UK MAA Issue RA 5800 Series Type Airworthiness Engineering Regulations
The UK Military Aviation Authority (MAA) have issued a package of Notice of Approved Amendments (NAAs) to change their design regulations to integrate European Defence Agency (EDA) EMAR 21 (the European Military Airworthiness Requirement Part 21) concepts into the MAA Regulatory Publications (MRP).
Summary of Changes
- NAA 16/20: The 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 16/21: Required 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 16/22: The 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- NAA 16/23: RA 1500 has been withdrawn as content has been incorporated in RA 5810 (Military Type Certificate [MTC] MRP 21 Subpart B) and RA 5820 (Changes in Type Design: MRP 21 Subpart D).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 changes introduce concepts such as design organisation privileges, a changed product rule concept and revised oversight and assurance levels for different type of modification. The UK has however decided that the Military Type Certificate Holder (MTCH) shall be the air system Type Airworthiness Authority (TAA) within DE&S.
RA 5800 Series Implementation
The NAAs are accompanied by a Regulatory Notice, MAA/RN/2016/08, that describes implementation timescales. 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.
When the MRPs were first issued in 2011, the design regulations were 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.
An EDA funded study (conducted by Eurocopter, now Airbus Helicopters) estimated that the adoption of the EMARS would deliver a reduction of up to 50% of the development time and at least 10% of development costs up to initial-type certification. Significant further cost savings could also be achieved during the in-service phase.
Following preparations that began in April 2013 (involving the MAA, ADS and DE&S Airworthiness Team [DAT]), two rounds on Notice of Proposed Amendment were issued in 2015 and 2016 (described in updates to our original 2014 feature article on the project).
UPDATE 10 October 2016: EDA holds Annual Military Airworthiness Conference in Lisbon. EDA Chief Executive Jorge Domecq said Member States should aim for:
- a single certification approach for multinational programmes, which would result in less development costs and optimised use of certification resources;
- the development and application of common agreed industrial standards which would strengthen the position of the European defence industry in the global market;
- optimised pooling and sharing of spare parts and maintenance resources within a single regulatory and oversight system (of key interest in relation to civil-derivative aircraft, but also with regard to military platforms such as A400M, Eurofighter, NH90 and others);
- optimised use of oversight resources by collaboration in oversight obligations;
- minimised gaps or differences between national regulatory and oversight systems, which would in turn minimise safety risks in multinational materiel cooperation programmes.
However, “a real common approach can only be established if EMARs are also implemented in a uniform way, which is a national responsibility of the Member States”, he stressed.
UPDATE 1 March 2017: ADS are hosting a seminar with the MAA in Bristol on 23 March 2017 on the changes.
UPDATE 10 May 2017: The MAA published a Type Airworthiness Engineering (TAE) RA 5000 series compliance check list