Petition to Minister Truss
Well done Senator Fawcett..
CVD & IOS Senator
hears your angst!
Senator FAWCETT (South Australia—Deputy Government Whip in the Senate) (18:55): I rise to make a few comments this evening on the state of aviation and its regulation in Australia. But first I wish to note the appointment of Jeff Boyd to the CASA board by the government, which I welcome. Mr Boyd has a long history in the aviation industry, as a LAME—understanding the engineering and the mechanical side—as an in-flight instructor and with his ownership and running of Brindabella Airlines. He has a depth of experience which will be very welcome on the board, and I look forward to the government's appointments of other board members in the near future—particularly as the board will have a key role in implementing the recommendations, as the government approves them, from the Forsyth review into aviation safety regulation.
The issue I would like to touch on tonight though is about a small group of people in the aviation environment. One of the characteristics of a plural liberal democracy such as we have here in Australia is that we respect and look after the rights of minorities. Amongst the pilot population in Australia—the estimates vary, but it is well over 30,000—there is a small group, numbering in their hundreds, potentially around 400, who have a colour vision deficiency. For many years—in fact going right back, I think the first publication that dealt with this was in 1926. People made the assumption, as they looked at aircraft deriving from the days of sailing ships and steamships where they had red and green lights for navigation lights, that if a pilot could not discriminate colours, then he was not safe to fly by night. And since 1926, that document has formed bodies of thought that have flowed through into regulation.
The current ICAO—the international organisation that looks after aviation—document recognises that, to use climate change terms, the science is not settled. They are not actually sure what difference a colour vision deficiency makes to an individual's ability to safely pilot an aircraft by day or by night. Despite that, regulators around the world have tended to err on the side of safety and say, 'We won't let people fly by night unless they pass one of a number of tests'. What that has meant is that for around nine per cent of the male population around the world, those who would aspire to be pilots or even air traffic controllers, are often denied that opportunity.
That changed here in Australia about 25 years ago. In the Administrative Appeals Tribunal there was a case that has become known as the Denison case where a colour-vision-deficient pilot took the regulator to the tribunal saying: 'This is unfair. I can demonstrate that I'm competent to fly.' The Commonwealth, because of the degree of interest, funded the applicant as well as the defence, through the then CAA, and so you had a test case where both parties brought in lots of experts. At the end of it, the judgement was made that in fact pilots who had a colour vision deficiency should be able to demonstrate their competence and be licensed to fly. The only condition that was put on that was that they could not captain high-capacity airline aircraft.
As a result of that, Australia is unique in the world in that we now have some 25 years of experience of people with a colour vision deficiency who have been flying, and they have been flying everything from light aircraft by day through to regional type airliners; single pilot, for example overnight freight or the Royal Flying Doctor Service, through to co-pilot roles, particularly in regional type aircraft. We also have—because a number of the principal medical officers within the Civil Aviation Safety Authority have sought to facilitate people with a colour vision deficiency to fly and have implemented things like practical flight tests for people to demonstrate their competence—some people now captaining large capacity aircraft and they have been doing so quite safely for a number of years and in some cases have well over 10,000 hours of flying. That says that, despite the theory, much of which has its origins in that 1926 document, practice shows that people with a colour vision deficiency can operate aircraft safely.
There are four key areas that people raise concerns about. One is to do with the tower. If you lose your radio and there is a control tower, you have to look for the red, green or flashing lights to tell you whether you can land, take off et cetera. People are concerned that if you cannot distinguish the lights then you would not be able to land safely. Again that was probably valid in 1926, but the reality is that on the top of the approach plates that I and other pilots use when we fly is the phone number for the tower. It says, 'If you lose radio contact, phone the tower.' The headset I use, like many others, has a bluetooth connection for a phone so you can quite safely, if you need to, have a redundant system that is specified in the publications to call the tower. So I think that argument is somewhat outdated.
There is also the argument that, with the advent of EFIS screens or glass cockpits, the increased use of colour means that you must be able to distinguish the colours in order to be able to operate safely. One pilot recently underwent a test in a simulator with a CASA flying operations inspector. He specifically asked to be tested on all the night sequences information from the cockpit and he was assessed as being quite safe to operate. In my own experience of modifying aircraft and certifying them for use with night-vision goggles one of the common applications in the cockpit is to put a large green filter over the glass displays so all the colour hierarchies are essentially diminished and yet we certify the aircraft, and pilots fly quite happily by day and night with no incidents. So, whilst the colour is nice to have, clearly it is not an essential characteristic of the cockpit.
There is also concern about traffic and whether you will see the position lights on aircraft. The reality is that many aircraft now have bright white strobe lights for collision avoidance. The interesting part is that the aircraft that most these people have been able to fly over the 25 years are aircraft that do not have automated systems to support the pilot. The one type of aircraft they are not generally allowed to fly in Australia—your larger airlines—has things like white strobes; predominately flies in controlled airspace where air traffic control provides a degree of separation; and has traffic collision avoidance systems, TCASs, that give automated warnings of proximity to other aircraft. So there appears again, both in practice and just conceptually, to be a problem with the restriction that has been placed on people there.
The last area is the PAPI, the precision approach path indicator, which is a glide slope indicator that is positioned next to a runway for pilots to use at night. Because it relies on a combination of red and white lights there is a concern that certain kinds of colour-vision-deficient pilots would not be able to interpret those lights. Again, the confound for that theory is that over 25 years hundreds of pilots have flown thousands of approaches at night using PAPIs quite safely, which says that either the PAPI itself has additional cueing, such as the intensity of the lights, or, more probably, there are enough redundant cues in the surrounding environment that the pilot can land safely. That is backed up by the fact that CASA will provide an exemption if the PAPI is unserviceable: you can still fly your aircraft and land it. That says that the PAPI is a nice thing to have but it is clearly not essential for landing an aircraft.
For this minority group of pilots there has been a change in CASA's view. They have decided to review the safety of these people flying aircraft. They have written to the individual pilots and to employers saying that research, which they have not published, has shown that these pilots may be unsafe. But they have not clarified what that is. The history over the last 25 years shows that that is not the case. Previous principal medical officers in CASA have shown a willingness to support pilots. I am concerned that the attitudes of a few within the regulator may be putting at risk this group, albeit a minority group. In our democracy we look after the rights of minorities. There is an injustice being done to this group. I will be working with the government to fund either another test case or research to make sure that this group receives the justice that the last 25 years have shown that they are due.
Senator FAWCETT (South Australia—Deputy Government Whip in the Senate) (18:55): I rise to make a few comments this evening on the state of aviation and its regulation in Australia. But first I wish to note the appointment of Jeff Boyd to the CASA board by the government, which I welcome. Mr Boyd has a long history in the aviation industry, as a LAME—understanding the engineering and the mechanical side—as an in-flight instructor and with his ownership and running of Brindabella Airlines. He has a depth of experience which will be very welcome on the board, and I look forward to the government's appointments of other board members in the near future—particularly as the board will have a key role in implementing the recommendations, as the government approves them, from the Forsyth review into aviation safety regulation.
The issue I would like to touch on tonight though is about a small group of people in the aviation environment. One of the characteristics of a plural liberal democracy such as we have here in Australia is that we respect and look after the rights of minorities. Amongst the pilot population in Australia—the estimates vary, but it is well over 30,000—there is a small group, numbering in their hundreds, potentially around 400, who have a colour vision deficiency. For many years—in fact going right back, I think the first publication that dealt with this was in 1926. People made the assumption, as they looked at aircraft deriving from the days of sailing ships and steamships where they had red and green lights for navigation lights, that if a pilot could not discriminate colours, then he was not safe to fly by night. And since 1926, that document has formed bodies of thought that have flowed through into regulation.
The current ICAO—the international organisation that looks after aviation—document recognises that, to use climate change terms, the science is not settled. They are not actually sure what difference a colour vision deficiency makes to an individual's ability to safely pilot an aircraft by day or by night. Despite that, regulators around the world have tended to err on the side of safety and say, 'We won't let people fly by night unless they pass one of a number of tests'. What that has meant is that for around nine per cent of the male population around the world, those who would aspire to be pilots or even air traffic controllers, are often denied that opportunity.
That changed here in Australia about 25 years ago. In the Administrative Appeals Tribunal there was a case that has become known as the Denison case where a colour-vision-deficient pilot took the regulator to the tribunal saying: 'This is unfair. I can demonstrate that I'm competent to fly.' The Commonwealth, because of the degree of interest, funded the applicant as well as the defence, through the then CAA, and so you had a test case where both parties brought in lots of experts. At the end of it, the judgement was made that in fact pilots who had a colour vision deficiency should be able to demonstrate their competence and be licensed to fly. The only condition that was put on that was that they could not captain high-capacity airline aircraft.
As a result of that, Australia is unique in the world in that we now have some 25 years of experience of people with a colour vision deficiency who have been flying, and they have been flying everything from light aircraft by day through to regional type airliners; single pilot, for example overnight freight or the Royal Flying Doctor Service, through to co-pilot roles, particularly in regional type aircraft. We also have—because a number of the principal medical officers within the Civil Aviation Safety Authority have sought to facilitate people with a colour vision deficiency to fly and have implemented things like practical flight tests for people to demonstrate their competence—some people now captaining large capacity aircraft and they have been doing so quite safely for a number of years and in some cases have well over 10,000 hours of flying. That says that, despite the theory, much of which has its origins in that 1926 document, practice shows that people with a colour vision deficiency can operate aircraft safely.
There are four key areas that people raise concerns about. One is to do with the tower. If you lose your radio and there is a control tower, you have to look for the red, green or flashing lights to tell you whether you can land, take off et cetera. People are concerned that if you cannot distinguish the lights then you would not be able to land safely. Again that was probably valid in 1926, but the reality is that on the top of the approach plates that I and other pilots use when we fly is the phone number for the tower. It says, 'If you lose radio contact, phone the tower.' The headset I use, like many others, has a bluetooth connection for a phone so you can quite safely, if you need to, have a redundant system that is specified in the publications to call the tower. So I think that argument is somewhat outdated.
There is also the argument that, with the advent of EFIS screens or glass cockpits, the increased use of colour means that you must be able to distinguish the colours in order to be able to operate safely. One pilot recently underwent a test in a simulator with a CASA flying operations inspector. He specifically asked to be tested on all the night sequences information from the cockpit and he was assessed as being quite safe to operate. In my own experience of modifying aircraft and certifying them for use with night-vision goggles one of the common applications in the cockpit is to put a large green filter over the glass displays so all the colour hierarchies are essentially diminished and yet we certify the aircraft, and pilots fly quite happily by day and night with no incidents. So, whilst the colour is nice to have, clearly it is not an essential characteristic of the cockpit.
There is also concern about traffic and whether you will see the position lights on aircraft. The reality is that many aircraft now have bright white strobe lights for collision avoidance. The interesting part is that the aircraft that most these people have been able to fly over the 25 years are aircraft that do not have automated systems to support the pilot. The one type of aircraft they are not generally allowed to fly in Australia—your larger airlines—has things like white strobes; predominately flies in controlled airspace where air traffic control provides a degree of separation; and has traffic collision avoidance systems, TCASs, that give automated warnings of proximity to other aircraft. So there appears again, both in practice and just conceptually, to be a problem with the restriction that has been placed on people there.
The last area is the PAPI, the precision approach path indicator, which is a glide slope indicator that is positioned next to a runway for pilots to use at night. Because it relies on a combination of red and white lights there is a concern that certain kinds of colour-vision-deficient pilots would not be able to interpret those lights. Again, the confound for that theory is that over 25 years hundreds of pilots have flown thousands of approaches at night using PAPIs quite safely, which says that either the PAPI itself has additional cueing, such as the intensity of the lights, or, more probably, there are enough redundant cues in the surrounding environment that the pilot can land safely. That is backed up by the fact that CASA will provide an exemption if the PAPI is unserviceable: you can still fly your aircraft and land it. That says that the PAPI is a nice thing to have but it is clearly not essential for landing an aircraft.
For this minority group of pilots there has been a change in CASA's view. They have decided to review the safety of these people flying aircraft. They have written to the individual pilots and to employers saying that research, which they have not published, has shown that these pilots may be unsafe. But they have not clarified what that is. The history over the last 25 years shows that that is not the case. Previous principal medical officers in CASA have shown a willingness to support pilots. I am concerned that the attitudes of a few within the regulator may be putting at risk this group, albeit a minority group. In our democracy we look after the rights of minorities. There is an injustice being done to this group. I will be working with the government to fund either another test case or research to make sure that this group receives the justice that the last 25 years have shown that they are due.
Last edited by Sarcs; 10th Jul 2014 at 22:59. Reason: Video added....enjoy. Edit layman to LAME
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This article from Ben Sandilands – Plane Talking – is worth the read; and it's very nice to have men in government who keep their word.. – Xenophon -.
Addressing true safety issues vs CAsA minority embuggerance
Comment from the PT article goes to the pettiness of this whole sordid stance by the FF PMO (DAS & iron ring) to CVD pilots...
:
The Creamy post #406 on ESB thread perhaps eloquently summarises the FF (BASR) legal viewpoint when it comes to the John O'Brien AAT hearing in October. However the proposed FF embuggerance, of yet another minority group, further highlights how so far removed from mitigating legitimate air safety risk the regulator has become...
Meanwhile the rest of the world marches on in improving air safety...
Quote from last week's Senator Fawcett Senate adjournment speech on CVD pilots, here(my bold)...
"...In my own experience of modifying aircraft and certifying them for use with night-vision goggles one of the common applications in the cockpit is to put a large green filter over the glass displays so all the colour hierarchies are essentially diminished and yet we certify the aircraft, and pilots fly quite happily by day and night with no incidents. So, whilst the colour is nice to have, clearly it is not an essential characteristic of the cockpit...
...The last area is the PAPI, the precision approach path indicator, which is a glide slope indicator that is positioned next to a runway for pilots to use at night. Because it relies on a combination of red and white lights there is a concern that certain kinds of colour-vision-deficient pilots would not be able to interpret those lights. Again, the confound for that theory is that over 25 years hundreds of pilots have flown thousands of approaches at night using PAPIs quite safely, which says that either the PAPI itself has additional cueing, such as the intensity of the lights, or, more probably, there are enough redundant cues in the surrounding environment that the pilot can land safely. That is backed up by the fact that CASA will provide an exemption if the PAPI is unserviceable: you can still fly your aircraft and land it. That says that the PAPI is a nice thing to have but it is clearly not essential for landing an aircraft..."
Perhaps to help Senator Fawcett with his reasoned, empirically, factual argument, the following is a short poohtube vid from Rockwell Collins promoting their, soon to be approved, Enhanced Vision System.
Hmm...not a lot of colour in that display...
Also noticed a short article from Oz Flying that came out yesterday about an Aussie invention that could actually save lives i.e. mitigate a safety issue that is killing people:
Well done that man..
So while FF continue to argue the toss on a non-safety issue (BASR), other bright people (including an aussie) are quietly getting on with the business of actually improving air safety...CAsA for WOFTAM award 2014..
:
Fueldrum
To fly across the sky is a privilege, not a right. To be protected against illegal discrimination is a right, not a privilege. The rights of one are the rights of all.
Disability discrimination is illegal unless (a) the disability actually elevates the risk of an accident, and (b) no steps that can reasonably be taken will offset that elevation of risk. If CASA had any scientific evidence that colour vision defects elevate the risk of an accident, they would have published it by now. Certainly they had nothing resembling defensible evidence in the court cases 25 years ago.
If CASA can, without evidence, exclude pilots with this insignificant disability from aviation, then pilots with diet-controlled diabetes, puffer-controlled asthma, and a hundred other insignificant ailments will not be far behind. We all remember what happened to our CVD colleagues in air traffic control.
To fly across the sky is a privilege, not a right. To be protected against illegal discrimination is a right, not a privilege. The rights of one are the rights of all.
Disability discrimination is illegal unless (a) the disability actually elevates the risk of an accident, and (b) no steps that can reasonably be taken will offset that elevation of risk. If CASA had any scientific evidence that colour vision defects elevate the risk of an accident, they would have published it by now. Certainly they had nothing resembling defensible evidence in the court cases 25 years ago.
If CASA can, without evidence, exclude pilots with this insignificant disability from aviation, then pilots with diet-controlled diabetes, puffer-controlled asthma, and a hundred other insignificant ailments will not be far behind. We all remember what happened to our CVD colleagues in air traffic control.
Meanwhile the rest of the world marches on in improving air safety...
Quote from last week's Senator Fawcett Senate adjournment speech on CVD pilots, here(my bold)...
"...In my own experience of modifying aircraft and certifying them for use with night-vision goggles one of the common applications in the cockpit is to put a large green filter over the glass displays so all the colour hierarchies are essentially diminished and yet we certify the aircraft, and pilots fly quite happily by day and night with no incidents. So, whilst the colour is nice to have, clearly it is not an essential characteristic of the cockpit...
...The last area is the PAPI, the precision approach path indicator, which is a glide slope indicator that is positioned next to a runway for pilots to use at night. Because it relies on a combination of red and white lights there is a concern that certain kinds of colour-vision-deficient pilots would not be able to interpret those lights. Again, the confound for that theory is that over 25 years hundreds of pilots have flown thousands of approaches at night using PAPIs quite safely, which says that either the PAPI itself has additional cueing, such as the intensity of the lights, or, more probably, there are enough redundant cues in the surrounding environment that the pilot can land safely. That is backed up by the fact that CASA will provide an exemption if the PAPI is unserviceable: you can still fly your aircraft and land it. That says that the PAPI is a nice thing to have but it is clearly not essential for landing an aircraft..."
Perhaps to help Senator Fawcett with his reasoned, empirically, factual argument, the following is a short poohtube vid from Rockwell Collins promoting their, soon to be approved, Enhanced Vision System.
The new system, available on both head-up and head-down displays, includes a proprietary multi-spectral EVS sensor, developed by Rockwell Collins, that significantly improves detection of outside terrain, hazards and obstacles in low-visibility conditions caused by weather phenomena such as fog. The EVS-3000 also brings the industry-first ability to fully detect LED lighting, which is increasingly utilized by airports as a runway lighting solution (watch preview video).
“We’re bringing unprecedented accuracy in sensing what’s ahead during critical phases of flight,” said Craig Olson, senior director, Head-up Guidance Systems for Rockwell Collins. “At the same time, operators will experience enhanced reliability and lower cost of ownership from our lower-weight, more energy-efficient EVS solution.”
“We’re bringing unprecedented accuracy in sensing what’s ahead during critical phases of flight,” said Craig Olson, senior director, Head-up Guidance Systems for Rockwell Collins. “At the same time, operators will experience enhanced reliability and lower cost of ownership from our lower-weight, more energy-efficient EVS solution.”
Also noticed a short article from Oz Flying that came out yesterday about an Aussie invention that could actually save lives i.e. mitigate a safety issue that is killing people:
Aussie Invention Tackles Spatial Disorientation
14 Jul 2014
A South Australian general aviation pilot has developed a system to help pilots avoid spatial disorientation.
Spatial disorientation involves pilots being unable to detect the position of their aircraft when they have no visual reference of the horizon, such as when flying on dark nights or in IMC.
The Green Orientation Light (GO Light), invented by pilot Russell Crane, casts a green light over the lower section of the cockpit, and is always aligned with the horizon, regardless of the aircraft attitude or angle of bank.
This enables pilots to use peripheral vision in the cockpit rather than having to seek out the artificial horizon to establish the aeroplane's attitude.
"The GO Light is a system of gyroscopically moving lights that will give pilots a constant reference point of the horizon in their peripheral vision, helping them stay continually aware of the plane’s attitude,” Crane said.
“Everyone has experienced spatial disorientation at some time or another. Think of when you’re in a car, stationary in traffic, and you get the feeling of backwards movement when the car next to you moves forward. That’s spatial disorientation.
“Presently, to verify orientation when there are no visual cues, the pilot has to focus on their small attitude indicator (AI) instrument. However, this verification requires the pilot to recognise that they may be disorientated and actively focus their attention on the AI."
The idea has the support of AvLaw International chairman Ron Bartsch – a former airline safety manager and current UNSW aviation lecturer.
“A solution to spatial disorientation is like the elusive Holy Grail of aviation safety,” Bartsch said. “The GO Light takes the concept of the AI and turns it into a constant part of the pilot’s subconscious perception.
“If this concept can be taken forward and commercialised, it could be the most important Australian aviation invention since the black box.’’
To find out more, visit the GO Light website.
14 Jul 2014
A South Australian general aviation pilot has developed a system to help pilots avoid spatial disorientation.
Spatial disorientation involves pilots being unable to detect the position of their aircraft when they have no visual reference of the horizon, such as when flying on dark nights or in IMC.
The Green Orientation Light (GO Light), invented by pilot Russell Crane, casts a green light over the lower section of the cockpit, and is always aligned with the horizon, regardless of the aircraft attitude or angle of bank.
This enables pilots to use peripheral vision in the cockpit rather than having to seek out the artificial horizon to establish the aeroplane's attitude.
"The GO Light is a system of gyroscopically moving lights that will give pilots a constant reference point of the horizon in their peripheral vision, helping them stay continually aware of the plane’s attitude,” Crane said.
“Everyone has experienced spatial disorientation at some time or another. Think of when you’re in a car, stationary in traffic, and you get the feeling of backwards movement when the car next to you moves forward. That’s spatial disorientation.
“Presently, to verify orientation when there are no visual cues, the pilot has to focus on their small attitude indicator (AI) instrument. However, this verification requires the pilot to recognise that they may be disorientated and actively focus their attention on the AI."
The idea has the support of AvLaw International chairman Ron Bartsch – a former airline safety manager and current UNSW aviation lecturer.
“A solution to spatial disorientation is like the elusive Holy Grail of aviation safety,” Bartsch said. “The GO Light takes the concept of the AI and turns it into a constant part of the pilot’s subconscious perception.
“If this concept can be taken forward and commercialised, it could be the most important Australian aviation invention since the black box.’’
To find out more, visit the GO Light website.
So while FF continue to argue the toss on a non-safety issue (BASR), other bright people (including an aussie) are quietly getting on with the business of actually improving air safety...CAsA for WOFTAM award 2014..
Last edited by Sarcs; 15th Jul 2014 at 12:23.
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Ducked - in a row.
Ducking amazing, the rest of the world moves forward; blind landing HUD from Rockwell, who decided that colours were not only un-required but would distract. NVG same thinking, the Australian developed 'horizon' generator (what a bonzer idea).. All developed to promote safety and efficiency in hostile environment.
Yet here we sit, the enlightened 'regulator' hell bent on taking a 25 year leap, back in time.
Stellar, breathtakingly, stunningly, amazingly wonderful. Makes me proud to be an Australian, if only I could loose the ball and chain, I might even be able to jump for joy in celebration of our enhanced safety ethos.
Give me strength, I know patience is out of the question..
Toot toot....-.
Yet here we sit, the enlightened 'regulator' hell bent on taking a 25 year leap, back in time.
Stellar, breathtakingly, stunningly, amazingly wonderful. Makes me proud to be an Australian, if only I could loose the ball and chain, I might even be able to jump for joy in celebration of our enhanced safety ethos.
Give me strength, I know patience is out of the question..
Toot toot....-.
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We'll done guys, keep em coming!
Let's show Aussie pilots can get together and do some good united!
Let's show Aussie pilots can get together and do some good united!
Last edited by Dingowalkabout; 17th Jul 2014 at 05:09. Reason: Add on
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Two great leaps forward in safety. Here's me thinking the electric roller door was a miracle and CVD was probably only a handicap when in the interior decorating business.
Last edited by Frank Arouet; 21st Jul 2014 at 04:25.
Petition update
Latest count is at 1627 signatures, would be nice to take to 2000 or beyond..
A comment from the petition that goes to the heart of this injustice...
Although Creamy's post #431 is somewhat reassuring in regards to the flawed legal argument from CAsA, it is dependent on the matter continuing through to the Federal Court, a process that could possibly be very prolonged, unaffordable and out of reach for JO (& others)...
Quote from Senator Fawcett's latest newsletter (The Fawcett Flyer, July '14):
Now although it is reassuring that DF is still very much fighting for the CVD cause, it is apparent that his efforts (so far at least) to garner govt support & funding for JO to be equally represented in the AAT (& potentially the Federal court) have fallen on the very deaf ears of Truss...
Therefore the better option IMO is for the miniscule to stop this lunacy before it gets to the AAT i.e. get back to Reason. However the word is the old DAS is using the CVD matter for his last hoorah to stick it up the IOS (with a middle finger)...
So until such time as the miniscule gets off the pot & actions the ASRR recommendations and appoints a new Board, who in turn appoints a new DAS, the current PMO CVD policy will not change!
SIGN the Petition NOW!
A comment from the petition that goes to the heart of this injustice...
After 23 years of being in command of commercial aircraft including 12 years with the Royal Flying Doctor Service and now with a large airline it seems CASA in their infinite wisdom suddenly say I'm unsafe. I have accumulated over 8000 flight hours including over 2000 at night in single pilot IFR operations in full glass cockpit aircraft. What a load of BS! Still I'll line up for the doll if it happens, I've certainly paid enough in taxes over the years.
Quote from Senator Fawcett's latest newsletter (The Fawcett Flyer, July '14):
My background as a test pilot and flying instructor has informed my invovlement in the reform of aviation safety regulation (see article attached which appeared in Australian Aviation Magazine July 2014).
Australia has 36,000 licensed pilots, of whom a small group of around 400 have some colour vision deficiency (CVD) and are now finding their careers under threat from decisions taken by the Civil Aviation Safety Authority (CASA). For many decades, global aviation authorities have relied on assumptions (first published in 1926) that the inability to distinguish red and green would render an individual unsafe to pilot an aircraft, particularly by night.
These assumptions were challenged in the Adminstrative Appeals Tribunal over 25 years ago and expert witnesses presented a convincing safety case that a CVD did not in fact make a pilot unsafe.
Following this evidence-based ruling, Australia has led the world by allowing pilots with a CVD to fly as the captain or co-pilot of aircraft, engaged in roles ranging from overnight freight to the Flying Doctor. CVD pilots have now flown thousands of hours by day and by night with no safety incidents or concerns as a result of their vision. Even though it has not produced any new evidence to support its decisions, CASA now appears to have decided to wind back these hard won rights (as highlighted on ABC 7:30 recently). While it may be a relatively small group of people whose lives and careers are impacted, it is a matter of justice for those affected, and I will continue to pursue a just outcome for these Australians.
Australia has 36,000 licensed pilots, of whom a small group of around 400 have some colour vision deficiency (CVD) and are now finding their careers under threat from decisions taken by the Civil Aviation Safety Authority (CASA). For many decades, global aviation authorities have relied on assumptions (first published in 1926) that the inability to distinguish red and green would render an individual unsafe to pilot an aircraft, particularly by night.
These assumptions were challenged in the Adminstrative Appeals Tribunal over 25 years ago and expert witnesses presented a convincing safety case that a CVD did not in fact make a pilot unsafe.
Following this evidence-based ruling, Australia has led the world by allowing pilots with a CVD to fly as the captain or co-pilot of aircraft, engaged in roles ranging from overnight freight to the Flying Doctor. CVD pilots have now flown thousands of hours by day and by night with no safety incidents or concerns as a result of their vision. Even though it has not produced any new evidence to support its decisions, CASA now appears to have decided to wind back these hard won rights (as highlighted on ABC 7:30 recently). While it may be a relatively small group of people whose lives and careers are impacted, it is a matter of justice for those affected, and I will continue to pursue a just outcome for these Australians.
Therefore the better option IMO is for the miniscule to stop this lunacy before it gets to the AAT i.e. get back to Reason. However the word is the old DAS is using the CVD matter for his last hoorah to stick it up the IOS (with a middle finger)...
So until such time as the miniscule gets off the pot & actions the ASRR recommendations and appoints a new Board, who in turn appoints a new DAS, the current PMO CVD policy will not change!
SIGN the Petition NOW!
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PMO changes his mind...again
It seems the PMO can't stick to a decision about CVD pilot applicants.... The FAQ section of the CAsA website has been changed yet again today
In April we had...
In May we had...
In June we had....
Today we have...
There is also the debacle of Bill Smith's ATPL privileges being withdrawn then re-instated.
Perhaps it's time for the PMO to resign and let someone else assume the role who can at least be consistent with their decisions? Perhaps someone who respects the advice of those who are more qualified and capable of making judgements?
How much longer will this bureaucrat be allowed to continue to destroy pilot's livelihoods and send them (and the taxpayer!) broke through the AAT before enough is enough?
I see Senator Fawcett is asking the same question in a written QON published a few days ago:
As Creampuff has eloquently highlighted in the ESB thread, the CVD matter is boiling down to the PMO's inability to interpret CASR 67.150(6)(c).
He could even start by looking up some of the definitions in the new Part 61. It may give him a few hints on the meanings of those tricky words.
CIVIL AVIATION LEGISLATION AMENDMENT REGULATION 2013 (NO. 1) - REG 61.010
In April we had...
You would have noticed that your recent medical certificate had a condition 13 which read "Limited to flights conducted inside Australian territory" instead of the earlier "Holder does not fully meet requirements of ICAO Convention Chapter 6 of Annex 1".
Recent research undertaken by CASA in the context of an extensive matter before the Administrative Appeals Tribunal revealed that foreign aviation authorities in a number of countries take a much stricter approach to the medical certification of pilots with colour vision deficiencies (CVD) than is currently the case in Australia. Given the significant difference in the treatment of pilots with CVD in other countries, CASA formed the view that medical certificates issued to persons with CVD should be limited to the conduct of operations in Australian territory. The condition 13 on the medical certificates was accordingly modified. This was on the basis that it was not considered appropriate for CASA to authorise persons to fly in the airspace of a foreign country in circumstances where the aviation authorities in that country would not countenance medical certification of the pilot concerned.
On the basis that CASA did not consult with affected pilots prior to making the change to the condition text, it has been decided that a replacement certificate reinstating the previous condition should be issued to you, and that is attached. At this point in time, CASA has no intention of changing the condition text in the immediate future.
I apologise for any inconvenience caused to you, and if you have any questions please contact 1300 4 AVMED.
Aviation Medicine
Recent research undertaken by CASA in the context of an extensive matter before the Administrative Appeals Tribunal revealed that foreign aviation authorities in a number of countries take a much stricter approach to the medical certification of pilots with colour vision deficiencies (CVD) than is currently the case in Australia. Given the significant difference in the treatment of pilots with CVD in other countries, CASA formed the view that medical certificates issued to persons with CVD should be limited to the conduct of operations in Australian territory. The condition 13 on the medical certificates was accordingly modified. This was on the basis that it was not considered appropriate for CASA to authorise persons to fly in the airspace of a foreign country in circumstances where the aviation authorities in that country would not countenance medical certification of the pilot concerned.
On the basis that CASA did not consult with affected pilots prior to making the change to the condition text, it has been decided that a replacement certificate reinstating the previous condition should be issued to you, and that is attached. At this point in time, CASA has no intention of changing the condition text in the immediate future.
I apologise for any inconvenience caused to you, and if you have any questions please contact 1300 4 AVMED.
Aviation Medicine
Initial issue of class 1 medicals
Pilot must undergo all three stages of tests until a pass, as per Part 67. If all tests are failed, the class 1 certificate is refused.
Pilot must undergo all three stages of tests until a pass, as per Part 67. If all tests are failed, the class 1 certificate is refused.
Initial issue of class 1 medicals
A pilot must undergo all three stages of tests until a pass is achieved before a class 1 medical certificate can be issued in accordance with regulation 67.150 of the Civil Aviation Safety Regulations.
A pilot must undergo all three stages of tests until a pass is achieved before a class 1 medical certificate can be issued in accordance with regulation 67.150 of the Civil Aviation Safety Regulations.
Initial issue of class 1 medicals
Applicants for a Class 1 Medical Certificate must either satisfy the criteria specified in CASR 67.150, or be found by CASA not to pose a danger to safety on account of their CVD. To satisfy the requirements of CASR 67.150, the applicant must first attempt the Ishihara test. If they fail that test, they must then undertake the Farnsworth Lantern test. If the Farnsworth Lantern test is also failed a third level of test specified (for the individual case) by CASA must be undertaken. Failure of that third-level test may allow for the issue of a medical certificate if CASA finds that the applicant’s CVD does not pose a danger to safety. A Medical Certificate issued on this basis will be subject to certain limitations or restrictions.
Applicants for a Class 1 Medical Certificate must either satisfy the criteria specified in CASR 67.150, or be found by CASA not to pose a danger to safety on account of their CVD. To satisfy the requirements of CASR 67.150, the applicant must first attempt the Ishihara test. If they fail that test, they must then undertake the Farnsworth Lantern test. If the Farnsworth Lantern test is also failed a third level of test specified (for the individual case) by CASA must be undertaken. Failure of that third-level test may allow for the issue of a medical certificate if CASA finds that the applicant’s CVD does not pose a danger to safety. A Medical Certificate issued on this basis will be subject to certain limitations or restrictions.
Perhaps it's time for the PMO to resign and let someone else assume the role who can at least be consistent with their decisions? Perhaps someone who respects the advice of those who are more qualified and capable of making judgements?
McSherry and Civil Aviation Safety Authority [2014] AATA 119 (6 March 2014)
50. We note that in expressing that opinion, Associate Professor Navathe differed from both Associate Professor Ward and Dr McRae, each of whom regarded the risk of an incompletely incapacitating bleed causing problems for Mr McSherry whilst he was flying to be extremely small. Further, we do not consider this aspect of Associate Professor Navathe’s evidence to have been well-supported or well-reasoned and we formed the impression that this aspect of his evidence may well have been influenced by his desire to justify the decision he had made, to impose conditions on Mr McSherry’s class 1 medical certificate. We were also troubled by the significant differences between the opinions expressed in Associate Professor Navathe’s statement of 8 October 2013 on the one hand, and his oral evidence on the other.
56. The respondent’s decision of 6 August 2013 is set aside and in substitution for that decision it is decided that Mr McSherry is entitled to the issue of class 1 and class 2 medical certificates, without conditions.
50. We note that in expressing that opinion, Associate Professor Navathe differed from both Associate Professor Ward and Dr McRae, each of whom regarded the risk of an incompletely incapacitating bleed causing problems for Mr McSherry whilst he was flying to be extremely small. Further, we do not consider this aspect of Associate Professor Navathe’s evidence to have been well-supported or well-reasoned and we formed the impression that this aspect of his evidence may well have been influenced by his desire to justify the decision he had made, to impose conditions on Mr McSherry’s class 1 medical certificate. We were also troubled by the significant differences between the opinions expressed in Associate Professor Navathe’s statement of 8 October 2013 on the one hand, and his oral evidence on the other.
56. The respondent’s decision of 6 August 2013 is set aside and in substitution for that decision it is decided that Mr McSherry is entitled to the issue of class 1 and class 2 medical certificates, without conditions.
I see Senator Fawcett is asking the same question in a written QON published a few days ago:
273
244
CASA
FAWCETT
Cost of Investigations
1. What was the cost of the investigation ‘Antidepressant Usage and Civilian Aviation Activity in Australia 1993-2004’?
2. What has been the financial cost to CASA of the last five AAT Hearings in which CASA has been involved? Please provide the following:
a. Staff involved;
b. Number of witnesses called;
c. Length of time;
d. Legal fees;
244
CASA
FAWCETT
Cost of Investigations
1. What was the cost of the investigation ‘Antidepressant Usage and Civilian Aviation Activity in Australia 1993-2004’?
2. What has been the financial cost to CASA of the last five AAT Hearings in which CASA has been involved? Please provide the following:
a. Staff involved;
b. Number of witnesses called;
c. Length of time;
d. Legal fees;
The CAD Test does not "simulate" anything, much less an "operational situation" remotely connected to aviation. Therefore, the CAD Test is not a valid test for the purposes of CASR 67.160(6)(c).
The PMO needs to brush up on his comprehension skills and look up the words "simulate", "operational" and "situation" in the dictionary. The phrase "simulates an operational situation" has an obvious and uncontroversial meaning.
The PMO needs to brush up on his comprehension skills and look up the words "simulate", "operational" and "situation" in the dictionary. The phrase "simulates an operational situation" has an obvious and uncontroversial meaning.
CIVIL AVIATION LEGISLATION AMENDMENT REGULATION 2013 (NO. 1) - REG 61.010
"operational endorsement" means any of the following endorsements:
(a) an aerial application endorsement;
(b) a flight activity endorsement;
(c) a flight examiner endorsement;
(d) an instrument endorsement;
(e) a low-level endorsement;
(f) a night VFR endorsement;
(g) a night vision imaging system endorsement;
(h) a private instrument endorsement;
(i) a training endorsement;
(j) a flight engineer examiner endorsement;
(k) a flight engineer training endorsement.
"operational rating" means any of the following ratings:
(a) an aerial application rating;
(b) an examiner rating;
(c) an instructor rating;
(d) an instrument rating;
(e) a low-level rating;
(f) a night VFR rating;
(g) a night vision imaging system rating;
(h) a private instrument rating.
"simulated flight" time means time spent in a flight simulation training device during which a pilot is performing the duties of a pilot.
"simulated IMC" means flight in an aircraft or flight simulation training device during which the pilot is prevented from viewing the external horizon.
(a) an aerial application endorsement;
(b) a flight activity endorsement;
(c) a flight examiner endorsement;
(d) an instrument endorsement;
(e) a low-level endorsement;
(f) a night VFR endorsement;
(g) a night vision imaging system endorsement;
(h) a private instrument endorsement;
(i) a training endorsement;
(j) a flight engineer examiner endorsement;
(k) a flight engineer training endorsement.
"operational rating" means any of the following ratings:
(a) an aerial application rating;
(b) an examiner rating;
(c) an instructor rating;
(d) an instrument rating;
(e) a low-level rating;
(f) a night VFR rating;
(g) a night vision imaging system rating;
(h) a private instrument rating.
"simulated flight" time means time spent in a flight simulation training device during which a pilot is performing the duties of a pilot.
"simulated IMC" means flight in an aircraft or flight simulation training device during which the pilot is prevented from viewing the external horizon.
Why is it that CASA appears unwilling or unable to read and apply the law?
Today we have ... Applicants for a Class 1 Medical Certificate must either satisfy the criteria specified in CASR 67.150, or be found by CASA not to pose a danger to safety on account of their CVD.
The relevant requirement is not that the candidate "be found by CASA not to pose a danger to safety on account of their CVD."
The relevant requirement is, unsurprisingly, what the law says.
The law says the requirement is:
(e) either:
(i) the applicant meets the relevant medical standard; or
(ii) if the applicant does not meet that medical standard—the extent to which he or she does not meet the standard is not likely to endanger the safety of air navigation;
(i) the applicant meets the relevant medical standard; or
(ii) if the applicant does not meet that medical standard—the extent to which he or she does not meet the standard is not likely to endanger the safety of air navigation;
The requirement is not that the applicant "not pose a danger to safety". The requirement is that the applicant is "not likely to endanger" the safety of air navigation.
The test stated by CASA - "not pose" - is binary: Zero danger. The test stated in the law is a probability: "not likely". There is a profound difference.
Were CASA not blinded by prejudice, it would comprehend the reason for the requirement being a probability: Everyone and everything poses a danger to safety, but the probabilities and consequences are infinitely variable. The world is a dangerous place and life is full of risk. Witness the fact that most aviation accidents and incidents are caused by humans with perfect colour perception.
It's simple, CASA: Just apply and comply with the law in its terms.
Last edited by Creampuff; 2nd Aug 2014 at 22:06.
CVD ATC 1st cab off the rank, pilots next??
Trolling through (now ancient history) some of the submissions of the CAsA HREOC exemption application in 2002...
"...The Civil Aviation Safety Authority (CASA) applied on 29 July 2002 to the Human Rights and Equal Opportunity Commission for temporary exemption under the Sex Discrimination Act 1984 ("SDA"), section 44, and the Disability Discrimination Act 1992 ("DDA"), section 55, for persons acting pursuant to existing Civil Aviation Regulations regarding medical fitness and proposed amendments to those regulations..."
...some of which are very good and hold many similar arguments that the pilot CVD fraternity are currently putting forward and that Arthur successfully argued all those years ago...
A. Denman; W.Hamilton; Civil Air Association; Aircraft Owners and Pilots Association / Association of Women Pilots;
From CAA submission:
Alas it was all to no avail as the HRC in their wisdom granted CAsA an exemption for a period of five years...
I can only presume that in the interim period of the exemption (cause it is very hard to track) that FF then took it upon themselves to notify the only difference to the ICAO CVD SARP as such...
"...Para 6.2.4.4 Candidates for an air traffic controller licence who fail an Ishihara 24-plate test are, in practice, not employed by Australia’s ATS provider..."
...and if you read, in particular, the Denham & CAA submissions you will see that this strange (discriminatory for future ATC CVD applicants) ND is very much in keeping with the regs (CASR 67.150 & 67.160) as it still facilitates for those existing & identified ATC CVD officers.
However my questions are:
Is this ASA discriminatory ATC hiring policy still in place or are future ATC applicants with an identified CVD limited in scope of the roles they can perform??
Was the 2002 FF exemption application (approved for five years) all part of a GMP (Grand Master Plan) to bring us in line with the ICAO SARPs & therefore avoiding any possible future liability (liability paranoia strikes again)??
TA in advance...
"...The Civil Aviation Safety Authority (CASA) applied on 29 July 2002 to the Human Rights and Equal Opportunity Commission for temporary exemption under the Sex Discrimination Act 1984 ("SDA"), section 44, and the Disability Discrimination Act 1992 ("DDA"), section 55, for persons acting pursuant to existing Civil Aviation Regulations regarding medical fitness and proposed amendments to those regulations..."
...some of which are very good and hold many similar arguments that the pilot CVD fraternity are currently putting forward and that Arthur successfully argued all those years ago...
A. Denman; W.Hamilton; Civil Air Association; Aircraft Owners and Pilots Association / Association of Women Pilots;
From CAA submission:
Colour perception
3.37
Can readily distinguish the colours that need to be distinguished for the safe exercise of privileges, or performance of duties, under the relevant licence
Note For how to demonstrate this, see subregulation 67.160 (6).
There have not been any ATC performance issues, be they safety related or otherwise, to support these changes. The changes to the testing process for colour vision impaired people proposed by CASA are unnecessary and will certainly discriminate against current and future air traffic controllers with colour vision impairment.
Discrimination in employment is dealt with at section 15 of the DDA. At clause 4, it states,
“(4)Neither paragraph (1)(b) nor (2)(c) renders unlawful discrimination by an employer against a person on the ground of the person's disability, if taking into account the person's past training, qualifications and experience relevant to the particular employment and, if the person is already employed by the employer, the person's performance as an employee, and all other relevant factors that it is reasonable to take into account, the person because of his or her disability:
(a) would be unable to carry out the inherent requirements of the particular employment; or
(b) would, in order to carry out those requirements, require services or facilities that are not required by persons without the disability and the provision of which would impose an unjustifiable hardship on the employer.”
We stand on the evidence of past practice and performance of employees with colour vision impairment to illustrate that these people are able to carry out the inherent requirements of their particular employment and indicate that the test that allows them to do so, the Farnsworth lantern test, does not cause unjustifiable hardship to their employer, Airservices Australia. The tests for colour vision impairment are conducted once only as the condition of colour vision impairment never alters. As an alternative, all other Class 3 medical tests such as eyesight, audio, physical fitness, cholesterol level, diabetes, blood pressure must be conducted every two years because these results can change. Even accepting the proposition that the additional Farnsworth test is an expense, it not an ongoing expense and given the limited nature of the condition in males (8% or less), it is not required very often and if required would be conducted within the cost structures associated with normal biannual medical examination (at no additional cost).
To allow the exemption sought by the CASA would mean that colour vision impaired people would not be able to work as air traffic controllers despite no evidence that the condition prevents them from performing the inherent requirements of the their occupation and on that basis we submit that the exemption conflicts with the object of the DDA.
We note the findings of Mr. Barry L Cole AO, Professor of Optometry, Feb 1998, who prepared a report for Airservices Australia, “Colour Vision Standards for Air Traffic Controllers” the purpose of which was to advise, “whether or not the current Australian colour vision standards for air traffic controllers is appropriate for operation of the Thomson radar TAAATS air traffic management system”
He provided three options for Airservices Australia to consider for risk minimisation, and we quote these directly from his report,
“Option 1 – Exclude all persons with defective colour vision.
Exclude all persons with abnormal colour vision on the grounds that there is risk and that there is no present method of test that has been shown to differentiate from among those with mild deutronomaly which ones may be handicapped in the operation of modern ATC systems.
This option makes the presumption that the social and economic risks of air accident outweighs any social disadvantage arising from the exclusion of a further 3% of men from employment in ATC.
Mertens recommends this option and it is well supported by the evidence. It is an easy and inexpensive standard to administer. The high social and economic risks that could be associated with errors in air traffic control give further weight to the argument that all colour vision defectives should be excluded.
Option 2- Introduce a test of the ability to distinguish surface colours additional to the Lantern Test
Modify the existing standard in the following ways –
(b) ensure that the standard based on the Farnsworth lantern is administered rigorously without exception or waiver so that those who pass are the more mildly affected anomalous trichromats, and
(c) subject those who pass the Farnsworth lantern to further tests to-
(i) identify and exclude those who have a protan defect by testing using the locally available Medmont C100 test or by referral to a colour vision clinic for testing with an anomaloscope.
(ii) confirm (or otherwise) they have reasonable ability to distinguish surface colours. This can be done by administering and requiring a pass the Farnsworth Panel D15 test.
These changes to the colour vision standard will ensure that only those with mildly defective colour vision and who do not have a reduced ability to see red signals undertake ATC duties.
Option 3 - A practical test of performance with colour coded displays
A third option is to develop a practical test to establish whether or not a person with defective vision is able to carry out the task of air traffic control using colour coded graphics displays.
This option is an attractive one to those who are concerned that occupational health standards do not discriminate unfairly against people with disabilities. A practical test reassures those who are not convinced that presence of a disability in itself demonstrates that there will be reduced task performance.
This is a reasonable viewpoint: it is necessary to show that the presence of a defect will impede practical performance and, if it is not possible to do this, then a test to exclude people with a disability would be discriminatory.
However, in riposte, it can be said that the evidence supporting the view that defective colour vision is an impediment to satisfactory performance in tasks involving colour coding is quite compelling. This evidence has been summarised in the sections above. It can also be said that there is no experimental evidence to show that persons with defective colour vision do perform such tasks equally as well as those with normal colour vision. It is not as if there is a conflict of evidence, there is evidence that defective colour vision is a risk factor and no evidence that it is not.”
In his final recommendation, Cole proposed to exclude from ATC all people with defective colour vision as this would be the least expensive option and because of the risks associated with such people not properly recognizing colours. As an alternative, for people who had a very mild defect and may not have any trouble with ATC colour codes, he proposed that such people must pass the Farnsworth lantern test and also seek an optometrists opinion about whether they have a deutean defect or a protan defect. The suggestion here being, we believe, to exclude people with a protan defect.
For convenience we underlined the section in this report that shows how these tests can discriminate against people with disabilities. Cole identifies the option that contains no risk and least cost (Option 1) but also notes that, “it is necessary to show that the presence of a defect will impede practical performance and, if it is not possible to do this, then a test to exclude people with a disability would be discriminatory.”
On the basis of this material we submit that the case for the psuedoisochromatic test in isolation being fair or not discriminatory is undermined by Cole’s statements in the report provided to Airservices.
3.37
Can readily distinguish the colours that need to be distinguished for the safe exercise of privileges, or performance of duties, under the relevant licence
Note For how to demonstrate this, see subregulation 67.160 (6).
There have not been any ATC performance issues, be they safety related or otherwise, to support these changes. The changes to the testing process for colour vision impaired people proposed by CASA are unnecessary and will certainly discriminate against current and future air traffic controllers with colour vision impairment.
Discrimination in employment is dealt with at section 15 of the DDA. At clause 4, it states,
“(4)Neither paragraph (1)(b) nor (2)(c) renders unlawful discrimination by an employer against a person on the ground of the person's disability, if taking into account the person's past training, qualifications and experience relevant to the particular employment and, if the person is already employed by the employer, the person's performance as an employee, and all other relevant factors that it is reasonable to take into account, the person because of his or her disability:
(a) would be unable to carry out the inherent requirements of the particular employment; or
(b) would, in order to carry out those requirements, require services or facilities that are not required by persons without the disability and the provision of which would impose an unjustifiable hardship on the employer.”
We stand on the evidence of past practice and performance of employees with colour vision impairment to illustrate that these people are able to carry out the inherent requirements of their particular employment and indicate that the test that allows them to do so, the Farnsworth lantern test, does not cause unjustifiable hardship to their employer, Airservices Australia. The tests for colour vision impairment are conducted once only as the condition of colour vision impairment never alters. As an alternative, all other Class 3 medical tests such as eyesight, audio, physical fitness, cholesterol level, diabetes, blood pressure must be conducted every two years because these results can change. Even accepting the proposition that the additional Farnsworth test is an expense, it not an ongoing expense and given the limited nature of the condition in males (8% or less), it is not required very often and if required would be conducted within the cost structures associated with normal biannual medical examination (at no additional cost).
To allow the exemption sought by the CASA would mean that colour vision impaired people would not be able to work as air traffic controllers despite no evidence that the condition prevents them from performing the inherent requirements of the their occupation and on that basis we submit that the exemption conflicts with the object of the DDA.
We note the findings of Mr. Barry L Cole AO, Professor of Optometry, Feb 1998, who prepared a report for Airservices Australia, “Colour Vision Standards for Air Traffic Controllers” the purpose of which was to advise, “whether or not the current Australian colour vision standards for air traffic controllers is appropriate for operation of the Thomson radar TAAATS air traffic management system”
He provided three options for Airservices Australia to consider for risk minimisation, and we quote these directly from his report,
“Option 1 – Exclude all persons with defective colour vision.
Exclude all persons with abnormal colour vision on the grounds that there is risk and that there is no present method of test that has been shown to differentiate from among those with mild deutronomaly which ones may be handicapped in the operation of modern ATC systems.
This option makes the presumption that the social and economic risks of air accident outweighs any social disadvantage arising from the exclusion of a further 3% of men from employment in ATC.
Mertens recommends this option and it is well supported by the evidence. It is an easy and inexpensive standard to administer. The high social and economic risks that could be associated with errors in air traffic control give further weight to the argument that all colour vision defectives should be excluded.
Option 2- Introduce a test of the ability to distinguish surface colours additional to the Lantern Test
Modify the existing standard in the following ways –
(b) ensure that the standard based on the Farnsworth lantern is administered rigorously without exception or waiver so that those who pass are the more mildly affected anomalous trichromats, and
(c) subject those who pass the Farnsworth lantern to further tests to-
(i) identify and exclude those who have a protan defect by testing using the locally available Medmont C100 test or by referral to a colour vision clinic for testing with an anomaloscope.
(ii) confirm (or otherwise) they have reasonable ability to distinguish surface colours. This can be done by administering and requiring a pass the Farnsworth Panel D15 test.
These changes to the colour vision standard will ensure that only those with mildly defective colour vision and who do not have a reduced ability to see red signals undertake ATC duties.
Option 3 - A practical test of performance with colour coded displays
A third option is to develop a practical test to establish whether or not a person with defective vision is able to carry out the task of air traffic control using colour coded graphics displays.
This option is an attractive one to those who are concerned that occupational health standards do not discriminate unfairly against people with disabilities. A practical test reassures those who are not convinced that presence of a disability in itself demonstrates that there will be reduced task performance.
This is a reasonable viewpoint: it is necessary to show that the presence of a defect will impede practical performance and, if it is not possible to do this, then a test to exclude people with a disability would be discriminatory.
However, in riposte, it can be said that the evidence supporting the view that defective colour vision is an impediment to satisfactory performance in tasks involving colour coding is quite compelling. This evidence has been summarised in the sections above. It can also be said that there is no experimental evidence to show that persons with defective colour vision do perform such tasks equally as well as those with normal colour vision. It is not as if there is a conflict of evidence, there is evidence that defective colour vision is a risk factor and no evidence that it is not.”
In his final recommendation, Cole proposed to exclude from ATC all people with defective colour vision as this would be the least expensive option and because of the risks associated with such people not properly recognizing colours. As an alternative, for people who had a very mild defect and may not have any trouble with ATC colour codes, he proposed that such people must pass the Farnsworth lantern test and also seek an optometrists opinion about whether they have a deutean defect or a protan defect. The suggestion here being, we believe, to exclude people with a protan defect.
For convenience we underlined the section in this report that shows how these tests can discriminate against people with disabilities. Cole identifies the option that contains no risk and least cost (Option 1) but also notes that, “it is necessary to show that the presence of a defect will impede practical performance and, if it is not possible to do this, then a test to exclude people with a disability would be discriminatory.”
On the basis of this material we submit that the case for the psuedoisochromatic test in isolation being fair or not discriminatory is undermined by Cole’s statements in the report provided to Airservices.
Decision of the Commission
The Commission grants a conditional exemption from sections 19 and 29 of the DDA, and from sections 18 and 26 of the SDA, to persons acting pursuant to existing Civil Aviation Regulations regarding medical fitness, or pursuant to currently proposed amendments to those regulations.
The exemption is subject to the following conditions.
1. The exemptions commence on 26 November 2002 and expire on 26 November 2007.
2. The exemptions are to apply only where a person's pregnancy (for the purposes of the SDA) or disability (for the purposes of the DDA) prevents the person safely fulfilling the inherent requirements of the role covered by the licence concerned.
The Commission grants a conditional exemption from sections 19 and 29 of the DDA, and from sections 18 and 26 of the SDA, to persons acting pursuant to existing Civil Aviation Regulations regarding medical fitness, or pursuant to currently proposed amendments to those regulations.
The exemption is subject to the following conditions.
1. The exemptions commence on 26 November 2002 and expire on 26 November 2007.
2. The exemptions are to apply only where a person's pregnancy (for the purposes of the SDA) or disability (for the purposes of the DDA) prevents the person safely fulfilling the inherent requirements of the role covered by the licence concerned.
"...Para 6.2.4.4 Candidates for an air traffic controller licence who fail an Ishihara 24-plate test are, in practice, not employed by Australia’s ATS provider..."
...and if you read, in particular, the Denham & CAA submissions you will see that this strange (discriminatory for future ATC CVD applicants) ND is very much in keeping with the regs (CASR 67.150 & 67.160) as it still facilitates for those existing & identified ATC CVD officers.
However my questions are:
Is this ASA discriminatory ATC hiring policy still in place or are future ATC applicants with an identified CVD limited in scope of the roles they can perform??
Was the 2002 FF exemption application (approved for five years) all part of a GMP (Grand Master Plan) to bring us in line with the ICAO SARPs & therefore avoiding any possible future liability (liability paranoia strikes again)??
TA in advance...
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The thing I don't get.
Is how, disability and discrimination law can be used to effectively discriminate against folks – by an exemption against the law which prohibits it?? The AOPA and WPA argument made by Marjorie Pagani (Hi Damon) makes excellent sense and supports Creampuff's stance. The ATCO union made equally as much sense; of course, now the expired exemption has been cast in stone as "policy" and just not challenged; perhaps these groups need to look once again to their armour to protect their digs – being as it's come now to the pilots turn to be the thin end of the wedge. Liability paranoia – writ large...
The other submissions provided by Sarcs are equally compelling; perhaps it's just me being 'thick' but really, from where is the PonyPooh-Shambollic argument going to find some serviceable legs – in law – without that champion of law benders prepared to lend them the tools to do it.
The tick stopped tocking a number of years ago on the discrimination waiver; perhaps this is a heroic attempt to wind it up; it's certainly winding up everyone else's.
What say you Maestro Creampuff.
Hesitant Toot – with a slightly bemused second - toot.
Pagani
a. The bases upon which it is based are fundamentally flawed;
b. It is anathema to the concept of protection of fundamental human rights to grant a “temporary” exemption for five years (or at all) for exemption from human rights legislation, so as to enable the applicant (the Civil Aviation Safety Authority, referred to as the CASA) time within which to attempt to persuade the parliament to amend the existing legislation (Civil Aviation Act) to exclude the human rights legislation;
c. The application, and proposed regulations, would have the combined effect of reversing the onus of proof from the authority seeking to discriminate, to the person against whom the discriminatory conduct has been directed.
The CASA (and former authorities differently named and constituted) has therefore had, respectively, fourteen years and ten years to take steps to have the CAA amended in order to protect it from suits brought pursuant to the human rights legislation. The CASA now and proposes further regulatory frameworks which it is concerned may offend the human rights legislation. The proposed regulations have been extant for more than four years, and contain some provisions which mirror those in the existing regulations.
The CASA alleges that it has “initiated action” to have the relevant section of the CAA amended so as to enable it to make the proposed regulations with impunity, so far as the human rights legislation is concerned. The submission made is vague in the extreme. No information is provided as to what steps have been taken, when they have been taken, what stage the action has reached, and importantly, when the debate is likely to occur. Indeed, the applicant merely submits that it “cannot..say what the time frame is for this amendment to be enacted.” The application appears to be brought for the purpose of buying an indefinite period of time within which to persuade parliament to enact legislation which would prevail over the human rights legislation.
The application is not consistent with the objects of the relevant human rights legislation. The effect of the proposed legislation and exemption will be to promote, rather than eliminate, discrimination, in circumstances where the affected person must have the financial and emotional resources to challenge the discriminatory act which has been carried out without regard to the individual circumstances of that affected person. A statutorily-imposed right to discriminate should only be permitted in the most extreme circumstances, and where no other course is possible. This is not the case in the present application, and it is submitted that there has been presented no evidence of such a nature as would permit a finding that the CASA would be compelled to do the proposed discriminatory acts for the purposes of aviation safety or consistency with other States.
The legislation seeks to eliminate discrimination where possible. The exemption sought seeks to permit mandatory discrimination with impunity against redress by the affected person.
a. The bases upon which it is based are fundamentally flawed;
b. It is anathema to the concept of protection of fundamental human rights to grant a “temporary” exemption for five years (or at all) for exemption from human rights legislation, so as to enable the applicant (the Civil Aviation Safety Authority, referred to as the CASA) time within which to attempt to persuade the parliament to amend the existing legislation (Civil Aviation Act) to exclude the human rights legislation;
c. The application, and proposed regulations, would have the combined effect of reversing the onus of proof from the authority seeking to discriminate, to the person against whom the discriminatory conduct has been directed.
The CASA (and former authorities differently named and constituted) has therefore had, respectively, fourteen years and ten years to take steps to have the CAA amended in order to protect it from suits brought pursuant to the human rights legislation. The CASA now and proposes further regulatory frameworks which it is concerned may offend the human rights legislation. The proposed regulations have been extant for more than four years, and contain some provisions which mirror those in the existing regulations.
The CASA alleges that it has “initiated action” to have the relevant section of the CAA amended so as to enable it to make the proposed regulations with impunity, so far as the human rights legislation is concerned. The submission made is vague in the extreme. No information is provided as to what steps have been taken, when they have been taken, what stage the action has reached, and importantly, when the debate is likely to occur. Indeed, the applicant merely submits that it “cannot..say what the time frame is for this amendment to be enacted.” The application appears to be brought for the purpose of buying an indefinite period of time within which to persuade parliament to enact legislation which would prevail over the human rights legislation.
The application is not consistent with the objects of the relevant human rights legislation. The effect of the proposed legislation and exemption will be to promote, rather than eliminate, discrimination, in circumstances where the affected person must have the financial and emotional resources to challenge the discriminatory act which has been carried out without regard to the individual circumstances of that affected person. A statutorily-imposed right to discriminate should only be permitted in the most extreme circumstances, and where no other course is possible. This is not the case in the present application, and it is submitted that there has been presented no evidence of such a nature as would permit a finding that the CASA would be compelled to do the proposed discriminatory acts for the purposes of aviation safety or consistency with other States.
The legislation seeks to eliminate discrimination where possible. The exemption sought seeks to permit mandatory discrimination with impunity against redress by the affected person.
Civil Air.
Civil Air seeks that the application by CASA for exemption from the DDA and the SDA be refused on the basis that the changes proposed by CASA to Part 6 of the Civil Aviation Medical Standards would be in conflict with the objects of the Disability Discrimination Act and Sex Discrimination Act. Those objects in essence seek to eliminate discrimination on the basis of disability or gender. Our interest in this issue applies to discrimination in the workplace.
In relation to the changes proposed by CASA to alter the testing regime for class 3 medical holders with colour defective vision (67.160(6) and (7)); we are aware of operational air traffic controllers who are working despite their colour vision impairment. These people have been employed by Airservices for significant periods of time and their length of employment combined with an absence of any evidence of identified problems in performance suggests that these individuals are most able to carry out the ‘inherent requirements’ of their particular employment. This continues to be the case in the current Australian Advanced Air Traffic System (“TAAATS”) environment where the colour palette is certainly diversified. TAAATS has been operational since 1999. The condition has not to date been safety relevant in any way.
Civil Air seeks that the application by CASA for exemption from the DDA and the SDA be refused on the basis that the changes proposed by CASA to Part 6 of the Civil Aviation Medical Standards would be in conflict with the objects of the Disability Discrimination Act and Sex Discrimination Act. Those objects in essence seek to eliminate discrimination on the basis of disability or gender. Our interest in this issue applies to discrimination in the workplace.
In relation to the changes proposed by CASA to alter the testing regime for class 3 medical holders with colour defective vision (67.160(6) and (7)); we are aware of operational air traffic controllers who are working despite their colour vision impairment. These people have been employed by Airservices for significant periods of time and their length of employment combined with an absence of any evidence of identified problems in performance suggests that these individuals are most able to carry out the ‘inherent requirements’ of their particular employment. This continues to be the case in the current Australian Advanced Air Traffic System (“TAAATS”) environment where the colour palette is certainly diversified. TAAATS has been operational since 1999. The condition has not to date been safety relevant in any way.
The tick stopped tocking a number of years ago on the discrimination waiver; perhaps this is a heroic attempt to wind it up; it's certainly winding up everyone else's.
What say you Maestro Creampuff.
Hesitant Toot – with a slightly bemused second - toot.
Again, and unsurprisingly, it all depends on the evidence, and the weight to be attributed to that evidence.
You will see in the extracts copied by Sarcs above, extracts from a report to Airservices by a "Mr. Barry L Cole AO, Professor of Optometry". His report said, among other things:
If what Mr Cole's report said about the "evidence" were an accurate representation of peer-reviewed, statistically-valid and otherwise properly-conducted studies of practical performance of real life tasks, there would be no argument and no one with a colour vision deficiency would be an ATPL or ATCer.
(Setting aside, for the moment, the inconvenient reality of the safety record of pilots with CVD...) The fundamental flaw in all the reasoning I've seen in reports like Mr Coles' is to conflate "practical performance" with the results of tests that are "tasks involving colour coding". Precisely the same conflation is happening now in AVMED, where someone seems to think that the CAD test simulates and operational situation.
Everyone knows that people with a colour vision deficiency are not going to perform as well as persons without colour vision deficiency in tests that are "tasks involving colour coding". Message to AVMED: WE GET IT. We already know that pilots with a colour vision deficiency have a colour vision deficiency. That deficiency was discovered during tests that are tasks involving colour coding. The Ishihara test is a task involving colour coding: Read the numbers on these pages. But the Ishara test does not simulate an operational situation. Nor does the CAD test.
If you want to test "practical performance", do what the law requires and set a test that simulates an operational situation. If you really want to serve the interests of safety, rather than hide behind safety rhetoric, set a test that simulates the most important safety-critical task that has to be performed, in reality, by a pilot (or, for ATCers, by an ATCer), that requires the identification of coloured lights. And, if you want to pass the test of objectivity rather than blind prejudice, make sure the simulation does not include any failures or characteristics that are never encountered in real life.
You will see in the extracts copied by Sarcs above, extracts from a report to Airservices by a "Mr. Barry L Cole AO, Professor of Optometry". His report said, among other things:
[I]t is necessary to show that the presence of a defect will impede practical performance and, if it is not possible to do this, then a test to exclude people with a disability would be discriminatory.
However, in riposte, it can be said that the evidence supporting the view that defective colour vision is an impediment to satisfactory performance in tasks involving colour coding is quite compelling. This evidence has been summarised in the sections above. It can also be said that there is no experimental evidence to show that persons with defective colour vision do perform such tasks equally as well as those with normal colour vision. It is not as if there is a conflict of evidence, there is evidence that defective colour vision is a risk factor and no evidence that it is not.
However, in riposte, it can be said that the evidence supporting the view that defective colour vision is an impediment to satisfactory performance in tasks involving colour coding is quite compelling. This evidence has been summarised in the sections above. It can also be said that there is no experimental evidence to show that persons with defective colour vision do perform such tasks equally as well as those with normal colour vision. It is not as if there is a conflict of evidence, there is evidence that defective colour vision is a risk factor and no evidence that it is not.
(Setting aside, for the moment, the inconvenient reality of the safety record of pilots with CVD...) The fundamental flaw in all the reasoning I've seen in reports like Mr Coles' is to conflate "practical performance" with the results of tests that are "tasks involving colour coding". Precisely the same conflation is happening now in AVMED, where someone seems to think that the CAD test simulates and operational situation.
Everyone knows that people with a colour vision deficiency are not going to perform as well as persons without colour vision deficiency in tests that are "tasks involving colour coding". Message to AVMED: WE GET IT. We already know that pilots with a colour vision deficiency have a colour vision deficiency. That deficiency was discovered during tests that are tasks involving colour coding. The Ishihara test is a task involving colour coding: Read the numbers on these pages. But the Ishara test does not simulate an operational situation. Nor does the CAD test.
If you want to test "practical performance", do what the law requires and set a test that simulates an operational situation. If you really want to serve the interests of safety, rather than hide behind safety rhetoric, set a test that simulates the most important safety-critical task that has to be performed, in reality, by a pilot (or, for ATCers, by an ATCer), that requires the identification of coloured lights. And, if you want to pass the test of objectivity rather than blind prejudice, make sure the simulation does not include any failures or characteristics that are never encountered in real life.
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I'll assume, because nobody has said otherwise, that the 5 year exemption expired on 26NOV07.
Doesn't this then, leave CAsA now open to investigation by that Anti-Discrimination Board under their Act. An option to those who have been discriminated against not previously available?
Doesn't this then, leave CAsA now open to investigation by that Anti-Discrimination Board under their Act. An option to those who have been discriminated against not previously available?
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Who wants to take a bet on who'll be next on Pooshan's hitlist once he's done with CVD pilots?
Bolding is mine.
All-Female Aircrews
Bolding is mine.
All-Female Aircrews
All-Female Aircrews
[email protected] wrote:
It has come to my attention that one of the C-130 flying units had an interesting decision recently. As the schedulers of the different departments sent names to the central scheduler, it became apparent that a particular mission was to be flown by a crew of women. All five crew positions would have been female. The commander chose to not authorize this roster, and requested that a male replace one of the women. His rationale, as I am told, is that had the crew become involved in a "mishap", the investigation might have asked him why he authorized an "all-female" crew, even though each were current and qualified in their respective positions.
This begs me to ask, are any other flying organizations concerned about an "all-female" flight crew? Does this ever happen, without any intrepedation?
Has there been any research into the "effectiveness and efficiency" of an all-female crew, compared to the traditional all-male, compared to a mixed-gender crew?
Greg Deen
Raytheon
Subj: [crm-devel] Re: All-female crewsDate: 3/16/99 11:59:45 PM Central Standard TimeFrom: [email protected] (Pooshan D Navathe MD)
This issue had come up for discussion among flight schedulers for transport crews. The dates of the menstrual periods come under part of private information. Since it is known that women may not be at their best just prior to menstruation, will it be safe to fly an all women crew who are all premenstrual? Who should check that? How? These are the problems faced, and the simple solution is to have a male member in the crew.
Any comments?
Pooshan
Wg Cdr Pooshan D Navathe B Ed, MBBS, M D (Aerospace Med), DipAvMed (USA), FaeMSAssociate Professor (Aerospace Medicine)Field Aerospace Medical Research and Indoctrination Cell (FAMRIC)
Air Force Station, Lohegaon, Pune, 411 032 India
Tele 91 20 685312 Extn 2315 (O) Extn 2393 (H)
91 20 691256 (H)
Email [email protected]
[email protected]
[email protected] wrote:
It has come to my attention that one of the C-130 flying units had an interesting decision recently. As the schedulers of the different departments sent names to the central scheduler, it became apparent that a particular mission was to be flown by a crew of women. All five crew positions would have been female. The commander chose to not authorize this roster, and requested that a male replace one of the women. His rationale, as I am told, is that had the crew become involved in a "mishap", the investigation might have asked him why he authorized an "all-female" crew, even though each were current and qualified in their respective positions.
This begs me to ask, are any other flying organizations concerned about an "all-female" flight crew? Does this ever happen, without any intrepedation?
Has there been any research into the "effectiveness and efficiency" of an all-female crew, compared to the traditional all-male, compared to a mixed-gender crew?
Greg Deen
Raytheon
Subj: [crm-devel] Re: All-female crewsDate: 3/16/99 11:59:45 PM Central Standard TimeFrom: [email protected] (Pooshan D Navathe MD)
This issue had come up for discussion among flight schedulers for transport crews. The dates of the menstrual periods come under part of private information. Since it is known that women may not be at their best just prior to menstruation, will it be safe to fly an all women crew who are all premenstrual? Who should check that? How? These are the problems faced, and the simple solution is to have a male member in the crew.
Any comments?
Pooshan
Wg Cdr Pooshan D Navathe B Ed, MBBS, M D (Aerospace Med), DipAvMed (USA), FaeMSAssociate Professor (Aerospace Medicine)Field Aerospace Medical Research and Indoctrination Cell (FAMRIC)
Air Force Station, Lohegaon, Pune, 411 032 India
Tele 91 20 685312 Extn 2315 (O) Extn 2393 (H)
91 20 691256 (H)
Email [email protected]
[email protected]
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The core problem that Wing Commander(retired) Poohsan Navathe has is that civilian and private aviation is not the military.
the core driving motivations that lead to non military aviation are so entirely different that a military mind just cannot understand them.
the Australian government however places great store in placing military aviators in positions of control over civilians. THIS WILL NEVER WORK.
to the ex-military civilian aviation must seem like herding cats.
the problem being that the military mind is incapable of understanding the activity.
the military and legal minds to date have blown 300 million dollars thereabouts trying to create a set of rules.
problem is that interesting novels get the business done in about 200 pages.
no one is ever going to read reams and reams of boring procedural nonsense which in all honesty don't relate to the actual activities of flying.
minister you really need a royal commission into all this.
it will uncover just how at odds to reality the military educated mindset is.
it will uncover just how poorly the whole model of certified approvals actually works.
it will uncover the desperate levels of corrupt behaviour that military minds stoop to when they are out of their favoured environments.
be aware as well that a royal commission would show in glaring detail just how moronically stupid you are in perpetuating all this pony poo.
the core driving motivations that lead to non military aviation are so entirely different that a military mind just cannot understand them.
the Australian government however places great store in placing military aviators in positions of control over civilians. THIS WILL NEVER WORK.
to the ex-military civilian aviation must seem like herding cats.
the problem being that the military mind is incapable of understanding the activity.
the military and legal minds to date have blown 300 million dollars thereabouts trying to create a set of rules.
problem is that interesting novels get the business done in about 200 pages.
no one is ever going to read reams and reams of boring procedural nonsense which in all honesty don't relate to the actual activities of flying.
minister you really need a royal commission into all this.
it will uncover just how at odds to reality the military educated mindset is.
it will uncover just how poorly the whole model of certified approvals actually works.
it will uncover the desperate levels of corrupt behaviour that military minds stoop to when they are out of their favoured environments.
be aware as well that a royal commission would show in glaring detail just how moronically stupid you are in perpetuating all this pony poo.
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UX2.8,
What you said,
And!!!
I heard during desert storm the Yanks sent as many premenstrual women they could find to the front because they were as aggressive as hell and retained water!
What you said,
And!!!
I heard during desert storm the Yanks sent as many premenstrual women they could find to the front because they were as aggressive as hell and retained water!
If CASA complied with the law and, in accordance with CASR 67.150(6)(c), determined tests that "simulate operational situations", a claim of discrimination would not have to be pursued.
A claim of discrimination might be worth it if CASA determined tests that simulated operational situations, but included, for the purposes of 'tripping up' pilots with CVD, failures or characteristics that are never encountered in real life.
A claim of discrimination might also be worth it if, in deciding whether the extent to which a candidate does not meet the medical standard is not likely to endanger the safety of air navigation for the purposes of CASR 67.180(2)(e), CASA simply said "you're CVD so you're a danger".
But if it were me, I'd be pursuing the AAT route (the AAT has power to issue medical certificates and remove conditions on medical certificates) and, if unavoidably necessary, the Federal Court, to get a declaration that the CAD test, and anything else that's merely a colour vision test rather that a proper simulation of an operational situation, is not a lawful test for the purposes of CASR 67.150(6)(c).
A claim of discrimination might be worth it if CASA determined tests that simulated operational situations, but included, for the purposes of 'tripping up' pilots with CVD, failures or characteristics that are never encountered in real life.
A claim of discrimination might also be worth it if, in deciding whether the extent to which a candidate does not meet the medical standard is not likely to endanger the safety of air navigation for the purposes of CASR 67.180(2)(e), CASA simply said "you're CVD so you're a danger".
But if it were me, I'd be pursuing the AAT route (the AAT has power to issue medical certificates and remove conditions on medical certificates) and, if unavoidably necessary, the Federal Court, to get a declaration that the CAD test, and anything else that's merely a colour vision test rather that a proper simulation of an operational situation, is not a lawful test for the purposes of CASR 67.150(6)(c).
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Sorry, no link, not a subscriber but the Australian Aviation magazine has a great article, "Tone deaf and Colour Blind". It runs to almost three very nicely crafted pages, tongue in and cheeky on occasion but, on the money.
I understand that it is considered good 'advertising' to have articles published on sites such as Pprune; BUT I understand that permission (PPR) from AA is required, perhaps someone with a subscription could 'ask'. The author is Michael Gisik – HERE – is a link to their website; if you can scrounge a read, do so – most refreshing. Recommended reading.
Toot toot..
I understand that it is considered good 'advertising' to have articles published on sites such as Pprune; BUT I understand that permission (PPR) from AA is required, perhaps someone with a subscription could 'ask'. The author is Michael Gisik – HERE – is a link to their website; if you can scrounge a read, do so – most refreshing. Recommended reading.
Toot toot..