Published responses to CASA's aviation medicals discussion paper (DP) are overwhelmingly in favour of adopting a self-certifying regime such as those recently adopted in the UK and USA.
CASA released the DP in December 2016, with a closing date for submissions of 30 March 2017. Submissions approved for publication were put up on the CASA website on Monday, which made up less than half of those that CASA actually received.
Many submissions contained personal medical cases that people wanted addressed, and others put forward alternative views for aviation medicals, or simply supported the Aircraft Owners and Pilots Association (AOPA) policy.
And it was not only pilots who supported self-certification; some Designated Aviation Medical Examiners (DAME) also saw it as the best way forward.
Respected DAME Dr Tony Van Der Spek pointed out that international aviation regulators had seen fit to relax medical rules, and that Australia should follow suit.
"The risk assessment procedures used by overseas regulators are very appropriate for Australian pilots and conditions," he said. "Are Australian pilots much more of a risk than their overseas counterparts? After all we fly in much less crowded airspace and we have much more benign flying conditions generally."
And it seems DAMEs are just as frustrated with CASA's Aviation Medical (AVMED) division as the pilots are.
"DAMEs bear the brunt of dissatisfaction with handling of Aviation Medicine Certification," Associate Professor Chris Andrews said. "I spend as much time answering phone calls and emails of dismayed pilots as I do in performing the assessment. I see it as a task of mine to assist pilots negotiate the AVMED system, which speaks to the implication that much is done and adopted by AVMED in a non-transparent and misunderstood, if not unreasonable, way.
"Criteria for assessing conditions are decided and not communicated – even on occasions to DAMEs, and certainly not to pilots. DAMEs are therefore somewhat in the dark, and cannot provide definitive answers to dismayed pilots.
"AVMED has lost a view of its role – AVMED is to determine the health of a candidate from a DAME interview and examination. It is not for, and has no mandate for, dictating the management of a candidate, and directions to treating practitioners in this unethical way in the guise of health promotion."
The Australian Helicopter Industry Association (AHIA) said in their submission that medical standards needed to be more appropriate to the class of operation than the current regime.
"AHIA does not support the 'one standard suits all' approach to medical certifications and believes the current system of three classes does not align with complexity of the various types of aviation activity," their submission stated. "Grouping high-volume airline passenger operations with low-volume VFR helicopter operations can eliminate some individuals who would otherwise be suitable and also makes accessing the relevant medical professionals difficult and expensive.
"AHIA would support the current Class 2 medical certification standards being applied to single engine VFR operations below 5700 kg MTOW and a higher standard for operations involving twin engine, IFR high volume helicopter passenger transport and emergency service operations."
Aero club submission were almost unanimous in their support for self-certification, unsurprising given that the result of over-stringent medical standards impact them significantly as pilots are forced to stop flying.
"In our view, CASA would do better to educate pilots to develop better health behaviours centred on their GP's qualified advice in an open and honest relationship," Peninsula Aero Club (Tyabb, Vic) stated in their submission.
"In our opinion, the AVMED system for GA private pilots is broken, its costly, ineffective and most probably counter-productive.
"The experience of RAAus and Gliding Australia medical exemptions surely demonstrates that pilots can manage their own health issues, evident by the lack of fatalities/incidents related to medical issues. Furthermore, it is our observation that other international aviation authorities are reducing their regulatory requirements as it does not support the efficiacy."
Devonport Aero Club in Tasmania is one of those that supported the AOPA policy, and spoke in tune with their Tyabb colleagues.
"Our club has seen a number of experienced general aviation pilots reluctantly sell their aircrafts and give up on aviation because they are sick and tired of the hoops they have been forced to jump through by AVMED to retain their Class 2 medical certificates.
"This is an unnecessary loss to the local aviation economy and the sad loss of an opportunity for less experienced pilots and student pilots to improve their skills and safety awareness by learning from these experienced pilots."
Alan Middleton, Queensland convenor for the Regional Airspace and Procedures Advisory Council (RAPAC) and Managing Director of Bluewater Airport near Townsville, took a more mathematical approach when it came to supporting his arguments.
"Statistical analysis doesn't support the premise that regular medical checks decrease fatal accident rates," Middleton pointed out. "Pilots that see their own doctors regularly are more likely to have trends in patient health picked up than one-off medicals performed by CASA authorised doctors (DAMEs).
"I would like to see CASA’s analysis of aircraft accidents due to medical complications as opposed to pilot error accidents. Amongst other things, this will also reveal whether pilots were on IFR or VFR flights. I am confident, as is the industry generally, that accident rates due to medical issues are extremely low (less than 1%) across both categories and thus excluding IFR pilots from medical reform rules would be discriminatory without a basis in evidence."
Aviation stalwart Sandy Reith went so far as to point out that the current medical system, ironically, could actually be bad for a pilot's health.
"The anxiety leading up to, and expense of repetitive investigations coupled with the current medical exam system is driving pilots out of GA. The anxiety caused by the possible licence loss, and the thought of having to sell one's aircraft may have a deleterious effect on pilot health. Certainly raised blood pressure is common with pilots leading up to their medical exams, known as 'white coat blood pressure'."
However, several individuals didn't respond so much to the DP, but took issue with the fact that any review was happening at all.
Brenton Rule had problems with AVMED being allowed to conduct a review of their own operations in a letter addressed directly to Acting CEO Shane Carmody.
"I am astounded but not surprised, that you have chosen to allow AVMED (the cause of all the problems) to be the ones to whom we should direct feedback on the changes to the medical system," Rule said. "I have had first-hand experience where the senior doctor on your staff refused to accept my GPs opinion and dismissed it out of hand. He quoted nebulous international (non aviation) so-called studies to back his claims. I then had to undergo more tests (at my expense) with absolutely no benefit to anyone except the bureaucracy and the lawyers.
"You need to engage an independent body or person to undertake a full review of the operations, qualifications and attitudes of your AVMED doctors, and also allow pilots' GPs to be more respected in their opinions"
Owen Bartrop provided a more simple, straightforward opinion on how to proceed.
"I find it incredible that time and money is wasted writing this review. The work has been done overseas both in the USA and Britain. Surely Australian pilots are no different medically to pilots from these two. Why not adopt their medical system instead of trying to reinvent the wheel?"
Several submissions quoted the RAAus experience, where pilots have only to satisfy conditions for driving a car to be allowed to fly. The RAAus submission, generally also supportive of self-certification for GA Recreational Pilot Licence (RPL), warns that reducing standards for the Recreational Aviation Pilots Medical Certificate (RAMPC) could advantage general aviation, with significant income ramifications that could endanger RAAus.
"[RAAus could face] potentially significant loss of revenue specifically if the RAMPC medical requirements are reduced. This could mean that the Recreational Pilots Licence (RPL) requirements will have a direct advantage over the RAAus Pilot Certificate with the possibility that members will leave RAAus to access CTA and [higher] MTOW, as has happened since CASA introduced the RPL.
"RAAus maintains its position that the RPL was an unnecessary introduction which added confusion and complexity to an already crowded marketplace. If CASA were to make accessing the RAMPC easier, it would be imperative that RAAus be given equal rights regarding accessing CTA and an increased MTOW to 1500 kg.
"This could result in a dramatic effect on the financial position of RAAus, which is a significant risk to the regulator should RAAus become unviable. If this did occur CASA would be left to manage some 10 000 pilots and 3 200 aircraft; it is questionable whether CASA has the capacity to undertake this responsibility."
All published submissions are available on the CASA website.