Short Approach - December 2019
Seasons greetings to all.
Good old CAA and Transport Ministry have timed the release of the latest Medical Standards ‘Notice of Proposed Rule Making’ (NPRM) right in the busy season and our responses are expected soon after the holiday season – great. However at least we have the document and can get on and analyse it.
Before I start commenting I would ask any member who is wanting to write a submission on the document to wait…. We, via the NZ Aviation Federation have engaged TDB Advisory Ltd to prepare a formal independent analysis of the document. Ian Andrews and I have been working closely with this group and we are looking for them to have their independent analysis finalised by late January. We have asked for an extension to the submission cutoff date to accommodate our submissions.
So now to the detail…. Initial impressions are of well-crafted government writing, the scene is well set by an introduction which sets out appropriate goals and how these are to be attained. However, the path is down hill from here. The most disappointing aspect to me is the inconsistent logic applied to the conclusions.
Sling load carrying PPL Helicopter pilots are to be permitted to fly with the DL9 (P) medical, this is logical because the pilot is specially trained and has an appropriate rating. Though few pilots use this privilege it is still approved. Great.
Compare this to PPL pilots who wish to spread fertilizer over their own farms, not common but it happens. Apparently due to the high number of incidents in this area of flying it is banned on the DL9 (P), you will need to still get a Class 2 medical. No evidence of medical reasons given. Seems just a whim.
Again, compare this to the ban on Night flying by PPL’s with DL9 (P) medicals. It is deemed that night flying is a low volume activity, and this is a reason to preclude it. CAA says that night flying is not a ‘recreational activity’ – well they should see the number of planes flying at Canterbury Aeroclub on a moon-lit winter evening. Colour vision competency is deemed more necessary for night flying, in spite of there being a new and good process for approving colour blind pilots. They seemed to have also ignored the anatomy of low light vision where the rods in our eyes adapt to the low light but can only see black and white, the cones which see colour are useless in low light conditions. So ban it anyway.
I do not want to go on and analyse each component here, those who are interested will be able to read the document at:
Just to end on a brighter note, the RPL pilots among us will relish the thought of taking 5 passengers and having an increased weight limit for their planes. Plus it appears that flight over built up areas will be allowed. You will still be allowed to fly as high as you wish, with oxygen of course, but not allowed IFR, no parachute dropping from over 10,000’ and you have to disable your aircraft’s pressurization system. If you want to fly with 2 engines you will need to fly a microlight. No aero’s under 3,000’, and no banner towing either. The high cost of the Class 2 is noted but for many of us it is the time delays and hassle of traipsing round seeing specialists which is the main disadvantage of the Class 2. DL9 (P) is seen as more user friendly and about 90% cost saving.
We will be reporting again once we have the independent report to hand and at that time we will be encouraging everyone to put in their submissions.
I hope you get some aviating in over the holiday season. Once the wheels leave the ground the stresses of the day all seem to dissolve away.. I just wish I could measure the benefits of flying for mental wellbeing, that would be a compelling argument to take to the MOT.