systems expertise
O DUGAST RM PSA
Technical authority axis: DT
DGA Aeronautical
Systems (airdrop, fast
roping, airlift, airframe
structure and systems)
Technical director for aircraft:
P. HADOU RP.ASA
Experts propulsion
Director of DGA Flight testing
(permit to fly for test bed aircraft)
People authorized to sign airworthiness decisions
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DSAE PILARS & MISSIONS
Central DSAÉ : 106
Outpost DSAÉ : 130
Total DSAÉ
: 236
CONTINUING
AIRWORTHINESS
INITIAL
CERTIFICATION
(TC)
CONTINUED
AIRWORTHINESS
TRAINING
&
OPERATIONS
ATM/ASM
AIRPORTS
CNS
MISSIONS:
MISSIONS:
MISSIONS:
REGULATION
CERTIFICATION
REGULATION
AIRSPACE MGT
CERTIFICATION
REGULATION
MONITIRING
HARMONISATION
SEVEN AVIATION OPERATING AUTHORITIES (AOA)
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Airworthiness directorate organisation
Airworthiness Director
Secretariat
Airworthiness Oversight
Department
Rulemaking Department
Rulemaking
Division
UCN air n° 1 – Villacoublay
UCN air n° 2 – Saint-Dizier
UCN air n° 3 – Nancy
Reference Manuals
& Guides
Division
Management
Division
Organisations
Oversight Division
Initial Airworthiness
Advisor
Aircraft
Oversight
Division
Production Planning Section
Training & Licences
Section
Registration
Section
Skill Management & System Tools
Section
Technical Assessment
Section
Certificates of Airworthiness &
Approved Maintenance Plans
Section
UCN marine n° 1 – LannBihoué
UCN marine n° 2 –
Landivisiau
UCN Terre
UCN Gendarmerie
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
UCN air n° 7 – Mont-deMarsan
UCN air n° 8 – Cazaux
= AOU : Airworthiness Oversight Unit
DSAÉ
Villacoublay
UCN air n° 9 – Tours
Outposts
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Airworthiness oversight units locations
UCN : Unité de contrôle de la navigabilité
= AOU : Airworthiness Oversight Unit
UCN-marine Landivisiau
UCN-air Villacoublay
UCN-gendarmerie
Villacoublay
UCN-terre
Villacoublay
UCN-air Saint-Dizier
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
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French airworthiness regulation structure
Interdepartmental level
Order
« Duties »
Authorities level
Decree 2006-1551 superseded by decree 2013-367
Order
« Conditions »
Order
« Registration »
Order
« Continuing airworthiness »
Order
« UAS »
documents : - applicable to State organisations and personnel
- applicable to industry through contracts
Instruction
« Initial airworthiness »
Instruction
« Report of
technical occurrences »
- Essential airworthiness requirements
- Regulations considered as acceptable
means of compliance
- FRA 21
- FRA Forms
Instruction
« Civil ADs and TCH
technical directives »
DGA Technical Authority
Instruction
« Stores and equipment
excluded from continuing
airworthiness »
Instruction
« Continuing airworthiness »
- FRA M
- FRA 145
- FRA 147
- FRA 66
- FRA Forms
- EMAR(FR) M (provision)
- EMAR(FR) 145
- EMAR(FR) 147
- EMAR(FR) 66 (provision)
- EMAR Forms
DSAÉ State Aviation Safety Authority
AMC & GM for all FRA
Internal documents
Mementos and procedures
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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
FR military airworthiness system
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The Airworthiness Controlled Environment
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
FR military airworthiness system
Technicians are trained in
FRA-147 approved
Maintenance Training
Organisation (MTO)
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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
FR military airworthiness system
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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)
FR military airworthiness system
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Ambitious implementation schedule
with 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
OK
TCs
CoAs
D
G
A
Legacy aircraft TCs
2007
CAMOs, MTOs
Operational MOs
2008
New aircraft TCs
100% TCs (Sustainable fleets)
2009
2009
Late 2009
2010
2011
2012
2013
100% CoAs (Sustainable fleets)
2014
Late 2014
D
S
A
É
2011
2012
2013
100% FRA M, FRA 147
2014
Late 2014
Industrial MOs
100% FRA 145 (Ops)
2011
2012
2013
2014
2015
2016
2011
2012
2013
2014
2015
2016
2016
100% FRA 145 (Industry)
2016
POs (*)
D
G
A
2011
2012
2013
2014
2015
2016
FRA 21 G
2016
Controlled environment : Late 2016
(*) FRA 21 J Design : no real timeframe constraint as, in the absence of DOA,
any airworthiness approval is done by DGA Technical Authority
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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 type level (applicable configuration)
Individual aircraft level
(applied configuration)
aircraft TC
TCDS
Baseline
Engine TC
Airworthiness review
TCDS
STC 1
STCDS 1
Supplementary information
clarifying the past
Airworthiness
reference data
sheet
STC 2
STCDS 2
Frozen approved
configuration
FR military airworthiness system
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?
….
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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
FR military airworthiness system
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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
FR military airworthiness system
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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
FR military airworthiness system
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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
FRA 66
EMAR 66
Part 66
AE1 & BE1.1 : aeroplanes turbine
basic operations
AE
A
A
AE2 & BE1.2 : aeroplanes piston
complex
operations on
airframe/engine,
avionic, armament
systems
BE1
B1
B1
AE3 & BE1.3 : helicopters turbine
BE2
B2
B2
BEArm.1 : armament on aeroplanes
whole aircraft
CE
BEArm.3 : armament on helicopters
BEArm
FR military airworthiness system
C
C
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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
FR military airworthiness system
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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
FR military airworthiness system
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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
FR military airworthiness system
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Thank you for your attention! Any questions?
FR military airworthiness system
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