There is nothing in this statement from Mike B that contradicts what I
wrote. It is not I that misunderstands the certification process or the
politics surrounding it. I think that Mike B does too, but objects to
some of the consequences of the process and the politics.
A South African manufacturer elected to certify to the European
standard, to gain a type certificate issued by the South African
authority. They did not elect to have the European authority do their
certification, and the European authority has, as they are entitled
(though not necessarily technically justified: this is politics and
economics coming into play) without further justification. It appears
that Australia has accepted the South African certification process,
perhaps following a desk-top review of the process, hence an Australian
type certificate has either been issued or is in process and the type is
flying on experimental certificates in the interim. (And only the agent,
the Australian owners and the certification authority know the full
details.)
Many people rail against "certification" for gliders and say we do not
need it. Would they likewise say that we should all be able to go out
and buy a car that had not been shown to meet the Australian Design
Rules? I doubt it, as the liability issues are far greater with a car
because of the number of "innocent bystanders" they expose is a much
bigger number. So what does certification do? It identifies that the
individual airframe conforms to a known and proven standard, giving at
least a partial guarantee that it has no known design defects and will
presumably be able to be sold to someone else in future without leaving
the seller with any residual responsibility. (Most experimental
aeroplanes in the US are never sold to a second owner - even if
perfectly serviceable they are simply abandoned when the owner/builder
retires either themself or the aircraft from flying.) It also provides
protection to the original buyer that the manufacturer takes
responsibility for the design and is required by law to report any known
problems and issue service bulletins to resolve them - these form the
basis for Airworthiness Directives to legally enforce carrying out the
work to fix the problem, as well as providing a maintenance schedule to
keep the aircraft in its original (or at least within tolerances of
that) for as long as possible.
The reasons for operating an aircraft outside its certification (and
hence voiding all these guarantees and safeguards) may be to allow the
owner to maintain it themself, or to make unapproved modifications (not
necessarily unsafe, but not proven or ones for which the manufacturer
will not assume responsibility), to allow the owner to fly the aircraft
outside its certified limits (weight, CG position, manoeuvres not
permitted by the manufacturer, etc). In the US these are done by opting
to fly the aircraft on an Experimental Certificate issued for
exhibition, display or air racing, which the FAA is usually happy to
issue provided some operating restrictions are accepted - such as not
flying over built-up areas or in certain types of airspace.
It is a sad fact that certification costs money (especially when the
certifying authority is EASA, as a 27-nation organisation has the
overheads of large bureaucracy without any particular advantage for
small or recreational aircraft). The advantages accrue to the large
aircraft operated by airlines, and unless they find an acceptable
process for light aircraft (and this still costs to develop a suitable
standard and process) then EASA may never be a suitable certification
authority for these aircraft. They have not yet accepted the LSA
standards that cover most glider designs quite adequately, except that
they restrict the approval of modifications to the original manufacturer
rather than to a competent engineer - even to the kind of radio fitted
in some cases!
Another problem with a certified product is that the engineer who
approves a modification has to take responsibility for that
modification, which in these times involves product liability insurance
or the risk of being sued under an imperfect legal system. Again this
raises costs.
It all depends on how much responsibility you are willing, or are
permitted by society, to assume on your own shoulders - and society is
often unnecessarily restrictive on the individual in an effort to
protect the majority against the very few who would be classed as
psychopaths, or even those who exploit the weaknesses of others to an
unreasonable extent for personal gain. The problem is defining what is
reasonable!!!
Wombat
On 28/04/2012 8:50 AM, Mike Borgelt wrote:
Maybe you should have looked at the Jonker site re certification
before going in to print.
EASA won't accept their South African certification unless they do it
again from scratch with EASA observers.
Alternatively EASA will accept this if South Africa and Europe come to
an agreement at a governmental level to allow this - negotiations on
this now seem to include agreement on bi-lateral airline links between
Europe and SA. In other words come back in a decade or so.
Even if this agreement is reached I wouldn't take a bet against the
Euros saying "that will be fine for the NEXT glider but as the
agreement wasn't in place for the JS1 you'll still have to do it again".
The rather sad joke doing the rounds is "Heard about the new CS 22
Amendment 3 ? All non German gliders must perform worse than German ones"
You might also read the FlightGlobal article I linked to "we have
created a monster" was a memorable quote.
There's no need for recreational aircraft to have this sort of
certification.
Mike
Bernard and others
The Republic of South Africa is a signatory state to the
International Convention on Air Navigation (i.e. a member of ICAO the
International Civil Aviation Organisation). As such it uses processes
accepted by all other ICAO member states for matters such as
certification, registration and flight crew licensing. Hence a South
African pilot flying a South African registered aircraft may fly into
other ICAO countries without hindrance.
Provided the certification standard used is compliant with ICAO Annex
8, other member countries are bound to accept it. Of course, CS-22
(the EASA glider standard) is so accepted, and continuing
airworthiness control is implied in the certification. So too are the
older OSTIV and BCAR Section K standards.
Australia will AUTOMATICALLY accept type certification by 7 or 8
worldwide regulatory authorities for the issue of an Australian
Certificate of Airworthiness. The EC (EASA) and USA (FAA) are two of
these, as are the UK, Sweden, New Zealand and Canada. An aircraft
with a type certificate issued elsewhere can be issued an Australian
type certificate after the standards and processes used for its
country-of-origin certification have been verified - usually a
desk-top exercise and probably not too difficult in the case of South
Africa as they are generally regarded as a "Western" nation using
standardised processes.
There should be no difficulty other than usual bureaucratic delays
due to workload and too few people working on it to the GFA being
allowed to issue an Australian C of A to a South African-designed
glider. They do this as a delegate of CASA, but CASA does the type
acceptance and then hands on the less complex tasks.
Wombat
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