Instructor Survey Flight Training Using Amateur-Built Microlights

Flight Training Using Amateur-Built Microlights

This survey has now closed. Thank you to all who took part.


Dear Instructor

As I am sure you are aware there is a restriction that prevents you from using an amateur-built (kit built) aircraft for remunerated flight training unless the student pilot is an owner, or part owner, of the aircraft. At one time only a sole owner could take and pay for such training. The BMAA managed to get the current extension which allows share owners to pay for flight training as well. However, we have been pressing the CAA to drop all restrictions and allow remunerated flight training to take place without the student pilot having to be an owner, either sole owner or a share owner.

Following a public consultation, the result of which was to support the BMAA’s proposal, the BMAA has been working on a procedure which will meet additional requirements that the CAA will likely impose for such use. The purpose of the requirements is to create a safety record to demonstrate whether there is any greater risk using these aircraft compared to factory-built aircraft. We hope that after a short period data would demonstrate that these aircraft are no less safe that factory-built aircraft used in the training role.

The Purpose of this letter to you is to gauge the likely take up of the change so that we can judge whether it is worth us going ahead to complete the project. There will be a significant cost to the BMAA in CAA fees as well as staff time, so we want to make sure that if we go ahead it will be money well spent. I have listed below the likely additional requirements for using these aircraft as opposed to a factory-built aircraft. We would like your feedback for which we have set up a response form lower down this page.

Aircraft suitability: Each aircraft must be individually approved for the use by the BMAA.

How: A school must first tell the BMAA of their intention to use the aircraft in this way. The BMAA will then appoint an inspector who will conduct a Permit to Fly revalidation inspection and the BMAA will subsequently revalidate the Permit to Fly at that point.

The aircraft will be assessed for its suitability for training use. This will include assessment of control layout, instrument fit, intercom fit. The assessment will also include an assessment of ground and flight suitability for flight training. It is likely that if the type is an amateur-built type that is already being used for flight training as a factory-built type it will automatically be assessed as suitable. However, if the type is unknown to the current fleet flight testing may be required.

The engine must not be allowed to run beyond the manufacturer’s recommended overhaul period or must satisfy an agreed alternative means of compliance. CAA have stated that there is no agreed alternative means of compliance for Rotax engines; they must therefore be maintained in accordance with the Rotax maintenance manual (particularly the engine's age and TBO).

The BMAA will maintain records of the aircraft use through the Permit to Fly applications.

Schools must report any occurrences to the BMAA as well as using the MOR process if applicable.

Permission: The original builder must give written permission for the aircraft to be used for remunerated flight training of non-owners.

Why: When there is an accident, particularly when there is injury to the student pilot, there is a chance that any legal proceedings trying to get compensation will also turn to the person who built the aircraft. We know of at least one example, which although there was no blame proven it still cost the builder a considerable amount of money in legal fees. The CAA are adamant that this written permission must be in place.

Outcome: The requirement for builder permission is in most cases likely to mean that the school will have to use an aircraft built by the school itself rather than an existing aircraft.

Recording requirements: Additional recording of use is required.

Why: The CAA want to build a data record of use to judge whether there is a greater risk using amateur-built aircraft for training than factory-built aircraft.

What: Use, maintenance and incidents.

An annual record of flight hours used for training in addition to total hours used in the year. These will be recorded at permit revalidation and held by the BMAA.

Maintenance must be recorded. (No difference to normal use, although an inspector sign-off of maintenance may be required as for aircraft used for hire. See BMAA Til032

MOR Mandatory Occurrence Reports The school must use the MOR system to report any incidents or accidents which occur involving the aircraft.

Informing the student: The student pilot must be informed that the aircraft is an amateur-built aircraft rather than a factory-built one before they fly.

The CAA are treating this as a significant step with a safety risk, consequently they are trying to mitigate any liability, and telling the student that the aircraft is not factory-built is one way they think will help. We know that amateur built aircraft have been used for flight training for years under the current system of owners only and don’t anticipate that this change of regulation to allow amateur-built aircraft to be more widely used will increase the risk to students.

Fees: Because the BMAA will have to maintain additional detailed records for the aircraft as well as paying additional CAA fees we expect to charge an initial fee when the aircraft is first registered into the system and an additional annual fee at the time of Permit to Fly revalidation. These fees will be set to cover the additional work entailed and costs that the BMAA may have to meet.


Thank you for your time taken to reading this introduction. Please help us by giving us your feedback on the website form below, even if you don’t intend to make use of this change. Just a name on the form and a single tick will do it for us.

All the best, safe flying.

Geoff Weighell on behalf of the BMAA

This survey has now closed. Thank you to all who took part.