[Sandy Reith]

I’ll play the Devil’s Advocate. Why does AVMED require funding, cooperation and resources in order to make rational changes for the good of Australia’s aviation industry? Changes that would drastically reduce its work to the point where its normal make work system couldn’t put up any semblance of the look busy theatre.

In reality is it really to do with the PMO? The whole charade about months have to pass with technical groups and consultations before reforms can be implemented is that same old tired playbook and revulsion at the thought of actually making decisions. Ms. Spence has been in the chair since the 17th of May last year and is fully cognisant of the condition of dire straits that is the sad reality of Australia’s aviation scene. Together with Minister Joyce she has had the power to unshackle the aviation community, in particular General Aviation, from the bureaucratic garrotte, but after the showing at the RRAT hearing it seems that Jon Aleck is the real CEO.

For a simple PPL medical reform, proven by years of RAAUS experience, let alone the experience and practice of other countries, there is no need for this unconscionable delay. Same for the Angel Flight restrictions that have been wrongfully left in place which is against the interests of treatment for those unfortunate people that AF serves.

Say what you like, give them time, bureaucratic process, don’t expect too much too soon, it’s different this time they are listening, reckon the Minister means business…….

What do we have now? Wonderful intentions and some advice how to assess one’s fitness to fly after contracting COVID19. Apparently AVMED receiving too many calls by lots of pilots who are so frightened by the CASA juggernaut that they can’t work that out for themselves. Heaven help them if they catch SARS 1 (common cold) or the ‘flu and are suspected of flying without strictly following the guidelines.

Looking today at some thirty and forty year old papers and letters written to MPs and CASA simply asking for reasonable improvements. In forty years the one common and outstanding feature of Australia’s GA has been the steady deterioration in the way government has treated aviation, with the exception in the late nineties some reforms, nod to Bill Hamilton and Dick Smith, that have been eroded since.

[Kharon]

Casual Interlocutor.

Sandy - "Why does AVMED require funding, cooperation and resources in order to make rational changes for the good of Australia’s aviation industry?"


Well, that is a fair question, one which has puzzled those who must use the AVMED system, across the board, have been asking for a long while now. Item - Cooperation. It is crystal clear that industry, the DAME and pilot body would absolutely support some serious changes to the AVMED system; no shortage of support or cooperation from those most affected by the current system. So it begs the question - where does the serious, long standing opposition to logical rationalisation of system reside? No brainer. Without internal cooperation, no matter how good the intentions, the logic and the system changes are; without 'internal' cooperation, nothing will change for the better.

Funding - even the logical, efficient notion to 'modernise' and streamline to a user friendly 'App' will cost money. The savings will need to be justified and funds allocated. Once again, it becomes a matter of internal cooperation and corporate will power to bring the AVMED system into the early 21 st century.

Resources - most have, at one time or another, had cause to contact AVMED; and, I believe most have been (once able to eventually talk to to someone) been happy enough with the first respondent, but once beyond the first gateway, the true picture emerges and it ain't a pretty one. How many times now has the best intentions of the 'off line' resources been overruled and ended up in the AAT? If the DAME finds a faulty spark plug and refers that to a 'specialist' who declares the said spark plug to be serviceable; why is that 'expert advice' challenged? Don't make sense - why is the valuable resource of expert advice so often ignored?

Anyway; I though Doc K made of the 'right stuff', my advice

Illegitimi non carborundum.

[Sandy Reith]

The point has been ‘carborundumed’ so many times it couldn’t be made more blunt, which ever way it’s viewed.

Without political intervention little will change and a whole industry will continue to slowly degenerate, costing the Government $billions in revenue let alone all the loss of aviation jobs and services.

This is what we have with Government ever increasing it’s bureaucratic powers. Today you can’t farm animals without having your property registered and passing a test. Your animals have to be ear tagged, even goats. To be a company director you now have to be allotted a number. Perhaps we should have this number tattooed onto our forearms, to make it clear that you are not a person, you are a number and subservient to the State.

But back to GA, we’ve actually seen not much more than zero in aviation reform, but plenty in the wrong direction, so I’ll rest my case M’Lud, no further witnesses now that you’ve looked at the parade down through years.

The likes of John Quadrio, Clark Butson, Brian Reddish, Stan van de Weil as examples of hundreds that have fallen foul of CASA as prosecutor, judge and jury. Then, and more recently the truly outstanding case of Glen Buckley, plainly a monstrous injustice that has been palmed off again to an Ombudsman.

Your taxes, and your CASA operating fees, at work.

[Peetwo]

Aviation medical policy review - (DP 2206FS) - Sandy's response

Response ID ANON-437A-VN42-9
Submitted to Aviation medical policy review - (DP 2206FS)
Submitted on 2022-05-03 12:05:59

Personal information
First name: Alexander
Last name: Reith
Email: sandy@reith.com.au

Do your views officially represent those of an organisation?
No, these are my personal views

Which of the following best describes the group you represent?
Air operators, Flight instructors and flight examiners, Flight training organisations, Pilots

Do you give permission for your response to be published?
Yes - I give permission for my response/submission to be published.

Medical certification structure
Topic 1a: Assess the implementation and outcomes of Basic Class 2 certification and of other changes to the Class 2 certification process.

Comments:
Your Basic Class2 in present form is not fit for purpose because :-
1). The operational restrictions, especially the irrational denial of IFR use.
Explanation, IFR is arguably the safest, most efficient and most controlled type of flying and should be encouraged. Existing IFR rated pilots should not be
induced to lapse their ratings, unreasonable restrictions beggar the whole of General Aviation and policies must change.
2). The present AUST Roads standard via BasicC2 is higher for the pilots than for than for truckies and bus drivers because of the ‘unconditional’
requirement. I was caught out on this one owing to a technicality. It is a fact that, as one highly dissatisfied pilot complained, he could drive a truck load of
fuel through a city centre but was prohibited from a BascC2 medical certificate.
3). Thus the Australian BasicC2 is so limited in benefit that it has little respect or utility compared to the very successful USA version which relies far more
on self reporting and does not preclude IFR.

Comments:
As my previous comment the USA model is a far better model, the AOPA organisation of the USA estimated that approximately 17,000 pilots came back to flying when that reform was introduced.

However for the best model look no further than that of our recreational low weight category that’s a proven safe model across some thirty years right here in Australia.

As to the question of risks, I’ll refer you to the record of the RAAUS experience, the model quoted above and tables and statistics from the USA, search their AOPA website and data from the FAA. I can send you excerpts from those sources if you wish.

These sources clearly indicate that the risk of accidents attributable to in flight medical incapacitation is negligible, the numbers so few, and also that there’s no pattern to distinguish between the classes of aviation medicals or no special medical examination.

Topic 1b: Austroads levels
The Private Austroads standard should be considered for the Class 4 noting the unconditional application of the Commercial Austroads standard for Aviation use can be a stricter standard to meet when compared to the conditional application of a Class 2 Medical.

Comments:
These matters have been canvassed for many years, the information about risk is as good as one could expect particularly with the record of RAAUS and from the USA record. GA is in need of rapid reform and the timetable of this inquiry is too long, if CASA wishes to have a GA industry worthy of Australia it
must get reform on the books urgently.

There’s no rational reason to delay, RAAUS self declared car driver standard with an annual GP examination fit to drive a private motor vehicle is the correct way ahead.

I urge all those involved to move this reform as quickly as possible.

Expanding DAME delegations
Topic 2: Determine the effectiveness of CASA delegations to Designated Aviation Medical Examiners (DAMEs) and whether these could be extended or improved.


Comments:
Apart from the politics

Self-declared medical for private pilots
Topic 3: Review other areas of aviation activity where medical certification could improve safety outcomes.

Comments:
As always it depends on the detail.

First principle is to determine the risk factors and what is the purpose of the aviation medical examination certificate. If it is mainly protect the general public, and I submit that that is a rational and legitimate government pursuit, then the conclusion must be that there’s no evidence that aviation specific medical examinations contribute to the safety of the public, or indeed the pilots themselves.

Furthermore I don’t see the proposal detailing operational restrictions, if any, such as aircraft types and other limitations, IFR or CTA operations for example.

Comments:
Unnecessary limitations based on nothing more than unsubstantiated opinions have severely reduced participation in General Aviation (GA).

Risk of accidents by medical incapacitation are far more likely to involve more people on our roads than in flight. We accept some extremely slight or negligible risk every journey by road, there’s no reason or facts to make flying so incredibly different.

BITRE statistics, especially if plotted against population growth, clearly demonstrate a very substantial decline of GA but arguably don’t show the full potential of where we should be because we are also a much wealthier and technologically advanced country than we were 30 years ago.

The negative outcome of our present languishing GA industry is lower levels of experience in safety management, less innovation towards efficiency and safety, less GA business and involved personnel.

Allowing free enterprise room to move will provide the very necessary motivation to keep up to evolving community standards and provide aviation services to a much greater extent than the present way of bureaucratic strangulation and regulatory overkill.

What we need is a simple ’road rules’ approach coupled with an airports policy to preserve availability to assist that growth and to fulfil a very important role in terms of National security. Aviation is undoubtedly a crucial element of our ability to project strength and protection for the Nation.

Standards for drone pilots
Topic 4: There are no current Australian medical standards in respect of remotely piloted aircraft operations. This is an area for future policy consideration, and we would like your ideas early.

Comments:
No, not until and unless there’s facts, and no doubt from the USA experience which is many times that which pertains in Australia, to give cause to make this an issue.

Flight instructors in sport and recreation
Topic 5: Establish whether the current structure of medical certification for recreational aviation is fit for purpose.

Comments:
This is a non issue by the very statements accompanying this question.

Firstly there’s not one quoted accident attributable to an instructor’s medical in flight incapacitation.

Secondly there’s not one shred of evidence to make claim that having an aviation standard certificate will preclude such an event.

In reality the quoted incident proves the point, it’s not possible to predict the onset of an incapacitation because the instructor no doubt had the required medical certificate.

There’s always some risk in flying, you generally drive your car to the airport past numerous other drivers with all sorts of possible medical conditions.

Lastly, in the USA instructors need no medical certificate if instructing those students who have soloed. Why not here and immediately instigate one easy reform? While we wait.

Modernising the rules
Topic 6: Examine the Part 67 regulation to ensure it is up to date and fit for purpose.

Comments:
Making advisory what is now in the regulations is sensible. In terms of clarity all regulations should be in plain English even if that means some difficulties for the legal perfectionists because the overall effect would mean that your rules are simplified, understandable and might even become respected.

Final feedback
Topic 7: Consider any other relevant matters.

Comments:
I’m sure that in my submission the message is plain. I understand that there’s inertia and a natural unwillingness to make simplification because this direction says that much of CASA’s medical work is not now necessary.

Sometimes change reduces personnel in one area but government could assist, encourage and promote technology for in flight health monitoring and auto pilot systems for autonomous flight and safe landing in case of single pilot incapacitation.

MTF...P2 

[Sandy Reith]

Amendment to my response which has been passed to CASA. I endorse the RAAUS self declared system of the car driver standard but in my submission stated “annual GP check..” but mistakenly omitted to say for those of 75 years of age and older.

Not that I really believe that such checks are necessary but most of us wouldn’t find that much of an imposition, and keeps this proposal the same as I understand presently applies to RAAUS certification which has been accepted now for several decades.

However the take up of a self declared certification regime should not include more restrictions than those operational parameters applying with the successful and proven USA BasicMed standard.

If this were adopted our system would be an advance on the USA BasicMed which was compromised at the outset by a very strong medical lobby against a more liberal self declared model.

[Peetwo]

Aviation medical policy review - Cont/-

Via Oz Flying:

Part 67 Consultation hints at Self-declared Medicals
2 May 2022


CASA today opened consultation on the future policy surrounding aviation medical standards, which contains the option to introduce self-declared medicals for private operations.

Recreational pilots have had self-declared medicals for many years, which has continued to be a sore point with private pilots who fly the same, or similar, aircraft, but have been subject to CASA medical examinations to stay in the air.

The consultation is part of the review of CASR Part 67, which covers the requirements of all medical standards.

"Our review of the aviation medical rules aims to simplify and modernise our overall approach to medical certification," CASA stated today. "It follows work done over several years to improve and reform aviation medicine through a tiered approach to risk management.

"This considers how we can make it easy and simple for private pilots to get in the air and stay flying. It allows us to focus effort on higher risk activities such as passenger transport."

The consultation focuses on six areas:

• examining Part 67 to ensure it is up to date and fit for purpose
  
• assessing the implementation and outcomes of Basic Class 2
  
• determining the effectiveness of CASA delegations to DAMEs and whether these could be extended or improved, or whether DAMEs can be given direct authority under the regulations to issue medical certificates
  
• considering other areas of aviation activity where medical certification could improve safety outcomes
  
• establishing whether the current structure of medical certification for recreational aviation is fit for purpose
  
• considering any other relevant matters.
  

Part 67 has been under review by a CASA technical working group (TWG), which forms the basis of much of the consultation. Among the options coming from the TWG are removing the requirement for medical examinations for PPLs, enshrining the principles of the Basic Class 2 into Part 67 and expanding DAME delegations to allow them to do more.

The consultation covers not only standards for PPLs, but also for drone pilots and flying instructors.

Feedback to the Part 67 consultation can be submitted to CASA through the Consultation Hub on the CASA website.

Plus from AOPA Oz, via FB:

CASA SEEK PUBLIC CONSULT ON PILOT MEDICAL REFORM, AOPA AUSTRALIA IS CALLING FOR INDUSTRY-WIDE SUPPORT
The Civil Aviation Safety Authority is seeking industry feedback for three key potential reforms to aviation medical policy, and are considering:
- self-declared medical for private pilots
- building the principles underlying the Basic Class 2 into Part 67 and simplifying the medical certification structure
- empowering DAMEs to do more by expanding delegations.

BEFORE YOU CONSIDER RESPONDING

AOPA Australia will today release a comparison table of pilot medical certification standards, that will enable you to see how Australia stacks up against our international counterparts.  In the week following this release, we will publish guidance material on how you can respond to this important public consult, and we are calling on pilots nationwide to get behind our push to achieve meaningful reform.

Plus some comments in reply:

Steve Curtis
  · 11:32
Ben, I trust you’ll include stats on the aircraft currently operating in Australian controlled airspace by self certified medical holders? Camden is a good example with the safe history of glider operations for at least the past 60 years.

---

Aircraft Owners and Pilots Association Australia

Steve Curtis yes I have collated these. Would not mind running this by you before I release today.

---

Mark Newton

Steve Curtis Not just Camden. The folks at the Canberra Gliding Club have been negotiating clearances with Canberra Approach for wave soaring flights above FL200 for decades.

Their “medical” is a box ticked on the annual membership renewal form to assert that they’re safe to fly.

---

Mark Newton

Steve Curtis (I’ve also had a clearance myself to get through the R’s north of RAAF Edinburgh between Lochiel and Gawler in a glider. No transponder, they gave me a block clearance with position reports and left me to it)

---

Shannon Baker

Mark Newton I don't get why controlled airspace increases risk?... It decreases it!
IE: if a pilot becomes unresponsive to the controller - they can clear traffic away from that aircraft... If anything it's the uncontrolled airspace that is higher risk. ?

Anyway, this point should negate most arguments entirely about operating in controlled airspace with a self declared medical ! All procedures etc are already in place for an unresponsive aircraft.. nothing new needs to be invented. ??

---

Mark Newton

Shannon Baker For some reason they’ve never adequately explained (because they outright refuse to proffer written safety cases), CASA has drawn a line in the sand between access to controlled airspace and medical standards not administered by avmed.

So you can fly RAAus on a drivers license standard, and not have access to controlled airspace; Or you can fly on a Basic Class 2, which is also based on a drivers license standard, but is administered by avmed and therefore conveys access to controlled airspace.

They’ve only been able to maintain that position by refusing to acknowledge the places where their own regulations have grandfathered-in occasions where controlled airspace access is permitted without avmed.

The most obvious of those cases are their 70-odd years of GFA regulation (where CASA has always allowed pilots to self-declare without any doctor involvement whatsoever, and has always allowed controlled airspace access), the Avalon Airshow (where CASA allows RAAus pilots access to controlled airspace, but only for three days once every two years) and capital city secondary airports (where the airspace is deemed too dangerous for RAAus pilots except in the early morning or the late afternoon when the tower is closed, in which case Kitfoxes can blast in and out of class D over built up areas with gay abandon)
When you see those examples, it’s obvious that CASA has no safety reason to discriminate between medical standards, and the only reason they do it is because THAT’S THE KIND OF ORGANIZATION THEY ARE. They are determined to be that kind of organization, which is why the only feasible way to fix this is to simply stop talking to them and go over their idiot heads and get the politicians to force them to perform whether CASA likes it or not, which is what the AOPA event on May 1st was all about.

If the reason was any deeper or more complex than “that’s the kind of organization they are,” they’ve had plenty of opportunity to show a written safety case which explains it. The first consultation for RAMPC happened in 2010. They’ve been “reforming” medical standards on a rolling continuous basis for nearly a decade and a half, and if they haven’t been able to explain themselves by now it’s because they can’t.

Personally I think we should spend a lot more time talking about their budget: Their only significant job is regulatory drafting, and if they can’t do it correctly they shouldn’t be paid for it. An organization with a $200m+ budget should be required to answer, “What the hell do your 900 staff do all day?”

---

Shannon Baker

Mark Newton obviously the statistics (facts) don't gel well (paint the picture the way someone wants) with whoever has a bee in their bonnet about it in the organisation. - so they simply ignore it... It's obvious the statistics are so supportive of the idea they are even beyond manipulation and cherry picking by CASA.

It's ok, I've seen how they run investigations - filter out and ignore all exculpatory evidence - so only the damning stuff (that is mostly out of context) is left to run a particular narrative.

Plus from Sandy:

Sandy Reith

If there’s rational reform for private pilot medical certification this would give our General Aviation industry a huge boost.

Well done Ben and AOPA for promoting a reformed certification, as opposed to the unreasonable regime that currently applies. We’ve been labouring under AVMED’s unreal standards that are based on nothing more than unsubstantiated opinion when all the evidence indicates that the current rules and administration of medical standards for pilots are restrictive and wasteful for no good purpose.

---

Sandy Reith

The USA’s investigations:

---

Sandy Reith

And the statistics, the USA BasicMed is largely a self declaration regime, includes IFR, six seats and 18,000ft and CTA. The restrictions such as they are were the compromise in face of a very strong physicians lobby but nevertheless very successful in bringing some 17,000 pilots back to flying as reported by AOPA - USA.

MTF...P2 

[Wombat]

Some time ago, I visited my GP for a flu shot and a chat and I decided to ask her to approve a basic class 2 for me.

i had done the questionnaire and had the necessary paperwork. I gave her the paperwork and not having done one of these before, she read it.

This took a while.............. It was followed by a phone call to her lawyer and another GP friend.

The result? Words pretty much as follows: "Wombat, I can't do this for you. The instructions and form require me to certify your health "unconditionally" in the sense that you meet the standard "unconditionally" in other words you have no medical conditions."

" The fact is, Dear Wombat, that as a Sixty Eight year old creature you DO have conditions. We manage your blood pressure very well, your right paw strength is good, your teeth are strong and you are in excellent condition ...for a Sixty Eight year old Wombat,,,,,,but that is not what CASA want me to certify, so I'm sorry but no can do."

[P7_TOM]

The Walrus and the Carpenter
Were walking close at hand;
They wept like anything to see
Such quantities of sand:
If this were only cleared away,'
They said, it would be grand!'

If seven maids with seven mops
Swept it for half a year,
Do you suppose,' the Walrus said,
That they could get it clear?'
I doubt it,' said the Carpenter,
And shed a bitter tear.

[Kharon]

Purblind leading the Colour blind -

Down the rocky road to the AAT - again: see - HERE -. What a hellish situation to be dumped into; without prior warning it seems - according to the posted opinion. Not too hard to imagine the range and extent of emotions raging through the CVD ranks.

But it intrigues me, this anti CVD crusade, particularly when it comes from an outfit that habitually uses 'numbers in percentage' when formulating policy and regulation. Now, the insurance companies have risk assessment matrix down to a very refined art; and yet they do not penalise those, who daily operate machinery in one of the very high risk categories - i.e. driving on the roads - with CVD.

So how many people driving on the same highway as you have CVD?

"The answer is that a quite surprising number of people are affected by colour blindness. In Australia, about 8% of males and 0.4% of females suffer colour blindness to some degree."

Traffic lights, blinkers, brake lights, reversing lights, hazard lights, road signs, work crews, even the humble 'lollipop' man at the school crossing - all, in varying degree rely on 'colour' to present 'visual information' to the driver. On an average city drive the number of times the 'colour' of something - means something - is almost uncountable. Thousands of vehicles on the road at any given time - and how many 'accidents' are attributed to drivers with CVD - or even with drivers needing vision correction - not too many; insurance rates support this. There is an even lower percentage of 'airborne' accident attributed to CVD aircrew.

So why after having won some relief from stupidity has the regulator changed the parameters, seemingly without warning, after a trouble free period under alignment with the gold standard NZ and FAA system. IMO it demands no less than a formal statement of explanation - one which may be tested - in law; and put away for ever, never to darken the horizon again..

Toot - toot...

[Wombat]

Kharon, in my opinion, the AVMED folk have simply jumped the gun by about three weeks.

There is a very good chance that Labor, supported by The Greens and independents, will take Government.

When that happens whatever momentum there was for reform of Aviation regulation will evaporate as well as any concern for the future of non RPT aviation at all. There will be no reform. We are classified as petrol guzzling dinosaurs and well off too. The regional concerns will be fobbed off with something called "High Speed Rail".

CASA will return to its old ways and it will seek revenge.

The airhead DAS and lazy Board will simply sit back and watch.

[Peetwo]

Bring back Senator Fawcett...

Via the UP:

papakurapilot

Hey Clinton!

Yep, doctors with not a single flight hour dictating what safe aviation requires, what is new!?

CASA is 'promising' a new OCVA but for now we have had to revert to the CAD test which the creator of literally said has not a single thing to do with aviation during John O'Brien's case at the AAT when he was called as a witness. This information is now on their website as of about 2-3 weeks ago. Unfortunately for a preceding period of months it wasn't and the old info was there and prospective pilots were spending thousands following it. There is zero timeline on the new test and literally no word on what it may entail. I've heard rumours of the word 'years' being used in the development of this test.

I am currently working in Aviation as a pilot and my medical thankfully has not been impacted. I am however in a role where I talk to other Colour Vision Defective pilots who are going for their first medical and this has been absolutely devastating to them.

One of these blokes I am in contact with has been in contact with the PMO and basically been told to sod off in what was a very confrontational phone call. He was told in no uncertain terms if he wants to 'lawyer up' that CASA has access to basically unlimited money to defend their position. P2 - Very disturbing if true...  

I'm absolutely at wits end with this. It's constant and never ending. I'm sorry but my faith in an organisation which delayed new alternate planning requirements less than 24 hours before they were implemented because they weren't ready is incredibly low. They promise the world and deliver a snow globe.

---

Clinton McKenzie

Zealots on a crusade for a noble cause, taking advantage of a change in CEO/Chairman.

I said this in my submission to the GA inquiry:

When a young Australian commits suicide because he has been told that, on the basis of anachronistic standards enforced with a crusader's zeal by CASA, his colour vision deficiency will prevent him from achieving his childhood dream of becoming an international airline captain, there is no negative impact on the safety of air navigation. But there is a cost which should not have been paid. (At least the New Zealand civil aviation safety regulatory comprehends this.)

In my supplementary submission I said:

I consider and submit that CASA's response, to the New Zealand CAA's [then] recent announcement that colour vision deficiency would now be treated as an operational competence issue rather than a medical fitness issue was - frankly - childish. Rather than accept the objective evidence of the 21st century - as the NZ CAA has done - and adopt, as the '3rd level' test, an operational competence test, CASA suggested that Australian pilots with colour vision deficiency should arrange to undergo the test under the New Zealand rules. CASA steadfastly leaves the unlawfully-determined CAD test as the '3rd level' test for Australian purposes. This is the behaviour of people who will steadfastly maintain the same opinion, irrespective of what new evidence is put before them, because they are "convinced of their righteousness" [which is a quote from an accepted definition of noble cause corruption and those who usually suffer from it].

This is the product of very small (usually men) with very big egos who enjoy putting stress on people and ruining their lives.

"..taking advantage of a change in CEO/Chairman.."


I would add taking advantage of government being in election caretaker mode...  

Even if slightly overstated by papakurapilot (and despite the election result) I say bring back Senator Fawcett...

AP reference: https://auntypru.com/forum/showthread.ph...d=83#pid83


MTF...P2 

[Peetwo]

AOPA PPL medical reform proposal

Via AOPA Oz:

PILOT MEDICAL REFORM PROPOSAL 2022

AOPA AUSTRLIA & AUSTRALIAN GENERAL AVIATION ALLIANCE

Members & Industry Supporters,

The Australian General Aviation Alliance (AGAA) is seeking the introduction of new self-declaration pilot medical certification standard (detailed in Table 1 of the proposal document) for Recreational Pilot License and Private Pilot License holders, along with key reforms to existing Civil Aviation Safety Authority (CASA) Class 2 Basic and Class 2 certification standards to safely unlock general aviation participation and growth.

Download a copy of the proposal document:
https://aopa.com.au/wp-content/uploads/2...eXFwpzuamc

CASA Pilot Medical Policy Review (DP2206FS) Public Consultation Link:
https://consultation.casa.gov.au/regulat...o_He1DhZ1M

The reforms that AGAA is seeking, have been implemented by aviation safety regulators in the United States of America (US) and the United Kingdom (UK), and across the past five (5) years have proven to be a safe method of pilot medical certification.  Both regulators based their reforms on the use of conditional private vehicle motor car license medical standard, with options for both self-declaration and General Practitioner assessment certification.

In the US, the FAA BasicMed pilot medical certification is widely regarded as one of the most successful aviation regulatory reforms in modern history, with over 66,000 pilots now accessing flying through this standard, with no demonstrated negative impact on aviation safety.  The UK reforms mirror the success of those delivered in the US and have opened up their local general aviation industry to growth.

In summary, recreational/private pilots in both the US and UK who use either a self-declaration or General Practitioner assessed medical certification standards; 

a. must meet the medical fitness requirements of the ‘conditional’ private motor vehicle license standard
b. can fly both single and multi-engine aircraft
c. can fly aircraft weighing up to 5700 kg
d. can participate in both VFR and IFR operations
e. can carry up to a maximum of six (6) passengers
f. can participate in aerobatic flight

The US now has in excess of 66,000 private pilots accessing aviation through BasicMed, with pilots participating in VFR and IFR operations in aircraft ranging between recreational light sport, experimental/amateur-built, general aviation certified singles and twins, helicopters, gyrocopters, warbirds and more.

AGAA regards both the introduction of a new self-declaration pilot medical certification standard and the reform of the CASA Basic Class 2 standard as a powerful gateway for the industry to sustain itself, reducing the regulatory burdens and costs currently imposed on the private general aviation sectors.  Such reform would make aviation more accessible nationwide, with strong benefits to pilots and aviation users throughout regional Australia, driving growth back into Australia’s ailing general aviation sectors.

Importantly, the introduction of a new self-declaration pilot medical certification standard and a reformed Basic Class 2 medical certification by CASA would deliver safe deregulation that is in alignment with the Minister’s Statement of Expectations and the Government’s broader deregulation agenda.

Sincerely,

MR BENJAMIN MORGAN
Chief Executive – AOPA Australia
Chairman - Australian General Aviation Alliance

Comments via FB:

Ian Tucker
  · 38:53

Thanks for all the work you and your team have done to put this together. All pilots now need to support you with the individual letters requested.

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Regan Lacey
  · 40:13

Good advocacy mate! Don’t agree with all your arguments, but I appreciate you arguing ??

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Gary Gould
  · 37:49

There are a lot of unnecessary expenses in general aviation flying. CASA medicals and ASIC cards are two of them. Good on you Mr Morgan!

---

Clinton McKenzie
  · 18:10

The recent steps taken by Avmed to return to the dark ages on pilot colour vision deficiency sadly demonstrates that CASA has ‘reverted to type’: Unwilling or unable to make decisions on the basis of objective evidence and objective risk.

---

Andrew Whiteman
  · 18:13

How many have given it away because the hoops CASA Avmed made them jump thru despite being overall fit as a fiddle were so onerous. This is absolutely ground breaking and will catapult GA back into being.

MTF...P2 

[Kharon]

Oi - "Where's my medical certificate?"

It is not a long thread on the UP - HERE - but it does refresh an old story; still valid today as to meet the legal requirements of any licence, one must hold a valid medical certificate. Anything which creates an uncertainty can and has led to 'bother' with CASA. DAME say's "good to go" - pay your $75 bucks and expect the paper (or electrical) version in the mail within a reasonable time frame.

Some have 'special' requirements; but, they know about these and have those attended to in advance, so the DAME has all the required 'paperwork' available 'on the day'. This is not rocket science, just the sort of forward planning and good management you could reasonably expect from a pilot. 

And yet despite sage advice from an expert in the Avmed field  (@ 24 minute mark):-

And, despite some hope being offered by the 'new broom':-

The 'anxiety' created waiting for this essential document to arrive still remains very real today. At very least industry should be provided with an explanation of why, in this modern age, there is not a smooth, prompt return service for a medical certificate. An even bigger question is why not bring in 'self certification' for PPL holders and reduce the paper log jams created by a dysfunction system.

Please explain!

Toot - toot...

[Sandy Reith]

“ An even bigger question is why not bring in 'self certification' for PPL holders and reduce the paper log jams created by a dysfunction system..”

The too smart answer is that self certification has been the successful standard for some 30 years, in the two seat low weight category. Recreational Aviation Australia, RAAUS, has now close to 10,000 members and it’s proven to be a completely satisfactory standard, yes 30 years.

But ‘K’ refers to the pilots of VH registered aircraft of General Aviation (GA), some of which can be registered in the low weight RAAUS system with numbers instead of the VH ‘regular’ CASA lettered registration marks.

As it stands currently, the VH pilot population are somehow quite a different risk as they step from the VH registered aircraft into the RAAUS registered one, even the exact same aircraft if re-registered.

But if not willing to go by this many years of experience of the RAAUS cohort, then we now have additional statistics from the USA model from the last six years of self certified private pilots. With pilot numbers, and hours flown way in excess of our truncated and declining GA sector, which is puny by comparison, no problem.

The new Principal Medical Officer of CASA, like the new CEO Ms. Pip Spence, came in and was hailed as the great hope for rational reform. Ms. Spence says they are working through 600 submissions about medical certification reform. Why bother? Just get on with it and begin the revitalisation of Australia’s GA. Reform will create thousands of jobs and create numerous GA businesses and services, all going to our strength as a Nation in this security important sector.

Will we see reform? There’s been one reform of note so far into the second year of Pip Spence’s reign, this was deleting the crushingly wasteful Cessna Special Inspections for private aircraft. All the while GA is still being strangled by the Bureaucratic red tape and Glen Buckley is not compensated. So the outlook is bleak and we must continue to call for the reforms that are expected, and call our MPs to action.

[Kharon]

Alternate available?

Sandy - "The too smart answer is that self certification has been the successful standard for some 30 years, in the two seat low weight category. Recreational Aviation Australia, RAAUS, has now close to 10,000 members and it’s proven to be a completely satisfactory standard, yes 30 years."


Despite the overwhelming evidence that the 'self declared' system has been demonstrated as effective, for some undefined reason CASA has its boot firmly on the brake pedal. OK, for some strange reason, they will not adopt best practice, so, will they consider a less radical plan? One notion worth a moments thought is to remove the CASA involvement in medical certification for PPL holders.

To qualify as a DAME, the Doc has to jump through the hoops of 'approval'. Fine, so why not just allow the DAME to sign out a PPL on the day of the medical? Walk in, go through the examination, accept any conditions and further advice, pay the fee and depart the fix - good to go - for another 12 month.

That which exists at present is a peculiar system. Say you are not feeling well; what any sensible person would do is trot off to see the doctor. The Doc may call in a specialist or not as the case may be. But: your personal trust in the doctor is enough to follow the qualified advice given to even the stage of major surgery. I know I trust my bloke, good man and a DAME. If his say-so is good enough for me (and my life) why is it not good enough for the Avmed school of second guessing a qualified medical opinion, even to the point of dismissing 'specialist' advice. Your personal well being is NOT in the hands of CASA; it rests with your own choice of medical practitioner and an inherent desire to be well. 

The sheer bloody minded arrogance of someone who would not know you if you jumped up and bit 'em in the arse, but can with impunity, overrule DAME and 'specialist' advice is beyond the bounds of practical common sense, realistic governance and an insult to the DAME who actually examines, makes the decision and accepts the responsibility for making sure you are 'fit to fly'. In short, the current system is a double dip load of pointless bollocks...

Toot - toot.  (long drive today - early start - now, where did I leave my coffee mug?).

[Peetwo]

Ben Morgan takes aim at CASA's snail pace on self-certification medical reform -   

Courtesy AOPA Oz, via FB:

SELF-DECLARED PILOT MEDICAL CERTIFICATION FOR CASA RPL & PPL HOLDERS:  IT'S BEEN SIX YEARS, WHERE IS IT?

It's now four (4) months since the Civil Aviation Safety Authority closed out the Aviation Medical Policy Review DP2206FS and the industry is rightfully asking 'why hasn't self-declared medical certification for RPL & PPL holders been delivered?'.

Meanwhile, the US and UK are enjoying 6 years of safe and successful use of self-declared medicals in their respective countries.  But... here in Australia our regulator remains unable to deliver the reform.

And some comments in reply...

Steve Curtis · 4:25

Ben, I think you’re being a bit tough. It’s only taken 25 years to implement some of their regulation reform.

I reckon it’ll only take another 10 years to introduce an unworkable self certified medical.

Ian Carfrae · 0:00

Steve Curtis I hope you are wrong, but I fear that you are not

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Steve Curtis · 7:56

The GFA operate VH registered aircraft in controlled airspace, conducted aerobatics and operate over populous areas based on a self certified medical. There’s evidence it can and does happen in Australia.

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Steve Curtis

It’s interesting to find Aviation Medicals seem to be a bit of an industry now. Google Aviation medicals and many links pop up promoting services. It’s also interesting to note the cost of a class 2 medical plus the CASA processing fee is around the same cost of RAAus membership.

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Ian Tucker · 7:17

Good on ya Ben, CASA is a bloody disgrace and dispite early promise, Pip Spense has obviously been nobbled by the CASA salary factory machine. Keep exposing this blight on the GA community, self declared medicals MUST happen.

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Gary Gould · 0:03

Sir Humphrey Appleby:
"Yes, yes, yes, I do see that there is a real dilemma here. In that, while it has been government policy to regard policy as a responsibility of Ministers and administration as a responsibility of Officials, the questions of administrative policy can cause confusion between the policy of administration and the administration of policy, especially when responsibility for the administration of the policy of administration conflicts, or overlaps with, responsibility for the policy of the administration of policy".

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Ralph Holland · 0:52

It’s probably because they did not like the responses they received and they are trying to work out how they can get their way - as usual

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Jan Haak · 9:03

Probably never happen..... Sadly CASA seem to be working against aviation in every way.
They pulled the OCVA for colour defective pilots this year with no notification.
Independent instructor approvals is another point they haven't really actioned on at all.
You just need to watch the senate estimates hearings to see how disfunctional they really are.
Keep up the great work.

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Marc Sibun · 10:51

Gone to plan for RAus! Now they can continue the dictatorship!

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Barry Hayward · 4:31

Will never happen while the panel consists of DAME's and the head of raaus that make their money from medicals for recreational pilots. did someone say "Conflict of Interest"

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Simon McDermott · 6:13

Sorry Ben I’ll need to get you an estimate and you will need to pay it first before looking at that question

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James Geale · 8:12

Bloody joke, bureaucrats protecting jobs. Good on you Ben for saying it for what it is!

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Charles Mifsud

Keep it going Ben for /years casa medical has been making me do all different tests cause I got pace maker my specialists cardiologist approve me my pacemaker specialist approve me Both my GP and Dame and professor in stress approve me but casa keep sending me for more test at huge expense and I only fly 2 seat rv9

MTF...P2 

[Wombat]

Look at it from CASA’s perspective; they are trying to give you ‘self certification” that isn’t.

The key was the use of total weasel language in their work plan’’

1. healthy pilots sometimes get caught in complex and cumbersome regulatory processes that offer little safety benefit

2. (investigate) the potentialintroduction of a self-declared pilot medical pathway for private/recreational operations.

This is code for creating a deliberately useless certificate because it will contain an impossible standard of proof of “health” such that a hangnail five years ago renders you ineligible. This is the same trick they pulled with the basic class 2 - requiring a GP to certify unconditionally that you were OK. No GP with an eye on their insurance policy would touch it.

Health is another meaningless word like. ‘’safety”. Health - compared to what?

[Sandy Reith]

Characterisation of CASA working at a snail’s pace is only correct when the snail is not moving.

This is the time when its little brain is trying to work out how to engage reverse or make a 90 left or right.

[Peetwo]

CASA: "We'll consult on the consult for medical certification!" - UFB! 

True to her reputation, Su_Spence blows off over 600 industry responses to the med certificate consult:

Feedback is in! Here's what we found.
We have published the summary of consultation on our proposal to simplify and modernise our approach to medical certification.

The feedback that you gave us identified several themes that will assist us with the next steps.
Read the su
Read the survey results

Next steps
We are still in the early stages of this work and will continue to work with the medical technical working group to draft a final policy proposal. We will seek your feedback on it in the first half of 2023. - 

This bollocks so incensed Sandy that he has forwarded the following correspondence to his local MP Dan Tehan to in turn forward to Ms Su_Spence...

Dear Dan,

Please forward the communication below to the CASA CEO Ms. Pip Spence. As I have related to you in the past my previous email to Ms. Spence remains unanswered and unacknowledged in spite of my follow up requests, even just to ascertain CASA’s receipt of email.

Hopefully, as my Parliamentary Representative you will receive an answer and I’m asking specifically that you make this representation on my behalf.

Best regards,

Sandy

Ms. Pip Spence 
CASA 
Aviation House 
Canberra ACT 

Dear Ms Spence,

Thank you for the notification regarding the ’feedback’ about the proposed reform of pilot medical certification. 

I note that there’s no particulars or details of permitted types of flying operations that may be applied to any new reformed certification. No mention for example, the fact that USA instructors need no medical certificate provided their students have soloed. 

No mention either of the statistics that pertain from the USA in view of their recent years of history of a self declared private medical certification in regard to risk. Or, in reality, no noting the absence of risk compared to having no specific aviation medical regime and the USA Federal Aviation Administration’s (FAA) structured system. 

Supporting statistics were provided to your ‘feedback’ team. See below, these may be verified from the FAA or from the National Transportation Safety Board USA. 

In regard to your stated timeline, quote;  

“] We are still in the early stages of this work and will continue to work with the medical technical working group to draft a final policy proposal. We will seek your feedback on it in the first half of 2023.” 

This will be considered by most within the General Aviation (GA) community to be taking far too long, and that’s putting it mildly. We are losing pilots all the time due to the current AVMED system. The restrictions of COVID put GA backwards and it needs your assistance now. 

Your reform timeline does not even get past yet another consultation. We should not be strung out like this, there’s too much at stake. 

CASA should, and could, put in place some immediate sensible relief, interim measures;  example for our instructors as in the USA. 

And more broadly for Private Pilots adopt the Austroads private vehicle medical standard, instead of the present unconditional Commercial heavy vehicle standard for the Basic Class 2. This would remain a Basic Class 2 General Practitioner assessed medical, simply a modification of the present assessment (and operational criteria?) making it not dissimilar to the UK and USA systems. 

I note also that your technical working group, that has been assessing the 611 public submissions from the GA community, is 90% made up of medical practitioners. No doubt dedicated to their work but the group’s composition presents an obvious pecuniary conflict of interest and could be open to accusations of bias. 

Regards,

Alexander Cran (Sandy) Reith 

Risk?  There’s no appreciable risk, see below, also demonstrated by 30 plus years of our Recreational Aviation AUS cohort in the low weight aircraft category, membership today c.10,000 with no medical exam regime until age 75 (then annual GP only).

Sandy also made this observation to some of the email recipients:

The medical TWG  made play of the Perth instructor who had a medical incapacitation. Didn’t he have a C1?

I want to make the point that the TWG couldn’t draw the conclusion that having a C1 doesn’t protect anything. Or C2 etc. 

There is mention that car drivers are potential risks to the public at large but they’ve not produced one substantial proposal for a GA reformed medical that fits the facts.

The section to which Sandy refers was from page 22 of the 'Summary of consultation on aviation medical policy review':

..However, pilot incapacitation remains an uncommon event and while instructor incapacitation does happen (as was the case at Jandakot in August 2019 where the student pilot needed to land the aircraft after the instructor became unconscious) such an occurrence is even rarer..

I am not sure if the instructor involved had either a class one or two but here is the ATSB 'Aviation Occurrence Brief' for that incident: https://www.atsb.gov.au/publications/occ...-2019-029/

I note that the 'Safety Message' did not focus on the instructor incapacitation and possibly medical certification, so much as the importance of effective communication in emergency situations:

This incident highlights the importance of how effective communication is crucial to aviation safety.

During the time the flying instructor was incapacitated, both ATC and the student pilot communicated clearly, calmly and proactively, resulting in a safe landing.

For those interested this was the Youtube recording of the radio comms for the incident:

Perhaps the most interesting part of this tale (and very much related to medical certification) was what caused the incapacitation of the instructor and the long term implications and fears for his continued employment as a flight instructor as a consequence - see HERE:

One month on, Mr Mollard revealed to A Current Affair on Tuesday night that his seizure was caused by a benign brain tumour.

"I was feeling totally fine, I hadn’t had any migraines, any headaches, anything like that, I was feeling completely normal," he said.

"I was completely unaware I was having a seizure because I was unconscious at the time and I’d never had one before."

Mr Mollard has since had emergency surgery and the tumour has been removed, however he said he was unsure if he would ever fly again.

“It’s going to be an uphill battle getting my medical back, best-case scenario is 12 months but it's possible that I’ll never fly again as a pilot," he said.

Hmm...I would be interested to know what the outcome was for Mr Mollard's pilot medical recertification...    

MTF...P2 

[Kharon]

Every once in a while.....

Master Morgan of the AOPA on occasion provides a video on the face-book platform which is well worth the time to watch and listen. The subject is pilot medicals and it is fairly well articulated; however, the really important message runs a little deeper. The message delivers an accurate overview of the way in which not only CASA standard operational practice works, it drags in the incredible waste of time and money spent working against industry efforts to have a sensible, practical, working system of administration and regulation fit for purpose.

_ HERE _ is the link; take the time to watch and 'hear' the underlying message.

Well done Master Morgan; nicely played..