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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