DASR require that Defence registered aircraft are operated by a Military Air Operator (MAO) organisation (DASR ARO.100). MAOs are ADF organisations approved by DASA through the issue of a MAO Certificate (MAOC).
An independent organisational approval of an organisation provides assurance of the ongoing safety of aircraft flight operations. The MAOC is the mechanism to achieve this approval and assurance.
Seeking initial organisation approval and maintaining this organisation approval involves close liaison between both DASA and the MAO, and carries mutual accountabilities. The outcome sought by both parties is the establishment and maintenance of an approval basis.
DASA must approve a MAO seeking to operate within the Defence Aviation Safety Framework (DASF) against DASR for the scope and level of operations required by their organisation, before their organisation can operate. Once approved, they become an ‘Approved Organisation’ for the defined scope and level of operations shown on their MAOC.
MAO is a regulatory term that is applicable to an organisation approved by the DASA to conduct Defence aircraft flight operations. To become a MAO the commander of the organisation nominated by their Service must apply to DASA by submitting an Operations Compliance Statement (OCS). DASA assesses information in the OCS to assure that it forms the basis of judgement for the suitability of flight operations of an airworthy aircraft, maintained operated to approved standards and limitations, by competent and authorised individuals, who are acting as a member of an approved organisation.
DASA may award a MAOC when satisfied that the MAO can safely conduct flight operations. The MAOC is accompanied with an Operations Specification (OpSpec) issued by DASA. The OpSpec contains the details of the scope of operations with any specific DASA approvals, conditions or limitations. An OpSpec annex is applied to the OpSpec to define the operations of each aircraft type to be operated.
While changes to a MAOC are infrequent, the OCS and OpSpec require amendment when circumstances change and OpSpec authorisations require updating. When an MAO identifies the need for an amendment to the MAOC or OpSpec, they are to apply to DASA using an OCS to seek those changes. The OCS must include factual and documented evidence that supports the proposed amendment. Subjective material or unsigned documents do not meet the suitable evidence requirement to support a submission.
Beyond initial approval, if an MAO is to keep operating under DASR, they must maintain their organisation approval basis. DASA approved updates to the approval basis are required for the introduction of new capabilities, changes to DASR, or for significant improvements to the organisational system of management. Maintenance of OpSpec currency is essential to ensure it accurately reflects current operations.
Accountability. The commander of a MAO organisation nominated by a Service is the Accountable Manager (AM) and their position listed in the OCS. Throughout the DASRs there are specific requirements placed on the AM. While delegation of the execution of these requirements is permissible, accountability for DASR compliance remains with the AM as part of their command responsibilities and cannot be delegated.
The AM appointment in the DASR establishes an accountable officer responsible for the implementation of DASR within an organisation and subordinate units. All authority for an AM to implement DASR comes from their appointment to command of that organisation and not their nomination as an AM. The nomination as an AM does not empower the officer, rather it establishes, within the DASF, their accountability for DASR compliance under the WHS Act 2011.
Chain of command. DASR compliance does not affect the chain of command. A MAO’s higher commander may elect to retain or direct implementation of DASR compliance at their level. Should this occur, the higher commander’s directions must be compliant with applicable DASR. This will create a situation where the higher commander and the MAO-AM become shared duty holders and accountable for their respective implementation of DASR11. The MAO OCS should reflect all specific circumstances, and from this, DASA will conduct oversight and enforcement appropriate to the context of the organisations.
Where DASR 21, Part M, 66, 145 and 147 call for and place requirements on an AM, the MAO-AM is the AM for their subordinate units subject to those regulations.
Initial Issue and variation of MAOC and OpSpec. The applicant organisation is to submit DASR Form 139a accompanied by an initial or updated OCS. When satisfied that all the requirements have been met DASA will issue or vary a MAOC and OpSpec.
Operations Compliance Statement. An OCS, submitted in accordance with the requirements detailed in DASR ARO.100, demonstrates readiness to conduct flight operations in accordance with the requirements of a MAOC.
With the exception of editorial and some administrative amendments, all applications for initial issue and variations of a MAOC or an OpSpec must provide factual and documented evidence. This evidence can take the form of published orders, instructions and publications (OIP), reports or certificates issued by a competent authority or other factual data. Draft documents or opinions do not constitute suitable evidence.
The OCS must include an attestation by the MAO-AM that:
the AM is accountable for the Organisation's compliance with DASR
the OCS is complete and correct
appropriate arrangements are in place to support the scope of flight operations contained in the Operations Specification.
The task of establishing or varying the MAOC may be conceptualised through steps shown below in Figure 1.
Figure 1: Generic Steps of MAOC establishment and amendment
Step 1: Establish Operational Parameters. The DASR Flight Operations regulations are a structured suite of requirements applicable to military aviation. These rules apply to all MAOs; however, a MAO will only need to demonstrate compliance to regulations that pertain to their planned operations.
Step 3: Planning. Successful introduction into service usually involves multiple lines of effort from a variety of different stakeholders. These activities include establishing or modifying the flying management system, developing and approving OIP, implementing training (including flight simulation and training devices), approving aeronautical life support equipment, role equipment and portable electronic equipment and risk management. These activities often relate to outcomes in the initial or continuing airworthiness streams of work. Given the potential for multiple interrelated lines of effort, it is recommend practise to develop a program of work plan to implement flight operations arrangements. Whilst not compulsory for all programs, it is advisable to produce a DASA endorsed Operational Authorisations Plan22 (OAP).
Step 4.a: Documentation. A MAO demonstrates compliance to the flight operations regulations by producing a suite of orders, instructions and publications, which record all aspects of the flying management system. At the apex of this documentation suite is the Operations Compliance Statement (OCS). The OCS records essential information about the proposed operations and limitations and provides traceability to relevant OIP, to establish the means of compliance to each applicable flight operations regulation. For a MAO to apply for a new OpSpec annex or to amend the existing OpSpec, the OCS must include the approval and references in the documentation applicable to the change.
Step 4.b: MAO Application and Attestation. The MAO must make a formal application to DASA to request a variation of the MAOC or OpSpec (see DASR ARO.100.C). This application must contain details of the changes required, evidence of compliance to the relevant regulations and an attestation from the MAO-AM confirming the OCS is complete and that that appropriate arrangements are in place to support the scope of flight operations contained in the OpSpec. DASA considers the MAO-AM attestation to be a significant part of the MAO approval process. As a result, the prior work done on applicability, planning and documentation stages should all support this attestation. Furthermore, at the time the MAO AM makes the attestation all documentation should be completed and available for review.
Step 5: DASA Assurance and OpSpec Issue. Submission of an application is via the DASA registry. Upon notification, DAVNOPS staff will review the application and conduct a desktop audit of the evidence to gain confidence that the MAO flying management system is suitable to the proposed scope of operations. Depending on the nature of the proposed changes, DAVNOPS may also conduct other safety assurance activities such as an on-site audit. When DASA is satisfied that the MAO has enacted suitable measures, it will prepare and approve a revised OpSpec.
The DASA is the issuing authority for a MAOC33 and the associated OpSpec, and any subsequent amendments to the MAOC and OpSpec.
DASA may issue a MAOC when satisfied that the MAO can safely conduct flight operations. Submission of an OCS, in accordance with DASR Part ARO.100, demonstrates readiness to conduct flight operations in accordance with the requirements of an MAOC.
MAO Certificate. The MAOC is a single page certificate to authorise flight operations. Submission of an OCS in accordance with DASR ARO.100 demonstrates readiness to conduct flight operations.
MAOC Operations Specifications. The OpSpec contains the detail of the MAO operations conducted under the MAOC.
Key personnel. The entry in the ‘Key personnel’ list is by appointment. An individual posted to the appointment becomes accountable for requirements of that position. A commander may determine the duties of the appointment. When an individual is temporarily assigned the duty of one the ‘Key personnel’ appointments, they become accountable for those duties for duration of the appointment unless there is a limitation specified in the promulgation.
Specific Approvals (if required). Aircraft require specific approvals that detail performance based navigation system capability to access designated airspace with reduced separation criteria44 or conduct nominated terminal flight procedures. DASA provide specific approval for performance-based navigation systems and record that in the OpSpec55. A MAO applying to DASA for a Specific Approval must support the application with factual and documented evidence that may include technical assessments, training documentation and other FIC elements.
Limitations or conditions (if required). Limitations or conditions prescribed by DASA are to assure safe operations of a particular aircraft type within the ability/experience of the MAO. Operational limitations do not replicate airworthiness limitations contained in airworthiness instruments / documents such as the MRTC, or flight manual. Typically, an operational limitation will include reference to a plan and timeline to remove the limitation by the closure authority. When the appointment of closure authority is outside of DASA or the MAO, the appointment holder is to support the MAO raising an OCS for submission to DASA to amend the OpSpec. Once the closure authority has approved closure of a limitation or condition, the MAO may conduct operations without the imposition of the limitation or condition. However, the MAO should provide DASA with an updated OCS, minimising the period of a conflict between the published limitation or condition and the conduct of operation. This will alert DASA to the change, which may affect the conduct of DASA assurance activities.
Adding new aircraft type to the OpSpec. When acquiring a new aircraft type an applicant (MAO or their representative, such as a Project Office) should seek allocation of an Application Identifier (AI) for the aircraft once Government has approved the acquisition. On receipt of an application for a new AI, DASA will add a new annex to the OpSpec annotated as ‘Reserved’. When ready to conduct operations, the MAO will submit an OCS with applicable documentation seeking to vary the OpSpec.
Interaction and timing. An SOIU and OpSpec are linked. An SOIU must have DASA endorsement and approval before proceeding with an application to add an aircraft to an OpSpec. The roles and tasks, CRE and aircraft usage defined in the SOIU forms the OpSpec operational boundaries.
Approval of an application for a MAOC and initial OpSpec nominally takes six to eight weeks upon receipt by DASA. This timeframe does not take into account an application for PBN approvals, which is an independent process. PBN approvals nominally take six weeks dependent on the factual and documented evidence. Recommend early engagement with DASA-DAVNOPS.
Initial Approval. To gain an initial Organisational Approval, the MAO must first create a local system of management that reflects DASR requirements for the proposed scope and level of activities, as captured in the approval basis. The expectation is that a MAO will liaise with DASA as part of the development process, before the system is ready for DASA evaluation.
DASPMAN Volume 3 Chapter 5 provides further guidance on regulatory oversight and enforcement activities.