Select Committee on Transport Written Evidence

APPENDIX 3: Memorandum by Mr Mike Godsell

  In considering the function and purpose of the CAA, it would be useful to make a comparison between the regulation and maintenance of cars, and of light aeroplanes (simple, single engine, less than 2,700 KGs weight).

  For both private cars and privately owned light aeroplanes, the main motivation for owners to observe rules and regulations is insurance. No sane car driver or aeroplane pilot would travel anywhere without valid accident insurance, to do so would risk legal action and financial disaster.

  However the simple and straightforward car MOT checks, and drivers responsibilities, are in stark contrast to the layers of regulation, the expense, and the numbers of persons involved, in assessing the safety of a small aircraft to fly.

  Even if the aeroplane is absolutely 100% physically fit to fly, with all systems correctly maintained and inspected, the absence of a single signature on some obscure document is enough to invalidate the insurance. Indeed we have now reached the point where owners are spending more and more time and money on checking layers of paperwork, to assess the legal and insurance status of the aircraft. This often limited time and money would be better spent on new parts and physical checks, which genuinely enhance the fitness to fly.

  For example, the so called Certificate of Airworthiness (C of A) issued at one and three yearly intervals by the CAA, should be more accurately named a Certificate of Legality" It has nothing to do with the fitness for flight of an aeroplane, it is only concerned with the fitness" of vast numbers of documents and contributes nothing to safety.

  The C of A should be issued to certify only that an aircraft conforms to design regulations, type certificate, etc. It should thereafter remain valid for the life of the unmodified aircraft. The main concerns of both owners and insurers would then be the actual physical fitness for flight of the machine.

  Responsibility for fitness should be placed on the owner. He should be able to access a number of specialist workshops able to carry out and certify engine overhauls, avionics, repairs, etc. The aviation equivalent of MOT establishments should assess aircraft condition and issue an aviation MOT certificate annually. At least one layer of CAA regulation should be removed to allow owners to maintain their aircraft, and engineers to practice engineering. Both groups need to know that insurers will be mainly concerned with aeroplane fitness, and not numbers of signed documents.

  The simplest way to achieve this is to put all simple single engine light aircraft on the PFA permit scheme, and do away with CAA over regulation.

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