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Class 5 Self certified medical for PPL

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Old 21st Jun 2023, 06:42
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Class 5 Self certified medical for PPL

Ben Morgan from AOPA has just reported that the technical working group today is being pressured to agree to a 2000kg MTOW limit, and he was silenced when he objected.
He is seven levels beyond livid. And rightly so.
see AOPA Facebook feed.
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Old 21st Jun 2023, 07:25
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Watched the video, wow. He also just described what it is like to work for CASA.
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Old 21st Jun 2023, 07:54
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What limit are they asking for? None?
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Old 21st Jun 2023, 08:29
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Maybe time for a Royal Commission into CASA and how they operate.
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Old 21st Jun 2023, 09:05
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What does 2000kg have to do with anything, and why would flying a Baron vs a Bonanza be any different risk wise all things considered. More stress flying a single over terrain you could have taken a twin for, leads to a heart attack.... There's a lot of high workload aircraft you can get into stressful situations much faster that are less than 2000kg. Just make the limit certified max 6 seats.
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Old 21st Jun 2023, 09:39
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CASA should be able to provide the evidence of the risk and cost consequence basis for the rules and limitations it proposes to impose.

Let’s call aviation medical standards and related operational limitations for what they are, like any other rules: The outcome of power/opinion struggles inside bureaucracies and politics.

BasicMed in the USA imposes a 6,000 lb (close enough to 2,700 kg) MTOW limit and maximum certified POB limit of 6. UK imposes 5,700 kg and a 4 POB limit on ‘self declaration’ operations, even if the aircraft is certified to carry more than 4 POB. Those differing outcomes are not the outcome of cold, hard analysis of objective evidence.

In the USA, BasicMed is the product of a law passed by the US Congress. It enacted the FAA Extension, Safety, and Security Act of 2016 (PL 114-190) (FESSA) on July 15, 2016. Section 2307 of FESSA, Medical Certification of Certain Small Aircraft Pilots, directed the FAA to “issue or revise regulations to ensure that an individual may operate as pilot in command of a covered aircraft” if the pilot and aircraft meet certain prescribed conditions as outlined in FESSA. The FAA then had an internal power/opinion struggle to make the rules to give minimum effect to that direction. There remains a (legitimate) debate about whether US BasicMed as grudgingly implemented by the FAA is the messiah or merely a naughty boy held up as the messiah.

The differing approaches to colour division deficiency across civil aviation regulators isn’t the consequence of different colours being used to mean different things in civil aircraft operations in different jurisdictions, giving rise to different risks. The objective risks and consequences of colour vision deficiency are the same, everywhere, in civil aviation. But the outcome of power/opinion struggles inside bureaucracies and politics result in the differing approaches.

Gender, homosexuality, race, religion … We’ve seen it all before and it will never change while humans are humans. There’ll always be a bunch of zealots, supported by a groundswell of credulous public opinion, creating or exaggerating some awful (usually prejudice-based) risk to justify intervention, restriction and ultimately extermination at the whim of bureaucratic opinion. Unfortunately, the mystique of aviation means that aviation regulators get away with some of the particularly egregious examples of it.
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Old 22nd Jun 2023, 08:15
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The US and UK options are at least workable to fly reasonable light twins, which affords extra piece of mind, safety, and lower stress in some situations. 2000kg you can't even fly a Seneca, so stacking 6 pob into heavy singles is the only way you'd get 6 on board anyway. 2700kg allows actual 6 seater, and more capable 4 seaters. I don't think you need to go all the way to 5700kg, but definitely closer to 3000kg would be the right area.
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Old 22nd Jun 2023, 08:52
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But then you get back to Ben’s point. Why not 5700kg? Why set an arbitrary limit at 3000kg? Even 5700kg is an arbitrary limit.

What does weight have to do with it? A PBY Catalina weighs about 12t normally. Ive flown one on a Class2 medical PPL. Whats the risk if I only have a Class5? Another of Bens points, you either have been taught to fly that particular aircraft competently or you havent. Your medical status has very little to do with it

Surely we’d get further if we could identify what risk we are trying to mitigate? Maybe we need to focus on types of operation rather than weight? This was also Bens point. CASA advertise themselves as a risk based regulator, yet they cannot articulate the risk they are mitigating against in the medical reform.
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Old 22nd Jun 2023, 09:55
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I think it's pretty obvious why the limit, the bigger it is the more damage it will cause on the ground should you incapacitate. Even truck drivers have higher standards for medical than the ordinary driver for the same reason, and dangerous goods drivers higher again.

If you crash a Warrior into a house it is much the same result as a car doing the same at speed, that applies up to about Baron/Seneca size. Beyond that the aircraft get significantly more able to both do significant impact and fire damage due to fuel loads.

In the past weight limits usually were set around allowing a particular type as the maximum, 3500kg allowing Navajos and Cessna 400 series. 5700kg/12,500lb was roughly half a DC-3 which was considered what would be the reasonable upper limit for a light/personal aircraft, set long before the big piston twins and such came about. The reason I understand for the 12,500lb was to protect airline operators which were using mostly DC-3s at the time, and by restricting other aircraft to half of ones weight below that placed a protection on the amount of passengers a smaller operation could carry. That then place protectionist rules for airlines to operate safely and at profit, or something along those lines.

Last edited by 43Inches; 22nd Jun 2023 at 10:11.
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Old 22nd Jun 2023, 11:47
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Im not arguing against limit. But if we are going to apply one lets make sure we all understand why.

I liked your examples. The truck driver examples apply a higher medical standard for the operation they undertake. Not necessarily the weight of the truck.

Seems logical that we would consider something similar for aviation?
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Old 22nd Jun 2023, 22:16
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Let’s assume there must be a POB and MTOW and other limits ‘linked’ with compliance with differing medical standards. The paradigm problem is that Avmed is not competent to make the decision as to where those limits are set. Avmed is competent only to express an opinion as to the risks and consequences, for an individual, of various medical conditions. For example, individuals who are blind are not able to… Individuals with this condition are at X% risk of sudden incapacitation.

It is axiomatic that, for example, the sudden incapacitation of a pilot will put at dire risk the 2 POB on board an aircraft with a maximum seating capacity of 2, the 4 POB on board an aircraft with a maximum seating capacity of 4, the 6 POB on board an aircraft with a maximum seating capacity of 6 and so on. Ditto for the potential damage done by steadily increasing MTOW of the aircraft being flown.

But there is no medical literature which ‘plots’ the varying levels of the risk of a pilot’s sudden incapacitation against the numbers of persons and the value of the property put at risk by that sudden incapacitation. CASA Avmed has no expertise and no qualifications to decide that 2 but not 4 people should be put at risk by medical condition X.

And let’s consider those very large trucks and buses the sudden incapacitation of the drivers of which will put ‘lots’ of people and property at risk. Strangely, they’re all sharing the highways in close proximity to vehicles whose drivers don’t meet the truck / bus driver medical standard and could bring the adjacent truck or bus undone with the next munch on a fat burger. And so it is aviation. Somehow it’s not ‘safe’ for a pilot without a CASA-issued medical certificate to fly an aircraft over 760kgs or with any passengers, but it is ‘safe’ for that pilot to share the circuit and the airspace in the vicinity of an aerodrome in 'G' with a 737 full of passengers.

The whole Part 67 ‘review’ and TWG process is fundamentally misguided. There’ll be a bunch of high-sounding rhetoric, the output of which will be the usual intuition-driven, cognitive bias-driven and interest group-influenced illogical mish-mash. That’s why there are substantially differing medical standards and operational limits applied in like aviation circumstances across the world. The worst examples are in countries whose governments leave their Avmed branches to their own devices.
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