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. 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?“ Contents:

3. 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. Introduction„Who are we - whom do we represent?“

4. 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 Introduction„Who are we - whom do we represent?“

5. 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 Introduction„Who are we - whom do we represent?“

6. 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 Introduction„Who are we - whom do we represent?“

7. 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 National rules - JAR - EASA„DOA in the past - what is the history?“

8. 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 National rules - JAR - EASA„DOA in the past - what is the history?“

9. 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 National rules - JAR - EASA„DOA in the past - what is the history?“

10. 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 National rules - JAR - EASA„DOA in the past - what is the history?“

11. 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 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 DOA´s National rules - JAR - EASA„DOA in the past - what is the history?“

12. Introduction of JAR 21 - DOA on an European level: total sum of costs by the switch “national to JAR21”:for 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... National rules - JAR - EASA„DOA in the past - what is the history?“

13. 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 National rules - JAR - EASA„DOA in the past - what is the history?“

14. 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 National rules - JAR - EASA„DOA in the past - what is the history?“

15. 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 National rules - JAR - EASA„DOA in the past - what is the history?“

16. 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 efficientAND NO BENEFIT regarding safety / certification speed. National rules - JAR - EASA„DOA in the past - what is the history?“

17. 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! Status quo„How works sailplane development today?“

18. 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) Status quo„How works sailplane development today?“

19. 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! Status quo„How works sailplane development today?“

20. 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 Future of DOA„What is needed for light aviation?“

21. 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 Future of DOA„What is needed for light aviation?“

22. 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 Future of DOA„What is needed for light aviation?“

23. 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 Future of DOA„What is needed for light aviation?“

24. 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 Future of DOA„What is needed for light aviation?“

25. Thank you - any questions? Future of DOA