The Future of Design Organisation Approval

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EASA Workshop „Future of DOA“ - Paris 7.11.2006

European Glider Manufacturers and Suppliers association

Verband DeutscherSegelflugzeughersteller e.V.

The Future ofDesign Organisation Approval

A perspective from the smallest design organisations

by

Werner Scholz, Spokesman of the

European Sailplane Manufacturers

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Contents:

Introduction„Who are we - whom do we represent?“

National rules - JAR - EASA„ DOA in the past - what is the history?“

Status quo„How works sailplane development today?“

Future of DOA„What is needed for light aviation?“

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Introduction

„Who are we - whom do we represent?“

The European sailplane manufacturers are represented by two associations:

• Verband deutscher Segelflugzeughersteller• European Glider Manufacturers and Suppliers association

Together they include 13 companies inAustria, Czech Republic, Germany, Lithuania, Slovenia with together more than 1000 employees.

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Introduction


Further members of the sailplane “industry”:

• Additional European sailplane manufacturers not represented by the two associations

• Manufacturers of glider-typical avionics

• Manufacturers of trailers and equipment

• Glider maintenance facilities

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Introduction


Together the European sailplane industry represents:

• more than 20 sailplane manufacturers

• more than 30 manufacturers of gliding equipment

• more than 90% of world-wide sailplane production(over 400 new aircraft per year)

• more than 3000 employees at the manufacturers and associated companies

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Introduction


The gliding community in Europe includes:

• over registered 20.000 sailplanes

• over 70.000 pilots flying gliders and powered sailplanes

• a starting point towards a professional career in aviation for several 100.000 people since more than 50 years

• close ties to other light aviation communities like hang-gliding, paragliding and microlights

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National rules - JAR - EASA

„DOA in the past - what is the history?“

On the national level before implementation of JAR 21 sailplane manufacturers mostly were already approved Design Organisations.

• the national DOA included all privileges as the current Part 21 Subpart J DOA

• design organisation manuals were in the national language

• manuals covered mostly procedures between DOA and NAA and internal procedures were kept minimal

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DOA on the national level:

• issuance of TC and of DOA at the NAA often by the same departments and/or persons with a personal background in gliding / light aviation

• certification verification was done at the DOA level, sometimes with the NAA; authorities checked technical content of the TC

• type certification as teamwork between manufacturer and NAA with technical expertise on both sides

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Introduction of JAR 21 - DOA on an European level:

• new possibility within JAR 21 to obtain DOA for “simple designs” (JAR 21.13b) with alternative procedures

• under this regulation most national DOA with full privileges became “semi-national” DOA according to JAR 21.13b with limited privileges

• DOA approval was issued by NAA but often now by DOA specialists without detailed knowledge of small manufacturers

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• design organisation manuals were mostly still in the national language

• the much advertised European certification turned out to be non-feasible due to exaggerated fees of NAA´s (invoices even from states where no gliders were sold!)and because of participating NAA without detailed experience in sailplane certification

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• the switch from the national DOA to the “simple design DOA” according to JAR 21.13b did cost on average:

A) about 1 to 2 man-years per company for introduction of new manuals and proceduresB) about 10.000 to 20.000 € per company for certification of the new manualsC) about 1 to 2 man-months per company within the NAA to issue the new DOA´s

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• total sum of costs by the switch “national to JAR21”:

for all European sailplane manufacturers togetherapprox. 1 Mio. €

for all NAA together: approx. several 100.000 €

BUT: The way sailplanes are designed stayed the same, only the privileges of the organizations were reduced...

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Introduction of Part 21 - EASA issues European DOA:

• the JAR 22.13b simple design DOA were not granted “grandfather rights” due to the limited privileges

• due to the limited workforce at EASA a “fast and easy” way to work under Part 21 was offered by EASA & NAA:Design Organisations working under Alternative Procedures (ADOAP)

• full Subpart J DOA seemed unobtainable due to long delays in the approval process and complicated rules

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Introduction of Part 21 - EASA issues European DOA:

• the result: most manufacturers now work under ADOAP (with the full scope of work from type changes to TC)

• loss of remaining privileges for the design organisations

• even more bureaucratic effort in the daily work as now EASA and NAA are often involved due to outsourcing of certification tasks done by EASA

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Experiences with ADOAP / DOA under Part 21:

• Part 21 is not fully understood by all manufacturers

• new manuals sometimes obligatory in English language

• approval of manuals a lengthy process - especially when the EASA specialists (either EASA employees or NAA people under task allocation) have no experience with small companies and/or light aviation

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Experiences with ADOAP / DOA under Part 21:

• “big company DOA” complain that DOA privileges do not lead to less bureaucratic certification procedures=> therefore no incentive to “upgrade to DOA”

• ADOAP approvals again caused significant efforts

• again: additional costs and procedures less efficientAND NO BENEFIT regarding safety / certification speed.

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Status quo

„How works sailplane development today?“

A a typical sailplane manufacturer:

• the whole company employs 50 to 150 people

• the design team consists of 2 to 5 engineers

• typical time in the company for the employees: 10 to 30 years!

• typical time for the company to be “in the business of building gliders”: at least 10 years, sometimes over 50!

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Status quo


Inside a typical sailplane manufacturer:

• typical number of contractors regarding design and certification: none or (very rare) one!

• maximum manufacturing depth - only the materials and standard parts are bought - the entire sailplane is produced in-house by the manufacturer

• designers, workers and managers mostly have personal experience in the operations of their products(i.e. competition gliding, club operations, instruction)

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Status quo


The typical design organisation of a manufacturer: verification of certification documents planning of certification tasks with authorities proper documentation and record keeping of

design and certification documentation classification into TC / STC / major and minor

changes together with authorities information of owners of products control of defects and other problems toward

airworthiness=> all basic principles of a Part 21 DOA are fulfilled!

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Future of DOA

„What is needed for light aviation?“

The basic needs for light aviation:

• small design organizations do not need the intensive procedural control, but sometimes competent technical assistance

• the administrative complexity in the certification process shall be reduced

• delegation of responsibilities to the companies is possible and appreciated but it has to be economical feasible during introduction and daily operations

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Future of DOA


How should the certifying / inspecting body (EASA / NAA under task allocation / assessment bodies) work?

• ability to handle processes in national language• proven technical competence and experience• one-stop support, grouping of responsibilities (including TC

and organisations certification), aiming at reduction of administrative burden

• long-time availability of technical documents regarding type certification

• continuity during processing

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Future of DOA


How should the implementation of the DOA rules be?

• representatives of the authorities need personal experience with the products / kind of companies

• the often quite long experience as design organisation has to be honoured - old privileges must continue

• inclusion of procedures into the manuals which are not needed (because of the tiny design organisations) should be avoided

• logical would be issuance of DOA by the persons who oversee the production organisation of the manufacturer or who work in the type certification process

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Future of DOA


How should the design organisation manual look like?

• if chosen by the applicant national language should be possible

• description of the company structure & the co-operation between design and production department

• only basic description of the typical design & certification process - no in-depth regulation / description of procedures within the company

• listing of the members of the design organisation with their respective roles and privileges

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Future of DOA


Last but not least a word on the financial side:

• gliding / light aviation is an economical small part of the European aviation community

• these small companies cannot finance significantly EASA • nevertheless they provide an important foundation of

aviation

=> make simple rules for the simple & light aviation => reduce costs for EASA and the small manufacturers

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Future of DOA

Thank you - any questions?

Documents

The Future of Design Organisation Approval