Airworthiness Standards for sub 150kg class RPAS Royal Aeronautical Society 8 May 2015 Nick Brewer: Head of Airworthiness and Standards: EuroUSC International 1 © 2015 EuroUSC International™ 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. 22 12/05/2015 © 2015 EuroUSC™ 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…’ 33 12/05/2015 © 2015 EuroUSC™ 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. 44 12/05/2015 © 2015 EuroUSC™ 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. 55 12/05/2015 © 2015 EuroUSC™ 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. 66 12/05/2015 © 2015 EuroUSC™ 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. 77 12/05/2015 © 2015 EuroUSC™ 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. 88 12/05/2015 © 2015 EuroUSC™ 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. 99 12/05/2015 © 2015 EuroUSC™ 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. 10 10 12/05/2015 © 2015 EuroUSC™ 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. 11 11 12/05/2015 © 2015 EuroUSC™ 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. 12 12 12/05/2015 © 2015 EuroUSC™ 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? 13 13 12/05/2015 © 2015 EuroUSC™ 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. 14 14 12/05/2015 © 2015 EuroUSC™ 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. 15 15 12/05/2015 © 2015 EuroUSC™ 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. 16 16 12/05/2015 © 2015 EuroUSC™ 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. 17 17 12/05/2015 © 2015 EuroUSC™ 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 18 18 12/05/2015 © 2015 EuroUSC™ 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. 19 19 12/05/2015 © 2015 EuroUSC™ 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. 20 20 12/05/2015 © 2015 EuroUSC™ 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. 21 21 12/05/2015 © 2015 EuroUSC™ 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. 22 22 12/05/2015 © 2015 EuroUSC™ 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. 23 23 12/05/2015 © 2015 EuroUSC™ Thank you Any Questions? 24 24 12/05/2015 © 2015 EuroUSC™
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