AirworthinessBrief N0042121R0077 Industry Day.pdf

Presented to:

Presented by:

CAS Aircraft Airworthiness

N00421-21-R-0077 Industry Day

Sorin Grigoriciuc

18 May 2021

Charlotte, NC

CAS Class Desk

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What is a NAVAIR IFC?

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• A formal document that provides assurance of airworthiness & safety of flight and ensures risk has been identified, mitigated and/or accepted at the appropriate level, within acceptable bounds for the intended mission

• Flight clearances provide flight / operating limitations and/or restrictions for specific configurations and store loadings.

– Does not account for every applicable limit or restriction

– Does not replace good headwork or common sense by the pilot / aircrew

Flight Plan

• How do I get a Navy Flight Clearance?

– Contract

– PAO Assessment / Determination

– Physical Configuration Audit

– Interim Flight Clearance

• Flight Clearance Data Requirements

• Wiring Assessment

• EMC SOFT and RADHAZ testing

• Continuing Airworthiness

• Takeaway

• References

• Questions

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How do I get a NAVY Flight Clearance?

NOTE: Activities such as Adversary fighter or Air-to-Air

Refueling (AAR) are considered PUBLIC operations as they are outside of the purview of the FAA.

• Five primary elements of the USN Flight Clearance

Process:

– Contract

– Public Aircraft Operations (PAO) Assessment/Determination and

Declaration

– Physical Configuration Audit (PCA)

– Interim Flight Clearance (IFC)

– Continuing Airworthiness (AW)

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Contract

• Contains but not limited to the following:

– Service being provided

– Who’s in the binding agreement with the government

– How Continuing Airworthiness oversight is being provided

– Liability/Indemnity

– Government Furnished Equipment (GFE) list

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PAO Assessment / Determination (1 of 3)

• Public aircraft flights or flights of civil aircraft conducted for a public entity where:

- Flight(s) cannot be conducted fully within 14 CFR

- Public Entity becomes Airworthiness Authority

• Examples of PAO missions:

– Mission is outside of FAA approved Operating Limits

(e.g. Adversary Fighter or AAR)

– Mission is in support of an inherently military requirement (e.g. Transport of Explosives, Dropping of Ordnance, Launching Targets, Electronic Attack

(EA) / Electronic Warfare (EW), etc.)

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40102(a) – Legislative definition of Civil and Public

40125 – Legislative qualifications for Public aircraft status

PAO Assessment / Determination (2 of 3)

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• For CAO

– It is the civil operator’s responsibility to operate their aircraft in accordance with 14 CFR

– If operations are required outside of 14 CFR, the contractor should refuse to operate and notify the requesting agency to provide a

PAO declaration

• For PAO

– Determination on a flight by flight basis

– NAVAIR IFC is required for any DON PAO

– Details regarding contracted configuration, mission, usage and pre-existing FAA certificates can make PAO determinations complicated

PAO Assessment / Determination (3 of 3)

• PMA-226, Airworthiness and CYBERSAFE Office (ACO), NAVAIR Aircraft Controlling Custodian Office (ACCO)

– Responsible for PAO Assessment and Determination

• PAO Assessment

– Used to determine if the contracted operation with its mission specific equipment is civil or public

– Uses U.S. Armed Forces PAO decision tool

– Input includes but not limited to the following:

• Detailed Mission Description

• Contract

• Contract Data Requirements List (CDRL)

• FAA Airworthiness Certificates and Operating Limits

• FAA Major Repair and Alteration, Form 337s

• FAA Statement of Compliance with AW Standards, Form 8110-3s

• Documentation for Unapproved Installations (Installations that do not have FAA approval documents or are not approved by the FAA)

• Carry-on Equipment

• Persons on board

• Program Letter for Special Experimental or Restricted Certificates

• Insurance Documentation

• PAO Declaration Letter provided by PMA-226 to Owner/Operator

• Owner/Operator provides declaration to FAA, as required by FAA

8DISTRIBUTION A. Approved for public release: distribution unlimited.

Physical Configuration Audit (PCA)

• PMA-226

• To establish existing aircraft pedigree

• Conducted on-site

• Formal Examination of the as-maintained configuration

(e.g. PAO Airworthiness Checklist) to identify non-conformances, if any

• Examination of aircraft as configured for PAO

• Various types of audits: Engineering drawings, specifications, technical data and tests, Quality

Assurance, processes and procedures and others as necessary, to determine existing aircraft pedigree for the intended mission

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Continuous Maintenance Record Coverage Critical to Support Pedigree / Airworthiness

Interim Flight Clearance (1 of 3)

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ACO/ PMA-226 PAO

Assessment determines

• Civil Operation

• Civil aircraft with civil certificate covering all aspects of intended operation & configuration

• Does not meet USC Title 49 for Public Mission aircraft

• Operation does not qualify as

Public Operation with PAO tool

• Complies with FAA /ACO agreement

• Example: Raytheon 727

• Type 2

• Public Operation

•Insufficient data available to completely assess

AW.

•Qualitative risk assessments are documented and accepted.

•Generally include operating limitations to ensure safety to people, property and environment.

Operating restrictions often due to lack of data.

•Previous AW certificates, aircraft maintenance pedigree, intended usage, etc., •Safe for Flight conducted.

•Contract checked for GFR oversight of maintenance, safety, and ops.

•Example: FAA experimentally certified aircraft, or former foreign military aircraft, with gaps in the aircraft pedigree, and/or configuration changes which cannot be fully evaluated due to the lack of aircraft data.

Non-Navy Owned

Contracted

Non-Navy Owned

Contracted

Type 1

Public Operation

• Based on previous AW certification(s), accepted aircraft pedigree & review of all aircraft modifications

• SMEs apply appropriate AW criteria, engineering standards, and data requirements for a Type 1 PAO contracted air services IFC.

• Example: FAA Type Certified baseline aircraft complying with FAA approved maintenance and operational practices, with modifications for military purposes which can be fully evaluated and approved by Navy SMEs

• Example: Former military aircraft with current and clear pedigree with modifications for military purposes which can be evaluated and approved by SMEs

DoDD 5030.61

Navy FC required, effort to likely include:

• Deliverables • Funding • SFF Inspection/ GFR

• Contract Language • Enduring audits • EMI SOFT/RAD

Title 14 CFR

P u b lic

A ir c ra ft O p e ra ti o n s

C iv il A ir c ra ft O p e ra ti o n s

NAVAIRINST 13034.1

Interim Flight Clearance (2 of 3)

• Conduct a Planning Meeting (Class Desk, Contractor, ACO, SMEs)

– To occur immediately post contract award

– Develop an Airworthiness Qualification Plan (AQP) and Engineering Data

Requirements Agreement Plan (EDRAP)

• PCA (Class Desk, Contractor)

– Initial PCA to determine aircraft pedigree

– Final PCA post modification completion

• Communicate early and often (All)

– Class Desk: actively coordinate and communicate with SMEs, ACO, Contractor

– Program/Contractor: Provide ALL required data, early enough, to allow for timely review

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Note: If a Safety of Flight hazard is identified, a Systems Safety Risk Acceptance (SSRA) is developed to document the hazard for formal acceptance.

IFC Process and Sequence of Events (3 of 3)

• Testing/Assessments

– Determine requirement (Class Desk, SMEs)

– Schedule tests (PMA, Class Desk, Contractor, SME)

• Typically occur post completion of required aircraft modification (or as required by SMEs)

• Electronic equipment (EA/EW Pods) must be available and approved for carriage prior to EMC SOFT testing

• Class Desk submits complete IFC request to the ACO

– A complete request means adequate planning & coordination with Stakeholders (Program, Airworthiness, Customer, Operator, Support Personnel, SMEs/Competencies) is in place and all data is ready and available

– Data includes all flight clearance references and any additional data required per EDRAP for review and release of an IFC by SMEs and Airworthiness authority

– Met all known SME requirements

• IFC Review (SMEs, Class Desk)

– Provide concurrence

• May require additional discussions and documentation

• IFC Release (ACO)

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• Once IFC is released, CAS Class Desk must be notified of any changes that impact:

• Aircraft configuration

• FAA Certificates

• Operating Limitations

• Operating Procedures

• These changes will be assessed to determine if an IFC revision is needed.

• Airworthiness Basis

– Criteria / Standards: MIL-HDBK-516, PBSS, JSSGs, FARs, etc.

– Method of Compliance: Evaluation method: model, flight testing, similarity, etc.

– Artifacts: Specific engineering data evaluated

– Assessment: SME assessment of configuration against tailored AW Requirements

• Doesn’t stop at compliance, but continues to id risks, implications, possible mitigations

– Results: Non-compliances identified, adjudicated, mitigated and/or risks accepted

Airworthiness Basis

C ri te ri a

516, FARs

EMACC

M e th o d o f

C o m p li a n c e

Test, Analysis

R e s u lt s o f

A s s e s s m e n t

Δ Limits & Risks

A rt if a c ts

Reports, Models

S ta n d a rd s

MIL-SPECs PBSS, etc.

Aircraft Configuration – e.g. Product Baseline + ECPs

Role – e.g. Transport, Air Superiority

Mission Environment – e.g. shipboard + high salinity

A s s e s s m e n t

Comply?

Flight Clearance Data Focus (1 of 3)

Flight Clearance Data Focus (2 of 3)

• FAA approved data: Data specifically approved by the FAA or FAA-delegated representatives

• OEM documents

– Aircraft Manuals, Procedures, etc.

– Model specifications

• Military Documentation

– Manuals

– Airworthiness Certification

– Technical Directives (TCTOs, AFCs, Bulletins, etc.)

• Test plans

• Test reports

• Engineering analyses

• Models and Simulations

• FMECA

• Engineering Drawings

• Any other source data applicable to hardware and software modifications

Flight Clearance Data Focus (3 of 3)

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Experimental Certificate: Modifications performed on aircraft with Experimental

Certificate are NOT validated by the FAA. This certificate requires further review of aircraft pedigree/design

Program Letter submitted to FAA for application of Experimental Certificate

–Identifies aircraft configuration

–States intended purpose

•Operating Limitations provided by FAA in conjunction with Experimental Certificate

• In the absence of FAA, OEM, or Military approved data, it is good standard practice to follow the recommended repair and alteration processes and procedures described in:

• AC 43-210A, Standardized Procedures for Obtaining Approval of Data

Used in the Performance of Major Repairs and Major Alterations

• Major Repair and Alteration Data Approval Job Aid

Testing & Assessment Requirements Prior to IFC

Release (1 of 2)

• Evaluation for operation of mission specific electronic equipment

– Determination of Safe Distances for:

• Hazards of Electronic Radiation to Personnel (HERP)

• Hazards of Electronic Radiation to Ordnance (HERO)

• Hazards of Electronic Radiation to Fuel (HERF)

– Electromagnetic Interference/ Electromagnetic Compatibility

Safety of Flight Test (EMC SOFT)

• Equipment operating in all modes and at all frequencies that will be used in flight

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Testing & Assessment Requirements Prior to IFC

Release (2 of 2)

• Aircraft Validation and Verification (Val/Ver) Electrical

Wiring Interconnect System (EWIS) assessments

– Conducted on wiring associated with aircraft modifications not approved by FAA

– May be required at four different stages within the modification process

• 30%, 60%, 90%, and 100% of completion

• Dependent on availability of engineering documentation

• Assessments for CAS aircraft are typically conducted at 100% completion

– All terminations are made

– Wire bundles and cables are completely installed and secured

– All of the equipment has been installed

– Quality Assurance (QA) function has accepted the installation

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Continuing Airworthiness Oversight

• Ensures contractor “maintains” airworthiness through approved air and maintenance operations over the life of contract. Required by:

– Contract

– DCMA INST 8210.1C w/ CH1 (NAVAIRINST 3710.1G CH 1)

• Government Flight Representative (GFR) conducts initial and semiannual audits to:

– Approve Contractor Ground, Flight Operational Procedures (GOPS / FOPS) and Safety Program

– Review Pilot and Maintenance Records to assure continued compliance with approved Procedures

• NAVAIR Aircraft Maintenance Management Team will conduct

Aircraft Maintenance Inspections (AMI) to provide an outside evaluation of the contractors maintenance and assess the overall risks associated with the contract

– Before flight operations

– Every two years thereafter

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• Multiple US Airworthiness authorities with different policies, unique to their missions

• CAO or PAO for each flight must be clear

• Civil operator’s responsibility to be in accordance with 14 CFR, or notify the requesting agency for a PAO determination, if necessary

• Specific details regarding air system configuration, mission, usage and pre-existing FAA certificates can make PAO determinations complicated.

• A NAVAIR IFC is required prior to conducting DON PAO.

• An AQP is required when utilizing non-DON airworthiness certifications and/or non- DON SMEs.

• Plan to leverage other airworthiness approvals as much as possible, but subject to receiving AW authority agreement.

• The AQP defines the plan for an air system to achieve flight clearances over the system life cycle, including the roles, responsibilities, processes and products to establish the initial and continuing airworthiness basis for the air system.

• Planning and tailored technical reviews are required for each NAVAIR Flight Clearance

• Provide available data as early in the process as possible; DON SMEs will assess risk in areas for which an AW basis can’t be established due to lack of data.

• Communicate any changes to configuration, certificates, limitations or procedures to ensure AW approval is obtained.

– Not doing so may invalidate AW with an individual agency

– May need to reconfigure to a cleared configuration for specific agency

Takeaway

Reference List

a) Advisory Circular 43-201A: Standardized Procedures for

Obtaining Approval of Data Used in the Performance of Major

Repairs and Major Alterations.

b) Major Repair and Alteration Data Approval Online Job Aid

c) Advisory Circular 00-1.1B: Public Aircraft Operations.

d) Advisory Circular 91-91 Maintaining Public Aircraft.

e) FAA Order 8300.16.

f) Title 14, Code of Federal Regulations.

g) DCMA INST 8210.1C (NAVAIRINST 3710.1G) w/ CH1

Contractor’s Flight and Ground Operations, 5 April 2017.

h) NAVAIRINST 13034.1F – Flight Clearance Policy for Air

Vehicles and Aircraft Systems.

i) Department of Defense (DoD) Directive 5030.61 DoD

Airworthiness Policy.

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QUESTIONS?

File: 2017.12.20.CAS_4TH_Gen_AirworthinessBrief 22

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