AOPA calls on CASA for private pilot medical reform

[coljones]

Being a doctor and a member of several aero clubs I am always being asked advice about getting spruced up for medicals and I have come to the conclusion that you should never ever ever have your gp as your dame.Your dame is testing you for a specific list of criteria, whose relevance to your safety is shown to be near zero but are required for an administrative purpose only.

 

He only needs to know what you want to tell them. You must be truthful about answers but never ever embellish or give complex scenarios or backgrounds to your story. Simple answer .... no more.

 

He has then no responsibility to manage your health or fix you up and no responsibility to go looking for health issues. That's what you gp is for.

 

He is there to simply examine you and see if you pass the casa criteria for having a licence. He is not your friend! He is a casa delegate.

 

If he suggests having an investigation that is not required - refuse ( politely).

but if you have diabetes or insulin resistance you will figure in the matrix- so sometimes it is better to work out what the matrix wants, do the tests and get your licence a couple of months earlier (given the probs with getting in to see a specialist.

 

 

[Jaba-who]

but if you have diabetes or insulin resistance you will figure in the matrix- so sometimes it is better to work out what the matrix wants, do the tests and get your licence a couple of months earlier (given the probs with getting in to see a specialist.

I'm not sure I follow your statement.

Who are you suggesting your do the tests early with - your GP or your DAME?

 

But the gist of getting tests done early is a two edged sword. Doing anything medical before due dates often triggers the dates of the issuance of the new medical to be backdated to the date when the investigations or examination etc were done. And their next medical brought forward commensurately. This has happened to several people I know. So if you get in early every time your medical falls due you may progressively decrease the time interval between your medical school.

 

It's difficult because if you wait you may end up having periods of no medical.

 

My advice to people is go to your GP early and get buffed up before you go to the DAME.

 

 

[Mike Borgelt]

Here are the options CASA are considering. You have till the 30th of March to put your 2bobs worth to CASAReview of medical certification standards | Civil Aviation Safety Authority

 

Options

 

There are six options that may be considered for future consultation, although further options will be considered on the basis of responses to this discussion paper.

 

The options are:

 

• continuing the existing medical certification requirements and arrangements (status quo)
   
   
  
• re-assessing risk tolerances which inform medical certifications standards in the context of industry and community expectations
   
   
  
• examining and streamlining medical certification practices across the various certification standards, including the approach to assessing incapacitation risk
   
   
  
• aligning certification standards across the sport and recreational sectors by revising the recreational aviation medical practitioner’s certificate to make it both more accessible to pilots and more widely applicable
   
   
  
• developing a new medical certificate for the sport and recreational sectors which considers overseas approaches with elements of self-certification
   
   
  
• mitigating the risks of any changes by applying operational restrictions.
   
   
  

 

 

Look at the sneaky wording of point 4. "to make it more accessible and more widely applicable'

 

in other words we want RAA RPC to need RAMPC.

 

They are red hot aren't they?

Icarus and everyone. For once don't say F___ You, I'm OK. Put in a submission.

 

I suggest you just dismiss the CASA talking points as irrelevant as the CASA discussion Paper is only there because AOPA rattled the cage and the CASA DP doesn't even acknowledge the AOPA proposal or the UK and USA changes.

 

Then fully support the AOPA proposal. If you want to have a medical to Class 2 standards at any time just do so. Don't perpetuate the current ridiculous system because you are too lazy to get check ups.

 

Yes, do what Supercub suggests also. Send in the form to the Minister. PRINT the form and put it in a envelope and post it. A pile of paper on the desk is more impressive than emails. Thanks for that Supercub.

 

 

[Super Cub]

Is there another pre typed letter we can print off and send to Casa to address their Review of Medical Standards.

 

I don't know the subject well enough to write a letter myself (and sound professional on the subject), but do agree the Class 2 is unnecessary for Private Flying (as they have determined overseas).

 

Anyone have a link.

 

Its a real shame the Casa medical seems to be a 'Guilty until proven innocent, rather than Innocent until proven guilty' system.

 

They should have to prove you are unsafe to fly a small single engine aircraft privately (due to sudden incapacitation risk) rather than being able to simply cancel your medical until you can 'prove to them' you are not going to crash because of incapacitation, through an endless (and likely annually) series of expensive specialists reports.

 

It shouldn't be legal to refuse a medical without proof, and based on research, they wont have sufficient proof.

 

 

[Mike Borgelt]

Is there another pre typed letter we can print off and send to Casa to address their Review of Medical Standards.I don't know the subject well enough to write a letter myself (and sound professional on the subject), but do agree the Class 2 is unnecessary for Private Flying (as they have determined overseas).

 

Anyone have a link.

 

Its a real shame the Casa medical seems to be a 'Guilty until proven innocent, rather than Innocent until proven guilty' system.

 

They should have to prove you are unsafe to fly a small single engine aircraft privately (due to sudden incapacitation risk) rather than being able to simply cancel your medical until you can 'prove to them' you are not going to crash because of incapacitation, through an endless (and likely annually) series of expensive specialists reports.

 

It shouldn't be legal to refuse a medical without proof, and based on research, they wont have sufficient proof.

here you go Super Cub, from the Australian EAA Chapter 1308 last meeting report:

 

Members should also be aware of the following:

 

Review of medical certification standards | Civil Aviation Safety Authority

 

[/url]

 

23 Feb 17 : CASA Briefing Newsletter - More comments needed on the future of medicals

 

Time is running down on the chance to have a say on the future of pilot medical certification. CASA needs comments from people across the aviation community on a comprehensive medical discussion paper. While some people have already sent submissions, many more are needed. The paper sets out a range of medical certification issues and puts forward a number of options. These options range from continuing existing medical requirements to developing a new medical certificate for the sport and recreational sectors. They also include re-assessing risk tolerances, streamlining certification practices, aligning sport and recreational standards and mitigating the risks of any changes through operational restrictions. The discussion paper looks at a range of other relevant issues such as CASA’s approach to aviation medicine, the approach to medical certification in four other nations, pilot incapacitation in Australia, accidents and risks, psychiatric conditions and the protection of third parties. The discussion paper makes it clear CASA’s operational objective is to strive to let as many people continue to fly as safely as possible. However, CASA is aware there is a perception from some elements of the pilot community that CASA can take an overly rigorous approach in terms of testing and contesting opinions from other doctors. Comment on the medical discussion paper by 30 March 2017.

 

Regarding Class 2 Medical reform, AOPA put forward a proposal on 23 August 2016 which you may wish to support (2 page summary CASA discussion paper and AOPO recommendation attached). Possibilities include addressing each of the 6 options put forward by CASA, or simply stating that "the AOPA proposal dated 23 August 2016 regarding Class 2 Medical reform is supported by me". Submissions to [email protected] by 30 March 17 and should include in the subject line: 'AvMed discussion paper'.

 

Attached AOPA pdf

 

My recommendation is to support the AOPA proposal which is closely aligned with the UK CAA medical rule brought in last August. Basically you make a declaration ONCE before age 70 that you are not restricted from driving ordinary private motor vehicle and every three years thereafter. The onus on you is to report if and when you would be unable to make this declaration at any time.

 

The UK does not have altitude or aerobatic restrictions.

 

The CASA discussion paper is a result of an approach by AOPA and SAAA to the Minister of Transport, Darren Chester. Unfortunately CASA is trying to obfuscate the issue by throwing the whole medical certification standards issue open. That is not what AOPA/SAAA are talking about. Only the medicals for PRIVATE pilot and something close to the AOPA proposal would be a great relief and save a lot of expense.

 

Below my proposed response to the CASA medical discussion paper.

 

Please at least write in, in support of the AOPA proposal. You may like to emphasis some points below.

 

Submissions to [email protected] by 30 March 17 and should include in the subject line: 'AvMed discussion paper'.

 

Consider sending a copy to your local member & Senator Pauline Hanson as well as Minister of Transport Darren Chester.

 

Contact email addresses for your local member & Hon Darren Chester:

 

Senators & Members Search Results – Page 2 – Parliament of Australia

 

[/url]

 

[email protected][/url]

 

 

 

 

 

 

 

 

 

 

 

 

Australian EAA Chapter 1308 response to CASA discussion paper on medical certification

 

 

 

 

 

 

 

 

Australian Experimental Aircraft Association Chapter 1308 strongly supports the AOPA/SAAA proposal on medical certification. It is closely aligned with recent changes in the UK and USA whose regulatory authorities have concluded after examination there is no value in continuing the old medical certification system for PRIVATE pilots.

 

 

 

 

 

 

 

 

The experiment of efficacy and safety has been run in the USA for many years where PRIVATE glider, motor glider and hot air balloon pilots self certify their medical status. Studies have shown that there is no significant difference in the accident rate due to medical causes (very low in any case) between them and GA pilots who have a Class 3 medical (Class 2 in Australia).

 

 

 

 

 

 

 

 

The experiment has also been done in Australia for many years where glider pilots self certify and ultralight pilots must be able to show they can drive an ordinary private motor vehicle without restriction.

 

 

 

 

 

 

 

 

Australian Experimental Aircraft Association Chapter 1308 is unaware of any problems with these medical standards as pilots with a Class 2 must in any case self certify on the other 729 days between medical examinations.

 

 

 

 

 

 

 

 

Accordingly Australian Experimental Aircraft Association Chapter 1308 rejects completely the 6 options raised by CASA in this discussion paper.

 

 

 

 

 

 

 

 

CASA has no evidence to show that a self certification as has been done for glider pilots in Australia and the USA and now in the UK for private pilots or the ordinary private drivers’ medical standard is in anyway detrimental to aviation safety.

 

 

 

 

 

 

 

 

Hence there is no case for extending the RAMPC (same medical standard as a Class 2) to recreational aviation or developing any other standard than the AOPA proposal for recreational aviators and PRIVATE pilots.

 

 

 

 

 

 

 

 

It should be noted that there are only two reasons for any standards in aviation:

 

 

 

 

 

 

 

 

1. Protection of innocent third parties on the ground from having aircraft crash on them.

 

 

 

 

 

 

 

 

2. Protection of other legitimate airspace users (includes fare paying passengers)

 

 

 

 

 

 

 

 

The overwhelming majority of aircraft crashes are from causes other than medical incapacitation and it is rare for there to be even significant property damage on the ground, let alone injuries and deaths to innocent third parties or other airspace users. Therefore it is untenable to claim that current medical certification in any significant manner prevents risk to the 2 categories of people.

 

 

 

 

 

 

 

 

It should be noted that private motor vehicle drivers are FAR more likely to do property damage and injure or kill innocent third parties on the ground in their motor vehicles due to sudden medical incapacitation than if they are flying a private aircraft.

 

 

 

 

Society accepts this.

 

 

 

 

 

 

 

 

Mike Borgelt, President Australian Experimental Aircraft Association Chapter 1308, Inc.

 

 

 

 

 

 

 

 

15/3/2017

 

 

 

 

 

 

[Icarus]

Has RAA a similar letter. I would hope so. This issue will affect RAA the most if CASA is allowed to have their way. Seems like the rest of the world is going one way while CASA goes the other .

 

Have a look at the link provided above. there is a discussion paper at the bottom of the page.

 

Here is the discussion paper:

 

https://www.casa.gov.au/file/176936/download?token=0N0PnquK

 

Looks like they want Drivers lic equivalent with 12 extra CASA requirements

 

ie RAMPC

 

 

[Icarus]

Does anybody know how many pilot incapacitation accident have occurred in RAA over the last say 10 years?

 

Would be a good measure to see if the current drivers lic equivalent is working. ie nobody on the ground has been killed by RAA pilot incapacitated

 

 

[aplund]

Does anybody know how many pilot incapacitation accident have occurred in RAA over the last say 10 years?Would be a good measure to see if the current drivers lic equivalent is working. ie nobody on the ground has been killed by RAA pilot incapacitated

This is a tricky one. Even if that study existed, there is a lack of a counterfactual.

 

But given that, it would be an interesting to see the raw statistics.

 

When doing the Bob-Tait online exams, I got a question about the leading cause of pilot incapacitation. I think I got it wrong on my attempt, but I remember the correct answer was acute gastroenteritis. There was also a reference to where that information was from, but I didn't write it down. I'm not sure I can go back and find it. But it is interesting to note that this condition is one that no level of medical screening will assist in preventing.

 

 

[aplund]

Found it:

 

Pilot Incapacitation: Analysis of Medical Conditions Affecting Pilots Involved in Accidents and Incidents

 

 

[Icarus]

Thanks Aplund. I am assuming this study was of pilots who have a class2 medical or higher. Interesting airliners was the most represented in icap incidents with the highest medical standards! No percentage given!

 

10 fatal accidents with most being from heart attack. All single pilot aircraft . They say the risk of a fatal accident increases with the pilot having a heart attack!!

 

Would be interesting to line up RAA numbers with these.

 

Interesting acute gastro 1st,, cabin fumes/ smoke second

 

 

[aplund]

Thanks Aplund. I am assuming this study was of pilots who have a class2 medical or higher. Interesting airliners was the most represented in icap incidents with the highest medical standards! No percentage given!10 fatal accidents with most being from heart attack. All single pilot aircraft . They say the risk of a fatal accident increases with the pilot having a heart attack!!

Would be interesting to line up RAA numbers with these.

Given that this report was from 10 years ago, it would indeed be useful. But let's not rule out driving statistics. I'm not sure if one can easily find out the rate of myocardial issues when driving cars. If comparing to a driver's license medical standard, then it would seem to be a reasonable thing to know.

 

 

[ave8rr]

Does anybody know how many pilot incapacitation accident have occurred in RAA over the last say 10 years?Would be a good measure to see if the current drivers lic equivalent is working. ie nobody on the ground has been killed by RAA pilot incapacitated

There have certainly been a number of RAAus accidents in the past few years where the PIC was getting on in years. Problem is we NEVER hear of the cause so will never know.

 

 

[Icarus]

I feel the medical requirement at the moment are fine.

 

RPC = Drivers lic equivalent

 

RPL 1 pax = Rampc [remembering access to CTA which is usually over built up areas and mixing with RPT]

 

RPL more than 1 pax = class 2

 

PPL = class 2

 

Do I have these right?

 

it seems to be more the process ,ie burecratic red tape and BS that is the problem.

 

Perhaps PPL and RPL with 2+ pax could be RAMPC, but some say this is harder than class 2?

 

 

[ave8rr]

I feel the medical requirement at the moment are fine.RPC = Drivers lic equivalent

RPL 1 pax = Rampc [remembering access to CTA which is usually over built up areas and mixing with RPT]

 

RPL more than 1 pax = class 2

 

PPL = class 2

 

Do I have these right?

 

it seems to be more the process ,ie burecratic red tape and BS that is the problem.

 

Perhaps PPL and RPL with 2+ pax could be RAMPC, but some say this is harder than class 2?

Remember also RAMPC is annually after age 65 whereas Class 2 is in most cases two yearly.

Mike..

 

 

[Icarus]

Does anybody know how many pilot incapacitation accident have occurred in RAA over the last say 10 years?Would be a good measure to see if the current drivers lic equivalent is working. ie nobody on the ground has been killed by RAA pilot incapacitated

As somewhat of an answer to my own question, from the discussion paper:

Advice from the industry is that there have been only 3–4 cases of medical incapacitation in over 450,000 landings by RA-Aus members, although it is not clear on what basis this claim is made

 

 

[turboplanner]

There have certainly been a number of RAAus accidents in the past few years where the PIC was getting on in years. Problem is we NEVER hear of the cause so will never know.

But CASA will know, which is why making a big noise without having the facts at your disposal is a strategic blunder; inevitably someone will go for the books and get the accurate data, and then we'll all be dragged down to the level of these whining misfits.

 

 

[Jaba-who]

I feel the medical requirement at the moment are fine.RPC = Drivers lic equivalent

RPL 1 pax = Rampc [remembering access to CTA which is usually over built up areas and mixing with RPT]

 

RPL more than 1 pax = class 2

 

PPL = class 2

 

Do I have these right?

 

it seems to be more the process ,ie burecratic red tape and BS that is the problem.

 

Perhaps PPL and RPL with 2+ pax could be RAMPC, but some say this is harder than class 2?

I think everyone except casa disagrees with you.

 

Not meaning to sound belligerent so I apologise if I do. Just trying to discuss.

 

Firstly you are not correct with the correlations of medical to licence and secondly there remains no evidence that backs up any medical requiring or benefitting from any licence levels regardless of how many passengers may happen to be in the aircraft and is not supported by overseas regulations. (Despite the lack of any evidence I think everyone is still happy to say commercial pilots should have medicals. )

 

And thirdly that's not what ALL our representative bodies are trying to get brought in.

 

There seems to be a consistent opinion expressed on the forum that RPL requires a RAMPC and PPL requires a Class 2. This is incorrect. You can have either type of licence with either type of medical. But if if you have a RAMPC you have some limitations. but essentially carrying no more than 1 passengers and in vfr is about all. You still have access to CTA ( so the belief that only class 2 medical or above can go into CTA is not correct).

 

Access to CTA does not just mean being over built up areas. In every area where CTA exists it is a wide circle extending out well into less built up areas - often into sparse areas or open ocean. Current exclusions of flight into CTA are not restricting exclusion to just populous parts of CTA but all of CTA which means even areas distant to and never-flown-in-by-anyone areas.

 

Many controlled airports (even some big international ones ) have approach paths and routes completely in to ground level that do not pass over any buildings for the entire approach so conflating issues of CTA access and flying over populous areas muddies the waters.

 

There is no doubt that a RAMPC is " harder to get and maintain" than a class 2. Mainly due to absolute exclusion where a diagnosis exists regardless of its effect on performance and the complete prohibition on appealing the decisions. In my area we have had several people try go to a RAMPC but fail and then go back and get a class 2. The differences and the reasons for this are worthy of an entire thread of its own.

 

 

[turboplanner]

I think everyone except casa disagrees with you.Not meaning to sound belligerent so I apologise if I do. Just trying to discuss.

Firstly you are not correct with the correlations of medical to licence and secondly there remains no evidence that backs up any medical requiring or benefitting from any licence levels regardless of how many passengers may happen to be in the aircraft and is not supported by overseas regulations. (Despite the lack of any evidence I think everyone is still happy to say commercial pilots should have medicals. )

 

And thirdly that's not what ALL our representative bodies are trying to get brought in.

 

There seems to be a consistent opinion expressed on the forum that RPL requires a RAMPC and PPL requires a Class 2. This is incorrect. You can have either type of licence with either type of medical. But if if you have a RAMPC you have some limitations. but essentially carrying no more than 1 passengers and in vfr is about all. You still have access to CTA ( so the belief that only class 2 medical or above can go into CTA is not correct).

 

Access to CTA does not just mean being over built up areas. In every area where CTA exists it is a wide circle extending out well into less built up areas - often into sparse areas or open ocean. Current exclusions of flight into CTA are not restricting exclusion to just populous parts of CTA but all of CTA which means even areas distant to and never-flown-in-by-anyone areas.

 

Many controlled airports (even some big international ones ) have approach paths and routes completely in to ground level that do not pass over any buildings for the entire approach so conflating issues of CTA access and flying over populous areas muddies the waters.

 

There is no doubt that a RAMPC is " harder to get and maintain" than a class 2. Mainly due to absolute exclusion where a diagnosis exists regardless of its effect on performance and the complete prohibition on appealing the decisions. In my area we have had several people try go to a RAMPC but fail and then go back and get a class 2. The differences and the reasons for this are worthy of an entire thread of its own.

And it would be worthwhile having just that thread, so people could see how others have managed to fly legally within the system we have.

 

 

[Mike Borgelt]

Yes, do what Supercub suggests also. Send in the form to the Minister. PRINT the form and put it in a envelope and post it. A pile of paper on the desk is more impressive than emails. Thanks for that Supercub.

 

OK attached is my effort. It will help if you put at least one of your thoughts in as well as the form. I've attached as a Word document so you can all edit it a lot easier. Don't forget your name and details.

 

Mine here:

 

27th

 

May

 

2017

 

The Hon Darren Chester MP

 

Minister for Infrastructure and Transport

 

House of Representatives

 

Parliament House

 

Canberra ACT 2600

 

Australia.

 

SUPPORT THE AOPA PROPOSED POLICY ON CLASS 2 PRIVATE PILOT MEDICAL

 

CERTIFICATION

 

Dear Minister Chester,

 

I write to you as a concerned general aviation industry user and participant, in support of the Aircraft Owners and Pilots Association (AOPA) who have recently called on you to

 

direct the Civil Aviation Safety Authority (CASA) to adopt their proposed policy on Class 2 Private Pilot Medical Certification.

 

The AOPA policy is important to the future of Australia’s general aviation industry and if implemented serve to reconnect thousands of perfectly healthy private pilots whom have been unfairly discriminated against by the existing CASA AVMED system.

 

This vital reform will dramatically reduce licensing costs to industry and will remove unnecessary layers of bureaucracy and red tape that have contributed to the serious decline in general aviation pilots in Australia, which based on CASA’s own data amounts to some 8,000+ pilots exiting our industry!

 

AOPA’s policy will help kick start private flying activity within the general aviation industry, which will result in increasing demand for the varying support services whilst creating valuable jobs and opportunities across the country.

 

Nobody minds RATIONAL regulation based of valid data but in the case of aviation medicals for PRIVATE pilots there is no data supporting the current system. The experiments have been run in various classes of aviation both in Australia and overseas with no detriment to the safety of the public and the regulators in the USA and UK have recently changed the aviation medical system for private pilots to ones similar to the AOPA proposal.

 

I ask that you show your support for our industry, small businesses that depend on it and the cause of rational regulation by directing the Civil Aviation Safety Authority to adopt the AOPA policy without delay.

 

Yours sincerely,

 

Signed

 

Michael Alfred Borgelt

 

proprietor/ chief design engineer, Borgelt Instruments

 

President Australian Experimental Aircraft Association Chapter 1308 Inc.

 

Ministermedical1.doc

 

Ministermedical1.doc

 

Ministermedical1.doc

[coljones]

I feel the medical requirement at the moment are fine.RPC = Drivers lic equivalent

RPL 1 pax = Rampc [remembering access to CTA which is usually over built up areas and mixing with RPT]

 

RPL more than 1 pax = class 2

 

PPL = class 2

 

Do I have these right?

 

it seems to be more the process ,ie burecratic red tape and BS that is the problem.

 

Perhaps PPL and RPL with 2+ pax could be RAMPC, but some say this is harder than class 2?

RPL doesn't give you CTA Access unless you have the training and the tick.

You can fly PPL with RAMPC but you are limited to I pax, less than 10,000 feet and day VFR (and I think SE, 1500Kg) unless you have a 2nd pilot.

 

 

[Mike Borgelt]

OK I'm about to post mine. I've done my bit. It is up to you people to make a pile of paper on the Minister's desk and jam CASA Avmed's inbox with comments.

 

How many will bother. If you don't you cease to have bitching rights about CASA Avmed screwing you over.

 

 

[Jaba-who]

RPL doesn't give you CTA Access unless you have the training and the tick.You can fly PPL with RAMPC but you are limited to I pax, less than 10,000 feet and day VFR (and I think SE, 1500Kg) unless you have a 2nd pilot.

Yep exactly what I said.

( except that for PPL with RAMPC no there is no 1500 kg limit as far as I am aware)

 

 

[biggles]

East Gippsland Aero Club circulated a petition for signatures at their meeting yesterday, but I will be sending in another, similar to yours Mike. Darren Chester is our local member, but reports indicate, perhaps not unexpectedly, that he may not be fully across all the issues, and will probably just go along with CASA's final recommendations ..... Bob

 

 

[coljones]

Yep exactly what I said.( except that for PPL with RAMPC no there is no 1500 kg limit as far as I am aware)

What aircraft can I fly if I am flying with a RAMPC? If you hold a private pilot licence and are using your RAMPC, you are limited to flying recreational aircraft only and only by day under VFR. Recreational aircraft are: › single-engine aircraft › certified for single-pilot operations › certified with a maximum take-off weight of no more than 1500kg › not rocket or turbine powered. If you hold a commercial or air transport pilot licence and are using your RAMPC, you are limited to the privileges of a recreational pilot licence. from https://www.casa.gov.au/sites/g/files/net351/f/_assets/main/lib100191/rr61_medical_fs.pdf

 

 

[Icarus]

Firstly you are not correct with the correlations of medical to licence

Not correct or incomplete?[ I was posting minimum medical requirements,prob should have made that clear]

 

RAMPC for ppl I was not aware of

 

And thirdly that's not what ALL our representative bodies are trying to get brought in.

Whats not "All our representative bodies trying to get brought in" ? I don't understand this statement.

 

Are they trying to get self certification for all lic classes to and including PPL?

 

While I believe the current minimums are fine ,I also believe that self certification would be better.

 

so the belief that only class 2 medical or above can go into CTA is not correct).

so this was correct?

 

RPL 1 pax = Rampc [remembering access to CTA which is usually over built up areas and mixing with RPT]

 

I think everyone except casa disagrees with you

One interesting point from the discussion paper was that 30 out of 250 RAMPC were declined or "did not meet requirements" in 2015-16

That is not good, and I can see why from that why people would not agree with the requirement.

 

So what does everybody want? if everybody disagrees with the current system.

 

Self certification all the way to and including PPL?