[Peetwo]

Update: AOPA joins in on SAAA call for Private Pilot medical reform -

SAAA pushing for Drivers Licence medical.

Courtesy Oz Aviation:

Two Sonex Amateur-built Experimental (AB-[E]) aeroplanes. (Steve Hitchen)

SAAA calls for Medical Exemption
28 July 2016
 
The Sport Aircraft Association of Australia (SAAA) has written to CASA asking for an exemption from medical requirements for members who fly aircraft with a revised maximum take-off weight of 600 kg or less.

The letter, dated 15 July, asks for SAAA members to have the same "self-certification" privileges as pilots administered by Recreational Aviation Australia (RAAus).

SAAA President Rob Lawrie, who signed the letter, points out the inequity of RAAus pilots being allowed to fly under a driver's licence medical, yet SAAA pilots flying aircraft of similar weights need to have a CASA Class 2 medical examination.

"We propose that such pilots of sport recreational aircraft would be responsible to self-certify their medical fitness, with identical conditions imposed upon their flight operations as those currently imposed on similar sport aircraft within Australian airspace," he says.

"The present situation is inequitable as the same pilot, who is rejected by the CASA medical certification process, may fly the same aircraft in Australian airspace under an 'alternate regulator'. This situation may reasonably be argued to result in a number of negative safety outcomes.

"We need a solution that is immediate and allows our members to continue to fly their aircraft, many of whom have spent countless years and thousands of hours constructing them. As such our members have a considerable investment and emotional attachment to their aircraft.

"The majority also hold considerable aviation experience and have demonstrated their ability to operate safely."

Rather than ask for a blanket exemption for all members, the SAAA proposal concedes that the exemption should apply only to pilots and operations meeting the following criteria.

• Single-engine amateur-built experimental (ABE) or amateur-built aircraft acceptance (ABAA)
  
• Day VFR limited to pilot and one passenger only
  
• No aerobatics
  
• Flight below 10,000 feet AMSL
  
• A revised MTOW of 600 kg for the flight or 650 kg for float equipped aeroplanes
  

The SAAA is also suggesting that pilots would need to carry their driver's licence on such a flight and people with certain conditions such as epilepsy and diabetes would need an annual statement of fitness from a GP.

"The initial exemption request is for identical weight limits and conditions as presently provided to RAAus for ultralight operations," Lawrie states. "This in itself is a very strong Australian based safety case, which CASA simply cannot ignore.

"RAAus have held these approvals for a considerable period of time. During this time there have been almost no reports of medical incapacitation of RAAus pilots and certainly far less that those experienced in commercial and RPT operations.

"This sort of data is essential in achieving regulatory reform. Essentially we must prove there will not be an adverse safety outcome to CASA’s satisfaction.

"CASA is required to demonstrate fair and transparent regulation in their dealing with the aviation community. We all fly in the same air.

"We believe these two factors will maximise our chance of success and make it more difficult for the initial request to be dismissed by CASA."

The full text of the SAAA letter to CASA can be downloaded from the link below.
SAAA medical letter to CASA

Read more at http://www.australianflying.com.au/lates...uGM1BE5.99

Ruling by exemption – Still.

Reading Rob Lawrie’s letter is like watching a rally car trying to get to the finish line while ducking a weaving through the obstacles, tree stumps, holes and soft edges. It’s a master piece of ducking and weaving through the artificial ‘obstacles’ built in by the manic race organisers; designed to impede and penalise entrants.  The argument ‘for’ is sound enough, but look at hoops and hurdles he needs to deal with before pleading and proving his way to a rational, risk based agreement, to become 'exempt'.

There should be no need for any of this, especially for ‘exemptions’ which oblige the receiver to ‘play nice’ with CASA: not if the rules were written sensibly.  The letter provides a perfect example of why regulatory reform is desperately needed.  The question we should be asking is why, despite the time, money and effort invested in the ‘new’ regulations does a respectable body, such as SAAA need to go to such extraordinary lengths to achieve ‘an exemption’.

Aside.  This artificial ‘weight’ limitation on medicals intrigues me.  I don’t get it.  Same as the weight limitations imposed on building; what’s the point of it?  Is 650 kg aircraft lobbing into a school yard going to do so much less damage than a 1000 kg aircraft? Why not provided an engineering based ‘range’ of acceptable weights, like between 550 and 880 kg.  What’s the difference, apart from legal flexibility?  Why should an aircraft weighing in at 605 kg be ‘illegal’ when the same thing at 600 kg is ‘legal’.  Are CASA saying that if you get hit by a fully loaded petrol tanker it’s much better than being clouted by a train.  Probably just me being thick, again; but it beats me hollow.

Aye well, good luck with it Rob; but remember what they say about making a deal with the devil and where the detail leads.

Toot toot.

Perhaps I'm a bit thick, but why not go down the RPL route instead?

"There should be no need for any of this, especially for ‘exemptions’ which oblige the receiver to ‘play nice’ with CASA:"

Statistics boatman, CASA is highly unlikely to allow a situation where statistics that they cannot control could be used against them. If they freed up the requirements for medicals for SAAA pilots could it be that, as happened in the USA, statistically it turns out, medicals are a waste of time with regards to safety.

Hot off the cyber-press: Ben Morgan has kindly sent an email copy of an AOPA letter sent today to CASA addressed to DAS Skidmore:

29th July 2016


Mr Mark Skidmore
Director of Aviation Safety (CASA)
Civil Aviation Safety Authority
GPO Box 2005
Canberra ACT 2601
Australia

The Hon Darren Chester MP
Minister for Infrastructure and Transport
House of Representatives
Parliament House
Canberra ACT 2600
Australia.

- Members of the Aircraft Owners and Pilots Association
- Users of the Aviation Advertiser – Australia network
- Government Ministers and Senators
- Industry media


Aircraft Owners and Pilots Association supports the 
Sport Aircraft Association of Australia call for PPL medical reform.

Mr Mark Skidmore,

I am writing to you as the Executive Director of the Aircraft Owners and Pilots Association (AOPA) in support of the request submitted by the Sport Aircraft Association of Australia (SAAA), calling on the Civil Aviation Safety Authority (CASA) to reform private pilot medicals.

Australia’s general aviation industry is being negatively impacted by excessive aviation medical assessments and approval requirements on private pilots license holders.  The result has been the broad discrimination of a large number of experienced and healthy pilots, removing them from active flying and forcing them from our industry.  

Over the past 9 years, a significant number of general aviation pilots have been forced to side-step into RAAus membership, to avoid the aviation medical bureaucratic red-tape.  This transference of pilots has played an enormous role in pushing our general aviation industries into serious decline and toward bankruptcy.

AOPA estimates that the current CASA medical assessment and approval process is unnecessarily burdening general aviation pilots in excess of $10 million per annum.  An unnecessary financial impost that is now recognised by leading aviation regulators as having no measurable value on aviation safety whilst negatively impacting industry economic performance and sustainability.

AOPA calls on CASA to take immediate action to harmonise private pilot aviation medical requirements, benchmarking both the United Kingdom and the Unites States of America, to provide all Australian private pilots – regardless of aircraft type flown – a level playing field.

As you are aware, the Civil Aviation Administration of the United Kingdom on the 9th May 2016 announced significant changes to medical requirements for private pilots.  These changes were a result of extensive industry consultation, which found that 96% of industry respondents supported reducing medical requirements for private pilots to that of a drivers license standard.

The UK CAA determined that existing PPL medical requirements were disproportionate, costing private pilots both time and money unnecessarily, when compared to the benefit they provide.  

The UK CAA consultation process considered the potential risks incurred by introducing changes, these included;

a)  GA fatal accidents with potential medical causes

Over a 10 year period 151 GA fatal accidents of which only 20 could have been possible medical causes.  These included factors such as hypoxia, fatigue, dehydration, alcohol and suicide.  The UK CAA determined that there was a significant degree of uncertainty with regard to the actual cause of these accidents, with the medical cause only suspected.  As a result, it was decided to focus the risk analysis on serious incapacitation in flight.

b)  Third party risk

UK CAA historical records demonstrated that the probability of a GA accident causing injury to people on the ground is extremely low.  Over a 10 year period from 2004-2013, out of the 151 GA fatal accidents, there were a total of six (6) accidents involving third parties on the ground.  Only two (2) of these accidents resulted in fatalities and both involved third parties involved in aviation activities.  The UK CAA determined that there were no fatalities to a third party as a result of serious incapacitation of the pilot.  It was therefore determined by the UK CAA that there is no significant increased risk to third parties identified.

c)  Risk of incapacitation in flight

The UK CAA gave consideration to the risk of incapacitation in flight by looking at the likelihood of different medical conditions occurring which could result in pilot incapacitation.  The focus was on conditions which could result in sudden incapacitation (e.g.  heart attack, seizure) where the pilot may be unaware of symptoms at the start of the flight.  The considered risk profile was based from consultation, where 99% of respondents stated that private pilots do not generally take part in flying if they feel unwell.  The UK CAA determined that there could be a total of approximately two (2) acute medical incapacitations events in-flight per year, compared with approximately one (1) at present.  The UK CAA determined that whilst the risk of pilot medical incapacitation is increased, the absolute risk of a medically caused accident was assessed to be very low.

As a result of their extensive industry consultation and assessment of risks, the UK CAA have updated their regulation so as to reduce the medical requirements for private pilots, accepting an ordinary drivers license medical standard with no routine requirement to attend for a medical examination.  The UK CAA clarified that pilots will be required to complete an on-line form once prior to the age of 70 years (and every three years after the age of 70) to make a legally binding statement that they meet this standard.

The UK CAA demonstrated that the drivers license medical was a more proportionate approach and would reduce both the amount of time and money spent on medical examinations and tests by private pilots, whilst having little to no impact on overall safety standards.


Attached to this email is a copy of the UK CAA CAP 1397 APR16 – Click here to view

AOPA calls on you Mr Skidmore to take immediate action and to demonstrate your support for general aviation by removing the unnecessary private pilot medical assessment and approval red tape.  If you would like to discuss this matter further, please contact me directly.  AOPA stands ready to work with CASA on this important issue.

Best regards,

BENJAMIN MORGAN
Executive Director

Aircraft Owners and Pilots Association
Mobile:  0415 577 724

Hangar 600, Prentice Street, Bankstown Airport NSW 2200, Australia

PO BOX 26, Georges Hall, NSW 2198, Australia.

Telephone:  (02) 9791 9099
Facsimile:  (02) 9791 9355
Email:  ben.morgan@aopa.com.au
Web:  http://www.aopa.com.au

MTF...P2