[Peetwo]

The Empire Strikes Back (AGAIN) on CVD Pilots: UPDATE!

Via the UP:

Clinton McKenzie

Some further ‘highlights’ from the documents disclosed under FOI and some comments arising from the content of the posts above.

When will the madness end?

When will the madness end? When some proper governance is applied again to CASA AvMed. As a consequence of inadequate governance, combined with how stressful and costly it is to take them on, CASA AvMed reckons the medical standards can practicably be whatever they reckon the standards should be, rather than what the law says the standards are. If the people paid to secure compliance of these zealots with proper governance requirements – Ms Spence and the CASA Board – won’t do it, it’s left once again to individuals to fight them in the courts and tribunals.

The awful safety risks and the change in name

The CASA AvMed echo chamber papers released under FOI list 3 ‘safety concerns’, the third of which is:

3. CVD cases recently cleared of all colour vision endorsements include:
- Cl 1 pilot who failed OCVA but passed Farnsworth - all CVD conditions/ restrictions removed
- Cl 1 pilot who fail PAPI but passed Farnsworth - all CVD conditions/ restrictions removed
- Cl 1 pilot with 0.5 hours flight experience severe CVD – passed OCVA which was incomplete

Newsflash, zealots: A person who has ‘passed Farnsworth’ in accordance with either CASR 67.150(6)(b) or CASR 67.155(6)(b) has demonstrated compliance with the colour perception criterion of the corresponding medical standard in Part 67. Full stop.

It should not matter whether the CVD zealots have an attack of the vapours about that. If they understood their duties as public officials administering the law they would understand that their personal opinions as to what constitutes compliance with the colour perception criterion are irrelevant. Unfortunately, they don’t have proper governance around them and they’ve been left to their own devices to implement the system their religion dictates, despite the law. These are public officials in government agency in the 21st century.

Someone who has ‘failed OCVA’ may be plain incompetent. Have the zealots been running a control experiment requiring pilots with ‘normal’ vision to undertake the OCVA to confirm that no pilot with ‘normal’ vision will ever fail the OCVA? (And by the way: the person who failed the OCVA puts the lie to the suggestion that no one has failed the OCVA.) I’ve never passed the Farnsworth test, the CAD or the OCVA.

And in the case of the OCVA “which was incomplete”, whose fault is that? The candidate just did whatever the candidate was told by the examiner, for as long as the candidate was told to do it by examiner. Maybe AvMed should have a chat with the examiner who did not administer a ‘complete’ OCVA?

I initially attributed the change in name from OCVA to ACVA to a manifestation of the self-appointed leadership of the Australian zealots. But then I was reminded, by the discussion above, that it’s another manifestation of the zealots’ obsession with CVD being a medical issue not an operational issue. I’ve seen the proposed ACVA described in CASA correspondence as a “medical flight test”.

The zealots’ religion simply refuses to accept that the ability to interpret information from an environment with different colours is an operational assessment, because being a doctor does not qualify someone to test whether a pilot is interpreting information adequately. And the zealots can hold their breath and stamp their little feet until their faces turn blue, but the applicable CASR says – remember that mere bagatelle the law – that the third tier test must ‘simulate an operational situation’.

More from the CASA AvMed echo chamber papers released under FOI. And this is the gist of the ‘safety’ issue arising from CVD, in the zealots’ religion:

[C]olour dependent cues are most important in critical phases of flight, add to this an emergency on-board, with heightened stress levels, the reaction time can become the determining factor between safety and accident.

And there you have it: Twofold nonsense.

The first nonsense is that in the aviation environment the colour of something is the sole cue and sole source of important information. The second and most palpable nonsense is that pilots with CVD are never put through any stressful, emergency situations and tested against objective standards of performance.

You couldn’t make this stuff up. It would be laughable if so many people’s careers and career aspirations weren't on the line.

When the zealots can specify the number of milliseconds that marks the boundary between ‘safe’ and ‘unsafe’ recognition times for each piece of information in the operational aviation environment, they can get those numbers put in the MOS and get every candidate tested against those numbers. At the moment, their religion dictates that it ‘must’ take pilots with CVD ‘longer’ to interpret information and therefore they must be ‘less safe’ than pilots without CVD. Just like female pilots must be less safe than male pilots because female pilots can’t lift as much weight as quickly as males and physical strength can become the determining factor between safety and an accident in an emergency.

Compliance with ICAO

As was so eloquently pointed out earlier – with reference to the number of pages of differences filed by Australia – the claimed ICAO compliance issue is a smokescreen. As CASA is so quick to point out – correctly – when it is convenient for CASA: There is only one obligation on member states to the Chicago Convention, and that is to notify of differences from SARPS. That’s why Australia has ‘filed’ so many ‘differences’. But for the zealots on the CVD crusade, their interpretation of the Convention provisions on colour perception is immutable, holy writ. Any difference from that interpretation is, by definition, unsafe.
(Yet strangely, as I pointed out earlier, CASA isn’t calling loudly and courageously for the ‘banning’ of anything that would expose us to the risks arising from those dangerous CVD pilots from the NZ or the USA, for example.)

Lying by omission

That oft-repeated statement by various CASA people, from various CEOs down, about the number of medical ‘approvals’ or certificates granted and refused falls within the scope of what I define as a “lie by omission”:
Stating a fact but omitting another important fact in order deliberately to foster a misconception.

An ordinary member of the public would assume that if CASA has issued a person a medical certificate in fact, that person has nothing to whinge about. CASA issues (a claimed and oddly consistently round figure over years of) 25,000 medical ‘approvals’ or certificates (the word varies depending on who’s speaking) and knocks back fewer than 100. How could the holder of one of these approvals/certificates possibly have any ground to complain?

Of course, us guinea pigs in the process know the whole truth about the costly and dangerous tests imposed by AvMed which tests qualified medical professionals say are unnecessary, and the conditions imposed by AvMed which effectively destroy – among other things – careers and career aspirations.

The only way in which I am able to give Ms Spence the benefit of the doubt is to assume that she’s completely ignorant as to what medical certificate applicants are put through and what ends up on their certificates.

“We issued driver’s licences to all those aspiring race car drivers with CVD!” (Forgot to mention: all of those licences are subject to the condition that the holder never exceed 60kph.)

Intellectual dishonesty

I was first struck by the extent of the intellectual dishonesty of the CVD zealots when I read some of the stuff produced by Dougal Watson. I could not believe that someone so obviously blinded by prejudice and his consequentially flawed reasoning could be taken seriously in any forum of qualified academics and medical professionals. I literally could not believe it. Then through discussions with Arthur Pape I came to realise that these ‘forums’ are actually echo chambers in which the CVD zealots perform their religious rites.

Then I read the NTSB report on the Tallahassee B727 which landed short in 2002. That report is referred to and partially quoted at Annex C of the CASA echo chamber papers released under FOI. Conclusion 13 of 16 conclusions is that: “The first officer suffered from a severe color vision deficiency that made it difficult for him to correctly identify the color of the precision approach path indicator signal during the below-glidepath, nighttime, visual approach to runway 9 at Tallahassee Regional Airport.” I came to that report with an open mind and the presumption that it would be the product of cold, hard analysis by disinterested professionals.

I then read the report.

I commend the report to anyone who hasn't read it. I’ll cherry pick bits below, but everyone should read the entire report and form their own views. I would particularly like to hear from people who, first, do not have any direct or indirect interest in CVD and, secondly, consider that CVD had any causal connection with the accident.

The accident flight crew consisted of three reserve FedEx pilots. The accident flight was the first time all three crewmembers had flown together; however, the captain and flight engineer had flown together once previously.

So pause there and note: 3 pilots on board.

According to the CVR transcript, about 0511, the flight engineer received the TLH weather information from the Gainesville Flight Service Station, which indicated: scattered clouds at 100 feet, 18,000 feet, and 25,000 feet; wind from 120º at 5 knots; visibility 9 statute miles; temperature and dew point 22º C (Celsius); and altimeter setting 30.10 inches of mercury (Hg)

So pause there and note the local time and the meteorological conditions - in particular the temp and dew point.

The flight engineer then briefed the captain and first officer regarding parking at TLH and, in accordance with company procedures, advised them that FedEx considered TLH a moderate controlled flight into terrain (CFIT) risk.

Recall that the ‘flight engineer’ is also a pilot.

The flight continues, with discussions about what runway would be used etc. Ultimately they decide on 09. Then…

About 0530:32, the CVR recorded sounds similar to a microphone being keyed five times within about 1.3 seconds. About 7 seconds later, the captain radioed “Tallahassee uh FedEx fourteen seventy eight uh extended uh left base leg for runway nine.” The first officer indicated that he thought he saw the runway about 0530:56; he called for “flaps 2” about 0531:10 and “flaps 5” about 12 seconds later. About 0532:34, the first officer stated, “I hope I’m lookin’ in the right spot here.” The captain responded, “see that group of bright lights kinda to the south down there and you see the beacon in the middle of it? right over there you’re kinda on about ten mile left base or so.” The first officer then indicated that he had been “ìlooking at the wrong flashin’ light.”

About 0533:05, the first officer repeated, “I was lookin ‘at the wrong light,” and the captain responded, “yeah okay, yeah.” The first officer added, “yeah, with the direction I took, we coulda used [runway] 27, eh?”, and the captain responded, “yeah, it dudn’t matter. Yeah, it’s about ten miles south of the VOR.”

About 0534:11, the captain stated, “I guess the lights came on, if not I’ll click ‘em again here when we get a little closer.” About 20 seconds later, the CVR recorded a sound similar to a microphone being keyed five times within about 1.5 seconds, and, at 0534:35, the captain said, “there we go.” The first officer requested “flaps 15” about 0535:24. About 0535:31, the first officer stated, “gear down, before landing check;” about 2 seconds later, the CVR recorded a sound similar to the landing gear handle being operated followed by a sound similar to the nose gear door opening.
….
About 0536:20, the first officer said, “sorry about that. I was linin’ up on that papermill or something.” As the first officer started speaking, (at 0536:20.2), the CVR recorded the ground proximity warning system (GPWS) announce that the airplane passed through 1,000 feet above ground level (agl). About 0536:23, the captain said, “that’s all right, no problem.”

So note: The captain (no CVD) effectively told the first officer (with CVD) that the GPWS warning was nothing to worry about.

It's about here that I started to get an inkling of the intellectual dishonesty that infects this report:

About 0536:37, the airplane was slightly more than 2.5 nautical miles (nm) from the airport and was transitioning from an angled base-to-final leg to line up with the runway. The Safety Board’s airplane performance study indicated that, about this time, the PAPI would have been displaying one white light and three red lights when viewed from the cockpit. About 0536:40, the PAPI display would have shown four red lights.

Note the words “would have”. Not “should have” or “would probably have”, but an expression of certainty: “would have”. The only people qualified to give first-hand evidence of what was being displayed at the time of the approach of the accident aircraft are the people who were looking at what was being displayed at that time.

PAPI used to have a latent defect. But it became a patent defect decades ago. The patent defect is that in some atmospheric conditions PAPI does not do what it should do. “The Safety Board’s airplane” did not fly the approach at the same local time in the same weather conditions as the B727 involved in the accident did.

I’ll jump forward a bit in the report to highlight these two tidbits:

The Safety Board notes that the National Air Traffic Controllers Association (NATCA) submission on this accident stated that there was a “high level of physical particle contamination” on the runway 9 PAPI boxes at TLH. However, investigators who examined the PAPI boxes during the on-scene investigation (including the NATCA representative and other members of the investigative team) noted no such contamination, and the investigation developed no evidence to support this contention.

Presumably NATCA just made it up. Presumably posters on this forum who report observing ‘four pinks’ on Australian PAPIs are making it up too.

Strangely, though, the report also says:

On December 12, 2002, the FAA issued CertAlert Number 02-08, “PAPI Operation” which advised that 14 CFR Part 139-certificated airport operators should “rewire pilot controlled PAPI systems to make them operate continuously in order to preclude environmental contamination of the lenses.” The TLH PAPI lights were subsequently rewired in accordance with the CertAlert.

Go figure. Why would that rewiring be necessary if there was never any contamination of the TLH PAPI lights just before dawn with the reported temp and dew point being the same?

But back to what the report says about the accident sequence:

During postaccident interviews, all three crewmembers described a normal flight until the last seconds of the approach. The captain stated that the airplane was established on final as it descended through about 800 feet. He stated that during the approach, he observed “white pink, going to white red” on the PAPI and that, as the airplane descended, “we started picking up a few little wispy, I want to say clouds or mist, but it didn’t obscure the airport.” The captain stated that his last recollection was of a “white red” PAPI indication, then “we started feeling a little bumping, and the rest of it I don’t recall.” The captain stated that the last thing he remembered about the approach was that “everything visually looked normal, based on the runway and that’s why I was somewhat shocked when I felt the thumping”.

The first officer stated the following about the approach:

“Everything was running exactly the way it was supposed to run. When we got down closer to the field and we had slowed down and the field was in sight and the wind was still prevailing down runway nine. And that’s when I mentioned should we go ahead and land on runway nine, since that’s where the wind is. [The captain] said okay, that’s fine. We were kinda lined up that direction anyway. And the speed was well within parameters Got the nose pointed to the airport, started slowing down, started dirtying up rolled out on the centerline on the PAPI I remember specifically adding a touch of power because I recall rolling out on centerline but 2 knots slow and a hair under the bug that’s the last I can remember I have no memory of the remainder of the flight.”

The first officer stated that when he first saw the PAPI lights, they indicated white next to red, showing that the airplane was on the glidepath. When investigators asked him to describe the PAPI system, the first officer described two white lights with two red lights next to each other. The first officer said that he would not have considered landing on runway 9 if it did not have the PAPI light guidance. He went on to state, “from the time I rolled out, I saw that I was on glideslope, added that power for the 2 knots, and it never changed. After that, since I have no memory of the remainder of the flight...I don’t know where the rest of the flight went.” When asked about power settings, the first officer told investigators that fuel flow for a normal visual approach would be 3,000 to 3,500 pounds per hour (pph) at 500 feet.

The flight engineer told investigators that he first saw the airport about the same time the first officer remarked that he had the runway in sight, when the airplane was on a modified left base leg for runway 9. The flight engineer stated that, when he first saw the runway, he observed a white, a pink, and two red lights on the runway’s four-light PAPI system. He further stated that, throughout the approach, he was scanning his instruments and looking outside for other air traffic and that, as they neared the runway, they could see the runway lights “plain as day, including the PAPI.” He stated that the visibility was good during their approach and indicated that he did not observe any of the low, scattered clouds that were reported in the TLH weather observation.

When I read that, as someone without CVD and no direct or indirect pecuniary or other interest in CVD testing, I conclude that, to the extent - if any - that colour vision had any causal connection with the accident, it’s ‘normal’ colour vision that is the problem. Or maybe pilots with ‘normal’ colour vision, like the captain and flight engineer in this case, are more prone to lie about what they saw. Maybe the NACTA people who stated that there was a “high level of physical particle contamination” on the runway 9 PAPI boxes at TLH were liars, too.

And then you find out that the first officer also spent 16 years in the USN.

And then there’s all this analysis of military colour vision testing. And on it goes.

But when you scratch the surface of the cited authorities, you see the names of the ‘usual suspects’. The adherents to the religion. The same people in the same echo chamber.

Please read it for yourself and let me know what you think.

And CM to do a YouTube SITREP at 2pm today:

Plus from Sandy & Arthur Pape:

Sandy Reith

Tallahassee B727

Anyone who has followed the some forty year saga of colour vision impairment in pilots won’t need to be persuaded.

Just as it appears that the sun orbits Earth so it is necessary (not) that all pilots must have exemplary colour vision in order to accomplish their flight duties in a safe and efficient manner.
In my view the lessor colour perception of around one in ten men should not be called ‘deficient’ because it’s so common as to be normal.

Whilst we do battle with The Empire in Australia, more correctly that we continue to be steamrolled and frightened into submission, we often look longingly to the US of A where their system is light years in advance of ours. But occasionally their ‘Empire’ has a slippage, some of their crew, hopefully a tiny minority, go the path of CASA.

One memorable example concerned the remarkable Bob Hoover who lost his USA medical because the FAA decided his red nose indicated he was drinking too much. He came to Australia and performed at the Avalon Airshow, having passed our medical.

It was my privilege to watch his incredible aerobatic flying routine which terminated after his rollout off the sealed strip onto the grass, both engines feathered, and he braked to a stop placing his left hand spinner in the upraised palm of the announcer’s hand.

He exited the Shrike to be interviewed by the said announcer, yours truly hanging by the fence just a few meters away, and he forcefully announced that he was grateful to Australia and that he could now fly anywhere in the world except in the USA because of an intransigent FAA medical officer. Not long after his return to the USA he regained his medical, they were shamed into restoring his flying status.

Asked to describe how it is to fly his airshow routine, he said in his Southern drawl, “well it’s like milking a mouse with big heavy gloves on.”

But that’s another story, the colour vision saga continues because the make work salary factory must keep on finding new and complex reasons for its existence, the truth or commonsense is too obtuse to the mind when power and money are the drivers.

---

Arthur Pape

Underlying science


Following Clinton's brilliant post, I thought I'd inform the debate further with the following links "Clark and Gordon Hazards of Colour Coding in Visual Approach Slope Indicators

This link is to a document, published by the Australian Defence Research Laboratories, which very clearly describes the inherent risks of contamination of the PAPI code, based on red/white discrimination, resulting in the distortion of the signal and ultimately, when it fails, it fails "UNSAFE".

When you've read this, and compared it with the NTSB report, it will be manifestlyclear that the crash was entirely due to a "fail unsafe" scenario with the Tallahassee RWY 9 PAPI.

The second link is to a paper, co-authored by myself and Boris Crassini, analyzing the dilemma inherent in the crash investigation, and proposing an alternative explanation (to that reached by the NTSB) of the crash. https://www.dropbox.com/scl/fi/pt03fnhg6...1f7yx&dl=0

:Thank you Clinton for bringing on this discussion.

Do note that the Clark and Gordon document does predict that CVD pilots may have difficulties identifying the PAPI code in certain circumstances, a conclusion I don't have any problem accepting.

To me the Fedex crash circumstances were a perfect fit for the predictions made by Clark and Gordon

MTF...P2