Presentation on theme: "The Future of Design Organisation Approval"— Presentation transcript:
1The Future of Design Organisation Approval A perspective from the smallest design organisationsbyWerner Scholz, Spokesman of theEuropean Sailplane Manufacturers
2National rules - JAR - EASA 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?“
3Introduction „Who are we - whom do we represent?“ The European sailplane manufacturers are represented by two associations:Verband deutscher SegelflugzeugherstellerEuropean Glider Manufacturers and Suppliers associationTogether they include 13 companies inAustria, Czech Republic, Germany, Lithuania, Sloveniawith together more than 1000 employees.
4Introduction „Who are we - whom do we represent?“ Further members of the sailplane “industry”:Additional European sailplane manufacturers not represented by the two associationsManufacturers of glider-typical avionicsManufacturers of trailers and equipmentGlider maintenance facilities
5Introduction „Who are we - whom do we represent?“ Together the European sailplane industry represents:more than 20 sailplane manufacturersmore than 30 manufacturers of gliding equipmentmore than 90% of world-wide sailplane production (over 400 new aircraft per year)more than 3000 employees at the manufacturers and associated companies
6Introduction „Who are we - whom do we represent?“ The gliding community in Europe includes:over registered sailplanesover pilots flying gliders and powered sailplanesa starting point towards a professional career in aviation for several people since more than 50 yearsclose ties to other light aviation communities like hang-gliding, paragliding and microlights
7National 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 DOAdesign organisation manuals were in the national languagemanuals covered mostly procedures between DOA and NAA and internal procedures were kept minimal
8National rules - JAR - EASA „DOA in the past - what is the history?“ 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 aviationcertification verification was done at the DOA level, sometimes with the NAA; authorities checked technical content of the TCtype certification as teamwork between manufacturer and NAA with technical expertise on both sides
9National rules - JAR - EASA „DOA in the past - what is the history?“ 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 proceduresunder this regulation most national DOA with full privileges became “semi-national” DOA according to JAR 21.13b with limited privilegesDOA approval was issued by NAA but often now by DOA specialists without detailed knowledge of small manufacturers
10National rules - JAR - EASA „DOA in the past - what is the history?“ Introduction of JAR 21 - DOA on an European level:design organisation manuals were mostly still in the national languagethe 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
11National rules - JAR - EASA „DOA in the past - what is the history?“ Introduction of JAR 21 - DOA on an European level: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 procedures B) about to € per company for certification of the new manuals C) about 1 to 2 man-months per company within the NAA to issue the new DOA´s
12National rules - JAR - EASA „DOA in the past - what is the history?“ Introduction of JAR 21 - DOA on an European level:total sum of costs by the switch “national to JAR21”: for all European sailplane manufacturers together approx. 1 Mio. € for all NAA together: approx. several €BUT: The way sailplanes are designed stayed the same, only the privileges of the organizations were reduced...
13National rules - JAR - EASA „DOA in the past - what is the history?“ Introduction of Part 21 - EASA issues European DOA:the JAR 22.13b simple design DOA were not granted “grandfather rights” due to the limited privilegesdue 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
14National rules - JAR - EASA „DOA in the past - what is the history?“ 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 organisationseven more bureaucratic effort in the daily work as now EASA and NAA are often involved due to outsourcing of certification tasks done by EASA
15National rules - JAR - EASA „DOA in the past - what is the history?“ Experiences with ADOAP / DOA under Part 21:Part 21 is not fully understood by all manufacturersnew manuals sometimes obligatory in English languageapproval 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
16National rules - JAR - EASA „DOA in the past - what is the history?“ 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 effortsagain: additional costs and procedures less efficient AND NO BENEFIT regarding safety / certification speed.
17Status quo „How works sailplane development today?“ A a typical sailplane manufacturer:the whole company employs 50 to 150 peoplethe design team consists of 2 to 5 engineerstypical 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!
18Status quo „How works sailplane development today?“ 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 manufacturerdesigners, workers and managers mostly have personal experience in the operations of their products (i.e. competition gliding, club operations, instruction)
19Status quo „How works sailplane development today?“ The typical design organisation of a manufacturer:verification of certification documentsplanning of certification tasks with authoritiesproper documentation and record keeping of design and certification documentationclassification into TC / STC / major and minor changes together with authoritiesinformation of owners of productscontrol of defects and other problems toward airworthiness=> all basic principles of a Part 21 DOA are fulfilled!
20Future 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 assistancethe administrative complexity in the certification process shall be reduceddelegation of responsibilities to the companies is possible and appreciated but it has to be economical feasible during introduction and daily operations
21Future of DOA „What is needed for light aviation?“ How should the certifying / inspecting body (EASA / NAA under task allocation / assessment bodies) work?ability to handle processes in national languageproven technical competence and experienceone-stop support, grouping of responsibilities (including TC and organisations certification), aiming at reduction of administrative burdenlong-time availability of technical documents regarding type certificationcontinuity during processing
22Future of DOA „What is needed for light aviation?“ How should the implementation of the DOA rules be?representatives of the authorities need personal experience with the products / kind of companiesthe often quite long experience as design organisation has to be honoured - old privileges must continueinclusion of procedures into the manuals which are not needed (because of the tiny design organisations) should be avoidedlogical would be issuance of DOA by the persons who oversee the production organisation of the manufacturer or who work in the type certification process
23Future of DOA „What is needed for light aviation?“ How should the design organisation manual look like?if chosen by the applicant national language should be possibledescription of the company structure & the co-operation between design and production departmentonly basic description of the typical design & certification process - no in-depth regulation / description of procedures within the companylisting of the members of the design organisation with their respective roles and privileges
24Future of DOA „What is needed for light aviation?“ Last but not least a word on the financial side:gliding / light aviation is an economical small part of the European aviation communitythese small companies cannot finance significantly EASAnevertheless they provide an important foundation of aviation=> make simple rules for the simple & light aviation => reduce costs for EASA and the small manufacturers