Airworthiness Standards for sub
150kg class RPAS
Royal Aeronautical Society
8 May 2015
Nick Brewer: Head of Airworthiness and Standards: EuroUSC International
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Background
The general public (via governments and their
aviation regulators) may not tolerate an increase in
the fatal aircraft accident rate especially if that
increase relates to RPAS.
It is therefore incumbent on RPAS operators to ensure
that an increase in the overall (aviation) fatal
accident rate does not occur.
RPAS airworthiness is one element of this
incumbency.
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Extract from the Riga declaration
‘The provision of drone services must not be less safe
than is accepted from civil aviation in general. The
incremental integration of drones in the aviation
system must not reduce the level of safety presently
achieved in civil aviation.’
‘Rules should be simple and performance based, to
allow a small start-up company or individuals to start
low-risk, low-altitude operations under minimal rules
and to develop, with light-touch risk-based
regulation…’
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The RPAS problem
The rapid evolution of small RPAS from the ‘leisure
toy’ marketplace to ‘near miss’ and ‘fly away’ stories
on the news has presented society with cause for
concern.
The NAAs appear to be struggling with the RPAS
issue, especially that of airworthiness.
Some have decided that a risk based safety case will
mitigate the risk with little or no deference to
airworthiness.
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The safety case problem
Safety cases that involve flights near or over 3rd
parties without airworthiness consideration may be
fundamentally flawed.
However, it is a far from easy exercise making a
complex process such as airworthiness, simple.
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What is airworthiness?
Airworthiness is a generic term intended to describe
the level of confidence we have in an aircraft to
complete intended flights.
The basic principles are good design practice, build
quality and effective maintenance.
RPAS should be no different.
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Why is airworthiness so difficult for small
RPAS?
Affordability is key to the industry!
SMEs who make up the majority of RPAS constructors
in this sector may not have the resources, capability
or experience to undertake certification as the
manned world knows it.
In the UK, CAP722 provides little useful airworthiness
guidance and no manifest sub 150 airworthiness
regulation is available to date.
The result is the airworthiness hiatus we have today.
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What airworthiness confidence do we
have today?
Very little at present.
Inspections and test of individual RPAS may provide a
rudimentary indication of a systems ability to function
as intended.
Although a step up from nothing, such individual
inspections may not be classed as airworthiness in the
true sense.
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What is needed?
Airworthiness assurance by way of:
Airworthiness requirements or standards whereby the
RPAS constructor demonstrates compliance of an
RPAS ‘Type’ to a set of considered requirements or
standards rather than an inspector looking at
individual systems; and
RPAS constructor organisations that demonstrate
compliance to an RPAS specific quality system.
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Such regulations or standards must be
effective, fit for purpose and contribute to a
standard of RPAS airworthiness
In response, Euro USC International has produced:
LUASS-AW: Specific RPAS standards for Airworthiness.
LUASS-DPS: Specific RPAS standards for Design and
Production including maintenance, repair and flight
test.
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Isn’t the EU via JARUS doing this already?
In a word, yes, but experience working on these
international rulemaking groups has shown that it will
take many years before such harmonised regulation
becomes available.
In the meantime the industry has nothing.
Therefore, a robust set of interim standards has been
produced by the industry to support the industry.
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What is LUASS-AW?
Airworthiness standards for RPAS of maximum RPA
take-off weight less than 150kg.
A succinct distillation of existing manned
airworthiness regulation tailored for small RPAS.
Designed to ensure minimum airworthiness standards
by way of controlling RPAS airworthiness risk to 3rd
parties.
Compliance is demonstrated by the applicant.
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LUASS-AW
36 individual standards.
The 4 main ‘pillars’ of airworthiness:
AW.301. Strength: Is it strong enough?
AW.601. Design: Has it been designed correctly?
AW.1301. Function: Will it work as intended?
AW.1309. Systems availability: How reliable is it?
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Example 1
AW.1421 Command and Control Data Link (C2)
(See GM AW.1421 & AMC AW.1421)
The C2 link must:
(a) Be resistant to interference and disruption that may
cause an unsafe condition.
(b) Comply with AW.601, AW.1301 and AW.1309.
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Example 2
AW.1309 Equipment, Systems & Installations
(See GM AW.1309 & AMC AW.1309)
(a) Any failure or system malfunction that could cause an
unsafe condition leading to a Catastrophic outcome must be
extremely improbable or;
(b) Additional means must be provided to minimise the unsafe
condition as far as reasonably practicable or;
(c) Operational provisions and/or restrictions must be in place
before commencement of flight to minimise the unsafe
condition.
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Example 3
AW.1357 Circuit Protective Devices
(See GM AW.1357)
Any circuit protection device must not compromise
airworthiness to a greater extent than the failure it is
intended to mitigate.
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What is LUASS-DPS?
LUASS-DPS is a much simplified quality standard
analogous in process to EASA Part 21, Part 145 and
other manned aircraft requirements. It has been
developed specifically for organisations intending to
design and construct RPAS.
Whilst the standards are suitably simplified to be fit for
purpose the levels of demonstrable rigor may
increase from smaller RPA to systems up to 150kg.
Such levels of demonstrated rigor may be agreed at
the time of application.
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Scope
LUASS-DPS is designed to allow organisations to
demonstrate compliance with any or all of the
following:
Subpart A: RPAS Design Organisation
Subpart B: RPAS Production Organisation
Subpart C: RPAS Maintenance and Repair
Organisation
Subpart D: RPAS Flight Test Organisation
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Proportionate standards
Both LUASS-AW and LUASS-DPS have been
developed to be linear, proportional and flexible.
Besides 150kg, no other limits are introduced.
Whilst the standards are suitably simplified to be fit for
purpose the levels of rigor may be different for
smaller RPA and their constructors than that of larger
systems to reflect the differing levels of risk.
The levels of demonstrable rigor will be agreed at the
time of application.
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What can compliance to these standards
bring?
Compliance to such standards, may provide a level
of RPAS airworthiness confidence hitherto unseen in
this sector before by:
RPAS design following formal airworthiness criteria
analogous to the EASA CS’ and
Design and production utilising controlled quality
processes and procedures.
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What can accreditation to these
standards bring?
Accreditation should allow the NAAs to more easily
process exemptions to operate, especially in built up
areas and over centres of population.
Alleviate the need for costly NAA investigations.
Allow series production of RPAS with Type Design
Accreditation without further showing of individual
airworthiness.
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What these standards cannot bring!
Perfection. Like any new product there will be
problems, faults and errors.
However by working within industry and hopefully
with the NAAs, these standards can be developed,
honed and improved.
An instant silver safety bullet. It is the total aviation
system that brings safety and not just airworthiness.
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In summary
This standards approach leaves the applicant free to
design and develop RPAS to proportionate levels of
airworthiness across the whole weight spectrum.
The standards have been developed to be user
friendly, fit for purpose and within the grasp of most
SMEs.
The standards are Riga declaration compliant (see
slide 3)
The standards should help to improve RPAS safety
and the image of the industry.
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Thank you
Any Questions?
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