August 6, 2021, ©. Leeham News: Last week, we went through the OTA, Authorization To Offer milestone.
Now we look at another important milestone in the Pre-Launch phase, the design Certification application. It involves some tricky differences in rules and procedures between the primary Certification authorities.
The FAA, Transport Canada, and EASA use different principles on how to arrive at a Type Certificate (TC) for the aircraft design.
The FAA system is a direct oversight system. FAA experts do the design oversight of a Type Certificate application until it reaches a Type Certificate. Alternatively, the applicant may hire FAA designees to do the FAA direct oversight, so-called Designated Engineering Representatives (DER) and Designated Airworthiness Representatives (DAR).
FAA states in 14 CFR Part 21.13: “Any interested person may apply for a Type Certificate.” It will then help the applicant to either hire the competence needed via DERs and DARs or assist in building up an organization that can get the project to a Type Certificate.
It’s a softer start system than the EASA system, which is an indirect system. It asks the project to build the necessary competence for self-certification before the application is approved. Then EASA follows the project with an indirect oversight, doing periodic inspections and sample tests of documents.
To get to where an organization can do its oversight, EASA demands you reach a Design Organisation Authorization (DOA) level before the application is accepted.
It has a comprehensive list of requirements for how to reach a Design Organisation Authorization level. You need to establish:
Transport Canada is somewhere in between these two.
TCCA 521.26 says: “An applicant for a type certificate in respect of an aeronautical product shall have, or have access to, the technical capability to conduct the design analyses and tests required to demonstrate the conformity of the aeronautical product with its certification basis.”
If it deems the applicant doesn’t have this competence, it can refuse the application.
In the end, all three organizations certify to very similar requirements, and the hurdles to get a Type Certificate are the same.
It’s how you get there that differs. The FAA method allows an upstart project to gradually build its competence, whereas EASA requires a minimum level before a Certification application is approved.
For an investor in an aviation upstart like ours, the information we have been granted an FAA application doesn’t have the same value as an EASA approval. It would mean we have an organization that can hold a DOA with all it entails regarding competence, procedures, and documentation.
The certification process requires you to issue and keep track of thousands of documents and files. It ranges from CAD/CAM/PDM files, Requirements, Specifications, Reports, Meeting protocols, Communication logs, Certification documents, etc.
All these files must be tracked with versions; which are the valid versions at a particular time, and which are checked out of the system for revision? Where are these in the revision flow, when do they check in again, and will they then become the valid version?
For this, the established OEMs have hundreds of IT applications, often homegrown. There are workflow applications available that support such flows. Some are from established CAD/CAM/PDM vendors, others from document management and workflow companies.
Before we go to the Post-Launch phase, such applications must be up and running, and people must be proficient at using them correctly.
We are soon transitioning from the conceptual design phase where we work with fewer than 100 engineers to the detailed design phase, which explodes our work packages to where we need perhaps a thousand engineers. The amount of documents and files increases accordingly, and we must be able to handle it.
There are large airplane projects that have not managed this process well, with dire consequences. The cable crisis of the Airbus A380 was because different organizations didn’t have the correct files to work from and one of the many reasons the Boeing 787 got into design problems was because the project lost track of where the design was at each point in time.