Eyrie:
Sunfish, you are being asked to make a submission to a public call for comment.
You aren't being asked to "pledge your life, fortune and sacred honour" ...........
....................You've been vocal here about how excessive regulation screws over Australian aviators. Now you have a chance to stand up and put your point of view officially.
Eyrie, your ingenuous suggestion - that I stand up, is at best pointless and at worst malicious.
I would recommend that no one but an association should comment and the comment itself should be a terse referral to previous submissions to the ASRR.
You see Eyrie, I hold a medical certificate. If I eventually develop a medical condition, the reissue of that certificate is at the whim of CASA AVMED. As evidenced by the ASRR, numerous appeals to the AAT, the entire colour blindness saga, CASA AVMED is quite capable of being totally capricious in its decisions and has the ability to bankrupt an aspiring pilot trying to get a clearance to fly through specialist report costs.
"Oh! But they wouldn't do that would they?" you say? They might, since CASA has proven itself to be vindictive and most importantly
untrustworthy.
So my first point. I would be exposing my medical certificate to risk by making an identifiable comment and suggesting otherwise borders on malicious.
But wait, there is more....... the discussion paper is a pointless exercise. It is an attempt by CASA to frame the debate about medical certificates on ground where CASA knows it can win. By "winning", I mean maintaining CASA's iron grip on Australian aviation and maximising its institutional power.
To put that another way, there is not a snowballs chance in hell that CASA wishes to voluntarily reduce surveillance and control of medical certificates,
they have too many staff whose careers depend on maintaining control and institutions NEVER voluntarily surrender power ever..
So given that CASA is untrustworthy, has invested itself in medical control of pilots which it wishes to maintain despite being advised numerous times about the deleterious effects of its medical regime, the latest being the ASRR, and is now faced by concrete evidence of change by overseas regulators, what does it do? It lets off a discussion paper! Well done Sir Humphrey!
Eyrie, CASA AVMED is run by lawyers, even AVMED's doctors say that to DAMES. The discussion paper is written by lawyers with a view to frustrating meaningful change, for example it is written using language that can be readily compared with the Aviation Act, a typical weasel trick because they already have reams of interpretations of the Act with which to frustrate change.
All you will get in the end is: " I know the FAA has agreed to XYZ, but the Aviation Act does not permit that because of ABC, risk to the public blah, blah".. The desired end result is that CASA can say they responded to change, consulted widely and came up with a revised class 3 medical certificate that looks like its overseas equivalents, but still ties us into the medical straitjacket we now have to wear. Pointless exercise until the Act is changed.