Annex B provides a non-exhaustive list of examples intended to illustrate the conduct of the Military Permit to Fly (MPTF) process within the DASR context. Where uncertainty exists, contact a DASA Desk Officer (DIA-TC or DAVENG), the platform DoSA, or a DoSA-FT (for MPTFs related to flight test).
EASA implementation of permits to fly stipulates a single aircraft may only have one valid permit allocated at one time, and that a permit to fly may only be applicable against a single aircraft. In order to accommodate Defence use of MPTFs, which is focussed on providing in-service flexibility within a military environment, AUS-unique DASR Acceptable Means of Compliance (AMC) and Guidance Material (GM) allows for concurrent MPTFs being valid against an individual aircraft, and for a single MPTF to be valid against more than one aircraft. Therefore, the scope of an MPTF application may include:
Type MPTF. Applicable to all aircraft of that type within a fleet. For example, an MPTF that authorises initial operation of a new aircraft type prior to award of a Military Type-Certificate (MTC).
Multi-tail MPTF. Applicable to a subset of aircraft within a fleet. For example, authorisation to fit a range of self-protection modifications to a number of Defence aircraft prior to an overseas deployment.
Tail-specific MPTF. Applicable to an individual aircraft tail number, which aligns to the traditional use for authorising flight with deficiencies/conditions particular to an individual aircraft. For example, for ferry flights to rectify damage.
Considerations for Multiple/Concurrent MPTFs. The potential for multiple MPTFs being applicable to an individual aircraft tail number, or a single MPTF having applicability to more than one tail number, requires the applicant for a new MPTF to ensure that organisations developing technical and operational substantiation for flight conditions are aware of existing MPTFs, and new MPTFs are raised only where the scope of the non-compliance to airworthiness or aviation safety requirements being addressed falls outside what would be considered as a change to existing MPTF(s).
As an example, where an extant MPTF provides authorisation to operate with a yet-to-be-approved modification, any significant defect or damage to elements of that modification, may be managed via a change to the existing MPTF; whereas an MPTF to support a ferry flight to a maintenance venue for an overdue structural inspection not associated with the modification is best processed as a new permit.
Furthermore, whilst Military Air Operator (MAO) understanding and execution of holder obligations for conditions and/or restrictions associated with a single MPTF may be relatively straightforward, in instances where multiple MPTFs may apply to individual aircraft, the holder of multiple MPTFs must establish systems to meet concurrent obligations. Therefore, the MAO must implement systems to ensure aircrew/authorising officers have visibility of an aircraft’s configuration and all relevant flight conditions and/or restrictions that enable safe flight under respective MPTFs, and correctly apply those that are applicable by ensuring aircraft maintenance and aircrew documentation adequately reflect requirements which are visible to aircrew on a flight-by-flight basis.
As an example, the aircraft technical log is amended (e.g. a defect raised) to accurately record the non-conformant condition and to reference the authorised MPTF that closes/defers the defect and informs aircrew of specific requirements. Flying Orders may also be used to provide pre-flight visibility of approved conditions to aircrew.
Potential scenarios where multiple, concurrent MPTFs may occur for individual aircraft include:
A Defence aircraft fleet operates initially under a Type MPTF in-lieu of a MTC/MAOC (when the status of the type-certification programme does not yet support award of a MTC). During operations under this Type MPTF, an individual aircraft is then damaged (e.g. bird strike, hail damage, overstress event, etc) and lands at a remote airfield. A concurrent, tail-specific MPTF is then also required to authorise a ferry flight to a suitable maintenance facility.
AWC is conducting flight trials to generate evidence for clearance of a new store. The evidence is contingent upon operation in various weather conditions and a multi-tail MPTF is therefore made applicable to all aircraft within a specific SQN. When required, weather conditions are forecast, and an available aircraft is fitted with the test store and a test flight is conducted, under the MPTF authorisation.
A number of Defence aircraft are deployed to an overseas area of operations, but prior to departure require fitment of aircraft self-protection modifications not yet approved under DASR-approved designs. A single, multi-tail MPTF for all modifications applicable to the subset of aircraft being deployed is raised. In this case, depending upon the mix of modifications to be fitted, the option for more than one MPTF to cover fitment of the modifications is also possible.
Scenario: Bespoke major modification for in-service Defence aircraft by a DASR MDO
A DASR Military Design Organisation (MDO) has been contracted by a CASG acquisition SPO to design a modification to an in-service aircraft. The modification will require an assessment of the general behaviour of the aircraft as part of compliance demonstration. Developmental flights for modification testing and generation of compliance demonstration evidence are to be conducted by ADF test aircrew under a Defence MAO’s authority, prior to supplemental type-certification of the modification by DASA.
Application for approval of Flight Conditions
Determination that MPTF is needed (Applicant). The SPO, in conjunction with the aircraft’s MAO, determine the flight test category for the compliance demonstration flights as Category 2 IAW DASR.FT.05, and hence an MPTF is required. As a Category 2 test is required, the SPO seeks AWC assistance for test conduct. AWC decide to conduct the test activities under the control of their own MAO and are best-placed to apply for flight conditions and the MPTF.
Technical substantiation. The modification of the baseline aircraft is quite extensive and hence a significant volume of technical substantiation is required. The SPO has maintained ongoing liaison with the MDO throughout the development phase and has obtained Type Design documentation, including completion of compliance demonstration evidence (as well as findings not related to flight test). These documents are formal in nature, signed by appropriate MDO staff, and include, with justification, flight conditions required for safe flight during the development and compliance demonstration testing.
Operational substantiation. IAW DASR.FT, operator substantiation and endorsement for a Category 2 test activity must be provided by a MAO member with appropriate flight test authorisations as determined by a DoSA–FT. In this case, AWC authorised staff review and endorse the adequacy of the flight conditions. Operational limitations inputs to flight conditions are derived from review of the technical documentation plus operational planning (i.e. test risk management) activities and are collated within an appropriate document (such as a Flight Test Plan).
Declaration of Safety. AWC staff collate technical substantiation from the MDO (via the SPO and/or MTC Holder) and the internally-generated operational substantiation/endorsement, sign the DASR Form 18b Declaration of Safety and submit to the Authority (DoSA-FT) for approval.
Approval of Flight Conditions. The DoSA-FT receives the application and conducts assurance review and approval. On approval, the Form 18b is signed by the Authority and returned to AWC staff.
Application for issue of MPTF
Organisation conducting the flight (Applicant). As AWC is the MAO under which the flight test activity will occur, appropriate AWC staff raise a DASR Form 21 and submit to the DoSA-FT requesting issue of the MPTF. This generally occurs coincident with the application for flight conditions.
Issue of MPTF. A Category 2 flight test MPTF may only be issued by a DoSA-FT. The AWC MPTF process supports direct forwarding of the application to the DoSA-FT for assurance review and issue.
Scenario: Bespoke minor modification for in-service Defence aircraft by a DASR MDO
A DASR MDO has been engaged by a CASG sustainment SPO to design and certify a minor modification to an in-service aircraft. Developmental flights for modification testing and generation of compliance demonstration evidence are to be conducted by ADF test aircrew under the aircraft MAO’s control prior to approval of the modification as a minor design under the MDOA’s privilege.
Application for approval of Flight Conditions
Determination that MPTF is needed (Applicant). The SPO, in conjunction with the aircraft’s MAO / CAMO, determine the flight test category as Category 4 IAWDASR.FT.05; hence an MPTF is required. A Category 4 test can be conducted within the aircraft MAO’s control, with this MAO / CAMO being best-placed to be the applicant for flight conditions and the MPTF.
Technical substantiation. The SPO, through liaison with the MDO during the development phase, has obtained Type Design documentation completed up to this point, including completion of compliance demonstration for all findings not related to flight test. These documents are formal in nature, signed IAW the MDO procedures, and include identification of, and justification for, flight conditions required for safe flight during the development and compliance demonstration testing.
Operational substantiation. As a Category 4 test activity, operational substantiation and endorsement must be provided by a competent member of the MAO, as determined by a DoSA-FT. In this case, the selected member reviews and endorses the adequacy of the flight conditions. The operational inputs to the flight conditions are derived from the technical substantiation, plus the operational planning (i.e. test risk management) activities and are collated within an appropriate document (such as a Flight Test Plan) by the MAO test staff.
Declaration of Safety. A MAO / CAMO staff member (such as the CAM or other authorised staff member) collates technical substantiation from the MDO (via the SPO) and operational substantiation and endorsement from the MAO staff member authorised by the DoSA-FT, signs the Declaration of Safety on DASR Form 18b and submits to the Authority for approval.
Approval of Flight Conditions. The Authority (DASA desk officer or platform-aligned DoSA) receives the application and conducts assurance review and approval. The Form 18b is signed by the Authority (or platform-aligned DoSA) and returned to the MAO / CAMO for use in the MPTF application.
Application for issue of MPTF
Organisation conducting the flight (Applicant). MAO staff under which the flight test activity will occur raise a DASR Form 21 and submit to the Authority (or platform-aligned DoSA) requesting issue of the MPTF. This step may occur coincident with the application for flight conditions.
Issue of MPTF. A Category 4 flight test MPTF may be issued by the Authority (or DoSA with appropriately-scoped MPTF delegation). The Authority (or platform-aligned DoSA) processes the Form 21 and issues an MPTF (Form 20b) to the requesting MAO staff.
Scenario: Aircraft damage in remote unsupported location
A transport aircraft in a remote location has sustained structural damage outside limits published within the Structural Repair Manual (SRM), which has rendered the Military Certificate of Airworthiness (MCoA) invalid. Repair of the damage at the remote location is considered impractical due to the level of equipment/facilities required to conduct the repair and MDO approval of unrepaired damage is not supported.
Application for approval of Flight Conditions
Determination that MPTF is needed (Applicant). The damage is outside of the Instructions for Continuing Airworthiness (ICA) limits and is considered to impact flight safety. The MAO (through its CAMO) determines that in-location repair is not practicable and hence an MPTF is needed to ferry the aircraft to a suitable repair venue. In this case, the CAMO is the most-appropriate applicant for approval of flight conditions.
Technical substantiation. The CAMO requests an engineering organisation with appropriate aircraft knowledge to provide a technical substantiation that the aircraft is safe to fly. The engineering analysis determines the aircraft can fly safely when subject to a number of limitations (e.g. pre-flight inspection, post take-off controllability check, straight and level flight while in transit, etc). This information is provided to the CAMO as formally-approved engineering advice/report.
Operational substantiation. The flight conditions contained within the engineering advice are reviewed and endorsed by an authorised MAO staff member. The review confirms the flight conditions in the engineering substantiation are deemed appropriate and also identifies additional operational conditions (e.g. a CAT B or higher aircrew to fly the aircraft, single aircrew only, etc).
Declaration of Safety. Upon obtaining technical substantiation and operational endorsement of the proposed flight conditions, the MAO Accountable Manager (or authorised representative) makes a declaration that the aircraft is safe to fly in the configuration and subject to the proposed flight conditions. The declaration is made, and signed for, on DASR Form 18b, then submitted to the Authority for approval.
Approval of flight conditions. The Authority (DASA desk officer or platform-aligned DoSA) receives the application and conducts assurance review and approval. The Form 18b is signed by the Authority (or DoSA) and returned to the MAO / CAMO for use in the MPTF application.
Application for issue of MPTF
Organisation conducting the flight (Applicant). As the MAO has the need to ferry its aircraft for repair, the CAMO applies for the MPTF using DASR Form 21. Part of that application is the requirement to provide reference to the approved flight conditions established and approved on Form 18b. This step may occur concurrently with the application for flight conditions.
Issue of MPTF. Upon receipt of the Form 21, DASA staff (or platform-aligned DoSA) conduct assurance review and approval. If satisfied the MPTF is issued on a Form 20a to the applicant.
Scenario: Continued operations beyond an Airworthiness Limit
An aircraft has made an unplanned landing at an away-base location, giving rise to the situation whereby a scheduled servicing linked to an Airworthiness Limitation (AwL) is now due. The servicing cannot be performed away-base, which has rendered the MCoA invalid. In this scenario, whilst initially considered, temporary extension of the AwL for this individual aircraft via DASR 21.A.445 unrepaired damage provisions (see also para 16 below) was deemed to not apply, for it was not possible to demonstrate that the temporary extension of the AwL in this instance (and any additional maintenance actions to support) was within the risk inherent in the TCB (and thus an elevated level of risk is present).
Application for approval of Flight Conditions
Determination that MPTF is needed (Applicant). An MPTF is required, since in this case, the Aircraft Maintenance Programme (AMP) cannot be complied with, and an AwL extension is not within the scope of the CAMO’s authority. The MAO (through its CAMO), who has the need to ferry the aircraft to a maintenance venue, should apply for an MPTF.
Technical substantiation. The CAMO requests an engineering organisation with appropriate aircraft knowledge to provide an engineering determination that the aircraft is safe to fly. In this case, the engineering analysis determines the aircraft can fly safely when subject to a number of limitations (e.g. additional pre-flight inspections and minor maintenance actions) and provide this information to the CAMO as formally approved engineering advice/report (note this is not an approved design, which would restore the extended interval to an approved configuration, hence negating the need for an MPTF).
Operational substantiation. The flight conditions contained within the engineering advice are reviewed and endorsed by an authorised MAO staff member. The review confirms the flight conditions are deemed appropriate and no additional operational conditions would practicably improve the safety of the flight.
Declaration of Safety. Upon obtaining technical substantiation and operational endorsement of the proposed flight conditions, the MAO (through the CAM or other authorised representative) makes a declaration that the aircraft is safe to fly in the configuration (i.e. with overdue maintenance) subject to the proposed flight conditions. The declaration is made, and signed for, on DASR Form 18b, then submitted to the Authority for approval.
Approval of flight conditions. The Authority (DASA desk officer or platform-aligned DoSA) receives the application and conducts the assurance review and approval. The Form 18b is signed by the Authority (or platform-aligned DoSA) and returned to the MAO / CAMO for use in the MPTF application.
Application for issue of MPTF
Organisation conducting the flight (Applicant). As the MAO has the need to ferry its aircraft for maintenance, the CAMO applies for the MPTF using DASR Form 21. Part of that application is the requirement to provide reference to the approved flight conditions established and approved on Form 18b.
Issue of MPTF. Upon receipt of the Form 21, DASA staff (or platform-aligned DoSA) conduct assurance review and approval. If satisfied the MPTF is issued on a Form 20a to the applicant.
DASR 21.A.701(a) includes potential circumstances requiring an MPTF, for instances where an MCoA is yet to be issued:
Development
Demonstration of compliance
Design organisation or production organisation crew training
Flight testing of new production aircraft
Flying aircraft under production between production facilities
Flying the aircraft for customer acceptance
Delivering or exporting the aircraft
Flying the aircraft for Authority acceptance
Market survey, including customer’s crew training.
These scenarios are largely associated with the exercise of MDOA/MPOA privileges for flight conditions approval and issue of an MPTF. The likelihood of these scenarios occurring within the DASR context is very low, compared to the flight test and invalid CoA scenarios. Hence no specific examples for this category are provided within this annex.
Should an MPTF be required in one of these scenarios the prospective applicant should contact DASA for further guidance.
Scenario: New aircraft development for Defence by overseas OEM
An overseas OEM has been contracted to design and certify a tanker aircraft capable of supporting probe-and-drogue and boom re-fuelling. Development includes a major modification to an existing transport aircraft. Developmental flights for product testing and generation of compliance demonstration evidence are to be conducted by the OEM prior to certification by the State of Design.
Discussion
The design and testing occurs under the Authority of the State of Design and IAW the OEM’s own Design Organisation flight test arrangements. As such, despite the aircraft being developed specifically for Defence use, the aircraft has not yet been delivered to the Commonwealth, is not on the Defence register, and the flights for development and demonstration of compliance evidence occur outside of DASA’s framework. In this case no MPTF is needed.
If required, Defence aircrew may be involved in the OEM testing activity, with their involvement supported via specific Authority (Defence)-to-Authority (State of Design) agreement (external to DASR scope).
Scenario: Unrepaired damage
An aircraft in a remote location has sustained structural damage outside limits published in the SRM that has rendered the MCoA invalid. Full repair of the damage at the remote location is considered impractical due to the level of equipment/facilities required to conduct the repair; however, the CAMO has approached a relevant MDO, that has advised they can provide approval for unrepaired damage subject to suitable limitations IAW DASR 21.A.445 Unrepaired Damage. See also Chapter 7.X Annex D, Scenario 4.
Discussion
If the CAMO is able to source a repair (with unrepaired damage assessment) from a relevant MDO (i.e. an MDO with the scope to apply for and hold repairs for the aircraft type) then the aircraft’s MCoA is re-validated. In this case, the DASR 21.A.445 unrepaired damage provision allows for damage to remain unrepaired where other limitations (that are defined as part of the repair) account for any repair shortfalls. In these cases DASR 21.A.445 requires either the Authority, or appropriately-authorised design organisation to assess the unrepaired damage for airworthiness implications. Once the CAMO has both the repair design and airworthiness assessment, the CAMO can release the aircraft for flight IAW the stated limitations. No MPTF is needed.
Scenario: Aircrew work-up per ICA
A MAO is conducting aircrew work-up on a new aircraft type, inclusive of missile firings on an overseas test range to meet the Initial Operating Capability (IOC) schedule. The aircraft have been recently procured, are on the Defence register and have an MTC and valid MCoA.
Discussion
The aircraft type has valid MCoAs for individual aircraft, and are being operated IAW ICA (such as stores loading manuals, aircraft flight manuals, and maintenance publications). Furthermore, the flight profiles being tested/worked-up are within the MAO’s approved mission risk profiles. In this case, the aircraft are flying within the bounds of approved technical and operational data. There is no requirement for a MPTF.