Continuing Airworthiness Requirements for Uninhabited Air Vehicle Systems
Effective Date: 12 April 2013
OPI / Telephone: DTAES 4-5 / 819-939-4757
Reference: TAM, Part 3
1.1 This Technical Airworthiness Authority (TAA) Advisory provides clarification and guidance pertaining to the standards governing the Department of National Defence (DND) continuing airworthiness requirements for supporting Uninhabited Air Vehicle (UAV) Systems.
1.2 This TAA Advisory is not mandatory, nor does it constitute a regulation. It describes a means acceptable to the TAA, but is not the only means to demonstrate compliance with the regulation(s). If you elect to use this TAA Advisory, then all aspects of it must be followed.
2.1. This TAA Advisory is applicable to organizations providing continuing airworthiness support to a UAV System.
3. Related Material
- Continuing Airworthiness – Continuing airworthiness involves those activities necessary to ensure that aeronautical products continue to meet the appropriate airworthiness rules and standards throughout their operating life. Continuing airworthiness is an integral part of the day-to-day management and monitoring of an approved type design and the associated aeronautical products after a type certificate has been issued. Compliance with airworthiness standards during the in-service period ensures that the initial inherent safety of the approved type design and the actual aeronautical products are maintained throughout the product life cycle.
- Uninhabited Air Vehicle (UAV) - A UAV is any uninhabited, powered air vehicle operated remotely and/or autonomously. Ammunition, projectiles and missiles are not UAVs.
- UAV System (UAS) - A UAV System includes the air vehicle, launch and recovery systems, if used, any ground control stations and all communication links.
Throughout this document the term “UAV” is used. However, it is not possible to manage the airworthiness of the UAV without taking into consideration the entire UAV system. As a result, where this document discusses UAVs, the discussion is intended to cover the UAV System.
3.2. Regulatory References:
3.2.2. C-05-005-001/AG-001 – Technical Airworthiness Manual (TAM)
3.2.3. Civilian and/or other military airworthiness regulations/advisories:
4.1. The DND/CF Airworthiness Program (regulatory reference 3.2.1) classifies UAVs as aeronautical products and, as such, they are subject to regulation under the Airworthiness Program. The TAA has issued Technical Airworthiness rules and standards applicable to all aeronautical products in the Technical Airworthiness Manual (TAM). The TAM does not contain specific guidance or adjustments to standards to deal with the unique airworthiness requirements associated with UAVs. This TAA advisory will provide the required guidance on how to apply the continuing airworthiness requirements of the TAM to UAVs.
For UAVs, it is possible to minimize risk to other aircraft and individuals on the ground by controlling the airspace (Class F) and area of operation. In addition, some UAVs are very small, resulting in very little kinetic energy in the event of an impact with another object. This is the reason why the TAA can adjust airworthiness requirements for UAVs and still maintain an acceptable level of safety.
4.2. This TAA Advisory utilizes the UAV Classification System proposed in the Canadian Forces UAV Campaign Plan (regulatory reference 3.2.3 b.). This results in the following possibilities for UAVs:
- Tier 1 (Greater than 5000 lbs MTOW) – This includes UAVs classified as MALE and HALE;
- Tier 2 (186 to 5000 lbs MTOW) – This includes UAVs classified as Tactical; and
- Tier 3 (0 to 185 lbs MTOW) – This includes UAVs classified as Micro, Mini and Small.
4.3. Tier 1 and 2 UAVs are required to meet all TAM requirements associated with sustaining Continuing Airworthiness for an aeronautical product.
It is recognized that the UAV Tier classification system is arbitrary and it is possible to have a “Tactical UAV” that could also be classified as a “Small UAV”. As a result, a Project Management Office may propose a Continuing Airworthiness system based on the Tier 3 guidance contained in this TAA advisory to the TAA for consideration.
4.4. Tier 3 UAVs are required to meet the Continuing Airworthiness requirements provided in section 4.5. below.
4.5.1. The TAC for a Tier 3 UAV can be issued by the TAA based on a demonstration that the In-service Support Program will result in an acceptable level of safety. For Tier 3 UAVs, the TAA will accept an In-service Support Program that is based on DND/CAF and Industry best practices. The In-service Support Program will need to provide for a DND/CAF Type Certificate Holder, and Engineering, Maintenance and Logistics Support.
4.5.2. Type Certificate Holder (TCH) Requirements – For UAVs that are placed on the DND/CAF aircraft register, there is a requirement for an organization acceptable to the TAA to be designated as a TCH organization. The UAV TCH organization will have the following responsibilities:
- Nominate an individual within the TCH organization who is acceptable to the TAA, as the Airworthiness Manager. This individual will fill the role of Type Certificate Holder;
- Ensure the establishment and maintenance of data, such as: operating instructions, maintenance manuals, drawings, parts catalogues, needed to support the UAV for the life of the project;
- Ensure access to any data provided by the UAV OEM to the TAA in support of the Technical Airworthiness Clearance;
- Monitor the UAV in service and report airworthiness-related issues to the TAA. This includes preparation of an Annual Airworthiness Report to be presented to the Airworthiness Review Board as required by regulatory reference 3.2.3 c.;
- Manage airworthiness risks identified during the operational service in accordance with regulatory reference 3.2.3 d.;
The TCH organization will require an assignment of authority from the TAA to approve the content of a risk assessment. This will require the TCH organization staff to take the AEPM Risk Management Course and have engineering and technical knowledge of the UAV system they are supporting.
- Ensure that the configuration management of the UAV is established and maintained for the life of the project; and
- Establish and maintain arrangements with organizations providing the required engineering, logistic and maintenance support.
While the TAM uses the term “Type Certificate Holder Organization”, this requirement exists even if the TAA has not issued a Type Certificate for the UAV. The criterion for requiring a TCH organization is the registration of the Aircraft (UAV) on the DND/CAF Aircraft Register. The TCH will be the “owner” of the UAV. As a result, where the UAVs are owned by DND, there is a requirement for DND to establish a TCH organization. Where DND is the TCH, it is acceptable to have a contracted support organization perform the activities required to enable the TCH responsibilities. However, the DND TCH still remains accountable to the TAA, regardless of the scope of the contracted support performed. The TCH organization will be required to submit to the TAA for approval procedures that enable TCH responsibilities to be executed. These procedures can be based on (or use directly) the AEPM Engineering Process Manual (regulatory reference 3.2.3.a.).
4.5.3. Engineering Support Requirements – The organization that will provide engineering support to the UAV must be assessed by the TAA. This normally requires TAA staff to travel to the engineering organization to conduct a review related to the core engineering support processes that will be applied to the UAV. The UAV engineering support program evaluated by the TAA will cover:
- Configuration management;
- Engineering (design) change approval;
- Technical and operational manual management;
- Supplier management and customer parts support;
- Technical problem support, including:
i. Technical queries;
ii. Non standard repairs;
iii. Field Service Reps; and
iv. Maintenance program deviations
- Training program for engineering staff;
- In-service monitoring of customer/supplier problems; and
- Quality management system.
Where engineering support is not provided by the UAV OEM, there will be a requirement for a support arrangement with the UAV OEM. As a minimum, the support arrangement will need to provide for in-service support for engineering (design) change approvals, configuration management and customer part support.
4.5.4. Maintenance Support Requirements – The organization that will be providing maintenance support to the UAV must be assessed by the TAA. This may require TAA staff to travel to the maintenance organization to conduct a review related to the core maintenance support processes that will be applied to the UAV. The UAV maintenance support program evaluated by the TAA will cover:
- Training program;
The training program can be tailored to the complexity of the UAV being supported. For example, a technician performing repair and overhaul on a UAV engine might require “two stroke small engine” training, whereas a technician working on an aircraft engine would require significantly more training and experience before being allowed to perform maintenance. It is also acceptable for a support organization that utilizes technician trades built around land vehicles or weapons to apply those skill sets to a UAV. The TAA will evaluate the complexity of the UAV maintenance against the proposed technician trade structure.
- Qualification and authorization process;
- Maintenance certification process;
- UAV release to operations process;
The TAA will evaluate if the complexity of the work performed to support the UAV requires “maintenance release” or “aircraft release” as stipulated within the TAM. For a Tier 3 UAV, the work performed will normally be treated as “elementary work and servicing” negating the requirement for a formal “maintenance release”.
- Maintenance record management;
- Maintenance scheduling and control;
- Parts control;
- Access to special tools and test equipment;
- Access to facilities suitable for the scope of work being performed;
- Maintenance publication management; and
- Quality management system.
4.5.5. Logistics Support Requirements – The organization that will be providing logistics support to the UAV must be assessed by the TAA. This may require TAA staff to travel to the logistics support organization to conduct a review related to the core logistics support processes that will be applied to the UAV. The UAV logistics support program evaluated by the TAA will cover.
- Receiving of parts;
- Packaging and handling;
- Shelf life control;
- Part documentation control;
- Vendor selection and parts ordering; and
- Quality management system.
The CF Supply System (CFSS) is acceptable for providing logistics support to aeronautical products. If the CFSS is used, the TCH organization will be required to ensure that only approved UAV parts are procured for use on the UAV and controlled through the CFSS.
5. Additional Airworthiness Considerations
5.1. Technical Airworthiness Authority Oversight – The TAA staff may require access to contractor and DND facilities to perform the initial in-service support system evaluation and any audits, review or evaluations conducted during in-service UAV operations. Where the TAA identifies that an audit, review, or evaluation is required, the following support will be needed from the organization being assessed:
- On-site support to the audit team, including office space to conduct meetings and interviews;
- Access to qualification and authorization files of staff supporting the UAV;
- Access to work orders and other technical data generated within the organization supporting the UAV;
- Access to engineering and technical information used in support of the continued airworthiness of the UAV;
- Access to the organization’s records and reports that support the Quality Management System registration;
- Access to organizational manuals, procedures and instructions used to support the UAV;
- Technical and management staff to support DND auditors; and
- Preparation of Corrective Action Plans, when required, that are acceptable to the TAA.
5.2. In addition to the TAA oversight of any of the UAV in-service support organizations that may occur, TAA staff will as a minimum review the Annual Airworthiness Report (AAR) produced by the TCH organization and all risk assessments generated during in-service operations.
5.3. Contract Considerations – Where activities identified within the UAV In-Service Support Program are performed by a contractor, the Statement of Work (SOW) should include provisions for the TAA organizational assessment that will be required to support the initial Technical Airworthiness Clearance. In addition, the SOW will need to identify that the contractor will be required to support in-service TAA audits on an “as required” basis and rectify to the satisfaction of the TAA any findings identified during an audit, review or evaluation.
5.4. Where activities identified within the UAV In-Service Support Program are provided by a “Prime” who is not the UAV OEM, the contract will need to have provisions that ensure the “Prime” establishes a support contract with the UAV OEM for engineering support services or the “Prime” will be subject to the full provisions of the TAM Part 1, Chapter 4, for accreditation or recognition as an ADO/ATO for the scope of the UAV engineering support work performed.
5.5. If a significant portion of the In-Service Support Program is performed by a contractor, the SOW shall have provisions to establish a contractor Airworthiness Manager who will be responsible for the implementation and management of the Contractor’s airworthiness program. The contractor’s Airworthiness Manager will act as the main Point of Contact (POC) for all airworthiness matters. The Airworthiness Manager will have the responsibility to facilitate and deliver the support required to meet all of the TCH organization’s responsibilities detailed in paragraph 4.5.2.