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Oz Flying summary on Class 5 consult -

Via the Yaffa...

CASA Invites Feedback on Class 5 Medical Self-declaration
30 October 2023


CASA has announced the long-awaited industry feedback consultation hub for the proposal of a new Class 5 medical self-declaration policy.

The Class 5 medical will allow private pilots to self-assess and self-declare without requiring a medical assessment if they meet fitness requirements and operate in accordance with specified operational limitations.

The policy aims to improve accessibility to a streamlined medical self-certification pathway for the general aviation and recreational aviation community.

To support the implementation of the new Class 5 medical self-declaration, there will be comprehensive guidance material for applicants, certificate-holders and healthcare practitioners.

"We are proposing to enact the policy through an exemption instrument to the Civil Aviation Safety Regulations 1998 (CASRs). This will enable industry to access the new Class 5 medical self-declaration as soon as practical," said CASA in a media release.

The proposal has been developed with input from the aviation community, including the aviation medicine technical working group and is also one of the initiatives CASA's General Aviation Workplan for simplifying health arrangements. 

The Technical Working Group consists of representatives from across the aviation community bringing diverse and different perspectives, AOPA's CEO, Ben Morgan, departed the group in June due to a clash with Principal Medical Officer Kate Manderson. Morgan said he did not support the TWG's attempt to recommend an arbitrary weight limit on self-certification and accused Manderson of "doing what's easy, not what's right."

CASA has maintained for several years that pilots operating in CTA would always need Class 1 or Class 2 medical certificates, but the requirement has been brought under scrutiny by the projects to permit PPLs to fly on self-declared medical standards (Class 5) and to grant Recreational Aviation Australia's (RAAus) pilots access to CTA. 

RAAus CEO Matt Bouttell told Australian Flying in June that he believed his members would be able to fly in CTA without needing the Class 2 medical that is currently required of PPLs.

"As far as the medical is concerned, RAAus has been operating safely with our self-declared system for 40 years, so much so that CASA is looking at emulating this," he said. "On this basis I am confident that RAAus pilots will have access to CTA without the need for a Class 2 pilot medical."

If Bouttell and RAAus get their wish, it will be very hard to see how CASA could continue to demand that PPLs still require a medical in CTA.

Submit your feedback here.


Access to CTA for Sport and Recreation Aircraft

In conjunction with to the Class 5 medical consultation portal, CASA is also seeking a separate consultation on access to Class C and Class D controlled airspace for sport and recreation aircraft. 


"We are seeking feedback on a discussion paper about controlled airspace separately as part of our commitment to facilitate greater operational opportunities for sport and recreational aviation activities when safe to do so, as outlined in our General Aviation Workplan," said CASA in the same media release.

Claiming comments from the industry has fed back that sport and recreational aviation’s access to controlled airspace is too restricted, the consultation will inform future policy on access to controlled airspace.


Topics for discussion


Pilots operating in controlled airspace currently must meet standards in relation to:

• pilot competencies
  
• radio competencies and English language proficiency
  
• medical fitness
  
• aircraft equipment
  
• priorities for airspace access.
  

These aim to ensure pilots can operate in controlled airspace safely.

Discussion Paper (DP) 2314OS examines the various requirements for users of controlled airspace and controlled aerodromes in Australia and the objectives underpinning the requirements.

CASA is seeking input on whether:

• the objectives are appropriate and reasonable
  
• the current requirements reflect the objectives
  
• there are alternative ways we could achieve the objectives.
  

The controlled airspace discussion paper is available here:

The Pilot Medical Declaration (PMD) used in the UK and BasicMed in the USA both have restrictions on operations without medical certificates, but neither of them bar operations in CTA.

In March this year, the Federal Aviation Administration (FAA) released a review report into BasicMed after three years of operation. The report showed "no difference in accident risk between flights conducted by pilots operating under BasicMed and flights conducted by pilots holding third-class [Class 2 in Australia] medical certificates."

The report also found that BasicMed had no impact on the slow decline in general aviation

Industry feedback will inform the finalisation of the proposed policy, supporting documents, and the regulatory review process.

Some commentary so far, via this UP thread - HERE:

Possum1

Consultation open: Class 5 medical self-declaration

Email to complete Class 5 medical self-declaration survey arrived today 27 October, 2023 from CASA. There are three documents to provide a background for what the survey is about totalling 179 pages! This is before I even start the survey! I would contend that if I am capable of this volume of study, and then successfully complete the survey, that this would qualify me for a Class 5 self-declared medical.

There are still "Medical limitations that exclude pilots with certain conditions from the Class 5 medical self-declaration" included. On the other hand, the TWG was, "comfortable in not recommending a mandatory medical assessment by a health professional," and they also noted that, "that a previously cancelled medical certificate should not exclude a pilot from a Class 5 self-declaration as it is a separate medical standard."

CASA sees Class 5 as a replacement for the RAMPC medical, so what, if anything will change?

Will anything change? Is AvMed planning redundancies or redeployment of their staff?

The proposal to allow suitably qualified sport or recreational pilot into Class C & D airspace might get up as the TWG has stated that the ability of pilots to fly in controlled airspace should remain only an issue of pilot training and competency.

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aroa

3 docs and 179 pages for starters. I’ll lay a bet that’s the first indication this will be a long convoluted process and the usual dogs breakfast.

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Possum1

CASA's proposal is that "Pilots are not eligible for a Class 5 ... if they have previously had a Class 1, 2, or 3 aviation medical certificate refused or cancelled." This is in direct defiance of the Technical Working Group's statement(Second Report 3 August, 2023), "that a previously cancelled medical certificate should not exclude a pilot from a Class 5 self-declaration as it is a separate medical standard."

CASA also includes this proposal in their list of excluded medical conditions as if having a medical certificate refused or cancelled is somehow a medical condition in itself.

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Clinton McKenzie

As usual, the wrong process being run by the wrong organisation. A bunch of ordinary medicos with delusions of being world-leaders in ‘aviation medicine’ have, as usual, been let loose to reinvent the wheel and will, as usual, produce something that isn’t round.

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First_Principal

...A bunch of ordinary medicos with delusions of being world-leaders in ‘aviation medicine’ have, as usual, been let loose to reinvent the wheel and will, as usual, produce something that isn’t round.

I don't know these people, and wish to be clear that I cast absolutely no aspersions, however your comment brought the following couple of quips from Dave Barry to mind:

'If you had to identify, in one word, the reason why the human race has not achieved, and never will achieve, its full potential, that word would be 'meetings.' ...and... 'Meetings are an addictive, highly self-indulgent activity that corporations and other large organizations habitually engage in only because they cannot actually masturbate'

FP.

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Clinton McKenzie

Re meetings and that second quip, CASA Avmed's 'complex case management meetings' are a classic example. There's a neat slang term for them which encapsulates the gist of the second quip, but I won't be so crude as to post it.

As to the broader process of medical 'reform', the protracted and unnecessary 'consultation' on the way to implementation of the pre-conceived ideas of the people running the process are the problem. The wrong process being run by the wrong organisation.

The process should be an analysis of data, not a survey of individuals and interest groups. That analysis should be done by disinterested experts in data analysis, not by people who have a direct personal interest in the outcome.

MTF...P2