The dyed-in-the-wool, antediluvian attitudes within the CAA are becoming unbearable.
There seems to be a complete lack of rational thought, logic and common sense applied to the proposal, along with the usual ploy of putting it out for consultation over a holiday period when most people are trying to enjoy time away, or rest from the daily grind.
Truly, a cynical and condescending swipe at our intelligence as pilots.
The CAA attitude seems to be ‘If they’ve read the proposal, let them blow off steam, and we’ll do it our way anyway’. This is ‘consultation’ as required, but at the lowest possible expected level of participation.
– the words of a CFI
Notice of Proposed Rule Making (NPRM) 19-04 – Part 61 Private Pilot Medical Review
Here is what the CAA’s NPRM is proposing to allow. It amounts to:
- Carry up to five passengers
- Maximum take-off weight 2730 kg
- Fly in the vicinity of controlled aerodromes (with radio)
- Obtain a glider tow and parachute drop rating
Do not become over-excited by the prospect of being able to exercise these privileges on a DL9-P medical, because effectively all other PPL privileges are prohibited.
We join the NZ Aviation Federation in stating that the NPRM does not deliver what we have campaigned for over many years. Just getting this issue to the NPRM stage has taken a great deal of behind-the-scenes work in correspondence and lobbying, and it may be a long time before we get another shot at it.
Consider also the many years of work that went into getting the views of the CAA’s Medical Unit overturned in relation to the colour vision deficiency issue. It was a long and bitter battle and now – faced with a similar medical certification issue – the CAA seems to want this PPL medical certification “done and dusted” in the space of a few weeks, with a submission period occurring over a holiday.
This is by no means the first time that the CAA has scheduled important “consultation” to fall within a Christmas holiday. And CMO Dougal Watson’s fingerprints are all over the NPRM.
An extension of the consultation period was applied for. The arrogance the CAA displayed in extending the submission period by just one week is an insult to us all. It appears that the authority has unwittingly revealed the clear direction it wants this submission process to head, and the result it has pre-ordained.
The GAA’s goal is exactly the same as that of the NZAF: to have an alternative medical, based on the NZTA DL9P driver licence medical, allowing all the privileges that relate to the Private Pilot Licence (PPL).
We recently observed in an email to another concerned aviator that this RPL / PPL issue seems like déjà vu, because we’d travelled down some of these roads when the RPL was first introduced.
Back in 2013, we challenged the CAA because it was using an outside contractor (a doctor with a diploma in occupational medicine) to covertly audit DL9s done by GPs.
In some cases, this doctor was recommending extra conditions be imposed, or testing be done.
Incredibly, the doctor had access to the CAA Medical Unit database and was comparing the results of previous Class 2 medicals with a GP’s assessment. There was no discussion between this doctor and the GPs, and the GPs were not told that their work was being audited.
Some of the GPs were pretty fired up about this when it was brought to their attention, and as one said: “I have no problem with my examinations and assessments being audited, but professionally I would expect a collegial conversation to ensue from that”.
This was all despite the fact that the CAA had previously stated that, with regard to the RPL, the CAA Licensing section would handle the DL9-P certification and the Medical Unit would be “hands-off”.
Once we had blown the whistle on this practice, the Director backed down and said that the “RPL had now come of age” (or words to that effect) and these audits would no longer be necessary.
However, with the new proposal to do away with the RPL, we are very concerned that the CAA’s Medical Unit will once again seize the opportunity to get its grubby hands on a “clean” DL9-P and impose restrictions over and above what the GP may have judged.
The other RPL issue we brought to the CAA’s attention was the need to keep as many of our “grey-haired” instructors in the seat, to pass down their knowledge to a younger generation. We’re thinking particularly about instructors with skills such as extensive vintage aircraft tail dragger time, experience on aircraft that have the potential to “bite your bum”, cross-country time in variable weather conditions, and so on.
That suggestion, which should have been a no-brainer from an enhancement-of-flight-safety perspective, turned into a major battle between the CAA and us before the authority eventually acknowledged that we were correct in our interpretation of the Rules and that an instructor rating was just that: simply a rating which could be used on a RPL.
After that battle, the CAA’s legal section couldn’t get their heads around the fact that an instructor offering services whilst exercising the privileges of a RPL would be prepared to do so on a pro bono basis. It took more correspondence with the CAA to get the authority to recognise that, while an instructor couldn’t charge for PiC time, they could legitimately charge for the time spent in pre-flight briefings and post-flight debriefings.
We note that when CASA created its version of a PPL based on an Australian equivalent of our DL9-P medical certification, it permitted a couple of hire and reward activities – flight instructors and Ag pilots. We took this up with the Director, but he said that this was a separate issue to the PPL / RPL proposal and that the CAA lacked the resources to examine it.
If the CAA doesn’t have the resources to examine this proposal on its own account, perhaps rather than “reinvent the wheel” it could simply use the CASA precedent and rationale. For example, consider how many years ahead of the CAA that CASA was in permitting professional pilots to fly with a colour vision deficiency issue. Why must Kiwi pilots be continually subjected to greater restrictions on our licences than our Aussie mates?
Please carefully consider the implications of the proposed NPRM, and put aside any thought that “it isn’t going to concern me, so why should I bother putting in a submission?”
We implore you to consider those pilots following in your footsteps, and perhaps even the freedoms that you would like to have when, for instance, you eventually retire from professional flying and may wish to continue flying recreationally.
Yes, this is a naked attempt to influence your views, and to advise you to hold off giving the NPRM your tick of approval until the NZAF has completed an analysis document (which we also hope to share with you).
If you have already filed a submission in support of the NPRM, and after reflecting further on the implications, you may wish to consider withdrawing that support. The ability to do this is just a few clicks away, using this link.