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

7 th November 2006www.ecogas.net2 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)

7 th November 2006www.ecogas.net3 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

7 th November 2006www.ecogas.net4 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

7 th November 2006www.ecogas.net5 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

7 th November 2006www.ecogas.net6 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

7 th November 2006www.ecogas.net7 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

7 th November 2006www.ecogas.net8 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.

7 th November 2006www.ecogas.net9 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,

7 th November 2006www.ecogas.net10 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.

7 th November 2006www.ecogas.net11 Question 1: Response …contd 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.

7 th November 2006www.ecogas.net12 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.

7 th November 2006www.ecogas.net13 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.

7 th November 2006www.ecogas.net14 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.

7 th November 2006www.ecogas.net15 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.

7 th November 2006www.ecogas.net16 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 ?

7 th November 2006www.ecogas.net17 Question 2: How are responsibilities/liabilities currently established in your organisation between DOA holder and sub-contractors ? Describe: a) How delegation of certification tasks are made, if any; b) What interfaces are present to control such delegation; c) How liability is addressed.

7 th November 2006www.ecogas.net18 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.

7 th November 2006www.ecogas.net19 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.

7 th November 2006www.ecogas.net20 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.

7 th November 2006www.ecogas.net21 Question 4: Do you foresee that the DOA will be ineffective/uneconomic in meeting the future needs of Industry. Describe: a) What are these future needs, or plans, in terms of distribution of design responsibilities. b) What kind of DOA would be required in that context.

7 th November 2006www.ecogas.net22 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.

7 th November 2006www.ecogas.net23 Question 5: Do you considerate it necessary to recognise expertise at system or sub-system level ? Please provide: a) justification and identify possible associated DOA privileges; b) Pros and cons for having such recognition managed and controlled by the Agency or by industry itself.

7 th November 2006www.ecogas.net24 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.

7 th November 2006www.ecogas.net25 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: a) What systems should be included, b) What you see as the pros and cons of such an extension, c) What interface issues may arise and how possible safety gaps are to be avoided, and d) How overall control and responsibilities are to be managed.

7 th November 2006www.ecogas.net26 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.

7 th November 2006www.ecogas.net27 Question 7: Would you be in favour of Industry self- certification of aviation products ? Please describe: a) What you see as the pros and cons of such an approach, b) What level of Agency involvement, if any, would be appropriate ? And, c) The pros and cons of certification by 3 rd party organisations.

7 th November 2006www.ecogas.net28 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.

7 th November 2006www.ecogas.net29 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