Military Commercial Derivative Aircraft (MCDA) and Federal Aviation Administration (FAA) Approved Meet The Intent (MTI)
DAU GLOSSARY DEFINITION
Military Commercial Derivative Aircraft (MCDA) - A commercial off-the-shelf produced aircraft with a Federal Aviation Administration (FAA) Type Certificate (TC). The aircraft may be modified for use as a military aircraft. Military modifications may be fully or partially FAA-approved to civil statutes for the purposes of achieving type design certification as an input to overall airworthiness certification and to develop continued airworthiness requirements.
Meet the Intent (MTI) - The concept of sustaining a MCDA in accordance with FAA operator regulations in an effort to maintain the FAA-approved Type Design, TC, and AW Certification using US Air Force (USAF) regulations and policies to the greatest extent possible.
The purpose of this article is as follows:
- To define the relationship between Federal Aviation Administration (FAA) regulations and Air Force (AF) policy as it pertains to Military Commercial Derivative Aircraft (MCDA) platforms
- To define the Meet the Intent (MTI) effort and impacts of not meeting requirements to maintain certifications and provide background on unique requirements governing a MCDA
- To provide considerations for selection of an Adaptive Acquisition Framework (AAF) pathway for MCDA
Air Force (AF) Policy Directive (AFPD) 62-6, Department of the AF Instruction (DAFI) 62-601, Military Handbook (MIL- HDBK)-516C all state that when a military mission is compatible with a certified civil usage, the AF will utilize FAA type certified MCDA to the maximum extent practical and that the USAF will leverage Airworthiness (AW) approvals issued by the FAA and other military AW authorities as a basis for USAF approval. MCDA are initially approved for safety of flight by the FAA and may have an FAA approved Type Certificate (TC) of AW.
One primary consideration for selecting a MCDA solution may be the ability to rapidly field capability. While the most common Adaptive Acquisition Framework (AAF) pathway for MCDA programs is the Major Capability Acquisition (MCA) pathway, the Middle Tier of Acquisition (MTA) pathway may be more advantageous when speed is paramount to supporting Warfighter needs with a Commercial Off The Shelf (COTS) approach. The MTA pathway allows for rapid fielding of COTS prototypes for new capabilities or rapid fielding of production quantities with proven technologies that require minimal development. After an appropriate pathway is chosen for a MCDA and the acquisition strategy is developed, the program transitions to the certification effort.
The basic flow down through certification to maintenance is Type Design, TC, to an AW and compliance to the maintenance/operational criteria in 14 Code of Federal Regulations (CFR) Part 121 and ultimately for the USAF to review and coordinate MTI requirements for USAF maintenance/operational in order to maintain all MCDA certifications. A fully Contractor Logistics Support (CLS) program that covers all requirements except organizational (O-Level) maintenance are only required to show compliance to 14 CFR Part 121 Section L (Maintenance, Preventive Maintenance, and Alterations) and 14 CFR Part 121 Section M (Airman and Crewmember Requirements) and have a Maintenance Management Program Plan (MMPP) approved by the FAA with all repairs performed by a 14 CFR Part 145-approved contractor.
- Type Design - The drawings and specifications, and a listing of those drawings and specifications, necessary to define the configuration and the design features of the product
- Type Certificate (TC) - A TC signifies the AW of a particular category of aircraft, according to its manufacturing design (e.g. Type Design). It confirms that the aircraft of a new type intended for serial production, is in compliance with applicable AW requirements established by the public law
- Continuing Analysis and Surveillance System (CASS) - An air carrier quality assurance system. In a structured and methodical manner, CASS provides air carriers with the required information needed to make decisions and maintain maintenance program objectives. If used properly, CASS can become an inherent part of the USAF ability to further ensure a safety culture within the organization
- Service Bulletins (SB) - The document used by the Original Equipment Manufacturer (OEM) of the aircraft, engines, or components to communicate details of modifications and possible safety issues for a specific system
- AW Directives (AD) - Legally enforceable rules issued by the FAA in accordance with 14 CFR Part 39 to correct an unsafe condition
More on Type Design
Per 14 CFR Part 25, 33, and 36, a Type Design includes “The drawings and specifications, and a listing of those drawings and specifications, necessary to define the configuration and the design features of the product.” Per 14 CFR Part 21, a TC is issued when the Type Design criteria of the air system are shown to comply with all FAA required regulations. A TC holder who wants to change a product’s type design may apply to the FAA for an Amended TC (ATC), or a Supplemental TC (STC). An AW Certification is an FAA document which grants authorization to operate an aircraft in flight. An AW Certificate remains valid as long as the aircraft meets its approved Type Design and is in a condition for safe operation and all maintenance (including preventative maintenance) and alterations are performed in accordance with FAA regulations.
MTI of FAA certification refers to the concept of sustaining a MCDA in accordance with FAA operator regulations in effort to maintain the FAA approved Type Design, TC, and AW Certification using USAF regulations and policies to the greatest extent possible.
The origin of MTI started with the KC-46 Pegasus Tanker and the comparison of FAA regulations against USAF policy (AFPD and AFI) to determine compliance. KC-46 received two MTI approvals, the first for the Air Force Sustainment Center (AFSC) Military Repair Station Depot Level (D-Level) maintenance, and the second for the O-Level maintenance capability. While 90 % of USAF policy for the O-Level does MTI, there were areas that required updates to show compliance. Examples include supply management, Extended-range Twin-engine Operations Performance Standards (ETOPS), reporting, and CASS. The MTI teams reviewed FAA Safety Attribute Inspection (SAI) sheets in 35 operational/maintenance areas encompassing ~1500 questions and ~1000 different USAF policy requirements. The effort resulted in a MTI letter from the FAA recognizing that the KC-46 program MTI of FAA guidance. This effort is easily adaptable/scalable to other MCDA programs as a baseline for an effort to recognize that platform as MTI and gain FAA concurrence. Other platforms must seek individual approval and do not fall under KC-46’s approval. There is currently no central organization for AW Sustainment requirements for CDA outside engineering and no overarching approved MTI by the FAA.
What is the value of pursuing this requirement outside the basic acquisition strategy requirements set forth in AFPD 62-6, AFI 62-601, and MIL HDBK-516C? The use of MCDAs offers significant opportunities including the following:
- Reducing development time, adapting more quickly to new technology, and lower life cycle costs by synergizing with industry
- Capitalizing on data access via data ownership, which offers a lower cost option for proven data and technology
- Maintaining program cost and schedule estimates as well as performance metrics that can be driven by the use of firm-fixed price (FFP) contracts
- The potential cost benefit from obtaining and maintaining a TC/ATC or STC aircraft is the use of the FAA-certified parts pool and the FAA sustainment and maintenance baseline for CLS of the MCDA
- Maintaining the MTI allows the USAF to ensures a minimum level of safety and AW equivalent to the aircraft‘s commercial counterpart that allows the USAF to take advantage of Commercial-off-the-Shelf (COTS) training, support equipment, technical manuals, facilities, and the use of CFR Part 145 certified Maintenance Repair Organizations (MROs) and maintenance providers that service commercial aircraft
What Happens if the Service Moves Away from MTI in Sustainment?
To move away from the TC, ATC, or STC for a platform, the USAF would need to pursue a totally different acquisition approach. The use of a MCDA with TC and STCs thru the OEM fosters a reduction in data ownership costs; and therefore, abandoning this strategy would drive the need for TC and STC data ownership. The USAF would need to purchase all Type Design data from the TC owner as opposed to maintaining government purpose rights. The data rights issues would trigger the following additional efforts:
- If the required engineering data is not procurable from the OEMs, then a significant reverse-engineering effort would be required to develop the data.
- In addition, a portion of the previously accomplished tasks for the FAA certification processes would need to be re-accomplished.
- Specifically, if approved TC and STC OEM testing baselines cannot be supported, it may be necessary to re-accomplish portions of those test points in order to validate or establish specific new Military TC (MTC) baselines.
- Future modifications to the CDA platform would also not earn certification under FAA STC rules and would only be able to be accomplished under MTC rules.
- That would eliminate FAA Military Certification Office (MCO) oversight in the certification process, thus causing an increase in time and cost to test and certify modifications and upgrades.
- This course of action would also require additional cost for nonrecurring engineering that would be required for all SB and AD support from the OEM and the FAA.
- Supply management and the use of certified parts pools would be lost and drive spare part inventory requirements to higher levels.
- It would also fracture industry relationships that drive Air Transport Association’s (ATA) Operator/Manufacturer Scheduled Maintenance Development (MSG-3) improvements and prevent future optimization opportunities of scheduled maintenance program from shared data.
Portions of Support without an FAA Approved MTI
There are a few examples where the USAF did not pursue MTI of FAA regulations and measures. These include supply management and program monitoring. This tailoring was developed with FAA, Defense Logistics Agency (DLA), AFSC, and Air Mobility Command (AMC) supply leads. This team collaboratively developed changes to DLA policy for consumable parts, AFSC Supply Chain Management Group policy changes for D-level repairable parts, and the processes to cover commercial pedigree parts to maintain type design requirements. Processes for reporting and monitoring the USAF air carrier maintenance programs that MTI of CFR Part 121 FAA Advisory Circular (AC) 120-16G are now captured in the CASS program. The KC-46 Program Office established the first operator program for CASS as a requirement of the MTI using FAA AC 120-79A and is actively auditing and providing oversight of ten Continuous Airworthiness Maintenance Program (CAMP) elements.
Program sources of information that provide data for certification efforts and maintenance and operations are derived from ICAs. The TC holder is responsible for providing/updating ICAs for continued airworthiness. ICAs are building blocks of a commercial program and must be maintained for the life of the aircraft.
ICAs reside mostly in the Technical Manual (TM) purview and include documents such as the Aircraft Maintenance Manuals, Structural Repair Manual, Wiring Practices and Wiring Diagram Manual, AW Limitations, Maintenance Planning Data, etc. The use of general USAF TMs must be approved in the ICAs for use. The FAA requires ICAs In order to comply with the Type Design of the aircraft, so it is critical to have a TM program that utilizes distribution and update policies that align with CDA practices, taking full advantage of commercial practices. This will allow the USAF to synergize with the OEM and provide for operator/user requirements at a lower cost.
Repairs outside the scope of the ICAs require engineering approval from the TC/ATC/STC owner as well as the FAA. The OEM may issue SBs and the FAA may issue ADs.
It is also important to understanding the difference between accepted and approved data. Approved data is “approved by the FAA or person to whom the FAA has delegated its authority” while accepted means “acceptable to the administrator.” It must be understood that all data used to substantiate a major repair or alteration, regardless of the source, must be FAA approved before being implemented. All changes, approvals, or modifications that are determined as major must go thru FAA-appointed OEM Organization Design Authority (ODA), Designated Engineering Authority (DER), or to the FAA directly for approval.
Maintaining the SB/AD Program Under the MTI
SBs are notices to aircraft operators from an OEM of a product improvement or deficiency that could be safety-related. ADs are issued by the FAA when they find that an unsafe condition exists. ADs notify aircraft owners/operators of a required special inspection, repair, or alteration to correct an unsafe condition. ADs are legally enforceable rules issued by the FAA to correct an unsafe condition and if not complied with can result in the loss of an operator's AW Certificate. An SB or AD may require immediate action or require to be addressed within a certain timeframe. In the case of the USAF under MTI the FAA may withdraw or suspend the MTI letter if deemed necessary. Maintaining a SB/AD program under MTI allows the USAF to leverage OEM engineering and FAA oversight to ensure the safety of the aircraft as well as TC/ATC/STC configuration control.
A contract CDRL required MMPP provided by the OEM is used to describe the elements that comprise an air carrier maintenance program and requirements to support the life cycle continued airworthiness of the aircraft. An MMPP uses FAA AC 120-16G (Air Carrier Maintenance Program) as a guide with the 10 CAMP elements as the framework. The MMPP makes reference to obtaining FAA acknowledgement of a MTI as well as a requirement for a CASS office/function. A lesson-learned by the initial MTI team was to use the commercial practice of developing a General Maintenance Manual (GMM) as a single document capturing the maintenance program and pointing to all other USAF regulation/policy. A GMM allows for a single source of management for all CAMP requirements as well as a single location to point the operator/user to guidance requirements. It is also used as CASS office program oversight guide when performing audits and evaluations of program issues.
More on CASS
CASS is required under 14 CFR 121 for operators to establish and maintain a system of oversight for the performance and effectiveness of their maintenance program. Within the USAF and the MTI effort, CASS was evaluated and a plan was presented to the FAA as part of the MTI approval. A CASS program includes processes to identify through program audits and self-reporting and to correct deficiencies identified in a maintenance program. FAA AC 120-79A outlines CASS program development and implementation based on AC 120-16G guidance and requirements for an air carrier maintenance program. The KC-46 program has stood up a CASS program and has added a technical manual to the program to capture processes (Technical Order (TO) 00-25-266-KC46). The manual states that it was developed under the direction and guidance of the Title 14 CFR Part 121.363 and 121.373, AC 120-16G, AC 120-79A, and FAA Order 8900.1. The manual addresses other subjects such as Reporting (internally and FAA MCO office), Contract Maintenance and Maintenance Provider Program, ETOPS, O-Level and D-Level surveillance, and Vendor surveillance. A CASS program is applicable to both organic and CLS MCDA and can be tailored to meet needs of either. The USAF does not currently have a central USAF CASS office, but may consider if one should be established to develop CASS plans and tools for individual MCDA programs. Many see this as a sound approach in order to to eliminate the requirement by individual programs in the USAF to choose an established FAA-approved baseline for MTI and CASS, and then ADD sometimes costly individual program requirements for MCDA life cycle AW compliance.
CASS efforts can also enhance predictive reliability reporting by collecting data to support MSG-3 inspection optimization used in CBM+ initiatives. The program can capitalize on USAF data collection using MCDA installed downloadable Aircraft Information Program (AIP) data, Integrated Maintenance Data System (IMDS), Core Automated Maintenance System for Mobility (CAMS-FM/G081), and Reliability and Maintainability Information System (REMIS) information. Augmenting this effort with a Government-owned, contractor-furnished data software tools platform to capture and store real time data to support modeling and reporting is already in practice. Modern MCDA platforms have Aircraft Communications, Addressing and Reporting System (ACARS) systems installed but cannot be encrypted for military use currently. Having USAF ACARS capability for maintenance and ground operations would provide dividends in aircraft availability by reporting airborne faults prior to landing as well as automating real-time data capture eliminating on aircraft downloads by crew and ground support personnel.
There is a MCDA structure that exists with tentacles that reach throughout a program from cradle to grave that must be understood in order to optimize the benefits of the approach. Whether a program's Product Support Business Case Analysis (PSBCA) recommends and the program chooses an organic or a CLS strategy, there are fundamental threads that must be maintained. From Type Design to TC to AW, Certification to USAF MTI, the challenges are great but come with rewards - rewards in cost, safety, aircraft availability, and beyond. The USAF has taken great steps in advancing the MCDA constructs of maintaining TC/ATC/STC and MTC, and implementing MTI requirements and standing up CASS offices as building blocks to compliance are taking hold. The challenges associated with culture changes and paradigm shifts are real, but support for these changes have taken root. With a more widespread understanding about the benefits to the Service, it is projected that these efforts will continue to grow.
This article was developed by a subject matter expert from the Air Force Life Cycle Management Center Intelligence Surveillance and Reconnaissance/Special Operations Forces Directorate (AFLCMC/WI). It is approved for public release; distribution is unlimited.