Originally Posted by
Clinton McKenzie
That's how Avmed 'justifies' its approach.
What do you mean justifies it's approach? It means they can't justify anything unless they can produce actual, achieved numbers. In particular, it means that for private pilots they need to show that the number is between 1% and 2%, or the standards they are applying are inappropriate.
Originally Posted by
Clinton McKenzie
And some private pilots fly many more hours a year, with many more passengers, than some holders of a commercial licence.
Some private pilots... some commercial pilots... meaningless for risk assessment. If you are assessing risk you need to pick a meaningful benchmark - probably average passenger hours, but maybe you want e.g. 95th percentile of worst case. Worst case risk for commercial pilots is pretty bad - e.g, pilots doing hundreds of hours carrying paying passengers in whatever the largest aircraft is that can be flown single pilot.