David
I can see that a lot of hard work has been done, and I know almost as well as you that this is the art of the possible. The changes from the CRD to the Opinion are undoubtedly helpful (particularly MED.B.095(d)), but they don't address the key issue of cost of an assessment/examination compared to a declaration.
In the
CRD EASA wrote:
68. Fit assessment: The Agency is of the opinion that a GMP who acts as an AME is assessing the pilot as fit to fly, or, if this is not possible, refers him/her to an AeMC or AME.
The
Opinion reiterates this:
12. British pilots and their associations strongly request that no change occurs to their present national regulations for glider pilots and holders of national private pilot licences (NPPL). The information on the CAA UK website for general practitioners (GP) is: "The first thing to emphasise is that you, the general practitioner, are not being asked to assess an applicant's "Fitness to Fly". Your countersignature confirms only that there is nothing in the applicant's medical history which would prevent him/her meeting the DVLA Group 1 or Group 2 driving standards. …".
13. However, the Basic Regulation states in Article 7 that, in the case of a leisure pilot licence (LAPL), a general medical practitioner (GMP) may act as AME if permitted under national law. This may lead to the conclusion that the GMP, just as the AME, assesses a pilot's fitness to fly.
I cannot believe that a professional will sign off such an assessment without reflecting on the accountability and requiring commensurate remuneration. One could argue, as EASA does, that the issue is not whether an
examination takes place, but rather that the BR requires an
assessment, and that the nails were in the coffin for the
declaration long before the NPA was published. But it's not the only topic where the letter of the BR has been used to override what many stakeholders considered to be its spirit, in this case by another group of stakeholders with a vested interest.
As long ago as 2000 Peter Saundby
wrote:
Many pilots think that medical certification has become a medical tax, unjustified by flight safety. Although age or disease will end all flying careers, pilots doubt whether the medical screening can separate those who will become incapacitated from those who will remain fit....
Having rejected the objections made by pilot's organisations, the medical subcommittee of the Joint Aviation Authorities is vulnerable. Attackers will ascribe unworthy mercenary motives.
In the same way that I'm reluctant to attribute EASA's often disproportionate regulations to malice rather than a genuine but misguided quest for safety, I'm a little reluctant to attribute the opinions of European AMEs to greed. Nevertheless, if they wish to be taken seriously as part of the aviation safety management process, AMEs will have to avoid such delightfully emotive titles as:
Leisure pilot license proposed for Europe: do you want such pilots crossing your flight path?
and start concentrating on assembly the evidence that Peter quite rightly
demands in response.
FWIW, I think the scriptwriters of
have a great deal to answer for!