DG's latest volley

In the latest DG newsletter:
http://www.dg-flugzeugbau.de/newsletter-138.html

As I read Dirks' comments, Weber is full of crap. I also think Weber
shot himself in the foot by publishing Dirks' comments.

As laid out by Dirks, the rules say "the latest version" of the manual
has to be used. He DOES NOT say that EASA requires it to be updated
ever, much less every year. Only that it be updated "if necessary,"
but if changes are made, then those manuals have to be made available
and used. The manuals need not be forced on people.

Dirks says,
"• Under 21.A.57 it states that the TC holder shall update all manuals
if necessary.
• Under 21.A.61 (b) it is stated that the TC must make the changes to
the
instructions of continued airworthiness (maintenance manuals)
available to all
known operators etc.." [emphasis mine]

Even when Dirks says,
"• Under M.A.401 a) it states that for all maintenance only applicable
current
maintenance data (manuals) can be used. In addition under M.A.401(c)
it states
that the person or organisation maintaining an aircraft shall ensure
that the
applicable maintenance data is current." [emphasis mine]

Dirks does not say that EASA says manuals have to updated every year.
As I read what Dirks says about MA.401 a), a 30 year manual can be as
considered current provided no safety issues or egregious errors have
come up in the mean time. A 30 year old manual with a minor typo that
does not effect safety is not an egregious error and EASA does not
require the manual to be changed.

Soooooooooo, when Weber says:
"There is the necessity always to have the valid manuals available."

He is correct. And when he says:

"This necessity does not need an A/D (Airworthiness Directive),
but it is defined in the rules of 'Part M'."

He is correct. And when he says:

"And there it is expressed absolutely clear."

Guess what! He is correct! It is just that Weber's actions are not
what is "expressed absolutely clear." As I read it, if anything is
"expressed absolutely clear" in Dirks' comments, it is that EASA is
not requiring ANY changes to the manuals.

So Friedel, put THAT in your pipe and smoke it!

On Apr 1, 10:24*am, raulb wrote:
In the latest DG newsletter:http://www.dg-flugzeugbau.de/newsletter-138.html

As I read Dirks' comments, Weber is full of crap. *I also think Weber
shot himself in the foot by publishing Dirks' comments.

As laid out by Dirks, the rules say "the latest version" of the manual
has to be used. *He DOES NOT say that EASA requires it to be updated
ever, much less every year. *Only that it be updated "if necessary,"
but if changes are made, then those manuals have to be made available
and used. *The manuals need not be forced on people.

Dirks says,
"• Under 21.A.57 it states that the TC holder shall update all manuals
if necessary.
• Under 21.A.61 (b) it is stated that the TC must make the changes to
the
instructions of continued airworthiness (maintenance manuals)
available to all
known operators etc.." *[emphasis mine]

Even when Dirks says,
"• Under M.A.401 a) it states that for all maintenance only applicable
current
maintenance data (manuals) can be used. In addition under M.A.401(c)
it states
that the person or organisation maintaining an aircraft shall ensure
that the
applicable maintenance data is current." [emphasis mine]

Dirks does not say that EASA says manuals have to updated every year.
As I read what Dirks says about MA.401 a), a 30 year manual can be as
considered current provided no safety issues or egregious errors have
come up in the mean time. *A 30 year old manual with a minor typo that
does not effect safety is not an egregious error and EASA does not
require the manual to be changed.

Soooooooooo, when Weber says:
"There is the necessity always to have the valid manuals available."

He is correct. *And when he says:

"This necessity does not need an A/D (Airworthiness Directive),
but it is defined in the rules of *'Part M'."

He is correct. *And when he says:

"And there it is expressed absolutely clear."

Guess what! *He is correct! *It is just that Weber's actions are not
what is "expressed absolutely clear." *As I read it, if anything is
"expressed absolutely clear" in Dirks' comments, it is that EASA is
not requiring ANY changes to the manuals.

So Friedel, put THAT in your pipe and smoke it!

I spoke to a local FAA guy this weekend. In his opinion no one is
required to pay for a yearly coversheet to remain legal.

Raul -

Here's how I read Dirks' comments:

He is not commenting on whether the manuals must be updated every
year.
He's saying that the law makes it clear: _If_ a manufacturer updates
their manuals, the Owners/Operators and Maintenance personnel are
required to ensure that they're using the updated manual.
The law doesn't state that DG must over the revised manuals for free -
just that they are required to be available.

I think Dirks' comments are being used to tell pilots in the EU "don't
ignore the fees from DG. If you refuse to buy updated manuals, you're
flying illegally."

As an extreme example: DG could come up with a new manual every week.
They could charge 100 Euros per manual and require pilots to walk
across a bed of hot coals at the DG factory before giving them the
manual. And if a glider pilot/owner doesn't have the most recent
manual (i.e. for that particular week) then they are not in compliance
with the law - Period!

Bottom-line: The way the laws are written (from what Dirks says),
owners/pilots in the EU are hostages - they are at the mercy of the
manufacturer. Any time the manufacturer revises the manuals, the
owners/pilots/maintenance-personnel are _required_ to get them. The
onus is on those people for having the proper manuals, no matter the
cost.

I love my DG-300; and boy am I glad that I am in the USA and that my
glider has an Experimental certificate! ...But Weber's actions
definitely have me re-thinking getting a DG-800 someday. ASW is
looking more appealing all the time (all donations are gladly
accepted)! :-P

--Noel

On Apr 1, 12:34*pm, "noel.wade" wrote:
Raul -

Here's how I read Dirks' comments:

He is not commenting on whether the manuals must be updated every
year.
He's saying that the law makes it clear: *_If_ a manufacturer updates
their manuals, the Owners/Operators and Maintenance personnel are
required to ensure that they're using the updated manual.

--Noel


Did you miss this part?

"Under 21.A.57 it states that the TC holder shall update all manuals
if necessary"


Who is going to judge whether these updates are "necessary"?

I still can't believe that a manufacturer would be allowed to use such
an arbitrary "loophole" as a money-making scheme.

On 4/1/2010 10:34 AM, noel.wade wrote:
Raul -

Here's how I read Dirks' comments:

He is not commenting on whether the manuals must be updated every
year.
He's saying that the law makes it clear: _If_ a manufacturer updates
their manuals, the Owners/Operators and Maintenance personnel are
required to ensure that they're using the updated manual.
The law doesn't state that DG must over the revised manuals for free -
just that they are required to be available.

I think Dirks' comments are being used to tell pilots in the EU "don't
ignore the fees from DG. If you refuse to buy updated manuals, you're
flying illegally."

As an extreme example: DG could come up with a new manual every week.
They could charge 100 Euros per manual and require pilots to walk
across a bed of hot coals at the DG factory before giving them the
manual. And if a glider pilot/owner doesn't have the most recent
manual (i.e. for that particular week) then they are not in compliance
with the law - Period!

Bottom-line: The way the laws are written (from what Dirks says),
owners/pilots in the EU are hostages - they are at the mercy of the
manufacturer. Any time the manufacturer revises the manuals, the
owners/pilots/maintenance-personnel are _required_ to get them. The
onus is on those people for having the proper manuals, no matter the
cost.

--Noel



That is how Weber wants you to interpret Dirks' comments. However, my
take is just the opposite -- the EASA has told Weber that they will not
cooperate with his scheme. Weber can never admit that he is wrong, so
his latest is an attempt to explain that the bad news at the EASA
doesn't matter, because you still need the latest manual from DG. I may
be missing something, but it does seem to me that this means that the DG
scheme has been shot down.

DG has lost its enforcement mechanism, because now it is just DG, rather
then EASA, that will say previous manuals are invalid. I would think it
is only EASA, not DG, that has the legal power to make old gliders
unairworthy.

Also, I believe DG originally had intended for EASA to declare that you
must get a new manual for your glider directly from DG, presumably with
your serial number on it. Thus, DG could extort money for the new
manual. But EASA has not cooperated, so now once one person has an
updated manual, everyone else can make a copy. So it would appear that
DG has lost the ability to charge for the updated manual.

On Apr 1, 10:43*am, Westbender wrote:
On Apr 1, 12:34*pm, "noel.wade" wrote:

Did you miss this part?

"Under 21.A.57 it states that the TC holder shall update all manuals
if necessary"

Who is going to judge whether these updates are "necessary"?

I still can't believe that a manufacturer would be allowed to use such
an arbitrary "loophole" as a money-making scheme.

I agree, its total B.S. However, there is no definition of
"necessary" in the laws that are currently written (at least, based on
what he wrote - I am in the USA and don't have time to review the
entire EU/EASA legal code).

I don't think Weber is trying to get rich off of this. But I *do*
suspect that he's been running his business at a loss, that he thinks
its because of the older gliders, and that he can close the gap by
employing this pay-for-manuals scheme. I happen to think he's wrong;
but I'm not alone in that opinion. :-P

-----
On a tangent -
-----
Given that glider manufacturing is a pretty labor-intensive process, I
wonder when the Chinese glider manufacturers are going to take off?
For awhile it seemed that affordable new gliders were coming from
Eastern Europe because of the depressed currencies and low labor
costs; but economic developments in those areas have changed the
equation. China is the logical "next place" for this activity, with
an abundance of cheap labor and the ability to ship out a product
globally. Some composite LSAs are now being built there and many
radio-controlled gliders are as well. Its only a hop, a skip, and a
jump from there to a Sailplane! The tough engineering work can be
done separate from the glider manufacturing itself. Frankly, I'm
surprised this isn't already happening (there may be a few limited
examples of it already occurring; but why isn't it more wide-spread?)

--Noel

On Apr 1, 11:33*am, "noel.wade" wrote:
On Apr 1, 10:43*am, Westbender wrote:

On Apr 1, 12:34*pm, "noel.wade" wrote:

Did you miss this part?

"Under 21.A.57 it states that the TC holder shall update all manuals
if necessary"

Who is going to judge whether these updates are "necessary"?

I still can't believe that a manufacturer would be allowed to use such
an arbitrary "loophole" as a money-making scheme.

I agree, its total B.S. *However, there is no definition of
"necessary" in the laws that are currently written (at least, based on
what he wrote - I am in the USA and don't have time to review the
entire EU/EASA legal code).

I don't think Weber is trying to get rich off of this. *But I *do*
suspect that he's been running his business at a loss, that he thinks
its because of the older gliders, and that he can close the gap by
employing this pay-for-manuals scheme. *I happen to think he's wrong;
but I'm not alone in that opinion. :-P

-----
On a tangent -
-----
Given that glider manufacturing is a pretty labor-intensive process, I
wonder when the Chinese glider manufacturers are going to take off?
For awhile it seemed that affordable new gliders were coming from
Eastern Europe because of the depressed currencies and low labor
costs; but economic developments in those areas have changed the
equation. *China is the logical "next place" for this activity, with
an abundance of cheap labor and the ability to ship out a product
globally. *Some composite LSAs are now being built there and many
radio-controlled gliders are as well. *Its only a hop, a skip, and a
jump from there to a Sailplane! *The tough engineering work can be
done separate from the glider manufacturing itself. *Frankly, I'm
surprised this isn't already happening (there may be a few limited
examples of it already occurring; but why isn't it more wide-spread?)

--Noel

I don't think China is going to be much intested in producing gliders
because the market it so small.

On Apr 1, 12:52*pm, Grider Pirate wrote:

I don't think China is going to be much intested in producing gliders
because the market it so small.

I agree with you that I don't see any *glider-only* companies
emerge.

But there are companies in China that are already in the business of
producing molded composites (R/C airplanes, LSAs, composite sub-
assemblies for various industries, etc). A company in this business
could build some gliders as a way to diversify their product offerings
and fill gaps in their production schedules (for example, if an LSA
manufacturer there isn't running at full capacity).

Chinese labor statistics are hard to come by, but one BLS study in
2006 (http://www.allbusiness.com/manufacturing/4004559-1.html) pegged
the aggregate labor rate at $0.67/hour. Even if that has tripled to
around $2/hour, that's still a HUGE cost-savings over other labor
markets. Sure, a bunch of your money is eaten up dealing with Chinese
governmental issues, corruption, export law issues, shipping ,etc...
But I bet it is still a cheaper solution overall. If its just a "part-
time" operation for a manufacturer there who's already engaged in
similar work (therefore having many of the tools and labor skills
already at-hand), I would bet that you could set a good enough profit-
margin for the manufacturer to make it worthwhile to produce 10 - 30
gliders per year; yet still represent a decent cost-savings over
existing gliders. Whether the savings is ENOUGH to convince people to
buy the glider is the big question. Its been tough for glider
manufacturers to sell less-than-cutting-edge gliders (people seem to
prefer to buy used equipment that's perceived as having top-notch
performance); but the question is whether this issue is a result of
the price difference not being big enough, or whether the market
simply won't support a "non-competitive" new glider at any reasonable
price.

OK, enough rambling for now...
[Can you guess who's taking a long lunch today?]

--Noel

-----
On a tangent -
-----
Given that glider manufacturing is a pretty labor-intensive process, I
wonder when the Chinese glider manufacturers are going to take off?
For awhile it seemed that affordable new gliders were coming from
Eastern Europe because of the depressed currencies and low labor
costs; but economic developments in those areas have changed the
equation. *China is the logical "next place" for this activity, with
an abundance of cheap labor and the ability to ship out a product
globally. *Some composite LSAs are now being built there and many
radio-controlled gliders are as well. *Its only a hop, a skip, and a
jump from there to a Sailplane! *The tough engineering work can be
done separate from the glider manufacturing itself. *Frankly, I'm
surprised this isn't already happening (there may be a few limited
examples of it already occurring; but why isn't it more wide-spread?)

--Noel

So far China has a reputation of making junk when it come so somewhat
sophisticated items. Motorcycles come to mind. China has made
"clones" of many of the Japanese motorcycles and scooters. They cost
less, look good, but fall apart quickly. There is practically no way
to get them to make good on warranty. Spare parts are hard to get
too.

If there were such a thing, I would think long and hard about buing a
Chinese made glider.

I wonder how Cessna will do with their Chinese airplane?

For now I, when it comes to Chinese products, I will stick to Mardi
Gras Beads.......

On Apr 1, 5:30*pm, "
wrote:

...If there were such a thing, I would think long and hard about buing a
Chinese made glider...

The middle ground that suggests itself is to outsource the larger,
more labor-intensive, components such as fuselage shells and wing
skins. Then you could join them into major subassemblies (wings,
fuselage) in an environment where their quality, and the quality of
the overall assembly, can be inspected and vouched for.