European Council of General Aviation Support

European Council of General Aviation Support Presentation to: EASA DOA Workshop - 7th Nov 2006 Dassault Aviation Saint- Cloud Paris France www.ecogas.net

What is ECOGAS? • ECOGAS is the European Council of General Aviation Support • ECOGAS comprises of the National General Aviation Associations and Commercial Organisations based in Europe • These Associations represent commercial General Aviation companies • General Aviation is that aviation outside military or major airline operations • ECOGAS was founded in 1988 by Gerard Pic (in France) and Danny Forman (in UK) www.ecogas.net

Objectives of ECOGAS • Co-operation and exchange of information between members • Representation of common interests to national and European Authorities • Co-operation with other European Associations in General Aviation • Expand General Aviation within Europe www.ecogas.net

Co-operation – Other European Associations • Co-operation with • European Business Aviation Association (EBAA) • European Regional Airlines Association (ERA) • International Aircraft Owners and Pilots Association (IAOPA) • European Association of Airline Pilots Schools (EAAPS) • Europe Airsports www.ecogas.net

What is the General Aviation Industry? • Design & Manufacture • Modification, including avionics installations • Maintenance • Supply of parts • Support services • Operations and flight training • New & used aircraft sales www.ecogas.net

Size of Industry in Europe – EU 15 • Approximately: • 29,000 single engine piston aircraft • 4,000 multi engine piston aircraft • 150 single engine turboprop • 1,000 multi engine turboprop • 2,000 jets • ECOGAS members represent the interests of around 1,000 companies • Companies from SME to multinational www.ecogas.net

For Today’s DOA Workshop • General Aviation is defined as: • CS Part 23 Aircraft – below 5,700Kg • VLA It is important to remember that Existing GA Companies are all Small or SMEs New start up projects must also be considered www.ecogas.net

The Presentation will follow the Question Sequence of EASA’s “The Future of DOA – Questionnaire to Industry” Some Perceived Problems are Identified and Suggestions are offered to help offset these. www.ecogas.net

Question 1: Are you satisfied with the current DOA concept as applied today ? If no, describe areas where the existing concept is seen as inefficient or doesn’t provide the necessary flexibility, www.ecogas.net

Question 1: Response • Answer – No • The financial burden for the acquisition and maintenance of a DOA for Small Companies and SMEs is significant (prohibitive to a new company) • This is compounded by having to employ sufficient people to meet the full range of skills demanded. Possibly justifiable for Large, CS 25, Manufacturers, but not the much smaller CS 23 and VLA companies. www.ecogas.net

Question 1: Response …cont’d • It is important to remember that the main competition comes from the USA where the concept of DOA does not exist. • In the USA an experimental category aircraft can be built and flown with comparative ease and minimal cost. • Experimental Category also allows a “Proof of Concept” aircraft to be built and flown before embarking on a Type Certification programme. www.ecogas.net

Question 1: Response …cont’d • The services of the FAA for example when demonstrating compliance with FAR 23 for Type Certification or STC are free. • For these reasons at least two new GA Design Projects are known to have gone to the USA in the last few years. www.ecogas.net

Question 1: Response …cont’d • It is essential we do what we can to encourage new GA projects in Europe – they provide the ideal breeding ground for new engineers to learn an gain experience in addition to creating commercial opportunities. • It is also important to minimise the overhead cost burden of airworthiness to European General Aviation companies to enable them to be competitive with the American market. www.ecogas.net

Question 1: Response …cont’d • Proposal 1: • Allow Small/SME companies greater freedom to nominate third party organisations, or consultants, to supplement their full time Design Team on an as and when required basis. This reduces the risk of employing under utilised full time specialists. www.ecogas.net

Question 1: Response …cont’d • Proposal 2: • For new General Aviation projects by start up companies, establish an equivalent to the USA Experimental Category to allow the production of a “Proof of Concept” prototype without a DOA(or POA). • Once the Prototype has been proven, allow for steady growth towards DOA as the Project develops. www.ecogas.net

Question 1: Response …cont’d • Proposal 3: • For small non complex aircraft develop a self regulatory system employing suitably qualified and experienced people in Trade Bodies, Voluntary Member Groups – and Companies ? • An MDM 032 consideration ? www.ecogas.net

Question 2: How are responsibilities/liabilities currently established in your organisation between DOA holder and sub-contractors ? Describe: • How delegation of certification tasks are made, if any; • What interfaces are present to control such delegation; • How liability is addressed. www.ecogas.net

Question 2: Response • Very difficult for a Trade Association to comment but typically in small companies internal delegation relies a conventional management “organigram” linked to the CVE structure. Use of external contractors seems to be kept to a minimum, preferring to bring people in-house when required. • This minimalist structure seems to suit small and SME companies. www.ecogas.net

Question 3: How are current Type Certification documents and data required for continuing airworthiness controlled ? Describe what control mechanisms are in place by the TC applicant to delegate and control documentation. www.ecogas.net

Question 3: Response • Small and SME companies typically use a controlled centralised Filing System for all documents and data. Electronic data storage is taking over but security is still a concern to some. • Accidents, incidents and MoRs are discussed at regular internal meetings and meetings with the NAA. www.ecogas.net

Question 4: Do you foresee that the DOA will be ineffective/uneconomic in meeting the future needs of Industry. Describe: • What are these future needs, or plans, in terms of distribution of design responsibilities. • What kind of DOA would be required in that context. www.ecogas.net

Question 4: Response • Yes: As covered under Q1, for small and SME GA companies the cost of obtaining and maintaining a DOA to present requirements disproportionately expensive. It is stifling new development and making competitiveness with US companies difficult. • The proposals made for Q1 are relevant here also. www.ecogas.net

Question 5: Do you considerate it necessary to recognise expertise at system or sub-system level ? Please provide: • justification and identify possible associated DOA privileges; • Pros and cons for having such recognition managed and controlled by the Agency or by industry itself. www.ecogas.net

Question 5: Response • Yes. There was some merit in the JAR 21 “JB” system for key component manufacturers. • Any such “JB” system must integrate with the minimum DOA as described under Q1. www.ecogas.net

Question 6: Some aircraft systems are already treated as Products and hold a TC in there own right (eg Engines and Propellers). Would you like to see an extension of theses principles to create a modular approach to certification ? If yes, describe: • What systems should be included, • What you see as the pros and cons of such an extension, • What interface issues may arise and how possible safety gaps are to be avoided, and • How overall control and responsibilities are to be managed. www.ecogas.net

Question 6: Response • In principle, yes.However… • Some major systems such as undercarriages and Auto Pilots are usually adapted to be aircraft specific. Where this is not the case, they could have their own TC or else the “core system” could have a TC. • The negative side could be the cost of the such TCs being out of proportion to the system cost. www.ecogas.net

Question 7: Would you be in favour of Industry self-certification of aviation products ? Please describe: • What you see as the pros and cons of such an approach, • What level of Agency involvement, if any, would be appropriate ? And, • The pros and cons of certification by 3rd party organisations. www.ecogas.net

Question 6: Response • Yes. • Covered in part under Q1 but benefits would be increased flexibility, cost savings and a better environment to encourage new designs. • Agency involvement could be limited to Audits and Final Approval for Projects wanting some form of Certification. • A (major) negative could be ultimate legal accountability. www.ecogas.net

Thank you for your attention • I hope I have made you aware of some of the concerns that exist in the small and SME GA companies relating to DOA and provoked thought with our suggestions and comments. • I will be pleased to answer any questions www.ecogas.net

European Council of General Aviation Support