Until 31 January 2020 the UK was a permanent member of the European Defence Agency (EDA), and the Military Aviation Authority (MAA) represented the UK in terms of military airworthiness. The MAA was formed on 1 April 2010 in response to the recommendations made by The Rt Hon Lord Justice Haddon-Cave, in his review into the RAF Nimrod, in-flight fire and subsequent crash, that killed 14 service personnel in Afghanistan in 2006. The ‘Nimrod Review’ called for a radical overhaul of military airworthiness regulation.
According to the MAA, licencing British military aircraft engineer technicians to a common European standard would involve incorporating European Military Airworthiness Requirements (EMAR) 66 and 147 into the MAA regulatory publications. An initial decision not to implement these regulations was taken by the MOD in 2015, with the requirement for the MAA to review in 2019. A Whitehall briefing note published on 15 June 2020 (https://is.gd/lebafi), confirms that decision.
As a former member of the EDA, the MAA did adopt three European regulations it felt would fill shortfalls in UK military airworthiness policy, or improve air safety. These cover aircraft certification, design and production; continuing airworthiness management and maintanence organisations. Its decision not to adopt the EMAR regulations that cover the regulation of training syllabi, approvals and issuance of licences and the regulation and assurance of air engineer technician maintenance and training providers differs from best practice by civil aviation regulators around the world, who universally regulate both maintenance training organisations and maintenance licences.
According to the MAA, EMAR 66 and 147 are currently neither beneficial in terms of adding safety, nor fit for purpose in terms of some elements being ‘too rigid and outdated’.
In addition, now that the UK has left the EU, it is highly likely that it will have zero influence within the EDA. So Brexit could be a significant influence over the MOD’s decision.
Another major factor is future aircraft platforms. The UK has been a major player in the European defence industry for many years. But Britain’s defence chiefs have been outspoken in their objection to a European Defence Force for some time. While the EU continues to develop more comprehensive defence cooperation between the EU27, it is still NATO and not the EU that undertakes the vast majority of defence-related activities and decisions in Europe. And the UK has become progressively more aligned with the US in terms of equipment procurement, especially in rotary and fixed-wing combat aircraft.
While researching this piece, an RAF spokesman confirmed: “The RAF is currently undergoing a transformation programme which is looking at how it delivers all engineering capabilities and standards.” As background to this, he added: “How the RAF conducts the engineering aspects of its aircraft is just one of the areas under review; with the aim of ensuring its engineering and technical capabilities are fit for future aircraft platforms.” This suggests that future aircraft engineer training and accreditation could be better aligned with US standards in the years to come.
There is no doubt that COVID-19’s effect on the economic landscape will have a profound effect on the defence budget. Some countries, such as Thailand and South Korea, have already reduced their military budget to allocate more funds to their pandemic response. The UK defence budget is around 2% of GDP and there were already financial black holes in multi-year equipment replacement plans, pre-lockdown. In a contracting economy and with Covid-19 a big influence, the MOD’s budgetary priorities are changing. It cannot be ignored that, since the Armed Forces played such a vital and visible role in the initial response to the coronavirus crisis – and still do behind the scenes - public perception of them as saviours and supporters of resilience at home, will have a long-lasting effect on how budgets are allocated.
This was highlighted by defence secretary Ben Wallace at a recent Defence Select Committee hearing that reviewed the UK Armed Forces’ response to the virus. Wallace said the UK needs to ask questions of whether it is spending money in the right places, and whether or not the pandemic has changed the nature of threats the UK has to deal with.
The MMA’s latest review into the potential implementation of EMAR 66 and 147 revealed it would be required to assess and approve around 60 military training organisations and issue up to 17,500 military aviation maintenance licences (MAML). Concerns were also raised over the highly prescriptive and mandatory structure of the part 66 basic course (the air engineer foundation training course). The MMA says it departs significantly from that of the existing, flexible, single service, Phase 2 training and Phase 3 career course requirements and content. This results in increases to training course length, bringing all three services’ training programmes and standards under one common syllabus, in addition to potential impacts to trade and rank structures. All of the above comes with significant additional, financial and people cost, at a time when the government is looking to reduce defence spending, so it can divert the money to fund more pressing needs in the political sense.
CURRENT UK MILITARY STANDARDS
Military aviation technician training is informed and directed by the defence policy, as described partly in Joint Service Publication (JSP) 822. It states: “Underpinning all training and education activities is the Defence Systems Approach to Training (DSAT).”
Army aviation-specific training is DSAT compliant, in accordance with JSP 822, according to deputy chief aircraft engineer Lt Col Steve Bharat of the Corps of Royal Electrical and Mechanical Engineers (REME), which is responsible for the maintenance of the British Army’s aviation assets and training its air engineers and technicians.
This involves specific levels of primary, secondary and tertiary audits and assurance to meet the required standard, as outlined in the MAA’s MRP 145.A.30(e) Regulatory article 4806(5), which says: “All personnel who maintain air systems, air system components and associated equipment, including contractor staff, should be trained, assessed as competent and authorised for specific tasks and roles.”
Bharat explained that, at the most basic level, the army works back from the suite of engineering authorisations (EA) to ensure that the training course content meets the requirement to assure competency. Topics are delivered in ‘MODules’ and are taught and tested through stringent examinations, practical activities, completed on training aircraft and activities such as role play.
According to Bharat, in 2017 the Training Development Standards Organisation within the Defence School of Aeronautical Engineering compared REME aircraft and avionics technician training, against Civil Aviation Authority (CAA) and European Union Aviation Safety Agency (EASA) part 66 MODules. This activity was supported by the CAA.
The result was that the majority of courses delivered by the School of Army Aeronautical Engineering (SAAE) was able to be directly cross-mapped with the framework (noting that currently they have not been technically accredited by the CAA). The training ‘delta’ limited by those MODules that have less relevance to military engineers. He said an example of this is MODule 10 Civil Aviation Legislation, which corresponds to (but is not cross-mapped with) the Military Aviation Legislation MODule. MODules such as in-flight entertainment and wooden structures are not covered through the Army’s training.
Conversely, there are areas of training which are not covered by the CAA MODules, such as defensive aid suites and aircraft mounted weapon systems. The Army also trains to operate in challenging and austere conditions, where the maintenance of aircraft and the robust application airworthiness standards cannot be compromised, when operating away from the normal main operating base or ‘airport services’.
Additionally, the military operates Continuing Airworthiness Management Organisation (CAMO) structures in line with EASA and EMAR standards. Considering the span of military operations, diversity of locations and facilities, and in certain situations very limited lines of communications, the Army must adapt its airworthiness decision making processes to meet CAMO’s stringent requirements, while enabling operational output, Bharat says. This brings additional training requirements and challenges for the Army.
While the MAA has decided to not formally adopt the EMAR regulations, the Army has been incorporating some aspects of them for the last three years. Bharat confirmed that the Formal Training Statements for new courses, being delivered at the School of Army Aeronautical Engineering since 2017, have identified where the correlation with EMAR 66 standards may be present and have mirrored MODule competencies to ease future cross-mapping.
An example is the MAE Technician Avionics course (F025A) which teaches the common MODule ‘Electrical principles relevant to aviation engineers’ using content derived from EMAR 66 MODule 3 Sections 3.8, 3.9, 3.10, 3.11 and 3.16. He adds that this practice has has been deliberate.
“Reflecting EASA and EMAR standards in routine Army Aviation training enables easy read-across to internationally recognised standards of training for our technicians,” he explains. “It provides a more coherent training environment for contractor delivery (reducing design costs) and lessens the additional training requirement for when and if we require military personnel to maintain aircraft that are on the civil register.”
It is worth looking away from the strategic and operational justifications and implications of the MAA’s decision and considering the careers of men and women who maintain and repair Britain’s military aircraft.
Over recent years, the Armed Forces have had concerning staffing shortages. One incentive to sign up is the alignment of military trade qualifications with civilian equivalents. Many of the Army’s technical trades have achieved this, especially in logistics. In fact the Army now prides itself as being the UK’s biggest apprenticeship provider. The MAA’s decision not to put in place a means of licencing military aircraft engineers and technicians, by virtue of walking away from the EMAR regulations, places these service men and women at a disadvantage, should they wish to pursue a second career in the aviation engineering sector in civilian life. Many leave the services in their early 40s, after a full military career.
Bharat confirms: “The Army’s chief air engineer is interested in expanding how we enable technician to attain CAA Aircraft Maintenance Licences. There are numerous advantages to this, including retention of our valuable people, widely recognised standards for our highly qualified aircraft maintainers and a benchmark for standards that have a recognised regulated framework that are also recognised by the UK’s multinational partners.”
As part of the RAF’s transformation programme, it is considering alternative employment options that may include recruitment from industry into the regular Services workforce. Air Command says it has also recently instigated a separate review into future licensing of aviation technicians. This review is still in its early stages and has not yet concluded.
Whether the underlying reasons behind the MAA’s decision are Brexit, budget, or both, it is apparent that the MAA’s decision has wrong-footed the military’s grass-roots air engineering community. It is now looking at alternative ways of gaining accreditation and international recognition for highly-skilled aircraft engineers and technicians. Failure to do so could pose further problems for recruitment and retention, which won’t go down well with the chiefs of staff of the armed forces.