With seven new models in different levels of certification, Russian aircraft makers are aggressively developing competitive aircraft. These comprise the Il-114-300, Tu-214, MC-21, Superjet, and smaller aircraft. Also expected as a critical milestone in the import substitution scheme is the certification of new local aircraft engines, including the VK-800S and PD-8. A complicated and time-consuming process, aircraft registration requires special knowledge, experience, and a lot of time to submit applications and compile many documents, including certificates, reports, and technical records, including the aircraft logbook, engine logbook, and instrument passports. Russian aviation laws mandate the registration and certification of civil aircraft.
The Federal Aviation Rules state that Russian aviation regulator Rosaviatsia must certify civil aircraft, aircraft engines, propellers, and onboard aviation equipment. Based on a kind of certificate, an operational suitability certificate, or an evaluation report proving adherence to airworthiness and environmental protection criteria, the Certificate of Airworthiness can be granted. These criteria cover all aircraft types, including ultralight aircraft with a maximum takeoff weight not exceeding 495 kg and light aircraft with a maximum takeoff weight under 5,700 kg for helicopters—under 3,100 kg.
Apart from manned civil aircraft, excluding ultralight aircraft with a structural weight of less than 115 kg, aircraft that must be registered with Rosaviatsia include Unmanned Aerial Vehicles (UAVs), except those with a maximum takeoff weight of 30 kg or less.
Federal Law No. 31-FZ, FAP-170, FAP-85, FAP-457, and FAP-287 are among the various Federal Aviation Rules (FAP) governing registration policies. Based out of Moscow, Rosaviatsia maintains the State Register of Civil Aircraft of Russia. Except for ultralight aircraft with a structural weight of less than 115 kg and unmanned aircraft with a maximum takeoff weight under 30 kg, civil aircraft cannot operate without a Certificate of Airworthiness. Rosaviatsia’s Regional Territorial Authorities (MTU) award a Type Certificate, Operational Suitability Certificate, or Aircraft Evaluation Report-based Certificate of Airworthiness, but aircraft certification based on an evaluation report cannot be applied for commercial flights.
Federal Aviation Guidelines (FAP) include FAP-132, FAP-175, and FAP-118, which guide the certification procedure. The certificate application must be turned in at least thirty-five days before the current certificate expires or before aircraft operations begin. Regarding foreign aircraft, the applicant must present operational records from the manufacturer together with an Export Certificate of Airworthiness from the US Federal Aviation Authority (FAA) or European Aviation Safety Agency (EASA). A standard aircraft’s Certificate of Airworthiness is valid for up to two years; a single-instance aircraft’s Certificate of Airworthiness is valid for one year; renewals follow the same procedure as the first certification.
Rosaviatsia is also working on a new law that will allow them to certify and approve the production of alternative parts for civil aircraft. This is needed to replace foreign spare parts that aren’t allowed because of the sanctions. The document contains amendments to Article 37 of the Air Code, which regulates the certification of civil aircraft, engines, propellers, and unmanned aerial vehicles or their parts. Currently, Chinese and Iranian aircraft parts receive priority.
The question is, what is the difference between Russian and Western aviation certification standards?
The purpose of the system is to ensure the competitiveness of the national aviation industry in the global market. The degree of uniformity in regulations, standards, procedures, and organization relating to aircraft is required by Article 37 of the Chicago Convention on Civil Aviation.
One of the key differences is that Western approvals have a stated need to ensure the competitiveness of the national aviation industry in the world market. The Russian documents do not state this.
The second main difference is the certification rules for aircraft in Russia aren’t similar enough to those in the West to allow for comprehensive agreements called Bilateral Aviation Safety Agreements (BASA). These agreements would typically streamline the acceptance of each other’s aviation products. The differences in requirements mean that a full, formal agreement like BASA, which would simplify the validation and acceptance of aircraft certifications between these regions, isn’t possible right now. The West is unwilling to harmonize BASA with Russia. Russia does not participate in the preparation of these documents along with the US, the EU, Canada, and Brazil. Unlike Russia, China is making every effort to join these processes.
The third difference is that there are no documents in Russia that define cooperation between the Russian Aviation Authority and representatives of the Russian aviation industry, similar to how this is done in the West. The fourth difference is that in Russia, there are no documents defining the assessment of the compliance of organizations developing aviation equipment with the requirements of the Aviation Authority of the Russian Federation, similar to how this is done in the West. There are no requirements for the presence of a Design Assurance System in an organization that develops aviation equipment. This system mandates organizational structure, responsibilities, procedures, and resources to ensure the proper functioning of the design organization.
The fifth is the introduction of the requirements of the Safety Management System in FAP-21 is not considered.
Russian aviation standards differ from Western standards in other key areas too. Even though Russian regulations (AP-25) were initially intended to align with American standards (FAR-25), they still incorporate older materials and sections from Airworthiness Standards or Airworthiness Norms that are not compliant with Western norms. A previous comparison by the Russian Aviation Register of the Interstate Aviation Committee highlighted these existing discrepancies between American and Russian standards.
The FAA is not known to have conducted a comprehensive review of Russian standards for aircraft engines and equipment. EASA has only partially assessed Russian regulations on engines and equipment during the validation of specific aircraft like the Tu-204CE-120, SSJ, and Be-200ChS-E, where much of the equipment was not of Russian design. Additionally, Russia lacks requirements for equipment in the Technical Standard Order format, which is common in Western aviation. Technical Standard Orders are a set of standards for aviation components.
The validation of the Russian Be-200ChS-E aircraft by EASA revealed that the primary challenge was not solely the differing regulations but also the contrasting interpretations of these regulations by Russian and European experts. Specific concerns raised by EASA included issues with flight in icing conditions, potential dangers from wheel and tire disintegration, hydraulic fluid overheating, fuel tank safety, isolation of flammable liquids, prevention of water and ice in the fuel system, cargo and technical compartment safety, protection from HIRF and lightning, equipment qualifications, and operational documentation, particularly regarding the electrical wiring system.
Like in the EU and the US, Russia lacks laws outlining the evaluation of the conformity of companies manufacturing aircraft equipment with the standards of the Aviation Authority of the Russian Federation. The worldwide aviation community is constantly divided on the mutual acceptance of type certificates issued by Russia’s aviation authority and the United States. This difference suggests that Russia, which took over the USSR’s civil aviation industry, has taken a stance that its system for certifying civil aviation equipment does not guarantee safety levels that are the same as those in the US.
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