The Future of Design Organisation Approval

1
The Future ofDesign Organisation Approval

• A perspective from the smallest design
  organisations
• by
• Werner Scholz, Spokesman of the
• European Sailplane Manufacturers

2
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?

3
IntroductionWho 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.

4
IntroductionWho 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

5
IntroductionWho 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

6
IntroductionWho 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

7
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

8
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

9
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

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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
  NAAs (invoices even from states where no gliders
  were sold!)and because of participating NAA
  without detailed experience in sailplane
  certification

11
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
  averageA) 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 DOAs

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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
  JAR21for 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...

13
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 NAADesign Organisations working under
  Alternative Procedures (ADOAP)
• full Subpart J DOA seemed unobtainable due to
  long delays in the approval process and
  complicated rules

14
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

15
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

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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
  proceduresgt 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!

18
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)

19
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
• gt all basic principles of a Part 21 DOA are
  fulfilled!

20
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

21
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

22
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

23
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

24
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
• gt make simple rules for the simple light
  aviation gt reduce costs for EASA and the small
  manufacturers

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Future of DOA

• Thank you -
• any questions?