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In 2018, we will celebrate the 20th anniversary of the signing of the historic document that marked the beginning of the integration of the Russian aviation industry into the world aviation community. This was the assessment, at least twenty years ago, of the signing of the "Agreement between the Government of the Russian Federation and the Government of the United States of America on improving flight safety" on September 2, 1998 (Bilateral Aviation Safety Agreement – BASA Russian Federation – USA).

As a follow-up to the Agreement, on September 12, 1998, the IAC, the Russian FAS, and the USA FAA signed the " implementation procedures for design approval, manufacturing activities, export airworthiness approval, post-design approval work, and technical mutual assistance between aviation authorities " (IPA), which became a working tool for cooperation between the Russian and USA aviation authorities.

At the end of the 90-ies of the last century, the FAA was the most experienced and influential state body of civil aviation authority in the world, we can say, "trendsetter" in the field of regulatory framework for safety. FAR airworthiness standards have been seen as a role model by aviation authorities in virtually all ICAO member States. The European aviation industry was just gaining momentum in an effort to become a full competitor for the dominant American companies in the civil aviation market. In terms of aircraft deliveries, Airbus was more than two times behind Boeing. The European joint aviation authorities (JAA) were not a full-fledged regulator, their activities were carried out through the national aviation authorities of those European States that agreed to cooperate in the development and implementation of joint airworthiness rules and procedures.

It is not surprising that as a result of intensive work of specialists of the aviation authorities of Russia and the United States in July 1994, the orders of the Ministry of transport of the Russian Federation, Aviation rules, Part 21 "Certification Procedures for aircraft" and Part 25 "Airworthiness Standards of transport category aircraft" (AR-25) were put into effect, close in structure and text to the American rules FAR-21 and FAR-25, respectively. The introduction of the new Russian aviation rules in AR-25, despite the existence of noticeable differences from FAR 25 and in the actual preservation in the Russian certification system requirements NLGS-3 belonging to other sections, in particular concerning the engines, avionics, etc., however, allowed to sign the Intergovernmental agreement between Russia and the USA on improving safety – BASA.

Since December 1991 to September 1998, the FAA carried out a specific program to study the Russian certification system. This study was conducted by the method of "shadow certification", that is, FAA constant observes the way the IAC AR conducts its certification of the Il-96T transport category aircraft project equipped  with Pratt & Whitney PW2037 engines and Collins avionics installed on it. The signing of the Agreement opened the way to the issuance of  FAA type certificate for Il aircraft-96Т to Ilyushin Company  on 2 June 1999.

Both parties-participants of the Agreement-seemed to have achieved their goals: to open the way for the products of their aviation industry to new markets for them. But the real consequences of the agreements reached for the success of the companies of the American and Russian aviation industry turned out to be almost diametrically opposite.

The signing of the Agreement did not require the American side to make any changes to the requirements for the aviation equipment products design used by American aircraft industry companies and the procedures for implementing these requirements, including certification processes. Practically, any kind of old and new American products received a legal opportunity to promote to the Russian market, which US companies immediately took advantage of.

The attempt of the Russian side to break into the American market by a narrow wedge, focusing, in fact, vague and constantly reduce in size the promises of the Americans for the purchase of Il-96, failed. The story of the purchase of Il-96 aircraft is well and repeatedly described in the media.

The first and obvious victim of the failed "breakthrough" attempt, which the Russian side deliberately made in those years, was the inclusion in the "implementation Procedures for design approval, production-related activities, export airworthiness approval, works after design approval and technical mutual assistance between aviation authorities" (IPA) of unequal approaches to aircraft certification developed in Russia and the United States. In particular, the provisions of section 2 of the Procedures established that the Russian Federation accepts FAA export certificates, without any restrictions, for all new and used aircraft developed in the United States, while the adoption of type certificates issued in Russia, there are significant restrictions. So, in the category of transport aircraft:

“2.1.2 Us acceptance of AR/FAS export airworthiness certificates for the following aircraft:

(b) new and used transport category aircraft (fully cargo configuration only), with FAA certified engines, propellers, avionics and approved for instrumental approach in Categories I and II only”.

The termination of work on the project of the Il-96T transport category aircraft equipped with Pratt & Whitney PW2037 engines and Collins avionics installed, led for many years to the termination of interaction with the FAA, aimed at harmonizing the Russian certification system with the American one. The restrictions imposed in 1998, which seemed temporary at the time, remain in the procedures for the Agreement (IPA) to the present time, completely blocking not only the possibility of promoting, in particular, Russian passenger or special aircraft to the American market, but also cutting off the path to the American civil aviation market for Russian companies-creators of engines and aircraft equipment.

Continuing inequality in the Agreement between Russia and the United States, in respect to the recognition of type certificates issued by aviation authorities of the parties to the global aviation community is tantamount to the fact that Russia, as the rightful heir to the civil aviation industry of the USSR, voluntarily and formally agreed, unfortunately, to be presented to the international aviation community as a state certification system which does not provide safety levels of the civil  aviation equipment to be created in our country, equivalent to the levels of safety provided by the USA certification system in relation to the created aircraft as a whole, i.e., equipped with Russian engines and equipment.

Henceforth, new Russian civil aircraft, designed to promote the world market, could be designed only with Western engines and equipment. Due to the partial harmonization of certain parts of the Russian airworthiness rules, procedures and other documents of the aviation regulatory framework used in the design, production, operation of the aircraft and its certification, the companies of the Russian aviation industry were forced and continue to work with an eclectic set of documents both domestic and foreign (due to the lack of domestic), including lack of MOC and AC.

The next attempt to get into world markets was made in the new century with the Tu-204-120SE aircraft in cooperation with the European aviation authorities JAA, and then – EASA. At that time, it was one of the most promising export programs of JSC “Tupolev". This type of cargo aircraft is equipped with Rolls-Royce engines, Vibrometer engine control system (USA), Sundstrand generators (USA), Vickers hydraulic pumps (USA), inertial navigation system, TCAS system, EGPWS (earth proximity early warning system) - Honeywell (USA) and other imported equipment that already has certificates ("before installation on the aircraft”) according to aviation standards in Europe.

It would seem that the work carried out earlier with the FAA on the Il-96T aircraft to harmonize domestic norms and procedures with Western ones will significantly reduce the time of validation of the AR-21, AR-25 aircraft certified in the IAC AR. But expectations were not met. Practical certification of the cargo modification of the Tu-204-120 aircraft according to the aviation rules JAR-25 was started in 2001. The aircraft, presented for certification according to the European aviation rules JAR-25, was assigned the index Tu-204-120SE. However, JSC "Tupolev" received a type certificate for the Tu-204-120SE, issued by the European aviation safety Agency (EASA) only on October 8, 2008 and again, as in the case of the Il-96T, the Tu-204-120SE program, shortly after receiving the EASA type certificate, was closed. (More details about the certification of TU-204 written in the book B. S. Maly " Practical certification of aircraft).

In parallel with the validation processes in EASA of the cargo version of the Tu-204-120SE and the Be-200ES-E amphibious aircraft (since 2005), significant work has been carried out to harmonize the European and Russian certification systems within the framework of the joint " EU-Russia international cooperation Project in the field of civil aviation (contract number: TREN/06/SUBV/ST/S07.66875), carried out with the participation of AR IAC, EASA, ASD and UAC in 2006-2009.

In the final Protocol of the project, which was interrupted, unfortunately, due to lack of funding, the goal and program of further harmonization of the Russian and European certification systems were, in fact, formulated:

«The creation of a regulatory framework that allows the European aviation industry to accept without further proof the results of Russian design and production activities will accelerate the further development of industrial cooperation, joint projects and increase the level of safety of our joint products.

EASA stresses that there is still no Bilateral Agreement between the EU and Russia, and it will take several years before an Agreement is reached at the government level. EASA and IAC AR will consider the recommendations included in the final brochure to promote future cooperation between the two authorities and to support discussions leading to the signing of the Bilateral Agreement.

EASA strongly recommends that applications for ongoing industrial cooperation projects be submitted to EASA for the approval of Russian developer organizations (DOA) and manufacturers (POA) applications be made by Russian industry companies as soon as possible to avoid delays. EASA will discuss the possibility of conducting an IAC survey in order to obtain EASA accreditation to support Russian applicants».

The condition for obtaining EASA DOA is that the company has a special survey system at the development stage – Design Assurance System – DAS, which is understood as a systematic process that enhances the development process in order to increase the probability of compliance of the designed product with all requirements, including the requirements of airworthiness standards and environmental protection. The DAS combines independent assessments used to identify design flaws as early as possible in the design cycle and is a tool to determine the adequacy and effectiveness of development processes and products. The principal feature of the DAS, which ensures objectivity and uncompromising assessments, is that the activities of the DAS involve specialists who are not directly involved in the process of developing a specific project or system. It is important that the assessments of such specialists are free from any conflicts and interests within the project and their reports are received by the top-level management of the company, bypassing the project management. The experience gained by DAS specialists in the process of interaction with various projects is used as an additional resource in each individual project. The interaction of the DAS subcontractors involved in the development of the project is coordinated by the specialists of the DAS of the parent company.

DAS at the development stage, to a large extent, performs the function corresponding to the function of the quality control in production:

«21.А.239 (b) Design Assurance System should include an independent compliance verification function, on the basis of which the organization submits compliance opinions and related documents to the Agency».

Unfortunately, as Russian companies have no DAS similar to European DAS systems in relation to the validation of Russian aircraft, EASA was forced to apply an approach that is the most expensive and unprofitable for Russian aircraft builders, including, in terms of the level of confidence of world airlines in products-through the direct involvement in each change, each issued certification document of experts of AR IAC with subsequent consideration of documents by experts EASA.

The accumulation of practical experience in the development and implementation of domestic DAS has been carried out since 2005 in parallel validation processes in EASA amphibious aircraft Be-200ES-E and certification of the version of this aircraft Be-200Е.

In order to overcome differences in the organization of development processes, the practical accumulation of European experience in this area, to increase the degree of confidence in the products of Russian companies on the part of European certification bodies and operators, in accordance with the agreement between EADS and JSC “Irkut”, in Toulouse (France) a unique design organization was established owned by Russian companies BISP (Beriev Irkut Seaplane) – the developer of the Be-200E amphibious aircraft. Structurally, BISP was a single geographically distributed design organization with units located in France, Russia and Ukraine. The principles of operation of the BISP met the requirements of EASA to the construction of European design organizations. EASA, in accordance with the DOA application, conducted an audit of the BSP in the process of approving the design organization for compliance with the requirements of part 21 of Subpart J. the Be-200E Project was not completed due to organizational difficulties encountered with the EASA audits in the organizations-developers of APU, equipment and systems for the Be-200ES amphibious aircraft.

Being appointed in 1992, as the chief designer of amphibious aircraft Be-200 and its modifications, I was directly involved in relations between the Russian and European aviation authorities, combining its position in Russia with the position of Head of design organization BISP HDO in Toulouse, where the agreement with Airbus under my direct supervision was an office of certification, composed of 9 specialists European company. As you know, the first certificate of type IAC ARC with certification basis, built on the basis of AR, was received in August 2001, and EASA certificate for the model Be-200ES-E - in September 2010 by the application, filed in 2005. The procedures developed and approved by EASA for the construction of a geographically distributed, international BISP company can be used as a basis for the formation of globally competitive Russian world-class aviation companies. Unfortunately, the accumulated knowledge and skills remain unclaimed.

From the point of view of development of process of harmonization of the Russian certification system with the European process of validation of the Be-200ES-E amphibious plane is interesting that on the plane engines of development of the CIS countries and, generally, the domestic equipment were installed. On November 6, 2008, EASA issued a Declaration of conformity of the D-436TP engine to European certification requirements and environmental protection requirements for installation on Be-200ES-E and Be-200E aircraft.

At the end of the first decade of this century, the cooperation of AR IAC with the FAA and EASA brought Russian companies three type certificates in the class of heavy aircraft-Il-96T (FAA), Tu-204SE-120 (EASA) and Be-200ES-E (EASA). None of these types of aircraft has yet entered the world market. One of the reasons for this situation was the lag of Russia from the processes of improving the certification systems of other countries-developers of civil aviation equipment, which leads to significant financial, temporary and image losses for Russian creators of aviation equipment, forced for several years to Refine and re-test aircraft between obtaining a type certificate in the IAC AR and its subsequent validation in the EASA.

Thus, for the Be-200ES-E amphibious aircraft, the validation process took 5 years, and the post-certification works stipulated by the EASA type certificate issuance conditions could not be completed even 7 years after receiving the type certificate.

Such a long period of international certification of civil aircraft, unusual for the rest of the aviation world, was required even for a Superjet equipped with foreign engines and, mainly, foreign equipment - more than a year. While its direct competitor Embraer-190 became the holder of the FAA type certificate just three days after receiving the type certificate in Brazil. Embraer's previous model 170 regional aircraft received type certificates from aviation authorities in Brazil, Europe and the United States within one month, in February 2004.The rapid completion of the certification process in the US, followed by the EU and Canada, opened the way for Embraer 170/190 aircraft to world markets, including the key American market. By June 30, 2005, Embraer had received 412 firm orders and 373 aircraft options 170/190.

It is expected that limiting the interaction between the AR IAC only EASA (existing Intergovernmental agreement with the United States (BASA) from 1998 does not allow FAA to accept type certificates issued by IAC AR on passenger planes), and an insufficient degree of harmonization of the Russian certification system with the European, caused the stretching of the validation process in time, not only led to the failure of Alitalia purchasing the Superjet aircraft in favor of aircraft Embraer, but to the loss of a number of other potential customers.

President of Alitalia Ricco Sabelli said that the airline was inclined in favor of the Sukhoi Superjet 100, but repeated delays in the certification of the aircraft were the reason for the decision: "We delayed our choice by 6 and 12 months in anticipation of the Superjet, and we took into account the involvement of the Italian company [Alenia Aeronauita] in the project, but we are still not sure of the date of European certification...", was not able to use all the possibilities of this achievement for the implementation of the plan for the supply of aircraft around the world.

In my opinion, in the Russian aviation industry there is still a misunderstanding of the importance of the certification system, as well as the regulatory framework in both the design and promotion of the civil aviation equipment to the market. Ten years ago, in the midst of validation work with EASA on the be-200ES-E amphibious aircraft (work on the Superjet aircraft was carried out in parallel), I published an article "the Weapon of the struggle for the market-certification", in which, as the chief designer of the aircraft, I tried to draw attention to the growing gap between the state of harmonization of the Russian certification system and the possibilities of promoting Russian aircraft to world markets. The article caused a negative reaction in IAC AR. This reaction was objectively caused by the lack, in practice, of communication between the tasks solved by the aviation registry of the Interstate Aviation Committee and the state bodies of the Russian Federation responsible for the development of the aviation industry. The above-mentioned difficulties in promoting the Russian civil aviation equipment to the world markets are caused, to a large extent, by the shortcomings of the management structure of the Russian aviation industry with the delegation of regulatory functions of the state to AR IAC.

The leading aviation States of the world are characterized by constructive cooperation of aviation industry enterprises with Aviation authorities in order to achieve competitiveness in world markets. The example below is a statement by the AeroSpace and Defence Industries Association of Europe (ASD), which brings together the aviation, space, defence and safety industries in Europe in all matters of common interest, with the aim of promoting and supporting the competitive development of this sector. ASD members include 15 major European aerospace and defence companies and 27 member associations in 20 countries. In 2013, more than 3,000 aviation, space and defense companies in these countries employed more than 777,000 people, and their annual turnover was €197.3 billion:

«High level position ASD:

– ASD contributed to the creation of the European aviation safety agency since the idea had appeared. The aerospace industry expects benefits from a regulatory and certification body powerful enough to help the industry withstand international competition. Such a task requires effective working methods and sufficient funds to perform the necessary certification tasks».

The intensification of competition in the market of suppliers of civil aviation products is accompanied by the construction of additional barriers for newly entering market participants through the use of changes made to the NPB, in particular, to the certification systems. So, in September 2015, the aviation authorities of USA, EU, Canada and Brazil – an unofficial "elite club" of providers of the vast number of civilian products at the world market – have signed the Charter about the Team building process management certification civil aviation equipment (Certification Management Team – CMT) to implement a common policy in the technical and political spheres on the basis of Bilateral interstate agreements on aviation security. In 2016, a Roadmap for the implementation of the agreements reached was signed. The purpose of the agreements is to reduce the financial and time costs of certification by eliminating the duplication of work on the validation of certificates and approvals issued in one country, while moving to other countries-participants of the agreements. At the same time, bilateral interstate agreements are continuously improved, maintaining the degree of trust between the aviation authorities. So since the signing of BASA between the EU and the US in 2011 the Agreement was  changed for six times.

The Eastern partner of Russia, in particular the Russian-Chinese wide-body long-haul passenger aircraft CR 929, jointly designed by UAC and COMAC, is making every effort to join the four leading aviation States of the world "elite club". On October 27, 2017, the press reported on the signing of a Bilateral agreement between China and the United States on safety. There is no doubt that in the near future a similar Bilateral agreement (BASA) between the PRC and the EU will be signed, work on the preparation of which is being carried out by the aviation authorities of China and Europe.

It is obvious that the Chinese are well aware of the role of certification processes in overcoming competitive barriers to the promotion of aircraft on the world market, formulated in the characteristic work of the Massachusetts Institute of technology (MIT) "Jose L. Fuentes "COMAC (PRC) is trying to destroy the Airbus-Boeing duopoly, will the attempt be successful?»:

«The aircraft certification process is the responsibility of the developer, which belongs entirely to its engineering division, despite having a legal connotation. This is as much a legal question as a technical one. A process firmly rooted in the design and development of aircraft. Simply put, the same engineers who design an aircraft to meet the requirements of the specification find themselves involved in the certification process to demonstrate its compliance with these requirements, after the aircraft is manufactured.

The certification process is part of the engineering integration role that market-leading companies such as Boeing and Airbus have developed and perfected over the past decades. This is often referred to as the role of "large-scale system integrator", which has become their core competence, something like the "secret sauce" peculiar to dominant companies when it comes to integration with suppliers».

Despite the developing process of international integration in the field of improving and simplifying the processes of design and certification of civil aviation, the Russian Federation remains aloof from this main path. Russia still does not have an interstate agreement such as BASA with the EU, and with the United States continues to operate BASA, signed in 1998, which, opening the doors to Russia to American products, almost completely blocks the path of Russian products in the United States.

Procedural norms AR-21 still do not contain requirements for the presence of DAS in the companies – developers at, despite the fact that today DAS are implemented by all world developers of aviation and space technology, including China, India, Brazil, with the exception of Russia. Practically, there is no work on the implementation of the requirements of the ICAO SMS in the AR-21, while EASA and FAA are going to issue new versions of Parts 21 of their norms no later than 2019, taking into account the ICAO requirements. Significant differences remain between the parts of AR norms that apply to aviation equipment and their foreign counterparts.

Implementation of the plans of the Russian aviation industry to promote to the world markets a new civil at - aircraft MS-21, PD-14 engine, avionics IKBO MA, systems and assemblies, as well as the continuation of work on already certified in EASA aircraft – SSJ and Be-200ES-E, obviously, require advanced development and improvement of the regulatory framework, acceleration of work on harmonization of the Russian certification system with the certification systems of foreign countries and, above all, with the American and European, which should ensure Russia's entry into the "elite club" of developers and manufacturers of the most advanced civil at in the world.

The task is facilitated by the fact that the FAA and EASA, as well as the world's leading aircraft companies (Boeing, Airbus, Canadair, Embraer) officially declare that safety is not a matter of competition. Working with air traffic safety organizations around the world to find new ways to improve standards for all is what is important. It should be noted that the group of companies listed above always meets and often exceeds the requirements of the two leading certification authorities of the European aviation safety Agency – EASA and FAA.

Fortunately, in recent years in the aviation industry of Russia, including the organization of the certification system, there have been serious positive changes, described in detail in the article by A. Y. Knievel "Certification of type, designers and manufacturers of civil aviation equipment", published in the magazine "Aviasoyuz" on October 18, 2017.

Of course, despite my 30 years of experience in the aviation industry, preceded by almost 15 years of experience in military service in the weapons system of the Soviet air force, the experience of leading domestic and international projects of aviation equipment development, interaction with experts EASA and FAA, numerous specialists of Russian and foreign companies, I in no way pretend that the above is the only truth. Rather, this article is an invitation to specialists and leaders of the Russian aviation industry to "sit down a little before the long road" of putting Russia into orbit of the leading aviation powers of the world, to think and exchange views on how we can all implement this goal faster and more effectively for the benefit of the Motherland.

For my part, I would like to make some suggestions for discussion the step that should be taken and how to accelerate the processes of positive changes.

  1. Key points of improvement of the Russian certification system
  2. a) during the coordination of the Working Agreement with EASA and changes in the Implementation Procedures (IP) of the Bilateral interstate agreement Russia – USA with the FAA to establish the ultimate goal signing of full-fledged Bilateral aviation safety agreements (BASA) with the EU, the USA and further – with Brazil, Canada and other participants of the world aviation market.
  3. b) to Develop measures and to start their implementation on introduction of SMS in the organizations of designers and manufacturers (obligatory condition of signing of the full BASA designated in item 1).
  4. c) In the process of improving the Russian certification regulatory framework, determined by the requirements of harmonization with the regulatory framework of the leading aviation States of the world, it is necessary to take into account foreign trends in the field of increasing the role of developers and manufacturers in ensuring an acceptable level of safety. To introduce the Design Assurance System as an obligation in requirements to approval of the aviation equipment design organizations (subpart J AR-21).
  5. d) The Ministry of transport of the Russian Federation, the Federal air transport agency, the Ministry of industry and trade of the Russian Federation, JSC "UAC", "Rostech", institutes of industry and transport to undertake the necessary structural reforms required to make the necessary changes in the Russian certification system. To organize special joint groups in the directions with attraction of necessary highly qualified and skilled personnel. To ensure the allocation of the necessary amount of funding for the advanced development of a harmonized regulatory framework for the design and certification of civil aviation equipment.
  6. Possible ways to solve the personnel problem

To accelerate the process of advancing the development of the regulatory framework, taking into account track changes in foreign regulatory framework, it is appropriate, in my opinion, the Engineering-consulting center support of the validation of Russian aviation Western aviation authorities (EASA, FAA), using an approach based on the successful Brazilian experience, which allowed, in particular, Embraer to take in the short term a significant share of the world market.

In Brazil, in 2006, the Brazil organization for the Development of Aeronautical certification (DCA – BR), a non-governmental Organization for the Development of Aeronautical Certification, was established in partnership with governmental organizations and private companies at home and abroad to deal with a wide range of issues, including training, professional qualifications, consulting, drafting of regulatory documents, interaction with aerospace authorities, developers and manufacturers. DCA-BR attracts the most qualified specialists of various companies with practical experience and those who, having experience, knowledge and business connections, have already left the companies in which they previously worked to solve the tasks.

Engineering and consulting center could work under the auspices of the Federal air transport agency, in close connection with the Aviation register on a contractual basis with the SIC "Institute named after N.E. Zhukovsky" and GosNII GA.

The use of such a competence center will not only help to bypass the competitive obstacles of using the experience and attracting highly qualified specialists of foreign aircraft companies for the development of processes in Russian companies, but also significantly reduce the cost of consulting work due to the already acquired skills of Russian specialists in the process of long-term cooperation with foreign colleagues.

A.V. Yavkin - REC Aerospace Company General Director 

Since 1992 to October 2016: Deputy General designer of BERIEV Aircraft Company , Chief designer of the Be-200 amphibious aircraft and the modifications

REC Aerospace Company Russian-European Consulting

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