This story continues from the previous installment here:
http://ozreport.com/16.098#5

Carsten Friedrichs [<carsten.friedrichs>]
writes:

According to Klaus Tänzler and Christof Kratzner no load test,
only pitch testing is necessary. I explicitly asked about load tests because I
know that with structural tests, I could just buy a new glider.

As I understand, they just want to verify what is written in the HGMA
documentation according pitch.

A general point why the DHV has a problem with the HGMA certification: They
insist on an independent test organization. Christof does not recognize the HGMA
as independent since the HGMA President is Mike Meier, a member of Wills Wing.
But you might know that.

Mike Meier <<Mike>>
writes:

If the DHV is offering, as you say, to issue the Gütesiegel on the
basis of the HGMA certification of a glider, this is the first I have heard of
it.

Regarding your statement, " Klaus told me that all manufacturers were informed
about that possibility but none did make use of that option yet," - no one from
the DHV has ever made the offer to Wills Wing that with a DHV test verification
of the HGMA pitching moment tests, done at no charge for an HGMA certified
glider, along with the submission of the complete documentation of the HGMA
certification, the DHV would then issue a DHV Gütesiegel. Had that offer been
extended to us we certainly would have taken advantage of it, as it implies a
process in which the DHV simply accepts the HGMA certification as is, without
any requirement that the glider meet any additional or different requirements
outside of the HGMA standards, and does so without any extra cost to the
manufacturer. This is (excluding the requirement for pitch test verification,
which we think is both problematic and unnecessary), what we've been asking for
all along, and of course we would accept this.

But this is not at all what the DHV offered the last time I discussed this with
them, which was the last time we certified two gliders with the DHV four years
ago, as I have explained below. What they have offered in the past was to waive
the fee for (only) the vehicle testing of an HGMA certified glider to the LTF
standards, as part of an application for LTF certification.

Also, I don't at all understand why they would need to verify only the pitching
moment tests. Aren't the structural strength and the flight characteristics of
the glider as important as the pitching moment test results? If they don't trust
the HGMA to do the pitch tests correctly, why would they trust the test results
for structure and flight characteristics? And what happens when they attempt the
HGMA pitch tests and don't get the same results? Who determines which results
are correct? Do we then engage a third party to verify the tests? If what the
DHV wants is to participate in the review process of HGMA certification
documentation, I can envision a simple way in which that could happen. The
normal HGMA certification process involves the manufacturer compiling all of the
documentation and test results for the glider, and the directors of the HGMA
then reviewing that documentation and then issuing the HGMA certification if the
documentation is correct and complete. A manufacturer wanting to obtain the DHV
Gütesiegel in addition to HGMA certification could then simply submit the
documentation to the DHV for their review as well as to the HGMA board. No
additional testing would be necessary or required. This could be a very easy
solution, and as I understand it, this may be possible under current German law.

As far as Mike Meier being president of the HGMA and a member of Wills Wing -
yes, this is true. It's also true that the HGMA president has no particular or
special authority in the HGMA program - the presidency is primarily an
administrative position - more like a secretary. Applications for certification
are reviewed by the HGMA directors. But yes, this is the way the HGMA is set up
- it is an association of manufacturers, and the directors and officers,
including the president, have always been elected from representatives of the
member manufacturers. And if one wanted to pose a hypothetical argument that
this structure might somehow compromise the validity or integrity of the HGMA
program, one could certainly make that argument. And if the HGMA program were a
new program just now being introduced, it might be entertaining to debate that
question. But in reality, that question is entirely irrelevant, as is every
other such hypothetical complaint that might be raised regarding the structure
or administration of the HGMA program. They are irrelevant because the HGMA is
not a new program, it is in fact the oldest hang glider certification program in
existence, with a thirty-five year history of certifying gliders. In that
thirty-five year history, three hundred and forty-six different hang glider
models have been certified by thirty-seven different member manufacturers, and
there is nothing in that thirty-five year history to suggest that those HGMA
certified gliders have been in any way less airworthy or less safe than the hang
gliders certified under the LTF (DHV) testing program.

And this simple fact points clearly to the only rational solution to the current
situation: Germany should simply accept the HGMA (and the BHPA) certification as
valid - without any requirement for any additional testing, verification, fees,
paperwork, or anything else. The proven history of airworthiness over more than
three decades of the gliders certified under these programs clearly shows that
this is the only rational response. By extension, any position that refuses to
recognize this simple fact is inherently irrational, or is based on motives or
interests that are not limited to concerns about the airworthiness of the hang
gliders in question.

With regard to Klaus' comment to you in his recent email that, "Christof
Kratzner is preparing a thorough comparison of the US requirements versus LTF
requirements for the next DHV board meeting at 16. June 2012. In this meeting
the board will look for a proper way how DHV can help that US and UK certified
gliders meet the German air law requirements."

Such a comparison has already been done - I did it four years ago at the request
of an LBA approved testing house. It is posted on our web site here:

http://www.willswing.com/articles/ComparativeAnalysisLTFvHGMA.pdf

It is fairly lengthy and in some places technical, and the complete history and
details of hang glider airworthiness testing and certification are far more
lengthy and far more technical, but in the end, all of that complexity and all
of those details are not really important to the question at hand. The reality
is that we have three ongoing hang glider airworthiness programs, each of which
has proven, over a period of more than thirty years, that it produces verifiably
airworthy hang gliders. That's all we really need to know, and all we really
need to do is recognize that simple fact.