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The Sport Aircraft Association of Australia (SAAA) has written to CASA asking for an exemption from medical requirements for members who fly aircraft with a revised maximum take-off weight of 600 kg or less.
The letter, dated 15 July, asks for SAAA members to have the same "self-certification" privileges as pilots administered by Recreational Aviation Australia (RAAus).
SAAA President Rob Lawrie, who signed the letter, points out the inequity of RAAus pilots being allowed to fly under a driver's licence medical, yet SAAA pilots flying aircraft of similar weights need to have a CASA Class 2 medical examination.
"We propose that such pilots of sport recreational aircraft would be responsible to self-certify their medical fitness, with identical conditions imposed upon their flight operations as those currently imposed on similar sport aircraft within Australian airspace," he says.
"The present situation is inequitable as the same pilot, who is rejected by the CASA medical certification process, may fly the same aircraft in Australian airspace under an 'alternate regulator'. This situation may reasonably be argued to result in a number of negative safety outcomes.
"We need a solution that is immediate and allows our members to continue to fly their aircraft, many of whom have spent countless years and thousands of hours constructing them. As such our members have a considerable investment and emotional attachment to their aircraft.
"The majority also hold considerable aviation experience and have demonstrated their ability to operate safely."
Rather than ask for a blanket exemption for all members, the SAAA proposal concedes that the exemption should apply only to pilots and operations meeting the following criteria.
- Single-engine amateur-built experimental (ABE) or amateur-built aircraft acceptance (ABAA)
- Day VFR limited to pilot and one passenger only
- No aerobatics
- Flight below 10,000 feet AMSL
- A revised MTOW of 600 kg for the flight or 650 kg for float equipped aeroplanes
The SAAA is also suggesting that pilots would need to carry their driver's licence on such a flight and people with certain conditions such as epilepsy and diabetes would need an annual statement of fitness from a GP.
"The initial exemption request is for identical weight limits and conditions as presently provided to RAAus for ultralight operations," Lawrie states. "This in itself is a very strong Australian based safety case, which CASA simply cannot ignore.
"RAAus have held these approvals for a considerable period of time. During this time there have been almost no reports of medical incapacitation of RAAus pilots and certainly far less that those experienced in commercial and RPT operations.
"This sort of data is essential in achieving regulatory reform. Essentially we must prove there will not be an adverse safety outcome to CASA’s satisfaction.
"CASA is required to demonstrate fair and transparent regulation in their dealing with the aviation community. We all fly in the same air.
"We believe these two factors will maximise our chance of success and make it more difficult for the initial request to be dismissed by CASA."
The full text of the SAAA letter to CASA can be downloaded from the link below.