Transcript The Future of Design Organisation Approval

Verband Deutscher
Segelflugzeughersteller e.V.
European Glider Manufacturers
and Suppliers association
The Future of
Design Organisation Approval
A perspective from the smallest
design organisations
by
Werner Scholz, Spokesman of the
European Sailplane Manufacturers
EASA Workshop „Future of DOA“ - Paris 7.11.2006
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Verband Deutscher
Segelflugzeughersteller e.V.
European Glider Manufacturers
and Suppliers association
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?“
EASA Workshop „Future of DOA“ - Paris 7.11.2006
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Verband Deutscher
Segelflugzeughersteller e.V.
European Glider Manufacturers
and Suppliers association
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 in
Austria, Czech Republic, Germany, Lithuania, Slovenia
with together more than 1000 employees.
EASA Workshop „Future of DOA“ - Paris 7.11.2006
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Verband Deutscher
Segelflugzeughersteller e.V.
European Glider Manufacturers
and Suppliers association
Introduction
„Who are we - whom do we represent?“
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
EASA Workshop „Future of DOA“ - Paris 7.11.2006
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Verband Deutscher
Segelflugzeughersteller e.V.
European Glider Manufacturers
and Suppliers association
Introduction
„Who are we - whom do we represent?“
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
EASA Workshop „Future of DOA“ - Paris 7.11.2006
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Verband Deutscher
Segelflugzeughersteller e.V.
European Glider Manufacturers
and Suppliers association
Introduction
„Who are we - whom do we represent?“
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
EASA Workshop „Future of DOA“ - Paris 7.11.2006
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Verband Deutscher
Segelflugzeughersteller e.V.
European Glider Manufacturers
and Suppliers association
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
EASA Workshop „Future of DOA“ - Paris 7.11.2006
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Verband Deutscher
Segelflugzeughersteller e.V.
European Glider Manufacturers
and Suppliers association
National 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 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
EASA Workshop „Future of DOA“ - Paris 7.11.2006
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Verband Deutscher
Segelflugzeughersteller e.V.
European Glider Manufacturers
and Suppliers association
National 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 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
EASA Workshop „Future of DOA“ - Paris 7.11.2006
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Verband Deutscher
Segelflugzeughersteller e.V.
European Glider Manufacturers
and Suppliers association
National 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 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
EASA Workshop „Future of DOA“ - Paris 7.11.2006
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Verband Deutscher
Segelflugzeughersteller e.V.
European Glider Manufacturers
and Suppliers association
National 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 10.000 to 20.000 € 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
EASA Workshop „Future of DOA“ - Paris 7.11.2006
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Verband Deutscher
Segelflugzeughersteller e.V.
European Glider Manufacturers
and Suppliers association
National 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 100.000 €
BUT: The way sailplanes are designed stayed the same,
only the privileges of the organizations were reduced...
EASA Workshop „Future of DOA“ - Paris 7.11.2006
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Verband Deutscher
Segelflugzeughersteller e.V.
European Glider Manufacturers
and Suppliers association
National 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 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
EASA Workshop „Future of DOA“ - Paris 7.11.2006
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Verband Deutscher
Segelflugzeughersteller e.V.
European Glider Manufacturers
and Suppliers association
National 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 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
EASA Workshop „Future of DOA“ - Paris 7.11.2006
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Verband Deutscher
Segelflugzeughersteller e.V.
European Glider Manufacturers
and Suppliers association
National 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 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
EASA Workshop „Future of DOA“ - Paris 7.11.2006
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Verband Deutscher
Segelflugzeughersteller e.V.
European Glider Manufacturers
and Suppliers association
National 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 efforts
• again: additional costs and procedures less efficient
AND NO BENEFIT regarding safety / certification speed.
EASA Workshop „Future of DOA“ - Paris 7.11.2006
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Verband Deutscher
Segelflugzeughersteller e.V.
European Glider Manufacturers
and Suppliers association
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!
EASA Workshop „Future of DOA“ - Paris 7.11.2006
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Verband Deutscher
Segelflugzeughersteller e.V.
European Glider Manufacturers
and Suppliers association
Status 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 manufacturer
• designers, workers and managers mostly have personal
experience in the operations of their products
(i.e. competition gliding, club operations, instruction)
EASA Workshop „Future of DOA“ - Paris 7.11.2006
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Verband Deutscher
Segelflugzeughersteller e.V.
European Glider Manufacturers
and Suppliers association
Status quo
„How works sailplane development today?“
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!
EASA Workshop „Future of DOA“ - Paris 7.11.2006
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Verband Deutscher
Segelflugzeughersteller e.V.
European Glider Manufacturers
and Suppliers association
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
EASA Workshop „Future of DOA“ - Paris 7.11.2006
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Verband Deutscher
Segelflugzeughersteller e.V.
European Glider Manufacturers
and Suppliers association
Future 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 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
EASA Workshop „Future of DOA“ - Paris 7.11.2006
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Verband Deutscher
Segelflugzeughersteller e.V.
European Glider Manufacturers
and Suppliers association
Future 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 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
EASA Workshop „Future of DOA“ - Paris 7.11.2006
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Verband Deutscher
Segelflugzeughersteller e.V.
European Glider Manufacturers
and Suppliers association
Future 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
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
EASA Workshop „Future of DOA“ - Paris 7.11.2006
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Verband Deutscher
Segelflugzeughersteller e.V.
European Glider Manufacturers
and Suppliers association
Future 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 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
EASA Workshop „Future of DOA“ - Paris 7.11.2006
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Verband Deutscher
Segelflugzeughersteller e.V.
European Glider Manufacturers
and Suppliers association
Future of DOA
Thank you any questions?
EASA Workshop „Future of DOA“ - Paris 7.11.2006
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