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PRELIMINARY ANALYSIS OF RESPONSES TO INDUSTRY QUESTIONNAIRE David Haddon Initial Airworthiness

PRELIMINARY ANALYSIS OF RESPONSES TO INDUSTRY QUESTIONNAIRE David Haddon Initial Airworthiness EASA Rulemaking Directorate. Background. WHY A QUESTIONNAIRE? Acknowledgement that moving from JAR 21 to Part 21 (EC 1702/2003) have created some difficulties in some areas

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PRELIMINARY ANALYSIS OF RESPONSES TO INDUSTRY QUESTIONNAIRE David Haddon Initial Airworthiness

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  1. PRELIMINARY ANALYSIS OF RESPONSES TO INDUSTRY QUESTIONNAIRE David Haddon Initial Airworthiness EASA Rulemaking Directorate

  2. Background WHY A QUESTIONNAIRE? • Acknowledgement that moving from JAR 21 to Part 21 (EC 1702/2003) have created some difficulties in some areas • Recognition that industry practices are changing • To seek out stakeholders views and to build on previous discussions to generate specific ideas • To listen to our stakeholders and to help ensure that regulations are developed that are appropriate and proportional to the safety risks

  3. Industry Response • 3 Associations • Aerospace & Defence Association of Europe (ASD) • European Council of General Aviation Support (ECOGAS) • European Glider Manufacturers Association (EGM) • 23 DOA holders • 16 Non-DOA holders Total 42 responses

  4. The Good News (Advantages of the current DOA system) • Clear lines of responsibility • The level of safety remains very high • DOA privileges to classify and approve compliance with EASA standards • DOA has contributed to an increased level of trust between holders and EASA • International recognition

  5. Stakeholder Satisfaction Only 26% of those who responded said they were satisfied with the current DOA concept. Reasons given for dissatisfaction included: • Part 21 is seen as being inferior to JAR-21/ National system • Loss of “JB” approval • Framework does not cater for a consortium of major companies • DOA system is not suitable for GA and recreational aircraft manufacturers.

  6. Meeting Future Needs 83% of respondents (92% of those who expressed an opinion) felt that the existing DOA will be ineffective/uneconomic in meeting the future needs of Industry. Areas for improvement include: • Recognition and distribution of responsibilities to suppliers and “centres of excellence” • Workshare between the EASA and DOA holders • De-regulation for GA and recreational aircraft • Etc, etc.

  7. Meeting Future Needs:Some Industry Ideas • Allow TC/STC holders to distribute responsibilities and privileges. • Harmonisation of design assurance rules. • Recognition of industry standards (e.g. EN 9100) • A single design and production approval. • Enhanced EASA oversight of NAAs. • New and/or extensions to DOA privileges • Simpler rules for GA and recreational aircraft

  8. Meeting Future Needs: Recognising Sub-Contractors 67% were in favour of recognising design expertise at sub-contractor/supplier level. • Against were manufactures of non-complex aircraft and equipment, who retained expertise in-house. • A TC/STC applicant will generally not have expertise for the complete design. • Already today, the TC applicant relies on sub-contractors/suppliers to support compliance declarations.

  9. Recognising Sub-Contractors PROS (for) • Serves the needs of industry. • Specialist firms can retain their expertise and know-how. • Post TC work would be more efficient if done by the OEM. • Aid acceptance of European parts in a global context. • Aid standardisation of implementing rules. CONS (against) • Privileges could only be granted if associated with a dedicated CS. • Must not lead to uncertain or ambiguous interfaces and responsibilities. • Determination of the effect a system change has on an aircraft could not be made without the TC holder, even for the approval of minor mods.

  10. Meeting Future Needs:Novel Concepts of Certification A modular approach to certification • 31% generally in favour - 40% against • Those against were generally the large aircraft/engine TC holders and existing DOA holders, who felt that this would blur responsibilities and create system integration issues. • Extension to ETSO? • Small aircraft manufacturers would like to keep both options open.

  11. PROS (for) Clearer allocation of responsibilities/liabilities. TC applicant could accept certification documents and data without further verification. PMA type approval could help European industry to compete. For GA applications, “plug and play” equipment could have a unique approval. Any generic system with potential multiple applications could be considered. CONS (against) Responsibility should be retained in a single org. Experience shows that interfaces are problematic. An aircraft is not a sum of its parts. Developing cert. specs. would be a huge effort. Integration of parts could result in dual certification. Each approval would add additional costs. Most systems are adapted for each specific aircraft. Recognition outside Europe. A modular approach to certification

  12. Meeting Future Needs:Novel Concepts of Certification Industry self-certification • 31% generally in favour - 43% against • GA and DOA holders (modification/repair), generally in favour, Large aircraft/engine TC holders and suppliers, against. • Could be linked to experience or Agency confidence. • A distinction should be made based on the criticality of the item. • Adopt a system of “Designees” similar to the FAA ODA system.

  13. Industry Self-certification PROS (for) • Product developer is fully responsible/accountable. • Existing DOAs could focus on integration issues. • Could formally adopt AS EN 9100. • Would reduce admin., provide flexibility and lead to cost/time savings. • Clearer planning of resources and activities would be possible. CONS (against) • Recognition by foreign authorities? • Decrease in the level of safety? • Loss of Agency expertise. • Experience with other self regulating bodies is poor. • Loss of uniformity. • Insurance? • Introduction of new technology/processes requires independent technical oversight.

  14. Meeting Future Needs:Novel Concepts of Certification 3rd Party Certification • Could be on a voluntary basis. • 3rd party organisation would need to be cheap, independent and constant. • Use existing NAAs in this role, subject to control.

  15. 3rd Party Certification PROS (for) • Could increase safety and reduce costs by enabling a greater focus on safety rather than continually preparing for different audits. • Would harmonise with FAA ODA. CONS (against) • Will add another tier of bureaucracy. • Issues of finance may cloud cert. requirements. • A single independent body should be retained. • International recognition? • Impact of insolvency and loss of traceability of 3rd party organisation. • Aviation safety is a state function to be controlled by the people, for the people.

  16. Questions Please feel free to ask any question

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