European Council of General Aviation Support

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European Council of General Aviation Support
Presentation to EASA DOA Workshop - 7th Nov 2006
Dassault Aviation Saint- Cloud Paris France
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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)

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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

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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

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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

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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

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For Todays 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

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The Presentation will follow the Question
Sequence of EASAs The Future of DOA
Questionnaire to Industry

• Some Perceived Problems are Identified and
  Suggestions are offered to help offset these.

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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
  doesnt provide the necessary flexibility,

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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.

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Question 1 Response contd

• 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.

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Question 1 Response contd

• 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.

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Question 1 Response contd

• 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.

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Question 1 Response contd

• 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.

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Question 1 Response contd

• 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.

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Question 1 Response contd

• 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 ?

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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.

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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.

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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.

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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.

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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.

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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.

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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.

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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.

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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.

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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.

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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.

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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.

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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