The Future of DOA Workshop 7 th November 2006 1 PRELIMINARY ANALYSIS OF RESPONSES TO INDUSTRY...

7th November 2006 1

The Future of DOA Workshop

PRELIMINARY ANALYSIS OF RESPONSES TO INDUSTRY

QUESTIONNAIRE

David HaddonInitial Airworthiness

EASA Rulemaking Directorate

7th November 2006 2


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

Background

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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

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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

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Stakeholder Satisfaction

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.

Only 26% of those who responded said they were satisfied with the current DOA concept.

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Meeting Future Needs

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.

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.

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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

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Meeting Future Needs: Recognising Sub-Contractors

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.

67% were in favour of recognising design expertise at sub-contractor/supplier level.

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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.

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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.



A modular approach to certification

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.




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.



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.




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.



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.



Questions

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The Future of DOA Workshop 7 th November 2006 1 PRELIMINARY ANALYSIS OF RESPONSES TO INDUSTRY...

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