[Peetwo]

The Empire Strikes Back on CVD Pilots - Update: 29/11/23

Arthur Pape, via the UP:

Apologies for the slowing down of the posts on the thread: A lot is happening in the direct communication space between the CVDPA directors and the CASA hierarchy, in particular the Director, Pip Spence.
I am working through the material that has come to me from the FOI section of CASA. It is disgracefully inadequate in that the lead players who were invited by CASA to help formulate their crusade, the identities of these individuals, as well as their qualifications that one would expect to be told, have been totally redacted (blacked out!).
In due course, we will be publishing the entire response obtained through FOI, but in the meantime, I intend to highlight some of the perverse logic promulgated by CASA to justify its equally perverse conclusions.
Example 1. CASA states: "There is a proposition that the absence of air accidents among CVD pilots could well be due to the fact that there ARE restrictions by way of the Colour Vision Standard.

Then there appears this gem, copied verbatim:
"Safety concerns:
For colour vision deficient pilots, while able to pass OCVA, the colour cues within and outside the cockpit (or flight deck) are vital during the critical phases of flight. During an emergency, with heightened stress levels, the reaction time can become the determining factor between safety and accident. This human factor aspect cannot solely be defined by medical certification, instead has a direct bearing on safe operations, in turn safety of air navigation.
1.
Deutan or Protan CVD defect is a lifelong disability with potential safety impacts:
i.
Reduced or absent ability to assess glide slope by reference to colour cues
Reduced or absent ability to identify and interpret colour cure as used in instrument landing such as PAPI and VASIS and where no redundancy systems can be employed
Reduced or absent ability to identify and interpret colour cues used at airports, including but not limited to, aerodrome markings, holding points runway lighting, marked obstructions, rotating beacons on ground vehicles and precision guidance systems
Reduced or absent ability to identify and interpret colour cues used in cockpit instrument including but not limited to electronic weather displays, indicator and warning systems" End of Quote

I offer you this. There have been three landmark AAT cases since the mid-1980s, and between them, each and every point made in the preceding paragraphs was rejected by the AAT. It is nothing more than pure sophistry, intended to deceive and blind the gullible observers of the debate. We have records of hundreds of pilots with severe colour vision defects that pass and keep on passing every operational test put to them, and I mean BIG TIME! These folk fly every conceivable modern RPT aircraft, and that's just the Aussie part of the sample. In the USA, no one cares to keep the exact figures, but there are thousands of severe CVD pilots representing many thousands of accumulated flight hours performed in safety, and thousands of check and training examinations.

More in a day or two.

Next I note that Senator Fawcett has submitted written QON to CASA in Supplementary Budget Estimates:

79. https://www.aph.gov.au/api/qon/downloade...onNumber79

Question
1.Mr Marcelja indicated that the information on the CASA website did not reflect the intended policy.
a.Who has a role in authorising changes to the CASA website?
b.Does CASA have a policy or approved process for ensuring due diligence is applied to check for alignment with approved policy before changes are made?
c.If the answer to b. is YES, why wasn't this process followed?

2.Ms Spence also indicated that the information was inaccurate.
a.Who drafted the information which was published on the website?
b.What steps have been / will be taken to ensure that individual employees are aware of their responsibility to curtail their personal views and support the agreed corporate policy position?

80. https://www.aph.gov.au/api/qon/downloade...onNumber80

Question
Providing evidence during Estimate (23 Oct 23) Dr Manderson discussed:
1. an international group of ''expert pilots and flying instructors''.
a. How many people were in the group?
b. How were the members of the group selected?
c. How many members of the group had recent (within the past 12 months) industry flying operations experience as CPL or ATPL qualified pilots?
d. How many members of the group had recent (within the past 12 months) industry experience as a flying instructor, flight examiner, approved testing officer or equivalent?
e. How many members of the group were CASA Flying Operations Inspectors?
f. How many members of the group were/are employees of CASA?

2. a meeting of colleagues from FAA, NZ, US DoD and ICAO.
a. How many of these colleagues had expertise in aviation medicine or academic/clinical fields related to the colour perception standard?
b. How many of these colleagues had expertise in aviation flying operations or flight examiners/instructors or equivalent?

3. that no medical certificates had been denied since the decision to review the operational test. This evidence was provided during a line of questions in respect of whether CASA would provide an ''unrestricted medical certificate'' to a candidate who has passed an operational test. While assertion that no medical certificates had been denied is technically correct, it is not accurate in the context of the Estimates hearing and evidence of restrictions being applied to candidates who have passed the operational test.
a. How many CVD candidates have been issued an unrestricted medical certificate since the OCVA operational test was announced by Mr Carmody??
b. How many CVD candidates have been issued an unrestricted medical certificates since the decision to review the operational test?
c. How many CVD candidates have been issued a medical certificate containing CVD related restrictions since the decision to review the operational test?
d. On what day and by what means did CASA make a public statement that the changes announced by Mr Carmody (2020) relating to CVD testing options and outcomes under CASR 67.150 (6)© were no longer going to be implemented / accepted by CASA AVMED?
e. What guidance was provided to DAMEs and CASA AVMED staff relating to changes CASA would implement during this period?

81. https://www.aph.gov.au/api/qon/downloade...onNumber81

Question
A senior aviation medical officer from CASA has indicated in written communication to CVD stakeholders (30 Aug 23) that:
1. ''Passing Farnsworth and or CAD test is considered equivalent to a pass for PAPI practical test, noting only those pilots with severe CVD are offered ACVA because they cannot pass the desk-based test we are accepting as proxy for PAPI - especially the CAD''.
a. In practice, this reliance on a desk-based assessment has occurred over some years regardless of a candidates flight experience (ie: many have no flight time when they do their medical). What evidence is CASA relying on to apply restrictions on a pilot who passes on operational test (regardless of flight experience) where they have demonstrated that they can correctly interpret the visual cues provided by a real PAPI in a real operational environment?
b. How many CAD testing locations are available in Australia?
c. Is it the intent of CASA to change the 2020 provisions and require a candidate to undertake the CAD before having the option for an operational test?

MTF...P2