[Peetwo]

Sandy email to Stakeholder Engagement Executive Manager Andreas Marcelja - 

Via the AP emails:

Dear Andreas Marcelja,
 
I’ve been given your email address by Ms. Pip Spence in regard to a proposed medical certification reform that’s being considered. 
 
I understand that there’s a possibility that a weight limit of 2000kg may be imposed on a new self declared medical standard for private pilots. 
 
I would object to that limit on the basis of safety and efficiency. 
 
The heavier aircraft such as the Beechcraft Baron, 2313kg, that I fly privately has two engines and flies well on one engine. 
 
1/.Statistically the chances of a General Aviation aircraft crashing by engine failure, the great majority being single engine types, are greater than the risk of aircraft crashing due to a pilot medical incapacitation. Flying twin reduces that risk of injuries on the ground due to a forced landing. 
 
2/. Heavier twin engine aircraft are usually faster than their lighter counterparts. For example my Baron cruises at 190 knots. If the 2000 weight limit exists I will be encouraged to sell my Baron and most likely buy a slower 120kt aircraft thereby increasing the risk (albeit an incalculably minute risk) of experiencing a medical incapacitation event whilst in flight. In other words faster aircraft spend less time in the air, thus reducing ‘risk’. 
 
3/. By encouraging Private Pilots to migrate into slower, and usually single engine aircraft, the market will, to some extent, devalue the heavier and more capable aircraft. Due to our low value dollar even more aircraft will be sold to overseas buyers. This reduces the fleet available to provide the most capable aircraft for the various uses that all of General Aviation needs, particularly for training that flows into commercial pilots and aircraft for all sorts of crucial purposes like air ambulance, firefighting, air rescue, aero medical and business charter. 
 
The health of General Aviation and safety of flight are interdependent, overly restrictive rules and increasing expenses means less flying and it’s well established that pilots that fly frequently maintain and increase their safe abilities. Financial stress can cause short cuts;  and excessive, ever changing and complex rules do not contribute to the health and safety of GA, including jobs growth and the importance of GA for National security. 
 
I have been subject over 20 years to an annual stress test that my specialist and DAME deem as not necessary. 
 
The USA statistics plainly show that  aviation specific medicals have no bearing on the (extremely low) occurrence of accidents caused by medical incapacitation. See below. 
 
As a private pilot might typically only fly 50  - 100 hours annually compared to, say, 200 hours driving a motor vehicle, if medical incapacitation was a problem it would surely show up on our roads. 
 
It has become obvious that the USA standard is one successful answer to private pilot medical certification with some 80,000 certifications accomplished in the five or six years of BasicMed implementation in the USA. 
 
Main limiting provisions of their BasicMed being six seats and 18,000,’ but does include IFR. The six seat provision caters for the ‘size’ argument, though statistically there’s no basis for that as creating an appreciable risk. 
 
Please pass this submission to the appropriate groups and please advise me of any questions or outcomes. 
 
Thanking you, 
 
Regards,  
 
Alexander Cran (Sandy) Reith
CPL (1968) 010873 

      
MTF...P2