EMAR Implementation; a non-eda member states view. Wing Commander Jason Dean Directorate General Technical Airworthiness Australian Defence Force

Transcription

1 EMAR Implementation; a non-eda member states view Wing Commander Jason Dean Directorate General Technical Airworthiness Australian Defence Force Military Airworthiness Conference Oct 2015

2 Scope Why would a non-eda member state be interested in EMAR? Challenges with EMAR Implementation Australian Context and EMAR Implementation Additional EMAR challenges for a non-eda member state

3 Why would any Military implement new Regulation? Hardest sell for non-eda member state is what s in it for us? Why would a non-eda member state allocate resources on the implementation of EMAR?

4 What is Good Aviation Regulation? Published a book identifying what makes good Aviation Regulation regulation: 10 Ways to Better Aviation Regulation

5 Why EMAR? - What else is out there? Civil International Civil Aviation Authority Military International Common Military Regulations/Policy For Air, Land and Sea Materiel

6 What are the challenges of EMAR implementation? Convincing senior military leaders to implement a European Military Aviation Regulatory Framework i.e. EMAR for a non-eda Member State Very little information exists on the quantitative benefits (time/cost) of EMAR High level compelling reasons as to why a non-eda member state may want to implement EMAR need to be established (context dependent)

7 Australian Context Australian Defence Aviation Safety Regulations Legislation and Policy (Defence Act 1903 and DI(G) OPS 2-2) Military Aviation Regulations (AAP ) Technical Aviation Safety Regulations* (established mid 1990s) Operational Aviation Safety Regulations (established late 1990s) * Organisational approvals for Engineering and Maintenance Unique Terms, Definitions, Artefacts, etc

8 Australian EMAR Implementation decision Evaluation of EMAR benefits and the merit of a new aviation framework Compared existing Australian Technical Aviation Regulations to EMAR and vice versa EMAR broadly satisfied safety assurance outcomes Australian shortfalls existed in MTC management aspects, Continuing Airworthiness (elements of), Production (robustness of) Compared existing Australian Operational Aviation Safety Regulations to ICAO based regulation sets i.e. FAA, EASA, Australian Civil Aviation Safety Authority, etc Developed Business Case EMAR is the emerging military global convention Senior Defence engagement Senior Bureaucrats, Australian Chief of Air Force (3 star) Conclusion New Australian Defence Aviation Safety Regulation (DASR) is warranted Model off EASA framework Will include Technical Aviation Regulations from EMAR (adopt/adapt) and remainder of EASA structure

9 EMAR implementation options Australian EMAR implementation to be titled Defence Aviation Safety Regulation (DASR) EMAR Part 21: Adopt and titled DASR 21 EMAR Part M: Adopt and titled DASR M EMAR Part 145 : Adopt and titled DASR 145 EMAR 66*: Adapt and titled DASR 66 EMAR Part 147*: Adapt and titled DASR 147 Adopt = only essential Australian Defence changes where absolutely necessary to EMAR Section A requirements. Will look and read extremely similar to EMAR. Adapt = tailor EMAR within the context of existing Australian Defence Aviation. * Delayed implementation of EMAR. Interim approach: to use national equivalency for maintenance licensing

10 Australian Implementation Schedule Jan 16 : Draft DASR released Community consultation (NPA/NPRM) Late 16 : New DASR promulgated Dec 18 : Existing Australian Defence Aviation Safety Regulations no longer supported Note: Regulated community converts from existing Technical Regulations to DASR from Jan 16

11 Example of future Australian Defence Aviation Safety Regulation (DASR) DASR modelled off EASA framework Implementing Regulations (IR) Basic Regulation Initial Airworthiness Continuing Airworthiness Air Crew Air Operations Air Navigation Systems (ANS) Rules of the Air (RoA) Aerodromes Aviation SMS Part 21 (Adopt from EMAR) Unmanned Aircraft System Part M Continuing Aw Requirements (Adopt from EMAR) Part 145 Requirements for Maintenance Organisations (Adopt from EMAR) Part 66 Military Aircraft Maintenance Licensing (Adapt from EMAR) FCL MED CC ARA ORA ARO ORO CAT NCC NCO SPO UAS Gen ATS Nav Aids Air Space MET AIS ABM TAC Gen RoA Gen ADR ARFF SAF SMS Regs Part 147 Aircraft Maintenance Training Organisations (Adapt from EMAR) FTE AWR Engineering Maint

12 EMAR/DASR smart user interface Regulations developed and published using Commercial Off The Shelf software - AuthorIT Regulatory Development and Publishing Tool in one One tool for entire framework Easy to use for both developers and users EMAR Version control can import from pdf/word docs Unique tracking of additions Access control multi concurrent access (internet hosted) Output display easily adjusted/changed/formatted, etc S1000D compliant International specification for the procurement and production of technical publications Demonstration of smart user interface [a demonstration will be conducted during the presentation]

13 EMAR implementation challenges non-eda member State Additional implementation challenges for non-eda member states Military non-familiarity with EASA framework Industry non-familiarity with EASA framework Lack of understanding of the rationale of EMAR development Militarisation of EASA Regulation, AMC and GM Training and Education Likely to be limited (if any) experience training providers within a non- EDA member state Training/education may have to outsource (from EU?) Australia contracted a training provider from EU Subject Matter Experts (SMEs) initially difficult to develop Australian SME development difficulties (slow ramp up) Cultural differences between non-european and European Nations Adoption of European requirements i.e. EMARS Is there a case here for International Military Airworthiness Requirements IMARS?

14 Conclusion EMAR is the emerging military global convention for military aviation safety regulation EMAR can be implemented by a non-eda member state Non-EDA member states face additional challenges Australian Defence culture is well positioned for EMAR Implementation Australia will implement EMAR based regulations (DASR) commencing 2016 More Information. Further EMAR/DASR information and Australian points of contacts can be found at: [then select EMAR Implementation ]

15 EMAR implementation; a non-eda member states view Questions?