Medical Proposal Doesn't Go Far Enough

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My petition (FAA 2009-0481) proposes replacing the third class medical for private-use aircraft under 6,000 lbs with a driver's license. No commerce is involved (remember that interstate commerce clause), and pilots of small family airplanes cannot be any more of a threat to themselves, their passengers, or people on the ground, than driving any SUV along the road. In fact, they are less of a threat in their airplane. AOPA EAA's recent proposal is really just incrementally expanding the sport pilot medical; and then barely an inch. At least for some, it would appear,a "small step for a man" remains a terrifying leap for the status quo.Who are they trying to please? I thought these guys were supposed to represent their membership! On one hand I am delighted AOPA and EAA have finally started to move on this but I am sorely disappointed they have started with such a weak and timid position. They stand to miss a great opportunity to really do something beneficial for their members. I've been getting comments from pilots across the U.S. about AOPA EAA's proposal, and frankly, pilots are very angry that these organizations appear so willing to sell them out. AOPA and EAA's proposed conditions also perpetuate the current illogical situation, the premises including flying behind 200 HP requires super-human skill; medical incapacitation increases the moment the sun goes down; cycling a landing gear handle takes super human strength, and lastly, it's okay to risk the life of one friend or family member in your airplane, but not two. Where did they come up with this stuff? Where is the leadership? On a more philosophical level, when you have thousands tied in bureaucratic chains, letting a few go isn't freedom. It's worse, because such a compromise perpetuates ongoing oppression for the many. AOPA and EAA ought to sound out their proposal to their membership; to see if it really reflects their members' interests. I'd bet a thousand dollars to a doughnut (and I'm talking chocolate glazed here), that pilots are tired of being forced to live (and pay for) half-truths and costly compromises just to keep the inner Washington beltway off their backs. This is not the moment in history to go silently into the corner. Now is the moment to firmly grasp and break these shackles, once and for all. It's time to go all the way. The truth shall set you free.

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Comments (146)

This is less than a half step of a proposal. Eliminating the 3rd class medical altogether should be the only goal. Who would choose to forego a 3rd class and be saddled with the restrictions, max 180 hp, pilot and only one passenger, etc. Not many will choose this option effectively perpetuating the status quo. I agree AOPA ans EAA are being timid at best with this proposal. Get rid of the 3rd class medical in it's entirty once and for all, period.

Posted by: Gary Caron | September 29, 2011 7:05 AM    Report this comment

I agree it is time to expand use of driver's license for medical qualification of pilots. I also agree with Mr. Wartofsky that the current EAA/AOPA proposal (still in discussion phase) doesn't go far enough.

Sport Pilots currently can only fly Light Sport Aircraft, and they can do it using a driver's license as medical qualification. The reason they are limited to LSA is the profound lack of training required to earn a Sport Pilot certificate. The simple nature of LSA is a good match for the very limited entry level training for Sport Pilots.

Expanding Driver's license medical qualification for recreational use by higher licensed pilots is a logical step. We have seen that this form of medical qualification works just as well as federal medical certification. I think this should allow any pilot to operate any plane under any set of conditions for which the pilot is qualified. The current discussion by EAA/AOPA limits this privilege expansion to 180 horsepower aircraft and VFR/Day operations. These aircraft are nearly identical in simplicity to LSA but can have 4 seats instead of 2.

I think it is a mistake to limit the proposal to these very limited aircraft and conditions. To suggest that pilots should have reduced flying privileges when using a driver's license for medical qualification is to admit this form of qualification is not as good as the certificates issued by FAA bureaucrats. I just don't think this is so.

Posted by: Paul Mulwitz | September 29, 2011 7:09 AM    Report this comment

I signed the petition submiited by Mr. Wartofsky and I support it as written. The AOPA and EAA are simply seeling us out. I prefer to fly at night, conditions permitting. So, under the alphabet proposal, I would still have to pay for a medical just to be able to do that. What a farce! I'm smart enough to ground myself because of a health issue. It's called good ADM. Most pilots are responsible enough to exercise good judgement. Those that aren't get fleshed out quickly enough. A 3rd Class medical is not going to make them any smarter about decision making.

Posted by: Meredith Hutto | September 29, 2011 7:25 AM    Report this comment

Why would I choose to forego a medical to fly daytime VFR with one passenger in an underpowered plane? I usually fly daytime VFR with 1 passenger, however, I treasure the ability to file IFR or take additional passengers if necessary. I feel my 235hp plane is safer than a 180hp model since I don't have the density altitude and payload problems with the same ease of handling.

Posted by: Sean O'Day | September 29, 2011 7:38 AM    Report this comment

Or it could be that EAA and AOPA understand the process of doing business in a dysfunctional government better than the members. Maybe "one small step for man" is all they believe can be done. It's not our organizations, it's our representatives. One could argue that in a perfect world, we would not need lobbying organizations at all, and a call to our elected officials would get the ball rolling. Anyone who believes that can happen, raise your hand.

Posted by: Jerry Plante | September 29, 2011 7:39 AM    Report this comment

Wartofsky's proposal is one that would make for meaningful change to the costs and time-consuming aeromedical process with no compromise to safety. Pilots and taxpayers alike would benefit from the change. Sadly, the AOPA version is merely a mild dumbing down of the existing requirements, but does little or nothing to cut the self-protective bureaucracy of the FAA. Too much coziness and revolving door employment between the FAA and AOPA. Not enough AOPA activism. Why is their membership level in trouble?

Posted by: M Coster | September 29, 2011 7:55 AM    Report this comment

AOPA and EEA have become more concerned with being accepted by the polical communtity and not loyal to their members regarding medical examinations, lead free gasoline and fees, etc. Operators of small single engine aircraft take pride in being able and in good health as they are flying their love ones with them. The LSA community is becoming just as regulated as the other elements of the aviation operators. Open your eyes to over regulations which means more jobs for individuals who do not understand the GA community.

Posted by: Robert E. Lee | September 29, 2011 8:00 AM    Report this comment

Frankly, the whole issue of eliminating the 3rd-class medical seems to me to be a pretty big yawn. Yes, the medical exam itself is not exactly probitive (pun intended) since seemingly if you can fog a mirror, you pass, but having to do it every 2 years reminds us that it is part of the whole process of keeping current. It is a reasonable barrier that asks on a regular basis "are we fit to fly (anything)". If you cannot pass the 3rd-class medical, you should be asking yourself regularly if you should be driving as well. It may not be part of ADM for every flight, but it helps set the tone we need.

I can certainly think of other much more important issues that AOPA/EAA coulda/shoulda become involved with over the last 20 years but did not, while spending our membership money on lunches with the Washington crowd.

This is just one of those relatively simplistic issues that the alphabets can use to get everybody exercised while conveniently losing sight of serious threats to GA that are much more difficult to fix.

We should be grateful for what we have here in the US on the aviation medical front. I started flying 50 years ago in Canada, but left 10 years later and have lived elsewhere since. Recently I learned that in order to re-activate my Canadian CPL license I need a 1st-class medical regardless of the flying that I intend to do. Don't get me started on why I cannot transfer my CFII and instruct in Canada either.

Posted by: David MacRae | September 29, 2011 8:10 AM    Report this comment

I support the idea 100%; if for no other reason than to reduce government in our lives.

Posted by: Lynn Farnsworth | September 29, 2011 8:46 AM    Report this comment

Thank you David Wartofsky! I fully agree that the AOPA/EAA proposal is exceptionally timid and makes them look like they are doing the least they can on this issue. Let's get rid of the useless bureaucracy that is the 3rd class medical altogether.

Posted by: Jon Carlson | September 29, 2011 8:57 AM    Report this comment

Mr. MacRae,

The Driver's license medical qualification is about a lot more than FAA medical exams.

Where the medical certificate becomes a real problem is when it is denied. This is usually not because the silly exam finds a problem. It is about the information you disclose to the government in your application. Once you face the bureaucracy for "Special Issuance" and the incredible conditions the bureaucrats impose to get you back in the air I think you will change your mind about this issue. It is crucial to keeping GA viable.

Each pilot must "Self Certify" his fitness for every single flight. It is this pilot responsibility that makes aviation safe rather than the government regulation of pilot health. The driver's license approach does this job at least as well as the FAA medical certificates and does it at essentially zero cost to the pilots and general public.

We need to reduce government spending. I can't think of a better candidate for cuts than the bloated FAA aeromedical bureaucracy. Eliminating the 3rd class entirely (not any of the current proposals) would allow dropping half the bureaucrats and their associated costs. If you buy the argument these medical certificates aren't worth the paper they are printed on then you must agree this is a painless way to cut excessive government cost (at least painless for everyone except the bureaucrats who will need to find actual gainful employment).

Posted by: Paul Mulwitz | September 29, 2011 9:06 AM    Report this comment

I agree also. The third class medical is a farce and should be done away with. We are truly no more dangerous when flying than we are when driving.

Posted by: Stuart Baxter | September 29, 2011 9:07 AM    Report this comment

The problem with the medical is that the FAA can pick whatever reason they want to deny it if they choose to. Two years ago I was admitted to the hospital with what I thought may have been a stoke but ended up to be nothing serious. Routine CTs and MRIs were run with negative results. For the last year and a half I have been forced to get a complete cardio work up(twice), see a neurologist multiple times, get another MRI, get all my hospital records and since they don't believe the radiologist reports I had to get all the original images of the MRIs from two years ago. Now they want another MRI, another neurological exam, and the images from the last MRI. My neurologist and AME have both said they see nothing abnormal on the MRIs and there is nothing wrong with me that they can see. I even had an FAA safety guy from our local FSDO tell them he talked to me at length and saw no physical problems with me. The FAA has yet to say what my "potentially disqualifying condition" is and my doctors don't know what it is. They just continue to request random information. Officially, they haven't "denied" the medical but they tave canceled it, so I haven't been able to fly for over a year, until this is cleared up. I even asked if I could go to OKC and meet with their neurologist but I'm told they don't do that. I'm just trying to clear it up so that I can try flying as sport pilot. I'm done with the medical.

Posted by: Larry Kindrick | September 29, 2011 9:17 AM    Report this comment

Oh yeah, by the way I'm talking about a third class medical....

Posted by: Larry Kindrick | September 29, 2011 9:20 AM    Report this comment

I would like to see third class medical go away. I have been trying for over a year to get my medical back. Every time I manage to jump through the FAA hoops they put up more. Correspondence with the FAA takes one to three months while I keep getting older. Therefore when the AOPA and EAA throw out tidbits I jump at the chance. Too bad we don't have an organization with the guts of the National Rifle Association.

Posted by: Ray Wyant | September 29, 2011 9:29 AM    Report this comment

The current third class medical harms the medical care of pilots who are passionate about flying and makes in-flight medical problems more likely. A passionate pilot may feel like there is some medical issue that they'd like to get checked out (e.g. vague symptoms of a heart issue). But if they have it checked out and, even if the doctor finds no problem, they will have extreme difficulty getting permission to fly again. Thus, the rational response is to delay getting it checked out until it is clearly a problem. This is not good for the pilot, his passengers, or the people around him when he is driving to the airport.

Posted by: Paul Fuoss | September 29, 2011 9:40 AM    Report this comment

Third class medical pilots don't have any news organizations that just represent them. AVweb, propwash, Aviation eBrief and others talk about everything from two place planes all the way up to the newest airline jet. It would be like reading a magazine that features motor scooters all the way to the latest semi-truck rig. I wish there was someone out there that knew how to unite us all to get rid of the third class medical.

Posted by: Ray Wyant | September 29, 2011 9:42 AM    Report this comment

The proposal by EEA and AOPA is a useless step laterally rather than a step forward. Larry Kindrick's comment reinforces the need to get government out of our lives as much as possible. There are probably many experienced pilots flying today who have failed to renew their medical and have caused no problems. They cannot admit to doing this, however. By the time they reach the age where this becomes a problem, the likelihood of their being risk takers has usually long passed. Therefore, they will often stop flying when it seems too risky to them. In addition, it would seem that there would be a large number of reports of pilots who have lost their medical in accidents were there to be a correlation. But that is not the case in the reports that I have read in various sources. Thye conclusion has to be that the presence or absence of a third class medical has contributed little to flying safety or to protecting the unaware public. With, or without a medical, there will always be pilots who run out of fuel, take off overweight, fail to account for density altitude. Finally, even a person with a valid medical can still have a stroke or heart attack while flying. That piece of paper does not clear the coronary arteries!

Posted by: Barry Fisher | September 29, 2011 9:42 AM    Report this comment

David Wartofsky, how can I get behind your petition (FAA 2009-0481)?

Posted by: Ray Wyant | September 29, 2011 9:45 AM    Report this comment

Maintaining the third class medical is a huge burden on the FAA with few if any demonstrable results. In the spirit of not doing things that result in no benefit, the third class medical should be eliminated.

Posted by: Ray Damijonaitis | September 29, 2011 9:57 AM    Report this comment

I lost my professional license some years ago due to diabetes. After loosing it I was invited to fly in a Navajo from the UK to the South of France and Spain. With a pilot along side me. It is far easier to take a blood sugar test in a stable aircraft than it is in, say a Piper Cub in turbulence. The one thing I have never seen from the aviation doctors is the effect of adrenalin on blood sugar. If you don't have any nerves before going flying, don't fly. The nerves are caused by adrenalin. Adrenalin, like insulin lowers blood sugar. I don't think the size of the engine or aircraft has much to do with it. Need a better class of civil servant and or doctor to decide these matters, in my opinion.

Posted by: Neil Munro | September 29, 2011 9:58 AM    Report this comment

AOPA/EAA proposal should be amended to eliminate the 3rd class medical requirement. Continuing the current medical requirement does nothing to ensure the safety of general aviation. The partial restrictions for hp and night flying makes no sense and only appeases FAA to try and change some of the standards. FAA needs to back-off from their antiquated and controlling of the 3rd class medical which makes no sense whatsoever.

Posted by: Roland Berg | September 29, 2011 10:24 AM    Report this comment

My medicare plus insurance pays for a physical every year, but not a flight physical. So, that is 3 physicals in 2 years, or an average of 1 every 8 months. If I still had my CDL that would mean 1 more. This could be performed by the same dr. Ironic, isn't it?

Posted by: Edward Jeffko | September 29, 2011 10:30 AM    Report this comment

This discussion reminds me of the age 60 rule. It was an arbitrary age originally chosen without review of the medical evidence available at the time. The FAA fought tooth and nail to keep the retirement age at 60 until it suited them to increase it. Facts be damned! I suspect you will see similar resistance to changing the medical certification requirements, despite the fact that Sport Pilots (and Glider pilots) have demonstrated that self-certification works. After all, even with a medical, all you have proven is that on that one day, a doctor thought you were fit to fly. The rest of the time you are making the judgement as to whether you are medically safe to operate an aircraft. I support Mr. Wartofsky in his efforts and hope that EAA and AOPA will see the light and get on board.

Posted by: Timothy Juhl | September 29, 2011 10:31 AM    Report this comment

I am waiting for a Special Issuance medical certificate for insulin dependent diabetes. In the mean time, I am flying as a commercial pilot in ex-Air Force TG-7A motorgliders. This aircraft has a 59.5 ft. wingspan, a gross weight of 1850 lbs. and a power package (firewall forward) from the Piper Tomahawk -yet NO medical is required because it is a self-launching glider. As a glider pilot, I have NO weight, speed, altitude or night restrictions (though the TG-7A is VFR day only). Why should we have a night restriction, a limitation of only two passengers, a restriction against retractable gear (though LSAs that are amphibians have already proven that retractable gear in itself is not a problem) and other pointless limitations? The years of glider and balloon pilots self-certifying, and LSAs with the driver's license medical, have proven that aircraft do not fall out of the sky due to pilot incapacitation at any statistically significant rate that is greater than those that have medical certificates.

Yes, I agree that the AOPA and EAA have stopped far short of what their members desire. We should eliminate the 3rd Class Medical Certificate for those not flying commercially.

Posted by: Michael Nutt | September 29, 2011 10:38 AM    Report this comment

Let's hear from the FAA. How many aircraft accidents have there been in the last 10 years where medical was a contributing factor? Oh wait, that wouldn't be a good question since the FAA so stringently denies for medical reasons. So... better yet, how many accidents on our national roadways are medically related? How many of these were caused by licensed drivers who are or “wanted to be” private pilot rated? How many private pilots drive cars? What is the ratio? On average how many people die in a car accident compared to an aircraft accident? Maybe we should be looking at medicals for a drivers license, ahh but that’s absurd. The 3rd class medical is therefore absurd.

Posted by: Brady Greene | September 29, 2011 10:52 AM    Report this comment

Sport Pilots currently can only fly Light Sport Aircraft, and they can do it using a driver's license as medical qualification. The reason they are limited to LSA is the profound lack of training required to earn a Sport Pilot certificate. The simple nature of LSA is a good match for the very limited entry level training for Sport Pilots.

Paul, you either have an incredible ego or are completely ignorant to the training for sport pilots single engine land. Other than night training and hood training there is no difference

You sound like an angry old man with a chip on your shoulder.

Posted by: Jay | September 29, 2011 10:56 AM    Report this comment

A small additional comment to my last post.. with respect to the huge burden for the FAA. I have decent insurance that paid for the previous MRIs but my doctor really can't justify why I need another one. I don't think "the FAA just wants it" will fly, no pun, with the insurance company.. MRIs are expensive and if I have to pay for it out of my pocket I may not be able to afford it. What about MY burden?

Posted by: Larry Kindrick | September 29, 2011 10:56 AM    Report this comment

I completely support the position of Mr. Wartofsky. Aviation physiology is no longer the mystery it was back in the 1920 - 1930 era. Flying exerts no more, and maybe less, exertion or stress than driving a car. The FAA's Civil Air Medical Institute (CAMI) is a bureaucracy out of control. For example, why should FAA medics be concerned about a pilot who has had a basal cell carcinoma removed? Why should a pilot who has had prostate cancer and/or prostate removal require a special waiver? Unless a pilot has a physical condition that might compromise a single flight, the FAA should have no business in determining if that pilot is capable of flying. There should be no requirement for a recreational pilot to have FAA medical certification, regardless of the size or horsepower of the aircraft, fixed or retractable gear, IFR or VFR operations, or day or night operations. AOPA and EAA should reevaluate their position on "gradually changing" the Class 3 medical requirements.

Posted by: Charles Brame | September 29, 2011 11:43 AM    Report this comment

I was really upset when I saw the proposal. I am 63 and have the endorsements to fly all single engine pistons, and I have a wife and 14 year old. I want to buy a DA40 and use it to visit the other 7 children I have. What use is this?? No better than LSA. We must have something that lets us use our earned privileges and at least fly with four.

Posted by: Tommy Brazie | September 29, 2011 11:50 AM    Report this comment

The word from FAA always was "Let's see how the SP medical thing goes, and if there doesn't seem to be a problem, we'll consider some minor expansion into the PPL world." Sounds like the FAA has now said "OK, we're willing to consider some minor expansion." You can't expect the FAA people to say "Hey, lets put a bunch of ourselves on the unemployment line!" What I haven't seen anyone talk about is what just this announcement could do to the LSA market. I know A LOT of PPLs that have bought LSAs (and many more considering it) just so that they can let their medicals lapse. Most of those would have rather just keep flying what they were ever flying. If they decide to just sit back and see where the chips fall, most of the LSA suppliers could just dry up and blow away.

Posted by: Ken Finney | September 29, 2011 12:01 PM    Report this comment

Ken,

I wouldn't lose any sleep worrying about the future of the new LSA market. I believe the LSA specification really does identify a very nice recreational aircraft. Compared to factory new type certificated planes, LSA are very inexpensive to buy and economical to operate. They offer owner maintenance with a minimal "Repairman" course requirement. They allow non-certified avionics to be used instead of older certified and much more expensive ones. None of these issues will change with a change in pilot medical qualification.

The issue at stake here is how much freedom pilots should have from unjustified bureaucratic interference in their freedom to fly. This is a much bigger issue than the question of whether or not the budding LSA industry will fail without punishing regulation for those who fly other planes.

Posted by: Paul Mulwitz | September 29, 2011 12:24 PM    Report this comment

When I saw it, my immediate thoughts were "What a sell out". I can't agree with any restriction, esp night and 4 passengers. One thing no one mentioned is that AOPA probably talked w people inside the FAA before proposing it and got an idea of what they were willing to accept. Not that I agree, however, it appears this is how humans work in large groups. Politics.

Posted by: David Schultz | September 29, 2011 12:57 PM    Report this comment

Paul- Wish I shared your optimism. It's pretty said that so many people/organizations (myself included) ignored recommendations 10 years ago from a couple of people thinking "outside-the-box". If, instead of SP/LSA, they had: 1. Raised the UL weight limit to at least 512 lbs. 2. Made the Recreation ticket a DL medical. 3. Allowed PPLs with >500 hours to fly with a DL medical. We'd be in a much, much better state today.

Posted by: Ken Finney | September 29, 2011 12:57 PM    Report this comment

This kind of idea is what the AOPA should be representing. Mr Wartofsky ought to be considered for a job at the AOPA. This is a terrific idea in keeping with the real world. How many pilots with great skills and high time in the cockpits are forced to quit instrument flight and then flight outside LSA just because they take an SRI or some other safe medicine. Hey I'm over 50 not dead! Great Idea.

Posted by: R. A. Fourt | September 29, 2011 1:09 PM    Report this comment

Lets take it up Higher for Bargaining Power, as follows: Dr Lic Med for Private Pilot, aircraft,12.5k lbs or less, Fixed or Retract, Passengers limited to aircraft seating, Day or Night Flying, IFR or VFR.

The D.L. med is not much more than a fairly lenient eye exam, yet approx 50k people a year, die on the hiways, and how many times do you read of medical incapacitation being the cause? Usually, its drinking, drugs, speeding, ignoring traffic rules, and just plain foolishness.

I know it sounds simple, and logical, but how about we put the above plan into operation and give it some time to prove itself. If I am wrong then we can revert back or go to stiffer limits, but I would tend to think you won't see much, if any difference from the current conditions and results.

From what all I read, the accidents in flying are generally a result of VFR into IMC without an instrument rating and exp., poor fuel management, reckless flying, and mechanical failures. Rarely, do the accident reports speak of pilot incapacitation, although it can happen, occasionally. However, I flew airline, years ago, and a Captain I flew with, 58 years old, healthy, passed all the med tests, but died of a heart attack one day, while home. So, no matter all the precautions you take, medical incapacitaion happens with any profession.

Anyway, that's my take on it. I realize it will take a Miracle for the FAA to see it my way, but nothing ventured, nothing gained.

Posted by: Randahl Holder | September 29, 2011 1:17 PM    Report this comment

Ken,

On the brighter side, the FAA is now considering revising the antiquated part 23 rules. This must be at least in part because of the success of consensus standard use in LSA. Today we are considering eliminating the 3rd class for all private pilots with conditions that have not yet settled. I am optimistic discussions like the one here will convince AOPA/EAA to make a more sweeping proposal than their original idea. I just don't know anything about the Recreation Pilot certificate. I believe very few were issued and that seems like a dead subject now.

Yes, I am optimistic. The statistics show driver's license works just as well for Sport Pilots and others (like me) choosing to operate with Sport Pilot restrictions. The FAA did a good job of ignoring Mr. Wartofsky's proposal a couple of years ago. I don't think they will take the same position when faced with a similar proposal from the two biggest GA organizations.

From my personal perspective, I would probably work to get an instrument rating as soon as it becomes legal without the medical requirement. I probably won't change airplanes I own - I just completed a high end LSA certified E-AB and am now in the middle of flight test. The freedom to get additional ratings would put an end to the current regulatory situation that puts pilots using a driver's license at a dead end regarding pilot training.

Posted by: Paul Mulwitz | September 29, 2011 1:27 PM    Report this comment

Randahl,

I agree with your ideas, but you are missing a little known fact about driver's licenses.

When a person is diagnosed with a condition that really makes it dangerous for them to drive a car that fact is reported to the state and their driver's license is immediately revoked. This is not the arbitrary kinds of conditions that gets the FAA all excited. Rather, it is things like epilepsy that can make someone become unconscious with little or no warning.

So, in this respect a driver's license is subject to more real time review by the state than FAA medicals are by the federal government. Between applications for renewal it is up to pilots to ground themselves when they think they should. The FAA is too busy to monitor pilot's actual health until they have announced their condition to the FAA.

Posted by: Paul Mulwitz | September 29, 2011 1:35 PM    Report this comment

As David, Ken Paul and others have noted, the entrance of AOPA and EAA into supporting the initial change toward the inclusion of 4 place, 180 hp and fixed gear a/c into the DL self-certiification is a beginning .Especially if they can include night , IFR and 3 passengers into the present proposal. Perhaps this can be one of a multi-stage presentation, with more complex (RG) and larger engines, and 6-8 place carriers to be added into an automatic one or two year cycle. Then, just the passage of time would provide the desirable outcomes for the changes the private pilot flying community forecasts as desirable.

One question I have is is a 3rd class medical required to fly in foreign (Canada or Mexico) airspace?

I do think both AOPA and EAA deserve kudos for realizing how important an issue this is to all of us as pilots, and especially so if they can get this change in an FAA rule making within a few months (Hey, I can dream... or take more of my anti-desusion meds!!!).

Posted by: roger bailey | September 29, 2011 2:17 PM    Report this comment

Just drop the 3rd class medical and all of the restrictions pro and con would be eliminated. The 3rd class medical has done nothing to assure the safety of the general public. AOPA and EAA need to develop a proposal to FAA, spelling out the new requirements with copies to the appropriate congressional oversight committees to start making the needed changes.

Posted by: Roland Berg | September 29, 2011 2:32 PM    Report this comment

I'm all for abolishing the 3rd class medical.

I have a suspicion the FAA resists eliminating the 3rd class because it is needed to support the AME network. If you eliminate the 3rd class then revenue for AMEs will only come from 1st and 2nd classes. There is probably not enough revenue from those classes to keep enough AMEs involved. With a reduction in AMEs the commercial pilots will have increased time and cost to keep their medicals, something the feds possibly would not want to impose. Just throwing this out as a possible explanation - we all know that when it comes to the government there is always the written, as well as unwritten, reasons for any of their decisions.

Posted by: Bob Carpenter | September 29, 2011 2:41 PM    Report this comment

As I've read all of the issues here, it occured to me that two issues were left out of the debate... and both related to the "why" of the 3rd class medical exam:

One is the restriction of day flight only. The 3rd Class medical tests for color vision, without which, one cannot determine the orientation of aircraft at night based on nav lights (never mind that we can't do anything similar during the day, since that little dot on the horizon doesn't have discernable orientation until it is time to dive and bank to avoid it!)

The second is peeing into a cup... yep... I think the main purpose of the medical is to give the FAA a chance to test for drugs. The 3rd class gives fewer chances to catch drug use, thus possibly missing the errant druggie... but that 1st class every six months sure will!

So, if we recognize these two issues as being the REAL issue, we need to address them head on, instead of nashing teeth over government spending vs. personal freedom, etc. The first issue can be addressed with a single, first time eye exam. The second issue it thornier. But must be addressed if we are ever to see any real action on getting rid of the 3rd class medical.

Posted by: Candice Brown Elliott | September 29, 2011 2:49 PM    Report this comment

My experience with FAA rule-making was disappointing.

In the late 80s -- while I was flying both as a civilian CFI and as a Navy P-3 Aircraft Navigator and Mission Commander, I submitted a suggested rule change. Most of you know that a winged military pilot gets an automatic commercial license/instrument rating/multi-engine rating by taking a simple test on FAA regulations. I submitted a requested rule change to allow winged, current (within 12 months) military navigators to get the FAA Flight Navigator rating by similarly taking a test on FAA rules. I even WROTE the proposed change based upon the pilot rules. It was a huge success. In the public comment period, it got 100% approval. Approval came from the DOD, The Navy, The Air Force, the ALPA, the public, and many FAA inspectors. It was a shoo-in. Then it got to Administrator Engen's desk. He disapproved it, saying he didn't trust Naval Flight Officers and Air Force Navigators. Engen was one of the "old breed" Navy pilots who reportedly hated NFOs. So After 18 months of work, that was the end of that.

That was the last time I've commented on any FAA rules changes. But I do agree that the 3rd class medical for light aircraft PIC is pointless and vindictive. In 39 years of instructing, I have had less than a half-dozen student pilots be judged medically disqualified.

Posted by: K. Sherman | September 29, 2011 2:50 PM    Report this comment

It's all well and good to complain about the 3rd class medical being unnecessary (which I agree with), but we *are* talking about government bureaucracy, which is slow to change. Did everyone really expect that after watching how the SP medical rules played out that the FAA would just be willing to completely drop the 3rd class? Also, I think it's unfair to blame AOPA and EAA for not going further. I attended this year's AOPA Summit, and the FAA was very directly clear that they aren't willing to drop the 3rd class. I would rather see incremental steps being taken than no steps at all, and with Congress' current "hold our breath until you see things out way" mentality, I think it would be a disservice if AOPA/EAA instead tried to take the "just drop the 3rd class" approach. Hopefully it is just a step forward, and we can see the proposed rule eventually broadened to finally do away with the 3rd class, but it's not going to happen overnight.

Posted by: Gary Baluha | September 29, 2011 3:02 PM    Report this comment

Gary, that's the same attitude why most things can not be changed or eliminated, with the FAA ignoring all resonable explanations and carrying-on with the outdated philosopy that only encourages more government intervention and control. In the description that K. Sherman, made in is dealing with FAA, points out the fact the regardless of a logical way to adopt new procedures the FAA, will ignore this and continue its outdated practices. Yes, AOPA and EAA are commended for their efforts to make a change, but in order to this by pacifying the FAA, that somehow they will relinquish their authority by finally seeing the light is unrealistic. The way to make change is by providing a resonable proposal based on factual information to the FAA, and to make sure that it is considered by requiring congress to look at this in their oversight responsibilities. No, the proposal is not just to say eliminate the 3rd class medical, a sound an fact filled proposal and way to make the change needs to be spelled-out and presented in written form. As far as FAA, not receiving sufficient revenue with the elimation of the 3rd class medical. Quite honestly, that is their problem, and only represents a minimal portion of the the FAA appropriation.

Posted by: Roland Berg | September 29, 2011 3:25 PM    Report this comment

After talking to someone at AOPA, the approach makes sense, considering how human-beings work in reality. Baby steps.

Posted by: David Schultz | September 29, 2011 3:30 PM    Report this comment

I'm bothered by a couple of nagging doubts.

1) The medical "examination" to obtain a drivers license in at least five states where I have in-depth knowledge has allowed family members who are severely impaired visually and cognitively to obtain a drivers license with zero difficulty. I speculate that the basic utility of a driver's license is so very desirable that the state examiners are not too critical of the applicants. I doubt the D/L will offer ANY appreciable help in sorting this out for us. Perhaps a strengthening of the criteria of the BFR would be in order.

The other problem is that, like it or not, we ARE all going to die of something. When we have experienced some significant medical event, we must consider that nature has put us on notice. As time passes, we are increasingly subject to recurrences. Whatever has happened is usually not "cured", a price has been paid. That toll increases as we age. I cannot escape the logic that a condition, once identified, MUST be tracked carefully. The 3rd class medical does provide that mechanism, a D/L does not.

BTW: I have fought and won my "Special Issuance" in spite of a complex cardiac condition (MI x2, stent and CABG). It took two years and was a significant undertaking but I now have been successful in achieving re-issue for the last six years. I jump thru a LOT of hoops. I consider that I am getting some great medical attention that will extend my life - flying or not.

Posted by: Walter Freeman | September 29, 2011 4:46 PM    Report this comment

If the American motorist had been as apathetic as general aviation has been about getting rid of the third class medical we would still be driving 55 mph on the interstate highways.

Posted by: Ray Wyant | September 29, 2011 7:08 PM    Report this comment

Walter Freeman, I don't want to spend two or more years and who knows how much money getting my third class medical. I don't need the FAA to make me be responsible for my own health.

Posted by: Ray Wyant | September 29, 2011 7:13 PM    Report this comment

Ray Wyant: If the FAA is asking for additional information to issue your waiver, I would assume one or the other (or both) of these conditions exist.

1) Your condition is more serious than your local medicos are telling you and you should get a second opinion.

2) You are not giving them the EXACT information that they need, in the form they need it.

I had both these problems. In fact, I fired the first MD because he did not push aggressively into the FAAs concerns. His replacement did so, and I got a by-pass BEFORE the "big one" and thru rehab am now good to go. I also learned that when the FAA says they want this and that, you better give them this and than and they will respond. I do agree that they are slow and frustrating and I wish you the best of luck in you pursuit. BTW: The AOPA has a excellent medical staff to guide and advise pilots in such instances. Free for members.

Posted by: Walter Freeman | September 29, 2011 7:31 PM    Report this comment

While AOPA and EAA are to lauded for finally taking a position on this issue, the proposal as stated is insufficient. It is clear from all statistical data that accidents resulting from medical incapacitation are so are few and far between as to be statistically irrelevent. Thus the 3rd class medical serves no viable purpose. Pilots self certify they are medically fit to fly as soon as they leave the physicians office and continue to do so until their next sceduled medical. Under this system aircraft have not been falling from the sky and pilots are free to fly at night, file IFR and fly high performance aircraft. Clearly self certification works and no pilot I know will fly when they are experiencing medical issues which might bear on there ability to fly safely. While I would agree that airline pilots do have a greater degree of responsibility and thus should be subject to periodic medical review (as are commercial truck drivers), private pilots flying light aircraft are no more likely to experience a medically induced accident as the driver of a typical SUV. Bottom line, AOPA and EAA should modify the proposal and simply petition for elimination of the 3rd class medical.

Posted by: Frank Novak | September 29, 2011 8:26 PM    Report this comment

Actually being responsible for my own health and then being honest with the FAA is what got me into medical problems. After submitting all the information they requested they now want tests repeated that I have already had. Unfortunately my AME is also my cardiologist.

Posted by: Ray Wyant | September 29, 2011 8:34 PM    Report this comment

There is one argument that could be made about why the 3rd class medical is still required, and that's *because* there have been so few accidents with a medical condition being the causal factor. It could be argued that most such accidents are prevented because the 3rd class catches those pilots who otherwise wouldn't be aware of (or have been trying to ignore) a condition that prevents them from being medically fit to fly.

Given the litigious nature of current U.S. society, I can actually see to a certain point why the FAA is so reluctant to completely eliminate the 3rd class medical. The one thing the sport pilot certificate has going for it is that by default, pilots are limited to good day VFR conditions, where as private pilots have a bit more leeway. I think this mainly provides for conditions where vision is less of an issue, and can get away with the jokingly simple medical requirements for a driver's license.

Posted by: Gary Baluha | September 29, 2011 8:45 PM    Report this comment

I can see requiring a medical certificate for commercial operations carrying many paying passengers for each pilot. We do have a LONG history with self certification for glider pilots with NO history of medical incapacitation. I see no reason whatsoever for any other requirement than that for glider pilots for any noncommercial operation in any airplane of any class as long as the pilot is properly equipped to fly it. Self certification prior to flight has proven sufficient. Why a "drivers license?" It shows that you are not totally blind and not totally incapacitated. I do know of several friends over the years who were able to pass the requirements for a third class medical while legally blind. The drivers license seems like a purely arbitrary requirement that has absolutely nothing to do with medical qualification anyway. Or is it just that they are concerned with a government issued photo id to make sure the pilots license is really yours?

Posted by: John Johnson | September 29, 2011 10:02 PM    Report this comment

A classic case of setting the FAR too low. Make the broth weak enough and no one will choke, but then there's no value to it at that point. I'm sure the three pilots this will help will be grateful, but not worth much effort either.

Good luck anyway

Posted by: Burns Moore | September 30, 2011 2:08 AM    Report this comment

This proposal is a good first step and will hopefully eventually lead to the elimination of the third class medical altogether. I wonder what effect this will have on light sport aircraft sales???

Posted by: Josh Johnson | September 30, 2011 6:35 AM    Report this comment

I assume the FAA will do to this proposal what it has done several times in the past: just say "no."

I don't see AOPA/EAA doing anything different to generate pressure on FAA to do otherwise - so why would it?

As we say in Hollywood, "what's the motivation?"

Posted by: Thomas Boyle | September 30, 2011 7:26 AM    Report this comment

I agree that the proposed restrictions are complete nonsense and not based in fact. I agree that the 3rd class medical should be dropped completely. There is no question that abuses of the medical approval process create an undue burden on some people, and that fear of being victimized by those abuses causes many pilots to ignore, hide, or delay treatment of potentially dangerous health conditions, thus having exactly the opposite effect on aviation safety as what the medical is supposed to address.

However, I think it's unfair to blame EAA and AOPA for the limited scope of the proposal. Incremental improvement is probably the best which can be hoped for when dealing with an entrenched bureaucracy.

A better proposal, and a more winnable fight, might be to reform the list of disqualifying conditions and/or the requirements for proving medical fitness. Many pilots are subject to great expense and delay in renewal for conditions which have no likelihood of causing incapacitation, and the test-retest cycle with no explanation or recourse is unacceptable. Narrowing the list of medical conditions subject to FAA scrutiny to those with a high probability of causing pilot incapacitation or severely reduced performance, and establishing an efficient appeals process for disputed testing or retesting would serve both to continue to protect public safety and reducing cost and trouble for both pilots and the FAA.

Posted by: Mark Consigny | September 30, 2011 11:45 AM    Report this comment

As a long time supporter of David's petition, I feel he too hasn't gone quite far enough. I recently submiited my own petition which dropped the medical requirement for any pilot exercising Private Pilot privileges in any aircraft which does not require a type rating. I have found no science to support the requirement for a medical certificate for any pilot, much less a pilot using an aircraft for his own use. I would have gone bigger, but it would probably be an overreach at this time in history. Data gathered from experience with Private Pilot operations will support further changes in the future.

Posted by: Steve Rossiter | September 30, 2011 12:43 PM    Report this comment

It's a part that's easy to overlook in the AOPA/EAA proposal, but I think the part that could have the best chance of advancing the cause to drop the 3rd class requirement for private-pilot privileges is the part about requiring recurring training in medical self certification. For those under age 40, it's five full years between required exams, which allows plenty of time for medical conditions to crop up which could affect flight safety. We already have to self-certify before each flight, but there currently aren't any real guidelines about what specifically to be aware of (aside from general guidelines like IMSAFE).

We don't need to be our own AMEs, but some more specific guidelines would be helpful, and will ultimately provide better protection against medical incapacitation than the every-2-or-5-year exams. This especially so if it means not avoiding treatment for a potentially threatening condition for fear of losing one's medical at the next exam. Even something as simple as hypertension that is being effectively treated can hold up re-certification, and things like this really need to change.

Posted by: Gary Baluha | September 30, 2011 1:00 PM    Report this comment

I'm encouraged to see EAA and AOPA finally engaged in a problem that affects a lot of pilots. I would much prefer to see them pursue the NPRM proposedby Mr. Wartofsky over two and a half years ago. The arbitrary restriction of 6000# is acceptable since that weight includes most GA light aircraft. No mention of horsepower,propellers or landing gear. It's simple and has the best chance of getting the job done.

Posted by: Ron Robinson | September 30, 2011 1:06 PM    Report this comment

I wonder what everyone's opinion will be when a handful of people start crashing and killing people on the ground due to medical deficiencies and inadequate "self certifying" as a result of yanking the 3rd class medical out of the system. I also wonder how the victim's friends and family would feel that their loved one was killed by a medically deficient pilot. I wonder how the public's perception of GA would be.

NTSB report:

NTSB: NYC07LA219 Occurrence Date: 09/07/2007 Location: Virginia Beach, VA

Five days before the above accident:

NTSB: NYC07LA209B Occurrence Date: 09/02/2007 Location: Farmingdale, NY

Posted by: William Wang | September 30, 2011 2:26 PM    Report this comment

Mr. Wang, You site two accidents 4 years ago. No activity is safe. How many people die in car crashes everyday?

Posted by: Ray Wyant | September 30, 2011 3:32 PM    Report this comment

I agree with Mr. Wartofsky completely, and I am so grateful for his intelligence and advocacy.

My airplane weighs 2900 lbs gross weight, and I know the extra horsepower has allowed me a great safety margin flying out of Lake Tahoe airport. Other times, my climbouts are steep and safe, so that I can actually glide back to the airport I used for departure! I have 235 horsepower, so I don't want the 180 horse limit.

Posted by: Ron Brown | September 30, 2011 8:52 PM    Report this comment

'I wonder what everyone's opinion will be... I also wonder how the victim's friends and family would feel...I wonder how the public's perception of GA would be.'

Oh, please, enough already. Get informed if all you can do is wonder about everything. If you are a pilot it can do just as much damage to the public's perception of GA to show such fearful trepidation of their opinions and feelings from all of this hand-wringing about what could happen in some future, ill-conceived scenario that has no basis in any reality, than it can worrying about their perception of us. Everyone makes their own world, we have no control over nor should we want any control over what others may or may not think about GA or anything else for that matter.

Since flying my lsa homebuilt now as a private pilot with no active 3rd class medical, I find the added freedom and responsibility of caring for my health and fitness to fly to be much better than before, not to say it wasn't good before. I would think 99% of pilots who would find themselves in a similar position if the 3rd class became history would feel the same way. I support the efforts to get it to go west forever.

Posted by: Dave Miller | September 30, 2011 10:55 PM    Report this comment

I certainly agree with not having the 180 hp limit - a Dakota or 182 isnt harder to fly than a 172. Rome wasnt built in a day though - any steps toward relaxing or removing the medical requirement is welcome by me!

Posted by: Josh Johnson | October 1, 2011 6:32 AM    Report this comment

David's premise is very sound! As are the charges against AOPA being too close to the bureaucracy. They live by keeping us in fear of FAA, too: Charging extra for legal assistance and now medical assistance. Time for a true representation and supporter of the GA population to surface.

Posted by: Chip Carter | October 1, 2011 1:07 PM    Report this comment

I'll put in my $0.02 and say that I think I know what the AOPA is doing. Incremental moves work better with the government. Get a little then go for more. An "all at once" approach seldom works. I'd love to see all Part 91 operations be self-regulated from a medical fitness standpoint. The FAA should publish medical guidelines for potentially harmful drugs and physical conditions for the medical community. That way one's own physician can read up on these guidelinse and advise you if it is safe for you to fly or drive or operate heavy machinery, just as he or she does now. If you get into an accident or have an incident that might have been caused by or made worse by a non-safe medical condition, the NTSB can look into whether or not you flew with a known unsafe medical condition or while taking potentially debilitating drugs contrary to his or her physician's advice. No different than the prohibition of taking certain kinds of OTC cold medication or drinking alcohol and flying. So, let's start by getting the FAA out of the Part 91 ops and then move on to all flying. Put the onus on the pilot and his/her physician.

Posted by: James Posner | October 2, 2011 10:54 AM    Report this comment

No 3rd class medical is going to assure the safety of the general public of which this is supposed to protect. The only force to do this is the pilot and their understanding of reasons why it would not be advisable to fly. No medical reqardless of any restrictions, guidelines, monitoring, evaluating is going to do this. Statistic prove and can be validated that the 3rd class medical has no bearing on the overall safety record for general aviation. The 3rd class medical needs to be scrapped! Let FAA make a case, based on statistics over the past several years that the 3rd class medical in some way has prevented or reduced the accidents based on this data. If they can do that, and can be shown by them in logical form, then continue the 3rd class medical requirement. If not, scrap it.

Posted by: Roland Berg | October 2, 2011 4:19 PM    Report this comment

No 3rd class medical is going to assure the safety of the general public of which this is supposed to protect. The only force to do this is the pilot and their understanding of reasons why it would not be advisable to fly. No medical reqardless of any restrictions, guidelines, monitoring, evaluating is going to do this. Statistic prove and can be validated that the 3rd class medical has no bearing on the overall safety record for general aviation. The 3rd class medical needs to be scrapped! Let FAA make a case, based on statistics over the past several years that the 3rd class medical in some way has prevented or reduced the accidents based on this data. If they can do that, and can be shown by them in logical form, then continue the 3rd class medical requirement. If not, scrap it.

Posted by: Roland Berg | October 2, 2011 4:19 PM    Report this comment

No 3rd class medical is going to assure the safety of the general public of which this is supposed to protect. The only force to do this is the pilot and their understanding of reasons why it would not be advisable to fly. No medical reqardless of any restrictions, guidelines, monitoring, evaluating is going to do this. Statistic prove and can be validated that the 3rd class medical has no bearing on the overall safety record for general aviation. The 3rd class medical needs to be scrapped! Let FAA make a case, based on statistics over the past several years that the 3rd class medical in some way has prevented or reduced the accidents based on this data. If they can do that, and can be shown by them in logical form, then continue the 3rd class medical requirement. If not, scrap it.

Posted by: Roland Berg | October 2, 2011 4:19 PM    Report this comment

One aspect of the proposal from AOPA/EAA that hasn't been discussed here is the restriction to "Recreational" flying.

Recreational flights are easy to cancel. A pilot might feel the weather is marginal or his physical/medical condition is less than perfect. It is a natural decision to cancel if the weather or pilot's health is less than ideal.

Addition of any business motivation to a flight adds a significant amount of pressure. Even a scheduled business meeting makes it harder to cancel a flight.

Commercial operations are worse. Exchange of money for operating a plane makes it nearly impossible for a pilot to say "Well, I am feeling a little bit under the weather. I think I'll cancel the flight." This is even more of a problem when operating scheduled service.

I think the question of what aircraft a pilot should be able to fly is more about the pilot's training than it is about his medical condition. Operating high performance or complex aircraft takes just the same amount of health as operating simple low powered ones. I think the same argument applies to number of passengers, number of seats, or aircraft weight.

I do agree that some sort of step by step approach to reducing restrictions on flight is in order. It makes more sense to do this based on the risks and pressures than on the type of aircraft.

I think reducing the medical restrictions from recreational operations is the logical next step.

Posted by: Paul Mulwitz | October 3, 2011 5:12 AM    Report this comment

Problem with eliminating the third-class medical is as follows: Years ago, Flying magazine columnist Gordon Baxter confessed to losing conciousness while flying (the plane was, thank goodness, on autopilot) for about 10 minutes. Two months later Terry Morgan (son of another legendary Flying columnist, Len Morgan) wrote an angry letter to Flying in which he said, "There I was with 154 trusting passengers and crew, and there he was comatose in cruise, and its only a matter of luck that we didn't meet. .... Is it part of the good order of things that one solitary life should have so much influence over perhaps hundreds of others, because of an impassioned love of a hobby?"

So allowing only a driver's license to fly anthing bigger than an LSA should depend on how thorough a given state's auto licensing agency is, in weeding out those who are likely to black out behind the wheel ... or the controls of an aircraft.

Posted by: Alex Kovnat | October 3, 2011 7:28 AM    Report this comment

Alex,

As I understand it, all states remove driver's licenses from those diagnosed with the kind of ailments you describe.

Also, I don't understand your first scenario. I would have thought any plane carrying 154 passengers would have two pilots. It is the second pilot that protects the passengers - not the medical certificate in the passed out pilot's pocket. I wonder why you think the medical certificate makes any difference at all in these kinds of situations.

I wonder how you make the jump from 154 passenger airliner to 2 seat LSA. Why don't you include any steps between those limits?

Posted by: Paul Mulwitz | October 3, 2011 7:38 AM    Report this comment

I can see the arguments on both sides of the "get rid of the 3rd class medical", and it seems clear that both have some good points. So in that sense, I can see the FAA wanting to move slowly in making any changes, since an enemy you know is better than one you don't, etc.

However, that being said, I don't think any class of medical could have prevented the situation Alex describes. In addition, there have been plenty of documented cases where some unreported medical condition a 1st or 2nd-class medical-holding pilot had played a contributing factor (though not always a causal factor) to some accident. The entire FAA medical process really still depends on word of honor that pilots will disclose *all* medical conditions/treatments/etc at their next exam. Sure, we all sign "yes, I am being fully truthful here, and risk losing my license if I'm not", but if you have a condition that you know is going to cause your medical to be denied anyway, many pilots may think they have nothing to lose by not disclosing.

Posted by: Gary Baluha | October 3, 2011 7:58 AM    Report this comment

If we had government agencies a few thousand years ago there would have been people trying to keep others from from climbing on the horse for the first time.

Posted by: Ray Wyant | October 3, 2011 8:02 AM    Report this comment

Given the history of flight, I can see how the medical came to be. However, a long history of aviation accidents also demonstrates how superfluous a medical requirement is when using an aircraft for personal transportation. The art of historical research should have removed that requirement long ago. Now, the medical requirement is threatening the solvency General Aviation. The basic services needed to maintain the fleet are hurting. It's time for the Third Class Medical requirement to go, so pilots can make an aviation investment without worrying about a doctor taking it all away with the slash of a pen.

Posted by: Douglas Fredlund | October 3, 2011 8:57 AM    Report this comment

Ray Wyant, so only accidents that happen days ago matter to you? At what point do you say to yourself, "well, this accident happened X days ago, so, there's no value." The pilot in the accident report was repeatedly dodging the medical review process, and in denial of his own medical issues, and thankfully, resulted only in the death of himself. A very public one at that.

Dave Miller, I am informed. You may want to read the commenting rules. The first rule is "Please keep it civil."

Gary Baluha, I also believe the reason why there have been so few accidents resulting from medical deficiencies is because the 3rd class medical exists. If you have no medical issues, the FAA won't deny you a medical certificate. Period. I wonder how many of these supporters of the elimination of the medical are in good health. One of the hardest things to do is to say that you have health problems. And even harder for pilots because we love to fly.

If pilots love flying so much, I think the prudent thing to do is live a healthy lifestyle, not chase down a process that IMHO, is working. We all might want to give up the $100 hamburgers and pancake fly-ins for our health's sake.

Posted by: William Wang | October 3, 2011 9:27 AM    Report this comment

FAA....leadership? Best interest of general aviation? Who is kidding who?

Posted by: Thomas Hempstead | October 3, 2011 9:38 AM    Report this comment

Mr. Wang isn't familiar with the facts of aviation safety. It is erroneous to assume that the reduced number of aviation accidents is responsible for the GA safety record. In fact, GA has a long way to go to catch up with commercial operations. That said, historically only 1% of all fatal aircraft accidents have had a medical component. Of those accidents with a medical component, none of the conditions would have been picked up in a Third Class Medical evaluation. Sophisticated database research shows that the requirement of a 3rd Class Medical is superfluous when it comes to safety. However, the contribution it makes toward a pilot's efforts to STAY HEALTHY, knowing he/she has to pass one, would be difficult to measure.

Posted by: Douglas Fredlund | October 3, 2011 9:41 AM    Report this comment

William,

It seems we will never agree on this issue, but let me try one more time . . .

The question here is not whether health is an important issue for pilots. It is whether we need remote government bureaucrats to determine whether we are healthy enough to fly.

If you have an innate need for government blessing for all pilots then the medical certificate is a great idea. However, history with the Sport Pilot rule has shown there is no safety difference between pilots with medical certificates and those with driver's license for medical qualification.

It wouldn't matter whether the bureaucrats were in the loop or not if only they were reasonable in their decisions. Several posters here have pointed out cases where they are overly conservative in their "Judgements". Demands for extra tests and extra documentation for ailments that might not even exist punish honest pilots while other pilots fly along by hiding the truth.

Indeed many pilots fly with no medical certificate and a fair number fly with no license at all. I suspect some of this happens because the bureaucracy has proven to be unreasonable. In other cases I am just as sure it is a matter of selfish decisions by pilots.

We don't need to agree on all of these points. We just have to present our arguments in a reasonable and civil manner and hope the powers in our government make decisions based on the public needs rather than on their own turf desires.

Posted by: Paul Mulwitz | October 3, 2011 9:48 AM    Report this comment

@Paul Mulwitz: I am sorry about the misunderstanding. Gordon Baxter was flying a single engine airplane at the time he admitted in his column in Flying, that he became comatose in cruise. Terry Morgan, son of the late Len and also an airline pilot at that time (1988), was referring to the possibility that G.B.'s aircraft could have collided with his airline aircraft. I'm sorry I didn't clarify this. We have to remember that in 1978 there was an airline disaster, with unfortunately no survivors, caused by a jetliner overrunning a Cessna in California. In all fairness to the Cessna pilot however, it apparently was a tragic error or misunderstanding by the airline crew. Terry M. may well have become spooked about general aviation by that tragedy.

Posted by: Alex Kovnat | October 3, 2011 11:37 AM    Report this comment

I wrote to both my US Senators and my Congressman and asked them to make David's petition a formal bill in Congress. I pointed out my dissatisfaction with the FAA's ridiculous attempt to shelve this until 2099. I suggest we all do the same.

Posted by: Tom OBriant | October 3, 2011 11:58 AM    Report this comment

It concerns me that so many jobs, AOPA and FAA, are dependent on 3rd class medicals. It seems that once a bureaucracy grows to the size of the FAA 3rd class medical team, there is no way they will ever do away with it until they can eliminate all those jobs through attrition, that may not happen in our lifetime. The government wont lay those people off. It is irregardless of whether the 3rd class medicals benefit public safety. I would suggest to the FAA to just charge us a fee to keep themselves employed but let us keep our flying privilege we worked so hard to acquire. Stop pretending 3rd class medicals are an effective way to protect the public. Stop taking away flying from perfectly healthy people. Stop forcing people to hide their medical conditions so they don’t lose their flying privileges. Get rid of the 3rd class medical now!

Posted by: Tom OBriant | October 3, 2011 12:01 PM    Report this comment

Unfortunately AOPA is focusing their efforts on offering us new medical products for $99 per year to ease us through the 3rd class medical process. What a joke. Capitalizing on desperate, honest pilots, in need of a voice. This is like buying protection from the Mafia. Now it would seem to me that the AOPA is profiting from the 3rd class medical fiasco which would make it highly unlikely they will do anything to help the GA community take on the FAA and abolish this ridiculous requirement. This will be my last year in support of AOPA. Historically, useless regulations have done one thing, force honest people to break the law.

Posted by: Tom OBriant | October 3, 2011 12:02 PM    Report this comment

I don't hold out too much hope for success with this endeavor, since such a change would be a tacit admission by a bureaucracy that their past practice has all been essentially a pointless waste of vast amounts of money & man-hours.

Miracles do happen, however. FAA’s “sister” organization the FCC for decades doggedly required & maintained detailed formal licensing of every aircraft, pleasure boat and CB radio transmitter in America. Then, sometime around 1996 they finally admitted it was a colossal waste of effort for essentially no real benefit and lifted the requirement. Wonder of wonders, everything went right along without a ripple.

Posted by: John Wilson | October 3, 2011 12:56 PM    Report this comment

Thank you, Alex.

I understand an unconscious pilot is a scary thing. On the other hand, an airline should be flying IFR with radar coverage in just about all portions of its flight. If the unpiloted plane presented a risk to the airliner I would hope ATC would vector the plane out of harms way.

The real risk to anyone choosing to fly with a private pilot (and just one pilot) is whether or not the pilot is really up to the task of safely completing the flight. It is not up to the government to protect these passengers. Each one should be prepared to make their own evaluation of the pilot's skill, his current condition, and any other potential problems with the flight. This just isn't the same thing as a paying member of the non-flying public hiring a plane and pilot or airline seat.

Posted by: Paul Mulwitz | October 3, 2011 2:36 PM    Report this comment

"Indeed many pilots fly with no medical certificate and a fair number fly with no license at all. I suspect some of this happens because the bureaucracy has proven to be unreasonable."

This is true. I believe most FBOs can name people that don't have medicals, or never received a formal pilot certificate because they can't pass the medical.

This is what happens when people perceive a law or restriction as too onerous--whether it is the 55 mph speed limit, medical certificate to fly, or increased taxes.

Those of us with a conservative bent know this as the "Law of Unintended Consequences"--where an overzealous law results in making things WORSE. Lower speed limits=more people breaking the law. Foolish medical laws=more people ignoring the requirement. Higher taxes=LESS revenue.

The FAA saw what happened with ultralights--nearly all of them were non-compliant. They couldn't put the toothpaste back in the tube with that one, so they changed the law instead.

Free us from unreasonable laws! Make the GOVERNMENT prove that a law is needed before enacting!

Posted by: jim hanson | October 3, 2011 4:50 PM    Report this comment

It wasn't that many years ago that if we wore prescription glasses, we would have to have a SECOND pair available for use while flying--a holdover from open cockpit days, when a pilot may lose his/her glasses in the slipstream. Somebody pointed out that we have closed cockpits now--and the FAA rescinded the rule--only 30 years since it was no longer needed!

When people decide that a regulatory agency has no basis for the rules, and start deciding which rules they will follow and which they will ignore, it starts the "slippery slope."

I'd like EAA and AOPA to turn the FAA argument on it's head--instead of looking at how many fatalities are caused by pilot incapacitation (none), as how many pilots died within the 2 year period of their last medical--after all, THE FAA CERTIFIED THEM AS SAFE! (sarcasm)

Posted by: jim hanson | October 3, 2011 4:56 PM    Report this comment

I think placing restrictions on what you would be able to fly is weak. You have experienced pilots with YEARS OF EXPERIENCE from ATP down to PVT and restricting them when they are very well or overly qualified to fly a lot of aircraft that they are approved in. They should not have to deal with restrictions such as the lesser experienced LSA pilots (NO INSULT INTENDED). We would still have to do our FR to insure proficiency and as we do now even with a 3rd class med have to self certify ourselves for each flight without the blessings of an FAA Med doctor standing at the door of our aircraft before boarding. Pilots other than LSA pilots have gone through extensive training and rigorous testing to earn our license and not to have it degraded and restricted in this fashion. The AOPA & EAA org. should not go in weak - they have the proof for 5 years that the 3rd class medical is a waist of time and money. If I were an ATP pilot and told I could only qualify for the existing proposal I would find it very insulting. We also have not considered new candidates wanting to get into the aviation field and not be a LSA pilot. This is another area that would help the Aviation Industry. Its time to get this passed and move on....It has dragged out too long.

Posted by: Garey Burns | October 3, 2011 7:25 PM    Report this comment

Garey,

It is not just new pilots that have a problem with the medical certificate requirements for advanced training.

Pilots, like me, who have chosen to limit their privileges to those of a Sport Pilot are at a dead end in development under today's rules. I have been flying airplanes, on and off, for over 40 years. I now have enough time and money to do things like try to earn an instrument rating or even multi-engine rating. I can't do this under the current rules because a 3rd class medical certificate is required for these ratings.

We get constant urging from the FAA to improve our pilot skills. However, if we choose not to have a federal medical certificate (which is perfectly legal for flying LSA Day/VFR) then we are not eligible to do what they say they want - train for further ratings.

Posted by: Paul Mulwitz | October 3, 2011 7:44 PM    Report this comment

William Wang, You sited two NTSB reports. In only NYC07LA219 was there a medical issue. The other one involved ear plugs and inattention to the situation. That is one accident in four years. It is not a matter of how many days ago that matters to me it is the total number of accidents. If you can only site one accident that happen 4 years ago there must be almost no accidents that are attributable to medical issues. That is the point of this blog. There is no safety reasons to continue with the third class medical. You are in the vast minority with your thinking. A recent AOPA pole showed over 88% of the respondents would like the third class medical to go away. What really scares me is that you or people with your kind of thinking work for the FAA

Posted by: Ray Wyant | October 3, 2011 8:06 PM    Report this comment

Paul – I concur (point well taken) with you as being able to upgrade your level of training to the next level really does enhance safety. You also have a good point that I overlooked concerning LSA pilots wanting to upgrade to Private or higher level of skill levels. Seems we are always trying to tell the FAA (With a track level to show) why they should do away with the 3rd class medical. The FAA has not shown us valid data as to why they want to keep it in place. It also appears that the majority is for the change (What happened to majority rules)?

Posted by: Garey Burns | October 4, 2011 7:03 AM    Report this comment

@Paul: Thanks. I am glad I clarified my initial post. I would like to point out that in the 1978 tragedy where a B727 overran a Cessna, neither of the pilots-in-command were in any way incapacitated at the moment of the fatal impact. When Gordon Baxter (author for years of Flying magazine's Bax Seat column) zoned out in his plane, it is indeed a matter of hypothesis and conjecture what MIGHT or COULD have happened. Perhaps the only fatality that might have happened had he not regained conciousness, would have been G.B. himself. It is a loss to the aviation community that this great writer ultimately developed Alzheimer's disease or something like that, and had to retire from both flying and writing.

Posted by: Alex Kovnat | October 4, 2011 7:33 AM    Report this comment

Ray Wyant, I'm not about to do your homework and dig through all the NTSB reports to satisfy your need for more than 1 example of gross abuse of the existing regulations on medical evaluation requirements of the pilot. MY thinking is MY thinking and if it's an unpopular thought, well, so be it. What's it to you that I don't agree with the elimination of the 3rd class medical? And frankly, I don't care what AOPA polls or thinks. They have their own agenda with this, which is to gain more members. That's their end game. It's not about the pilots. It's about how much dues and fees they can collect from a bigger pool of fish. And second, I don't work for the FAA.

So far, no one has made a case for why a healthy individual can't obtain a 3rd class medical or why it's such a burden to a healthy individual. In my personal experience and interactions with other pilots, NO ONE has had a problem obtaining a 3rd class medical who are healthy and fit. Not a single one. I have encountered pilots who needed a SODA due to color blindness. I have also known pilots who have legitimate health issues (diabetes) get denied. Honestly, I don't think there's anything wrong with what the FAA is doing. I'm open to be convinced otherwise. So if you want to swing my vote, cite examples. I'm happy to re-evaluate.

Posted by: William Wang | October 4, 2011 9:14 AM    Report this comment

William - here's a case. I've paid over $1500 more for insulin this year. Why - because changing the insulin I'm on to a brand that's covered, even if I've used it before for YEARS, will ground me for 5 - 6 months. Next I've paid $800 this year for my 4 endocronologist visits, instead of the $80 they should have cost. Why - because I'm afraid changing endos is something that will cause the FAA to not issue my SI. I'm also only a few short months out from having to submit my paperwork again and wait for MONTHS to see if some doctor in Ok. City, who doesn't know me or anything about me, decides whether I'm still safe to fly.

I've wasted THOUSANDS of dollars, and months of time, fighting with the FAA to continue my right to fly. p.s. - I'm diabetic - but perfectly healthy.

Scott

Posted by: Scott Powell | October 4, 2011 7:06 PM    Report this comment

William,

The question is not whether you are healthy enough to fly. The question is whether you can prove to a bunch of scared bureaucrats that you are healthy enough to fly.

It gets even crazier when you start to get into the prejudices and secret positions the FAA medical people have when it comes to prescription drug use. Even though the FAA's parent organization, the DOT, has done countless studies that establish there is no relationship between prescription drug use and transportation safety problems, the FAA has its own prejudices and grounds pilots all the time because of medicine they take. These same pilots drive cars and trucks all the time, but the FAA bureaucrats don't approve so they can't fly. n They also don't recognize they have any superiors to answer to in their work.

There are many other examples of the unjustified actions made by the FAA medical people. Just because you haven't heard of them doesn't mean they don't exist. There are 700,000 licensed pilots in this country and you probably have discussed this very personal issue with 10 or 20 of them. They might not have been completely truthful with you. I'm afraid you need to reexamine your position based on a severe lack of information.

Posted by: Paul Mulwitz | October 4, 2011 7:25 PM    Report this comment

I've been playing both sides of this argument, since it really isn't just a simple matter.

Regarding Paul's response to William, what may be true for driving cars and trucks isn't necessarily the same when you're talking about the varying temperatures, pressures, humidity, and various sorts of radiation (UV, etc) that a pilot encounters during a flight. Most of the time this difference is probably negligible, but I don't have the medical background to say it may never be an issue. Does the FAA often take an unnecessarily conservative point of view at times? Of course, but that doesn't mean their point of view is never valid, either.

I think most pilots would love to see the end of the 3rd class, and possibly 2nd and 1st classes too (especially those who have lost their livelihoods due to being denied a medical). But then so too would most pilots be happy without having to abide by the various FARs and doing whatever they feel is safe. However, I think we can agree that at least SOME of the regulations we have to follow came about due to accidents that could have been prevented, and pilots who violate obvious safety issues (VFR into IMC for one) deserve to have some sort of punishment enacted on them if it makes the whole of the pilot population look bad.

Posted by: Gary Baluha | October 4, 2011 8:04 PM    Report this comment

Paul Mulwitz, if pilots are so concerned about the bureaucrats, I'd think they'd do everything in there power to stay as healthy and fit as possible. I know it certainly has been a motivation for me to eat right and exercise. If pilots want to indulge and eat and live an unhealthy life style, then bitch and moan about a system that won't qualify them as healthy, I have zero sympathy for. I'd be more supportive if this initiative is to get rid of ALL the medical certification requirements based on the difficulties with the bureaucrats. But to isolate it to just the 3rd class, I think it smells like a bunch of unhealthy pilots looking to stretch their flying days pass their expiration date. But again, I have yet to see any healthy pilots have problems obtaining a 3rd class medical. And I've met with more than a couple of dozen pilots in my days. You can stop assuming.

Scott Powell, I'm sorry that you have medical issues that has resulted in some difficulty with OK City. Be happy that the FAA is working with you rather than denying you for life. I would be more sympathetic to your case but for you to say that you're "perfectly healthy" given your admittance to your conditions is reaching for the stars.

Posted by: William Wang | October 4, 2011 10:11 PM    Report this comment

William,

This is so frustrating, I don't think I will continue this line of conversation much longer. The 3rd class medical issue is NOT about being healthy. It is about whether a pilot can reasonably determine for himself if his health is OK or if it requires a massive bureaucracy located in Oklahoma City to make this determination for him. The years of experience with Sport Pilots and the driver's license medical qualification have proven the bureaucracy is dead weight when it comes to safe flight outcomes.

I agree that driving a car or truck and flying an airplane have somewhat different medical requirements. Driving a car requires absolute attention all the time. You are controlling a vehicle weighing several tons within inches of another one going in the opposite direction just inches away. When flying an airplane in normal cruise you never get closer than a mile or two to the nearest solid object. Flying requires a lot LESS attention than driving a car. While it is more difficult to learn to fly than to drive the actual activity is a lot easier to conduct.

Posted by: Paul Mulwitz | October 4, 2011 11:03 PM    Report this comment

'But to isolate it to just the 3rd class,I think it smells like a bunch of unhealthy pilots looking to stretch their flying days pass their expiration date.'

Ah, now we're getting somewhere. Unless your refined sense of smell can show even the slightest proof of your accusations of your fellow pilots, you have shown a most outrageous and disgusting form of discourse concerning the unknown, individual reasons for many of us to want to keep flying and share our passion for flight with others.

In addition, to be so obtuse about someone like Scott who may be in excellent health living with a controlled condition - just as I and countless others might be, is judgemental and ignorant of what good health is. Perfect health is an illusion, a mirage, and to believe it can exist is, indeed, reaching for the stars.

Posted by: Dave Miller | October 4, 2011 11:53 PM    Report this comment

To all the William Wang thinkers out there.............AAUGH!!!

Posted by: Ray Wyant | October 5, 2011 7:58 AM    Report this comment

-Be happy that the FAA is working with you rather than denying you for life.

Anyone who believes the FAA is working with or for you is delusional.

The FAA is using our tax money to secure their jobs by creating fear in the public, non-pilot majority. This has nothing to do with safety. If you have ever talked to them on the telephone, they are not on your side.....at all. They are rude and threatening because they have you by the balls and they know it.

Posted by: Tom OBriant | October 5, 2011 8:11 AM    Report this comment

Paul Mulwitz, you are right, I can't continue this line of conversation with you anymore either. We'll just have to agree to disagree. Especially when I read statements like "Flying requires a lot LESS attention than driving a car." Good luck with your flying sir.

Dave Miller, according to the Merriam-Webster dictionary:

health, n. a) the condition of being sound in body, mind, or spirit; especially : freedom from physical disease or pain b) the general condition of the body

I bring your attention to "freedom from physical disease or pain" part of the definition. And I'm not accusing anyone of anything. I'm offering my opinion. I'm not asking you to accept it or forcing you to adopt it. If pilots want to continue to fly, may I suggest they start with a healthy life style? I see pilots on the ramp pushing 250 lbs. or more, heaving for air, and prefer to drive from the parking lot to the airplane rather than walking it. Sounds healthy to me. *add sarcasm*

Tom OBriant, I call the FAA at OK City and my local FSDO often. They've been nothing but helpful in answering and helping me understand the system and how it works. I've also had experiences with CAMI and they have also been helpful. Any time I have a question, I call them and ask, and they're happy to answer. So while I appreciate your opinion of the FAA, my personal experiences with the agency differs quite a bit.

Posted by: William Wang | October 5, 2011 10:32 AM    Report this comment

Guys, I offer my opinion and perspective on this issue. While it's not popular, I also don't think you guys need to get all worked up over my views. If your support group is as huge as you claim it to be, then the 3rd class medical will disappear. I'm simply trying to understand why people think the 3rd class medical is such a bad thing when my personal experiences tells me otherwise. My experiences also tell me that pilots are poor at self certifying. If flying is your passion, do everything in your power to stay healthy and fit. Don't give the FAA any reasons to deny your medical certificates.

Posted by: William Wang | October 5, 2011 10:40 AM    Report this comment

-Don't give the FAA any reasons to deny your medical certificates.

In other words hide all of your medical conditions if you want to keep flying. I am on blood pressure medicine, I was honest about it. At first it was ok, then they wanted 3 BP readings and a statement from my physician, then they wanted a blood test, now they want more readings and another statement, and a second blood test, then they wanted an ECG and antoher statement from my physician. ALL AT MY EXPENSE AND TIME!!! I had to take unpaid days off of work for this nonsense. My medical expires at the end of November and I have been losing sleep over it for 3 months. So get off your high horse Willy Wang, they will eventually get your medical too.

Posted by: Tom OBriant | October 5, 2011 10:54 AM    Report this comment

If you look at the actual number of pilots being denied a medical, it's actually a small subset. However, the number of pilots who have to deal with an expired medical while going through the process of submitting all the required paperwork is likely much larger.

I don't have any numbers or hard evidence to back up my hypothesis, but I think a lot of pilots when faced with having to go through multiple tests and exams to gather the required paperwork to prove they are fit to fly often just decide not to bother. Most of the people I know who have done this (not bothering with the process) are older pilots who seem to feel that it's just not worth the effort. These same pilots that I know also tend to fly only by themselves or with one passenger, and prefer flying simpler aircraft (such as provided by the limitations in the AOPA/EAA proposal).

(to be continued)

Posted by: Gary Baluha | October 5, 2011 11:09 AM    Report this comment

(continued)

If it's just a matter of a pilot being lazy (and I don't mean this in a derogatory nature) of not wanting to go through a bunch of tests to prove they are still fit for a 3rd class (and likely being told by their AME that they can be cleared, or talking to other pilots with similar conditions as them), the AOPA/EAA proposal makes sense. If you're a pilot who only flies on clear days without much wind, in simple, easy to control aircraft, why should they be held to the same medical standard as someone flying in more stressful, demanding situations (such as hard IFR to minimums, or high-performance complex aircraft requiring a much greater degree of concentration to fly)?

Posted by: Gary Baluha | October 5, 2011 11:09 AM    Report this comment

Had to chuckle over "So get off your high horse...they will eventually get your medical too."

Crudely put but accurately paraphrases ex-Philadelphia Mayor Frank Rizzo's comment "Do you know what a conservative is? That's a liberal who got mugged the night before." No one is overly concerned until it is their money or their life that comes under the gun.

You frequently encounter people who say things like "the cost should not be a consideration where safety is concerned". First of all, you can bet it isn't the cost to THEM they are talking about. Secondly, it's an idiotic notion anyway, since taken at face value it means the entire GDP of America should be diverted to, for example, the Quixotic effort to "guarantee that no plane will ever again crash".

Personally, I'm more of a pragmatist on the 3rd class issue. No one has shown me evidence that the (purported) advantages these exams provide are sufficient to offset the disadvantages they carry with them.

Posted by: John Wilson | October 5, 2011 12:10 PM    Report this comment

People forget -- or never knew -- that FAA medical standards were adopted straight from military pilot requirements in the 1930s. Most civil fliers were former military pilots. And the FAA has worked hard to keep that level of adversity in civil flying.

I was privileged to fly with the US Navy for most of my career. Every year that meant a Navy/military flght physical. That means four hours of agony as the flight surgeon and HMs worked hard to find a reason to ground you while they drained and examined most of the fluids from your body. That adversarial climate only made fliers distrust flight surgeons, since being grounded permanently would end your Navy career fast.

This attitude remains today at the FAA headquarters level. I have found most AMEs interested in granting pilots their medical certificates, esp. at the 3rd class level. I am treated well for hypertension and have been for years. That didn't stop the FAA last year from suddenly demanding an insane amount of paperwork despite no changes in my health. Pages and pages of blood tests, urine tests, BP measurements, list of the same meds I've been on for 15 years, an affadavit from my doctor certifying that I was unlikely to drop dead at the controls, and a summary of my health for my entire life. What nonsense.

The adversarial relationship between medicine and flying, betwwen fliers and the FAA, is the problem.

Posted by: Ken Sherman | October 5, 2011 1:09 PM    Report this comment

'In other words hide all of your medical conditions if you want to keep flying.'

And get help with that if you can. Personally I know of several ATP airline pilots with small jars of kidney stones their AME's overlook for them because they have the ability to discriminate - something a faceless government agency is virtually incapable of.

'..may I suggest they start with a healthy lifestyle? I see pilots on the ramp pushing 250 lbs. or more, heaving for air, and prefer to drive from the parking lot to the airplane rather than walking it. Sounds healthy to me. *add sarcasm*

And perhaps he had just lost 20 lbs recently, goes to the gym regularly but fights a lifelong, genetic weight condition where a breath mint puts on a pound of weight he doesn't want. Or maybe he just delivered my daughter, and wants to celibrate it by a short flight. Or maybe he just lost his.

Your high horse is temporary, consider softening the fall you will eventually have from it by walking over and saying hi to your target and offer to help pull his plane out of the hangar. He just might deliver your daughter one day.

Posted by: Dave Miller | October 5, 2011 1:16 PM    Report this comment

Tom OBriant, I can understand your frustration but attacking me isn't going to win you any sympathy nor will it change the fact that you still have to go through the process. Do you really think they will get rid of the 3rd class medical by the end of November?

Dave Miller, we all make life choices. And if the pilot lets poor health choices accumulate over time, that's their problem, not mine, and it certainly isn't the FAA's problem. It was their personal choice. And the consequences is the loss of a medical certificate. And if I offered this person a healthy life style strategy, I'm sure I'll get laughed at and they wouldn't follow it. So they can go ahead and pull that plane themselves. It's a work out they probably need anyway. I have offered pilots help with their airplane, but you know what? Most of them say no. And I'd probably say no too. I wouldn't want someone I don't know touch my airplane either. And let's not go down the genetic path. Not everyone is blessed with qualities to be a pilot. Just like not everyone is blessed to be an Olympic athlete. I'm sure there are AMEs that overlook things, but that's an ethics problem with the AME, not a problem with the 3rd class medical.

(cont)

Posted by: William Wang | October 6, 2011 9:30 AM    Report this comment

Ken Sherman, thanks for sharing your story, and your services!

Yes, there will be a day when my health will cause me to not qualify for a medical certificate. And when that day comes, I'll happily hang up the hat and go fly with someone who can qualify for a medical certificate. The loss of a medical certificate will not keep me from flying. It'll only keep me from flying solo and act as PIC. When that day comes, I'm quite sure I'm not going to feel comfortable flying solo or care about being PIC.

Posted by: William Wang | October 6, 2011 9:31 AM    Report this comment

Willy Wang: If you need the Government to tell you when you should be medically grounded then you aren't psychologically competent to make the tough decisions we pilots must make on occasion. You should probably ground yourself now. I really don't want to share the skies with someone who isn't capable of making their own decision whether to fly or not. Perhaps they should add decision making abilities to the 3rd class medical.

Posted by: Tom OBriant | October 6, 2011 9:42 AM    Report this comment

I think it's important to realize that not all FAA-disqualifying medical conditions are necessarily safety-of-flight issues. For instance, the FAA just allowed several anti-anxiety/depression medications as approved, and even recognized that many pilots were hiding those and allowed a grace period of disclosure. So it is clear that over time, the regulations do change, and pilots who were previously deemed unfit to fly are now suddenly medically qualified.

Also, I was temporarily without a medical for a month while the FAA had to review some paperwork for some medication I was taking at the time. I was never actually medically unfit to fly, but the lack of a piece of paper meant I wasn't legally able to act as PIC. Then, when my new standard (non-special issuance) 3rd class medical came in, nothing medically had changed but now I was suddenly medically qualified again.

Posted by: Gary Baluha | October 6, 2011 10:04 AM    Report this comment

I passed my physical and got my 3rd class. The problem is what happens afterwards. I was admitted to the hospital while I was on the road traveling. It wasn't something I would have gone to the ER for but the docs didn't recommend driving until go it checked out. Due to circumstances I was admitted. This was on in Mar of 2009. After I got home I checked in with my PCP, which is also my AME, and he reviewed the records and said it was good to go and there was no reason to go further. In November I got my physical and all was good. In March the next year the first letter came. At first they wanted more info on the hospital visit. I thought that's reasonable. Then I had to go see a neurologist among many other specialists. An MRI was also done at the FAA request. Now it's been over a year and a half trying to prove I'm healthy. Not one of the reports have said anything negative. I had an MRI at the hospital and another one at their request and neither had anything negative or showed a problem. (continue)

Posted by: Larry Kindrick | October 6, 2011 3:00 PM    Report this comment

Now they want another MRI even though both previous MRIs showed no issues. I'm in contact with DR. Silberman and asked that if they see something on my MRI that warrants another one please let me know what it is so I can tell my neurologist because we're missing it. No response. I also volunteered to go to OKc and see their neurologist in person so he can see I'm OK but he said they don't do that. We don't see people just review records. My AME called them and they to ask what was up but they just said send in the information requested. The problem is if you don't send in what they want your denied. They don't even have to justify the need for a test. Just do it. There is no recourse. There is an appeal but the same people that denied you do the appeal.. What's up with that.. I hope Mr. Wang never has to go through this. Sorry for the lengthy post..

Posted by: Larry Kindrick | October 6, 2011 3:09 PM    Report this comment

I'm sorry about the lengthy posts and this is really the short version. I've spent lots of money and time and they won't even tell me what my "potentially disqualifying condition" is, and my doctors don't know what it is either. They are checking things way beyond the 3rd class requirements and keep going. I just want to let it expire and try and fly LSA. At this point its almost become a crusade. You think "they can't deny the medical because there's just nothing wrong with me" but they can. If you don't get the test they request,even though you've sent it in before, it's game over. They deny you for that. I really think my medical was denied at the first letter but they're trying to find something wrong to make it look legitimate. They are NOT on your side. No matter what Mr. Wang may think. I'm sure I can type for several more hours but I think I'm done. fly Safe.. I can't...

Posted by: Larry Kindrick | October 6, 2011 3:30 PM    Report this comment

Tom OBriant, grow up.

Larry Kindrick, I can see how your situation can be entirely frustrating. However, I also think that it has nothing to do with the validity of the 3rd class medical. If your situation is what everyone is screaming about to get rid of the 3rd class medical, I'd be in full support of requesting the FAA to streamline their internal processes rather than a full out "let's get rid of this class medical". Doing so would be like throwing the baby out with the bath water. Has your AME produced a letter to the FAA certifying your health and qualifications for the 3rd class medical? Personally, I'd get all the doctors to each write a letter attesting to your condition and send it in to OK City. Give them all the documentation so that there is zero reason to deny you. Then start the daily phone calls to CAMI until it is resolved. It is a pain but squeaky wheel gets the grease. And of course, there's always the lawyer route. Have you asked AOPA to help you?

Posted by: William Wang | October 7, 2011 12:59 PM    Report this comment

I have called AOPA several times. Without giving them money they won't help... I guess my dues for the last 30 years isn't enough. My AME DID write a letter to the FAA attesting to my health. We got a letter back saying "thanks for the note", go see a neurologist and while your there get an MRI. He also called to tell them but they don't believe their own AMEs. Why are they even out there? All my neurologists reports have been negative as well as all the other reports. What it has to do with is the FAA having the ability to drag my ass through the briar patch for no reason. If I can pass my 3rd class that should be it... My AME was aware of any problems I had and he cleared me. What's worse is how can someone that's never seen me determine if I healthy? It's more than a pain and unless you've gone through it I don't think you know how it feels. I've done everything and gotten every report they've requested and it's never good enough and they keep asking for more crap. Once I got my 3rd class and my AME said I was fine that should have been it! There's nothing in any report that suggest I have any problems at all. I don't know how old you are or where your from Mr. Wang but you are totally out of touch with reality. Why should I have to get a lawyer if there is nothing wrong with me? I was working with the regular medical guys and now they handed me off to the neurologist and now they want all the same stuff again. It just gotten ridiculous. The FAA is not your friend.

Posted by: Larry Kindrick | October 7, 2011 2:13 PM    Report this comment

Willy Wang, no need to insult me. Nobody cares what you would be willing to support. You are way outnumbered on this one. Sounds like you have some self reliance issues you may want to get some counseling with. Or just grow a set.

Posted by: Tom OBriant | October 7, 2011 2:25 PM    Report this comment

@Larry Kindrick. As my instructor says, "It's all about nuances." You are of the same belief that I was about allowing your medical to expire in order to exercise the privileges of Sport Pilot (or glider, or balloon for that matter). In fact, as long as you don't have a denial or revocation on your record, you could change to Sport Pilot today. Just fly following the regulations of Sport Pilot. For glider or balloon, you could fly today EVEN IF YOU HAVE A DENIAL. As long as you feel that you do not have an impairment that would affect your flying (as you obviously feel at this point), you can fly without a medical. Again, the glider and balloon licenses DO NOT REQUIRE A MEDICAL, not even a a drivers license medical. I am flying as a commercial pilot in a motorglider, without a medical, waiting to meet the criteria for a Special Issuance on insulin.

Posted by: Michael Nutt | October 7, 2011 2:33 PM    Report this comment

They cancelled my medical a year ago because I didn't get the info they requested back in time. they haven't officially denied it yet... Actually it expires this month. I don't know if the FAA will just let it drop or continue even after it expires. I don't plan to try for another one and will hopefully fly LSA in the future. If I were into conspiracy theory's I would say they're doing this to me hoping they catch something so they can say :ah-ha, See! if we didn't have the 3rd class medical we never would have caught this! Unfortunately, they have found any legitimate reason to deny it yet. And they won't because there isn't any. The fight goes on... Not really a fight I guess... I'm just the punching bag. I'll fall on the sword if if I have too, it will prevent future aviators from having to go through this.

Posted by: Larry Kindrick | October 7, 2011 2:49 PM    Report this comment

As everyone knows there is strength in numbers. And, numbers are something we GA pilots are losing every year. The third class medical is one of the reasons for that. If I did not own an airplane I would have thrown in the towel by now. I would think it would be a prudent and wise thing for all of us private pilots to stick together to make flying better. The FAA will be around even if GA goes away. We really need to show a united front to get rid of the third class medical.

Posted by: Ray Wyant | October 7, 2011 7:13 PM    Report this comment

Ray,

I agree with you completely. I think the best way, right now, for pilots to get rid of the 3rd class is to write to EAA and AOPA saying that is what we want.

The current proposal from the leaders of these important groups is very weak. Apparently they don't even know that pilots are already responsible for self certifying fitness for every flight. Their offer to promote this notion to the FAA is just plain silly.

I think it is great they want to put some pressure on the FAA to expand driver's license medical certification. My goal would be full replacement of the 3rd class medical with driver's license. I think this works just fine and gives just as much or more actual safety to the flying and nonflying public.

I have already expressed this position to the EAA where I have been a member for a bunch of years. I got a speedy response thanking me for my comments and saying they really haven't firmed up details of their proposal yet and won't until it is ready to hand over to the FAA. I don't belong to AOPA so I haven't written to them.

I strongly encourage all pilots who think this is the right proposal to write their thoughts and send them to these guys.

Posted by: Paul Mulwitz | October 7, 2011 7:44 PM    Report this comment

This has been an interesting thread. Lots of well-considered input. I cringe at hearing the horror stories and sympathize completely. We need less government in our lives. Having said that, I do agree that some folks are not safe flying from a medical standpoint, either of their own doing through living an unhealthy lifestyle or just from bad breaks. It’s the weeding out process I think that we need to change.

The FAA could save a lot of money by only being in the business of issuing guidelines for the medical community to evaluate their own patients specifically for aviation activities and letting the individual’s own doctor be the final authority as to fitness to fly. He or she is the one who should be on the hook in a NTSB inquiry following any incident or accident. If you develop a medical condition, the first person you are going to consult is your own doctor. He or she, in the process of treating you and/or prescribing medication, would advise you at that time to stop flying or not. If he or she says to ground yourself and you don’t, YOU are on the hook with the NTSB. This would simplify the process and put some logic back into it.

Continued…

Posted by: James Posner | October 8, 2011 2:25 PM    Report this comment

Continuation…

For example, in the FAA’s guidelines, they can recommend certain tests and acceptable results for certain conditions for the doctor to use in his or her evaluation. They can suggest which medications are not prudent in certain timeframes, etc. They can also suggest other safety-oriented testing such as periodic drug screening which they don’t even deal with today. But, at the end of the day, the best authority is the pilot’s doctor(s), not the FAA’s. This would be true for any class of medical certification.

The pilot’s physician would issue a letter to the pilot stating that he/she is good to go that would be “good until cancelled” with an annual physical being required (something we should be doing anyway and is usually covered by insurance). If you develop a condition or require medication that should ground you, he or she would issue you a letter stating that. When your condition improves and/or you stop taking or stabilize using the medication, he or she reissues the “good to go” letter.

Posted by: James Posner | October 8, 2011 2:26 PM    Report this comment

James,

I don't see how replacing experienced AMEs with inexperienced ones will enhance safety for anyone. Perhaps there is merit in your idea, but you would need 7 years of experience with it to compare it to the Driver's license qualification.

It is the experience we already have using state Driver's licenses for medical qualification with no medical incapacitation related accidents. This experience is the basis for the current proposal to eliminate the 3rd class medical at least in part and perhaps completely.

The simple truth is the states protect their highways from really medically impaired drivers already. It is leverage on this in-place system that makes the driver's license medical qualification for pilots a great idea.

Posted by: Paul Mulwitz | October 8, 2011 6:38 PM    Report this comment

The bottom line is that the number of fatal accidents caused by a medical problem detectable by a doctor during a 3rd Class Medical examination doesn't meet test of statistical significance (P> .05), meaning it doesn't do anything worth while to contribute to the cause of aviation safety.

Posted by: Douglas Fredlund | October 8, 2011 7:15 PM    Report this comment

Douglas,

As mentioned a number of times in this exchange, it never was about the silly exam related to the 3rd class (or 2nd or 1st) medical certificate. This whole issue is about the abusive medical bureaucracy in the FAA and the disclosure of medical conditions by pilots every time they fill out the forms to apply for the certificate.

The actual AME exam is just a trivial formality.

Posted by: Paul Mulwitz | October 8, 2011 7:39 PM    Report this comment

Paul, I think James' idea was about keeping some sort of medical professional in the loop on a regular basis, to supplement the pilot's own pre-existing self evaluation prior to any flight. This would actually mean /more/ medical evaluation than a driver's license, which basically consists of "is the person not dead, are they minimally color-sighted, and are they not legally blind". In fact, I don't recall even having to re-take any medical evaluation at my last driver's license renewal. Having some sort of medical evaluation is better than nothing, I would think.

Posted by: Gary Baluha | October 8, 2011 7:58 PM    Report this comment

There are some on this thread that think living an unhealthy life makes disqualifies them from flying airplanes. WRONG!!! Nothing in the FAR's says we have to live a "healthy lifestyle." So go ahead and eat your tofu and I will eat my bacon and we are both equally qualified to fly airplanes. Don't think for a second you are any healthier than anyone else based on that ridiculous, outdated 3rd class medical.

Posted by: Tom OBriant | October 8, 2011 8:35 PM    Report this comment

Tom, Sure, lifestyle choices certainly doesn't automatically medically qualify or disqualify someone to fly an airplane. An overweight, non-exercising alcoholic may very well be a far better aviator (of course, following the "8 hours" rule, in this hypothetical situation) than the super-athlete across the ramp. I think the point people are trying to make is that for most people, eventually that unhealthy lifestyle is going to catch up to them. But that's true regardless of who is doing the medical evaluation, and if we can't trust pilots to have the discipline to do the right thing, then we'll end up having to fly with an FAA regulator and AME with us on every flight.

Posted by: Gary Baluha | October 8, 2011 8:46 PM    Report this comment

Gary,

I don't know why this is so difficult to understand.

IT IS NOT ABOUT THE SILLY EXAMINATION.

For state driver's licenses, the gating item is the actual diagnosis of a disabling ailment by your own doctor that stops you. As soon as this diagnosis is made the state is notified and your license goes away. Nothing you do or don't do can change this arrangement. It is the state protecting its roads and citizens from really dangerous people. There is no procedure like this in the federal medical certificate program. So, the state driver's license is a better real-time measure of your fitness to drive and fly than the federal medical certificate.

Still, with all its problems and related protection from the state program pilots still manage to avoid causing accidents due to medical incapacitation. The accident records for both pilots with medical certificates and those who use driver's licenses today for medical qualification show this to be the truth. The whole business of medical certification is a waste of time, money, and good will.

On the brighter side, the state driver's license is a lot less intrusive into the lives of people who actually are quite capable of making the fitness decision on their own. In that way the driver's license is a much better solution to the need for medical certification than the federal medical certificate.

Posted by: Paul Mulwitz | October 8, 2011 8:53 PM    Report this comment

Paul,

That sounds like an examination is involved, one way or another.

I think the ultimate goal of whatever medical certification standard is used, is that pilot's take it upon themselves to verify they are fit before each flight, and that they see a medical professional on some regular schedule to catch anything that could be hidden or lead to having to disqualify one's self at some point. It's just a matter of: how often does one visit a medical professional, what type of doctor do they visit, and what knowledge do they have to self-certify before each flight.

Ultimately, I agree that the existing 3rd-class medical is mostly a vestigial standard that doesn't accurately represent the medical capacity of today's private pilots. However, government processes are slow to change, and they haven't kept up with the pace of everything else pilots have access to, to make their own decisions on what is safe and what isn't.

Posted by: Gary Baluha | October 8, 2011 9:08 PM    Report this comment

Gary,

I think I agree with your comments except for the notion that there must be regular exams. I do think that is a great idea from the perspective of doing what you can to preserve your health and prolong your useful life. However, it just doesn't matter when it comes to medical qualification to drive or fly.

The kind of things that really should disqualify a person from these privileges are only those that really present a clear problem for safe performance. A good example of the kind of ailment that really prevents safe performance is certain kinds of epilepsy. If you are likely to become unconscious with little or no warning then driving a car or flying a plane or any other kind of operating of a potentially dangerous machine is a really bad idea. That is why the states require doctors to report such ailments.

So, you probably will say -- but if you don't get a regular exam then how will the problem be discovered. The answer to that is the ailment will be discovered because you pass out in public or some other place where you are "Forced" into getting medical attention. The act of getting a regular exam might prevent the problem, but once you are afflicted with such a horrible ailment it will become known.

Posted by: Paul Mulwitz | October 8, 2011 9:49 PM    Report this comment

It isn't about the 3rd class for me. I passed the medical and was cleared to fly by my AME. He's also my PCP so he's known my medical condition for the last 20 years. It's about the FAA having the power to just ground you for no medical reason. Or have you jump through hoops for a year and a half even though not one medical report or test they've requested (demanded) is positive. The fact that some scared bureaucrat in OKC that's never seen me is deciding if I'm healthy enough to fly. It's about the fact that they keep having me get tests but won't tell me why I need them other "than we just want them". Its the fact that their AME in the field, that they certified, apparently isn't qualified to determine my health. If you've seen some of my posts you'll know what I'm talking about.. I could go on but breakfast is ready... Tofu and Bacon... Mmm Mmm good!

Posted by: Larry Kindrick | October 9, 2011 8:02 AM    Report this comment

Tofu and Bacon....opposite sides of the health spectrum for balance, eh? :)

Regarding the obligation of doctors to the states, my PCP says many states have voluntary reporting of patient health issues, and there are more to come. Considering that and the inbred strictness of entities like the FAA, I can't imagine them allowing such freedom and slack regarding medical issues to be handed over to voluntary state requirements.

James Posner's idea, which many of us have wondered about too, is the way to cut government spending while actually enhancing care. However, it begins to use common sense and government efficiency, so it may have little chance for success. One small example I just had is being found to be very low on Vit D, supplemented now, and happily a clear prostate exam, neither of which would be found with the token third class medical.

Nature abhors a vacuum, but government often takes it further and rejects it, so unless they can cover their jobs, I'm not very hopeful.

Posted by: Dave Miller | October 9, 2011 12:58 PM    Report this comment

--- I can't imagine them allowing such freedom and slack regarding medical issues ----

Yeah, I suppose it does seem out of character, but that is exactly what the FAA has done with Sport Pilots and others limiting themselves to SP privileges.

The really good news is after 7 years there have been no incidents of problems with this form of medical certification. So whether it seems in character or not it is reality and expanding it to recreational use by more pilots is a small step.

This whole discussion started with the question of whether or not the EAA/AOPA goes far enough with expanded pilot privileges with Driver's license medical certification. There is nobody who doubts the driver's license does the job since the history of its use already shows that. The big question now is how far to take this freedom from the bureaucrats.

The first cut from the AOPA/EAA leaders is merely a fat LSA and just one passenger as well as VFR/DAY limits. Most of us think it should go a lot further.

We are about to learn whether the leaders of these alphabet groups actually represent their membership or just use the members to justify their own actions.

Posted by: Paul Mulwitz | October 9, 2011 2:54 PM    Report this comment

How many people would really get behind the yoke of an airplane if they felt like they were going to die that day? None! How many people know what day they are going to die? None. How many people have had their death day predicted by the 3rd class medical? None! How many people have been grounded for many of their golden years because of the 3rd class medical. Thousands! How many lives have been saved by the 3rd class medical? None! Show me the numbers. Zero! How much money has been collected by the FAA for 3rd class medicals? Millions! It is a scam!

Posted by: Tom OBriant | October 9, 2011 6:45 PM    Report this comment

Every time I take my 3rd class medical my vision is checked, my blood sugar (via urine) and a half dozen other superficial but very real medical checks are performed. The last time my eyesight was evaluated for a drivers license, I was 16 years old. No motor vehicle bureau has ever checked my blood sugar, my equilibrium, my heart, blood pressure, etc. In fact they don't even care if I can understand English. I understand the gusto LSA pilots bring to this debate--I'd hate to argue global warming, evolution or right to work with these guys, but get a life, boys.

Posted by: Richard Herbst | October 12, 2011 2:26 PM    Report this comment

Let's face it, FAA is not going to give-up the 3rd class medical requirements, even though it can be proven that it makes no sense and does nothing to promote safety. FAA has no accoutability to make change and can continue along their same enforcement practices. AOPA/EAA's attempt to make some changes by asking for exemptions to the current regulations is a soft approach instead of taking a stand of eliminating the 3rd class entirely, proving through statistical facts that the 3rd class medical has no bearing on promoting safety. It allows FAA to continue their current practices, with no non-partial body to look at this issue and make a determination if the current practices should be continued. The only body that could do this would be the DOT oversight committee of congress. What would it take for them to look at this issue?

Posted by: Roland Berg | October 14, 2011 6:36 AM    Report this comment

Roland,

I think you are mistaken about the FAA. While they may be slow to change they are quite capable of doing just that.

The Sport Pilot/Light Sport Aircraft rule is proof positive the FAA can change from black to white with the right motivation. I don't know exactly what that motivation was, but I'm sure it included an interest in promoting general aviation and a reluctance to give up their authoritarian position over pilots via the medical certificate. They made some wrong guesses how this big change in direction would work out, but it did turn out to be a good move regarding medical certification for recreational flight. I think they may surprise a lot of nay sayers and jump on the opportunity to answer a reasonable request with a generous response. You see, I think they know just as the pilot population knows that the 3rd class medical is of questionable value at best.

What I think they need to give this issue enough priority to make a move is something like the push from EAA/AOPA. I'm optimistic we will have a rule change or at least a proposed rule change by next Summer.

Posted by: Paul Mulwitz | October 14, 2011 8:51 AM    Report this comment

Paul, Don't mean to be controversal, but guess I will. The reason the medical requirement for sport pilot was revised to use the driver's license in its place, is that it was forced on them and FAA retained some of their authority by requiring non-founded requirements for flying light sport aircraft. e.g. altitude, night flying, maxium speed, weight restrictions. Again, imposing arbitrary restrictions that has no basis in fact or safety. FAA has no evaluating system to determine the proper way to make exemptions to the regulations or amending regulations. If the regulatory option is used, it is only proposed comments are considered from a select few, this being in vain, becuase they have already pre-determined the outcome. Do you think these restrictions make any sense. Scrap the 3rd class medical requirements, none have any bearing on flying aircraft or the safety of the general public.

Posted by: Roland Berg | October 14, 2011 11:34 AM    Report this comment

Roland,

I know I will get some push back from the Sport Pilot community on this point but it is important right now. I think the reason for all the restrictions on Sport Pilots is the bare bones level of training they get. It is not about the medical qualification.

I suppose there could be a medical issue with night flying, but VFR/IFR, higher altitudes that require oxygen, retractable gear, constant speed propellers are all about keeping it as simple as possible for the Sport Pilots. There is no medical issue with remembering to lower the gear or adjusting RPM separately from the throttle.

For properly qualified pilots I think it makes sense to consider the medical qualification separately from the training and experience issues. So I think the 3rd class requirement should be eliminated for all pilots and all aircraft and all operating conditions and all numbers of passengers so long as the mission is recreation rather than business related. I hope the FAA sees it that way too.

Posted by: Paul Mulwitz | October 14, 2011 12:09 PM    Report this comment

Based on fewer comments lately, it appears that most think that we are speaking to ourselves with no influence on the decission making process of FAA. Many think the 3rd class medical has no validity and should be eliminated. AOPA/EAA's proposal to broaden the base to include other aircraft with limitations is frankly demeaning. In order to use the driver's license a rated and current pilot must, complete a course course on aeromedical issues (certainly the pilot would not be able to make a determination of disqualifying health issues without this), limiting the passenger to one (of course pilots would be willing to risk the safety of one passenger but not three), restricting to daytime flying VFR (certainly by using the driver's license we would not be qualified to that - should that not be dertermined by currency?), and the numerous other restrictions that would be imposed. That AOPA/EAA offer comprimises and to pacify FAA makes no sense, must be someone at FAA that could add two-and-two togather and not make five. Provide an exemption to the regulations to eliminate the 3rd class medical for recreational flying, it can be done without going through the lengthy proposed rule making process.

Posted by: Roland Berg | October 24, 2011 7:52 AM    Report this comment

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