In Woods v. Insurance Co. of North America (1974) 38 Cal. App. 3d 144, the court found the pilot was "'properly certificated'" under the terms of the policy although his medical certificate had expired 25 days before the accident. ( Id. at pp. 146, 152.) In concluding that "properly certificated" did not include the medical certificate, the Woods court considered several important points. First, in consideration of the premium, the insurer had deleted a standard exclusion for those "'not properly certificated by the required governmental authority.'" ( Woods, supra, at pp. 148-149.) Second, "properly" could not be read so expansively to cover any transgression of federal aviation regulations. Such a reading would make the policy illusory as few accidents occur without a violation of the detailed FAA regulations. ( Id. at p. 150.) Third, the policy provision in question required a pilot who was "properly certificated and rated for the flight and aircraft" and set forth the minimum number of pilot hours required. Read in this context, the phrase "properly certificated" addressed the pilot's flight proficiency and skill, and thus meant his pilot's certificate and license, not his medical certificate. ( Id. at p. 152.)