UK MAA to Integrate EMAR-21 into MRPs

UK MAA to Integrate EMAR-21 into MRPs (Updated: RA 5800 Series Issued August 2016)

The UK Military Aviation Authority (MAA) have issued a Regulatory Notice outlining its plans to integrate EMAR-21 (the European Military Airworthiness Requirement Part 21) into the MAA Regulatory Publications (MRP) Design and Modification Engineering (DME) 5000 series.

When the MRPs were first issued in 2011, the 5000 series was mostly derived from Defence Standard (DEFSTAN) 05-123.

However since 2008 the European Defence Agency (EDA) had been sponsoring the development of a European military requirements broadly equivalent to the civil European Aviation Safety Agency (EASA) Part 21 regulations.   The UK (both MAA and industry) has been actively engaged in this activity which is seen as having great benefit for future defence procurement projects and should allow design organisations working on both civil and military projects to have more common procedures.

EDA is not a rulemaking body like EASA, so the EMARs are not regulations but are simply harmonised requirements. It is the responsibility of each EDA Member State to implement these requirements into their own national military airworthiness regulations.

Following preparations that have been underway since April 2013 (involving the MAA, ADS and DE&S Airworthiness Team [DAT]), the MAA have decided to introduce a 5800 series to incorporate EMAR-21, though some existing Regulatory Articles will be retained where they cover material beyond the scope of EMAR-21.  An important and welcome development is the planned formal introduction of privileges for design organisations.  A programme of briefings is planned, acknowledging that this will be a major change from the DEFSTAN 05-123 based approach. An MAA Notice of Proposed Amendment (NPA) process, in the first quarter of 2015 after the EDA’s Member States have approved the EMAR-21 AMC this autumn.

UPDATE 1: The MAA have now issued this NPA on “RA 3100 / 4820 / 4954 / 5101 – Standardization of MAA Approval Policy and Recognition of EASA Part 21 Subpart J Approval”.

UPDATE 2: The MAA have also issued a Regulatory Instruction on Invoking Specific Privileges

UPDATE 3: MAA/NPA/15/12 was issued on 4 June 2015.  As part of the NPA, the MAA has proposed the UK Military Type Certificate Holder (MTCH) shall be the air system Type Airworthiness Authority (TAA) within DE&S.

UPDATE 4: There was a further, smaller, second round of of consultation with NPA 16/06 issued on 15 March 2016 on RAs 5212, RA 5219, RA 5401, RA 5502 and RA 5820.

UPDATE 5: On 25 August 2016, almost exactly two years after we first discussed this topic online, the MAA issue the following package of Notice of Approved Amendments (NAAs):

  • NAA 16/20The Design Modification Engineering (DME) RA 5000 Series has undergone a major review, a significant part of which has been to develop the new RA 5800 series based on EMAR 21 Subparts. The RA 5000 Series is henceforth retitled as the Type Airworthiness Engineering (TAE) RA 5000 Series. Note that the RA 5600 and RA 5700 series have not been subject to this review.
  • NAA 16/21Required to amend RA 5002 and the 5600 and 5700 sub-series to reflect the change in title of the main 5000 series… There are also amendments to cross-references to reflect the re-brigading of the main 5000 series RAs. No changes have been made to the technical content of any of the subject RAs.
  • NAA 16/22The whole RA has been amended to reflect the improved definition of the responsibilities of the Design Organization (DO) and Co-ordinating Design Organization (CDO), and to introduce and define the new Air System CDO role.
  • NAA 16/23RA 1500 has been withdrawn as content has been incorporated in RA 5810 (Military Type Certificate [MTC] MRP 21 Subpart B) and RA 5820 (Changes in Type Design: MRP 21 Subpart D).

The NAAs are accompanied by a Regulatory Notice, MAA/RN/2016/08, that describes implementation time scales.  Current Design Approved Organization Scheme (DAOS) approval holders need to submit a Design Organization Exposition (DOE) revision:

  • Three months ahead of the next planned audit, where the audit is scheduled to occur after 31 March 2017.
  • Otherwise by 31 December 2017.

UPDATE 6: On 10 May 2017 the MAA published a Type Airworthiness Engineering (TAE) RA 5000 series compliance check list

Aerossurance are aviation consultants with extensive experience with UK and European, civil and military airworthiness regulation, including the UK MRPs.  This includes direct experience with the UK military type certification of several air systems and gaining/maintaining MAA organisational approvals. 

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