Chief of Air Force Air Marshal Gavin 'Leo' Davies has described the implementation of the new Defence Aviation Safety Regulations (DASR) as a ‘seminal moment’, which has fundamentally changed the way military aviation safety is overseen.

Nigel Pittaway | Melbourne

“Australia leads the world with the introduction of the Military Air Operator,” AIRMSHL Davies said. “The MAO consolidates accountabilities for safe flight operation and continuing airworthiness under a single, accountable aviation commander.” 

The relationship between the MAO, SPO and industry is strengthened under the new construct.

The initiative is also good news for industry, as its adoption paves the way for mutual recognition of civil and military competencies and qualifications, potentially providing greater opportunity for civil companies to maintain ADF aircraft.

What is an MAO?

The MAO construct recognises that military aircraft are operated differently to their civilian counterparts and there are sometimes requirements to continue operations outside standard airworthiness regulations. For example during a conflict, it may be operationally necessary to fly an aircraft in a condition that would normally not be considered airworthy.

“The regulations allow operational commanders to operate an aircraft outside its certification basis or without a valid airworthiness instrument in an emergency, or compelling operational circumstance, as long as the decision to do so is based on the application of sound risk management principles,” explained Air Commodore James Hood, Director General – Defence Aviation Safety Authority (DG-DASA) to ADM.

While the principle is not new – the ADF was able to operate outside the old airworthiness regulations on a contingency basis through the previous Operational Airworthiness Authority - the MAO is designed to consolidate accountabilities for continuing airworthiness and flight operations under a single accountable aviation commander. Under the MAO construct the single accountable person is the One-star Force Element Group commander.

“The MAO is the central appointment for the safe operation of aircraft under the DASR,” AIRCDRE Hood continued. “The FEG commander is accountable for delivering capability outcomes while ensuring that aircraft continue to remain airworthy and personnel in the chain of command remain safe.”

Designing the new structure

Under the previous Operational Airworthiness Authority construct, responsibility for the safe operation and continuing airworthiness management of ADF aircraft was fragmented, with responsibilities spread throughout the services and CASG. Before the MAO, the delegate of the safety authority was a two-star officer, with the squadrons themselves responsible for the operational maintenance of their platforms. Engineering support and logistics was the responsibility of the Systems Program Office (SPO) within CASG.

Today the Chief of Air Force issues the FEG commander with a Military Air Operator Certificate and he, or she, together with a Group Captain Engineer (or equivalent), is responsible for the continuing airworthiness management and safe operation of all platforms under their command. Under this system the FEG Commander becomes the MAO Accountable Manager and the GPCAPT Engineer is the Continuing Airworthiness Manager (CAM).

Each of the five FEGS within the RAAF therefore has their own MAO responsibility. Commander of Forces Command is the MAO for Army aviation and the Commander Fleet Air Arm fulfils the role for Navy.

In effect, the design function in a SPO becomes the equivalent of the EASA/CASA Part 21 engineering organisation and the maintenance function in a squadron is equivalent to a Part 145 maintenance organisation. All other continuing airworthiness functions historically performed by a SPO or squadron are now overseen by the accountable MAO and CAM.

AIRMSHL Davies compares the FEG Commander to the CEO of an airline, accountable not only for the continuing airworthiness of their aircraft but also for the safety of flight operations.

“Safety remains a Command responsibility. The DASR reinforce obligations in the Workplace Health & Safety Act 2011 for MAOs to ensure that aircraft continue to remain airworthy and all aviation safety risks are either eliminated or minimised so far as is reasonably practicable in the circumstance,” he said.

“While the DASA is clearly analogous to CASA, the MAO operates within the military chain of command and takes direction from above, as would the CEO of an airline from the Board of Directors.”

Flexibility and industry opportunities

The new construct allows the FEG Commander a great deal more flexibility to have aircraft maintained or repaired and opportunities for industry are enhanced as the DASR become more closely aligned with CASA or other civilian airworthiness regulations and more militaries adopt the European Military Airworthiness Regulations (from which DASR are derived).

“The DASR allows for simplified recognition arrangements with other aviation safety authorities; rather than relying on the bespoke, elaborate and inflexible arrangements of the past. Under the new framework an MAO can fly an ADF aircraft into another country and, provided the safety authority is recognised, the CAM can approve for maintenance to be performed at a local civilian or military (Part) 145-equivalent organisation,” AIRCDRE Hood explains.

This has obvious benefits when operating outside Australia for example, where platforms such as the 737-derived Wedgetail or A330-based KC-30 could have maintenance or repair work carried out by an approved civilian Part 145 organisation in-theatre.

Air Commander Australia Air Vice Marshal Steve Roberton says the relationship between the MAO, SPO and industry is strengthened under the new construct.

“Most of our new platforms increasingly rely on global supply chains, the provision of design services from centralised organisations in the US, and shared maintenance services in or near theatres of operations. Increased recognition amongst coalition and regional partners offers the MAO greater flexibility to exploit the strengths of various continuing airworthiness arrangements, for different platforms and scenarios, rather than being locked into the bespoke and inflexible support arrangements of the past,” he said to ADM.

“In the future, I see MAOs approving Australian aircraft to be maintained by coalition partners in theatre, and vice-versa; potentially with blended workforces, shared facilities and equipment, and supported by a single supply chain for all aircraft of a common type.”

This article first appeared in the June 2017 edition of ADM.