Future Defence Aviation Safety Regulation Module 6 - EMAR Part 66 – Military Aircraft Maintenance Licensing July 2015

Why have licences?

145.A.30 (g) Personnel requirements: Any organisation maintaining aircraft …. shall in the case of aircraft line maintenance, have appropriate aircraft type rated certifying staff, qualified as category B1, B2 and B mil or national equivalent qualification in accordance with EMAR 66 There is a similar clause requiring personnel to be licenced to perform base maintenance Line vs base will be discussed later Note that 66 does not include B mil and Bmil will be deleted in the next update of EMAR145. (The treatment of military-unique equipment will be addressed later)

EMAR Part 66 – Military Aircraft Maintenance Licencing Scope EMAR Part 66 – Military Aircraft Maintenance Licencing The purpose of this brief is to: show how EMAR 66 fits within the EMAR structure provide an overview of Part 66 outline the main differences between TAREGs and EMAR66 identify some consequences of licencing This brief does not provide detailed information on the effects on current trades These slides are intended to provide awareness level information on EMAR66, it is not intended to provide detailed information on EMAR66 or to answer detailed questions about the effects of EMAR66 on the current trades, or for individuals (what’s in it for me). Answers to those types of questions require a detailed understanding of EMAR66 and will be provided at a later date.

EMAR Structure This is where EMAR66 sits in the Airworthiness framework.

TABLE OF CONTENTS SECTION A ................................................................................................................................... 6 TECHNICAL REQUIREMENTS .................................................................................................... 6 66.A.1 Scope ................................................................................................................................ 6 66.A.3 MAML categories ............................................................................................................. 6 66.A.5 Aircraft groups ................................................................................................................. 6 66.A.10 Application ..................................................................................................................... 6 66.A.15 Eligibility ......................................................................................................................... 7 66.A.20 Privileges ........................................................................................................................ 7 66.A.25 Basic knowledge requirements ..................................................................................... 8 66.A.30 Basic experience requirements ..................................................................................... 9 66.A.40 Continued validity of the Military Aircraft Maintenance Licence .............................. 11 66.A.45 Military Aircraft Type Ratings....................................................................................... 12 66.A.50 Limitations ..................................................................................................................... 12 66.A.52 Extensions ..................................................................................................................... 12 66.A.55 Evidence of qualification .............................................................................................. 13 66.A.70 Conversion provisions ................................................................................................. 13 This slide shows EMAR66’s Table of Contents. This brief only covers those clauses in red – the remainder are straight forward &/or administrative in nature

66.A.3 Licence categories Military Aircraft Maintenance Licences include the following categories: — Category A — Category B1 — Category B2 — Category C

66.A.3 Licence sub-categories Categories A and B1 are subdivided into subcategories relating to combinations of aeroplanes, helicopters, turbine and piston engines: — A1 and B1.1 Aeroplanes Turbine — A2 and B1.2 Aeroplanes Piston — A3 and B1.3 Helicopters Turbine — A4 and B1.4 Helicopters Piston A2 and B1.2 and A4 and B1.4 not relevant to Defence

66.A.20 Privileges (general) The licence provides the scope and level of maintenance activities that may be performed The Pt 145 organisation then authorises the activities (within that scope and level) the licence holder can perform and certify Currency and continuation training requirements Individual apply for licence; the Authority reviews the individual’s Q, T, E and issues licence, with/without exclusions ie the licence defines the scope and level of maintenance that individual may perform. The 145 organisation then applies their context against that licence and their own assessment of the individual’s competence and authorises the individual to certify particular maintenance activities. In Defence’s context, the 145 authorisations are essentially the same as the current Task Authorisations issued by the SMM (except that under EMARs, the QM issues authorisations, not the SMM) So, if an individual hasn’t completed the all the required training for a licence, then that individual may be issued with a licence with exclusions. Eg an individual who has a Cert IV in Aeroskills (Mechanical) has received minimal training in electrics and avionics. That individual could be eligible for a B1.1 licence with exclusions for electrics and avionics components/systems. The 145 may decide that an individual lacks sufficient experience within particular components/systems. That individual will not be authorised to certify for maintenance performed on those components/systems. Once the individual has gained the necessary experience, his/her authorisation will be amended to include the performance and certification on those components/systems. (Directly analogous to 7001.059 task authorisation process.) Similarly, individuals who have undertaken additional training and experience can be eligible for licence extensions Note that CASA requires additional competencies above the Cert IV qualification. The additional competencies relate to civil aviation legislation, supervisory responsibilities, maintenance management and a competency related to exercising the privileges of a licence and result in a Diploma in Aeroskills (Mechanical or Avionics). Defence has not formally compared training undertaken after IET (eg promotion courses, Trade Principles Supervisors, Sub2/4 training, POATT etc) If such a comparison was made, it is likely that NCOs would be eligible for a similar qualification. All licences have a currency requirement – licence holders must complete 6 months OJE in any 2-year period

66.A.20 Privileges – A licence An A Category licence permits the holder to issue certificates of release to service following minor scheduled line maintenance and simple defect rectification and in accordance with the authorisations issued by the EMAR 145 organisation EMAR definitions of Line and Base maintenance is somewhat vague – roughly Line is not Base & Base is not Line EASA & CASA are somewhat more prescriptive. However, AMC for EMAR145 states: For the purposes of category A, minor scheduled line maintenance means any minor scheduled inspection/check, up to and including a weekly check. For aircraft maintenance programmes that do not specify a weekly check, the NMAA will determine the most significant check that is considered equivalent to a weekly check Note that TMPs do not assist in determining all activities – ‘DM’ is clearly Base maintenance but how is an R2 classed – it depends (primarily on the complexity of the servicing – can it be done on the flight line or does it have to be done in the hangar? For the former – potentially a candidate for Line maintenance. If it has to undertaken in a hangar (needs jacking, lots of STE needed etc, then clearly base maintenance). In essence, the EMAR 145 organisationproposes the activities for line &/or base and the Authority approves/rejects the proposal. In the ADF context, Line maintenance approximates to maintenance activities carried out on the flight line, but could include scheduled servicings beyond Flight Servicings It is not mandatory for a 145 organisation which performs line maintenance to have A category licence holders, it can use B1 licence holders (efficiency vs cost)

66.A.20 Privileges – B1 licence Category B1 MAML shall permit the holder to issue certificates of release to service and to act as support staff for: maintenance performed on aircraft structure, powerplant, mechanical systems and electrical systems work on avionic systems requiring only simple tests to prove their serviceability and not requiring troubleshooting in accordance with the authorisations issued by the EMAR 145 organisation Licence limitations (exclusions) are used to manage training shortfalls Note that a B1 licence holder can perform maintenance on a much wider range of systems than current ADF trades. Current trade training does not match the training outcomes for a B1 licence. For example, an ATECH/ATA has limited training in structures and very limited training in electrical systems. Similarly, AVTECHs/ATVs have very limited training in engines, airframes and structures. These training shortfalls will be managed by licence exclusions. For example, the ATECH/ATA may be issued with a B1 licence, with structures and electrical exclusions, once they have the required experience The B1 includes the corresponding A subcategory

66.A.20 Privileges – B2 licence Category B2 licence permits the holder: to issue certificates of release to service and to act as support staff for maintenance performed on avionic and electrical systems electrical and avionics tasks within powerplant and mechanical systems, requiring only simple tests to prove their serviceability to issue certificates of release to service following minor scheduled line maintenance and simple defect rectifications and iaw authorisations issued by EMAR 145 The training outcomes for a B2 licence are very similar to current AVTECH/ATV training, ie AVTECHs and ATVs may be issued with a B2 licence with few exclusions, once they have the required experience Licenced by Authority, Authorised to certify by organisation following competence assessment CRS is restricted to work that the MAML holder has personally performed B2 does not include any A subcategory, but B2 licence holders can undergo additional training/experience to make them eligible for an A licence Minimum age for B1, B2 - 21

66.A.20 Privileges – C licence Category C licence permits the holder to issue certificates of release to service for an aircraft following base maintenance on aircraft The CRS privilege applies to the aircraft in its entirety

66.A.25 Basic knowledge requirements Appendix 1 to EMAR66 specifies the syllabus (knowledge levels and subject modules) required for A, B and C licences Only EMAR147s can deliver training CASA has converted the syllabi into UOCs UOCs for A and B1/B2 licences have been compared to current ADF technician training National training in Australia is delivered iaw the Australian Quality Framework, which uses Units of Competency (UOCs) as its basis, not syllabi. CASA Pt 66 Manual of Standards converts the syllabi for A, B and C licences into UOCs. That conversion has been accepted by EASA, demonstrating the equivalence of the training outcomes Training must be delivered by a Maintenance Training Organisation approved iaw EMAR 147 organisations or by the NMAA If the applicant holds an EASA Part 66 licence, the NMAA may accept the EASA licence as a basis, only requiring additional training to cover the differences between the EASA licence and the MAML requirements

66.A.30 Basic experience requirements For Category A: 3 years practical experience if relevant trade training not completed 2 years practical experience if relevant trade training has been completed 6 months of practical experience on operating military aircraft if trained at RAAFSTT (TBC) Examples shown on slide are only a sub-set of the experiential requirements set out in 66.A.30. ‘Relevant trade training’ – IET is likely to satisfy EMAR66, but yet to be confirmed – TMPs at RAAFSTT yet to be finalised

66.A.30 Basic experience requirements (cont) for Categories B1.1, B1.3 and B2 licences: 5 years practical experience if relevant trade training not completed 3 years practical experience if relevant trade training has been completed for Category C licence: 3 years exercising Category B1.1, B1.3 or B2 licence Category C licences can also be issued to TQ engineering officers if they have completed an engineering degree, plus: 3 years of experience working in a military aircraft maintenance environment on a representative selection of tasks directly associated with military aircraft maintenance including 6 months of observation of base maintenance tasks; or experience as detailed by the NMAA but not less than 6 months of observation of base maintenance tasks.

66.A.45 Military Aircraft Type Ratings Licences must be endorsed with the relevant Aircraft Type Rating, after completing Type Training at an EMAR 147 MTO Category A licence holders do not require a Type Rating, but must complete task training (iaw EMAR 145.A.35) Type Training is the same as the training in ADF which uses name such as Equipment Application Courses and Type Courses MTO = Maintenance Training Organisation. Australia’s ‘Registered Training Organisations’ (RTO) are similar, but not identical to MTO. Note that under EMAR 147, organisations delivering type courses – such as Field Training Flights, AAvnTC & TA-AVN have to be MTOs

Main differences between TAREG and EMAR TAREGs do not use licences and leave competency assessments of individuals up to the SMM. EMAR 66 licence training requirements very prescriptive. However EMAR 66 permits ‘national equivalent’ systems and processes : The services trade structure is broadly equivalent to licences, in that the trade, skill grades and rank structure identifies individual’s scope and level Units’ task authorisation (iaw -059) is directly comparable with EMARs authorisation requirements

Other matters Structures, Life Support, Surface Finishing & NDI Oxygen SMMs/WOEs (E) CFU approval Maintenance performed by Structures, Life Support, Surface Finishing & NDI trades are considered specialist maintenance and do not need A, B or C licences. Note that training at RAAFSTT provides the basis for an A licence (with exclusions) for these trades (NDITECHs who were ATECHs or AVTECHs will have acquired a B1/B2 licence before remustering.) Oxygen maintenance is aligned with B1 licences, but there is nothing to prevent Defence using AVTECHs for these activities (Issue them a B1 licence, with exclusions for structures and mechanical systems or a B2 licence, encompassing their avionics/electrical systems expertise, with an oxygen extension) Do SMMs and WOEs (E) require licences? SMMs – do they certify maintenance &/ sign CRS? If they do, they’ll require a licence. Possible to gain a C licence via an academic route, but TQ engineers will not be eligible for an A or B licence. However the 3 yrs experience requirement will be difficult to achieve WOEs will have achieved a B1/B2 Who can approve CFUs? TBD

Questions/Discussion?