The Future of DOA Workshop 7 th November PRELIMINARY ANALYSIS OF RESPONSES TO INDUSTRY QUESTIONNAIRE David Haddon Initial Airworthiness EASA Rulemaking Directorate

The Future of DOA Workshop 7 th November 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

The Future of DOA Workshop 7 th November 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

The Future of DOA Workshop 7 th November 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

The Future of DOA Workshop 7 th November 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.

The Future of DOA Workshop 7 th November 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.

The Future of DOA Workshop 7 th November 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

The Future of DOA Workshop 7 th November 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.

The Future of DOA Workshop 7 th November 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.

The Future of DOA Workshop 7 th November 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.

The Future of DOA Workshop 7 th November 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.

The Future of DOA Workshop 7 th November 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.

The Future of DOA Workshop 7 th November Industry Self-certification PROS (for) Product developer is fully responsible/accountable. Existing DOAs could focus on integration issues. Could formally adopt AS EN 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.

The Future of DOA Workshop 7 th November Meeting Future Needs: Novel Concepts of Certification 3 rd 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.

The Future of DOA Workshop 7 th November rd 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.

The Future of DOA Workshop 7 th November Questions Please feel free to ask any question