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Details of the AOPA-EAA petition (Drivers License Medical)

About time. In my experience, the current 3rd class medical requirement is counterproductive. I sure hope the EAA and AOPA can make this happen.
 
Looks like Rocket and RV 10 folks get left out.

Also, those of you with more than 180hp are sol.

I applaud the effort, but feel there is a lot more aircraft that should be included in this proposal.
 
They also said "non-complex" aircraft.

In your US setup, does that put aircraft with a constant speed prop outside the scope of this proposal?
 
US Complex Defination

FAR Part 61.31 (e) defines Complex as

(an airplane that has a retractable landing gear, flaps, and a controllable pitch propeller; or, in the case of a seaplane, flaps and a controllable pitch propeller).

Must have all three.




They also said "non-complex" aircraft.

In your US setup, does that put aircraft with a constant speed prop outside the scope of this proposal?
 
So if you are instrument rated and using your drivers license for self certification while on a VFR cross country and Wx requires an instrument approach at your destination you'll be in violation... uh oh.
 
Also, those of you with more than 180hp are sol.

Hmmm... The data plate on my Superior XPIO360 does not mention HP but it dynoed 188... Even if Lyco says it's 200hp, how does one know what any individual engine puts out without dynoing same? How about a placard that says something like "Under no circumstances is this engine to be run at a power setting above 180HP?"

I believe Carbon Cubs gets away with a similar deal for their 180 HP "light sport" thing..
 
I hope the EAA and AOPA efforts are successful. My concern is that during the discussion, it was stated they want this to include Cessna 172's and Cherokee's. These are 140 MPH airplanes. Very close to the 138 MPH/120 KT limit for Sport Pilots.

Would an RV 7 be included? It depends if there are speed limitations as there are on the Sport Pilot license. The proposed 180 HP limit is fine as long as long as I can still cruise at 180 MPH/155 to 160 KTS.

I would much rather finish my RV 7 and not have to consider moving down to an RV 12.
 
Greeat Big Thanks..

I would like to take the opportunity to thank EAA for creating the Light Sport catagory and the industry that we now have..
I would like to also take this opportunity to excoriate EAA and AOPA for their Joint effort to kill the industry in one fell swoop. The light sport industry will not survive the announcement of the proposed exemption..
 
I would like to also take this opportunity to excoriate EAA and AOPA for their Joint effort to kill the industry in one fell swoop. The light sport industry will not survive the announcement of the proposed exemption..

It certainly will impact the market; however, I think the biggest thing that the LSA manufacturers have going for them is the ASTM compliance versus Part 23 certification. A new 172 is still going to cost a LOT more than a new CTLS for instance. And yes, some people may cross shop a used 172 with a new LSA for similar cash. Will our hypothetical buyer want to buy a much larger, older plane than the mission requires and feed it more gas? Remember, you can't haul any more passengers in the 172 under the proposal. The 172 does have a lot more payload. Or will the buyer opt for that very sweet all glass panel and the responsive handling in the LSA? It's the buyer's choice.

I think, given the innovations the LSA manufacturers have brought to the table, the industry will survive. Certainly, some manufacturers may suffer from "new" competition; however, that isn't necessarily a bad thing as competition improves the breed!

Really, I see this proposal as making it easier for folks to find planes to rent and fly. As for buyers, it just adds another variable to the purchase equation.
 
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So if you are instrument rated and using your drivers license for self certification while on a VFR cross country and Wx requires an instrument approach at your destination you'll be in violation... uh oh.

The proposed exclusion negating the need for a 3rd class medical contains several limitations, among them as described in the video is that flying would be limited to daytime VFR. Therefore, it seems likely that a person will still need a 3rd class medical to obtain/maintain an IFR rating.
 
The proposed exclusion negating the need for a 3rd class medical contains several limitations, among them as described in the video is that flying would be limited to daytime VFR. Therefore, it seems likely that a person will still need a 3rd class medical to obtain/maintain an IFR rating.

Or, utilize the rear seats in my 10------even if they up the HP limit.
 
It's just really frustrating as an LSA manufacturer to be fed, nourished, supported, and encouraged BY EAA to invest our blood, sweat, millions of dollars and nearly a decade to grow this industry, and suddenly that same organization torpedoes us and leaves us for dead. We really, truly feel betrayed by this. It's like they never even thought through what would happen to us... or, maybe this was part of the plan from the beginning, and we were just sacrificial lambs to "prove" you don't need a medical to safely fly. Our industry is hanging on the prop right now.... Like in slow flight, where you can hold your own altitude, move forward, even climb a bit, but reduce the throttle just a bit, and you stall. Every customer and every sale counts in this industry. Now, we might lose half or more of our customers because guys that are losing their medical might be able to keep their old airplane or buy a used airplane for half the cost of new. How many RV-12's do you think Van will sell when people have the option of flying their RV-7, 8, or whatever?

The LSA industry is doomed unless we can modify LSA criteria to compete with a 172 or an RV-8. We are the minority, and it's our problem. I have mixed emotions personally-- I'm glad I'd be able to fly my RV-3 til the day I croak (and all my friends will be able to fly theirs). I'm not looking for sympathy and I don't want to argue-- I just want people to understand this isn't sunshine and rainbows for everyone. Good people will lose their jobs over this.

Anyone hiring? :(
 
I think eliminating the 3rd class medical should be the goal, not creating a super-Sport Pilot level. I do not understand how the medical certificate has anything to do with day/night flight, the amount of HP, or how many passengers. Is there any evidence that more medical issues occur at night, or with a bigger engine, or with someone in the back seat?
 
I would just like to see the Sport Pilot limitations relaxed to include aircraft with a higher gross, many light sport aircraft could be certified for higher weights and speeds. It would be nice to fly the Jabaru that I am training in without having to make sure the fuel load is less than 17 gal because of the weight of two people when the aircraft's origional design had a much higher gross limit but the certified weight was lowered to meet LSA standards. It would also be nice to have access to a larger selection of available rental aircraft.
 
....The LSA industry is doomed unless we can modify LSA criteria to compete with a 172 or an RV-8. We are the minority, and it's our problem. ...:(

The US should have adopted the 2003 EU CS-VLA category at 750 Kg (1653 lbs) max weight (or MTOM in EU terms...:)...) instead of going off and inventing their own standard.

The resultant aircraft for be much more useful than the 1320 max of a LSA if carrying two US near "bubba" sized folks on a trip.

In circular standards logic - the EU has now adopted the LSA standards, including ASTM standards, but with some additions, like CS props and retractable gear.
 
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...The LSA industry is doomed unless we can modify LSA criteria to compete with a 172 or an RV-8...

When people complained about the super high cost of these LSA aircraft (compared to older Cubs, Champs, etc), the response from "the industry" was that these are new airframes, packed with technology, etc. If that is indeed the case, then the industry will be able to hold its own in the market by providing a product people want. On the other hand, if the market exists only because of a "loophole" (the medical issue), then people are "settling" for LSA's because they have no other choice. If so, then the LSA market is built on a shaky foundation of dubious rules and regulations, and therefore doomed from the outset.

We need rules and regs that are practical and make sense. After that, a free market will sort itself out.
 
"The US should have adopted the 2003 EU CS-VLA category at 750 Kg (1653 lbs) max weight (or MTOM in EU terms......) instead of going off and inventing their own standard."

Yep... then our little Jabiru "LSA," at its original max gross of 1540 lbs, could haul 2 burger-lovin American Bubbas, full fuel, AND a whole load of golf clubs! :D If we had that, we'd be in better shape to compete with a 172 for the no-medical crowd.

And yes, my hope is that people will continue to buy LSA because it's what they want-- a new airplane for 1/4 the cost of a new 172, pretty, fun and full of electronics. Our customers right now are the pilots who don't want to settle for an old Cub or Champ... so hopefully they won't settle for an old Cherokee either. (but they might go for an RV...) I guess time will tell... and this rule has to pass first.
 
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The light sport industry will not survive the announcement of the proposed exemption..

The LSA industry has been one of the biggest obstacles to making changes to the LSA rules like increased weights, speeds etc, things that most pilots would love to see. For that reason, a small part of me feels that the industry would be getting their comeuppance.

This is one of the problems with an industry created by arbitrary government rules and not true market demand. The same thing is happening in the green energy sector (anybody want to buy and ethanol plant cheap?) for the same reasons. What the government giveth, they can taketh away.
 
I'm sure it would have an impact on the market but having a plane that burns very little fuel, doesn't cost a fortune, has great visibility and can be trailered home as in the RV-12 will still have a market.
 
Worried/excited about nothing?

Hasn't AOPA and EAA been arguing for this for years? What's different this time around that makes it any more likely to get into the regs?
 
Hasn't AOPA and EAA been arguing for this for years? What's different this time around that makes it any more likely to get into the regs?

I doubt anything will happen, but EAA and AOPA are not seeking a regulatory change at this time, they are seeking an exemption. They feel that is an easier route. They give some examples of exemptions being granted in the past.
 
The LSA industry has been one of the biggest obstacles to making changes to the LSA rules like increased weights, speeds etc, things that most pilots would love to see. ....

I bet the FAA set the max 1320 lbs gross weight, not the industry.

Once the standards are set, changes get performed at a pace slower than a snail...:)
 
A couple of things

There are a couple of things that haven't been mentioned. 1) I wonder what the insurance companies will have to say about this? If they frown on the idea and still want a Medical, then a greater possibility exists of folks flying around without insurance. I'm not so naive as to realize this isn't already occurring.

2) To me, an aircraft is an aircraft. How different is a 1320 pound airplane spiraling into a school than a 1800 pound one. Also, don't know what the difference is between day and night?? Why that restriction?

3) Finally, I don't think this will pass the "head line," test. I can see it now, "Pilot involved in fatal airplane crash didn't have FAA medical certificate." It matters not the details. So many people only read the head lines.

Popcorn ready. This is going to be a good one:mad:
 
And a few more things not mentioned...

It is not just a very difficult, sustained poor economy that has kept Katie and the many others involved in the LSA industry from thriving. The demand - for the SP license and the LSA's currently being offered - simply hasn't developed well. The pre-GFC numbers for SP student starts and LSA sales were not impressive and SP student starts continue to be underwhelming relative to PP student starts. The cost of a SP license is generally agreed to be ~$7500, a not insubstantial sum, after which most of the airports in the country don't offer convenient choices in LSA rental a/c for the SP to use and remain current in. (And this in turn is due to both the cost of most LSA a/c and the resistance within the GA pilot training industry, who give up potential training hours to switch to the SP curriculum). Bottom Line: This is a bootstrapping process and, while it strikes me as being very healthy for General Aviation overall in the long term, there was apparently a lot of over-forecasting upfront.

The immature nature of the LSA industry is itself a big problem right now. There are ~112 LSA FAA-approved models now being offered for sale in the USA right now while there were only 126 LSA registrations (aka: sales) recorded in the first 6 months of 2011. (So... there are perhaps 40 or 50 individual businesses trying to compete for annual sales of 250 aircraft, clearly an unsustainable circumstance). In that same 6 month period, six manufacturers accounted for 90% of those sales. (www.bydanjohnson.com/Sidebar.cfm?Article_ID=1499) Bottom Line: This very youthful industry is already experiencing the typical & inevitable economic shakeout that all new industries experience, and its marketplace really has been - so far - underwhelming. Entrepreneurs who choose to jump in on the front end of any new technology usually (should) understand they are accepting additional risk along with the promise of great(er) initial financial reward.

There are other steps the LSA industry could have chosen to take that would be to the industry's overall benefit - establishing a standardized manufacturing quality assessment process would be one such step - but given the intense competition and low profit margins, the dynamic of the LSA industry as a whole has been akin to the Tragedy of the Commons. (http://en.wikipedia.org/wiki/Tragedy_of_the_commons)

Personally, one of the things I like best in the proposal, which I notice no one is mentioning, is putting a formal process in place for 'medical currency'. Many, many pilots get their license in their younger years and then continue to fly while new physical conditions emerge, new meds are prescribed, and the aging process itself all impact their 'fit to fly' decision-making. Either an ASI or Wings course, on-line or held regionally, would be a simple, cost-effective way to implement this.

Jack
 
Eliminate all medicals

Why do any pilots need a medical is the real question. Do commercial drivers need a medical? The chance something bad happening if they are incapacitated when driving a bus load of people is greater then a ATP just because they do not have a copilot. All regulated by the same government agency, the Dept of Transportation. What are the facts on how many accidents are caused by medical issues in a plane? In a bus? In a semi truck?
If the FAA is going to use data on EAB being more unsafe then certified, they should use their own data to show how few accidents happen in all transportation due to medical issues with the operator.
 
What about seasoned citizens..

If the commercial driver analogy doesn't work, how about the seasoned citizens and our "snow birding" culture. You need no special drivers licence, let alone medical, to purchase a monster motorhome, truck trailer, what have you and head down the road at 70mph towards someone else doing 70mph in the opposite direction passing each other several feet apart.
 
Why do any pilots need a medical is the real question. Do commercial drivers need a medical? The chance something bad happening if they are incapacitated when driving a bus load of people is greater then a ATP just because they do not have a copilot. All regulated by the same government agency, the Dept of Transportation. What are the facts on how many accidents are caused by medical issues in a plane? In a bus? In a semi truck?
If the FAA is going to use data on EAB being more unsafe then certified, they should use their own data to show how few accidents happen in all transportation due to medical issues with the operator.

There was a test run in the 70's by the Soaring Society of America.

As you know, no medical at all is needed for glider flying. The SSA analyzed the fatal glider accidents caused by medical problems, and found that XX % had FAA medicals since they flew power planes as well. This XX % was essentially the same percentage of the glider pilot population that had FAA medicals - so pilots that had no medical did not have a greater percentage of fatal accidents.

The study was pre-internet and I can't find a link to it, but IIRC the XX % was around 40. The push for medicals at that time was by the AME doctors (more business?), and the SSA was pushing back. The doctors lost.

This "test group" is still flying around with no medicals so the study could be repeated and updated....:)
 
Why do any pilots need a medical is the real question. Do commercial drivers need a medical?

When I earned my Commercial Driver's License in Wisconsin for driving a 16 passenger bus, the DOT would not accept my FAA medical as proof that I was fit. They required that I spend the money and pass their own medical exam.

Take a look at Sport Pilot limitations and why they're there. Pilots have to be healthy enough to deal with altitude and loss of air pressure/hypoxia that goes with it (10,000 foot Sport Pilot limit). We need to see traffic (slow cruise speed). We can't suffer from vertigo or dizziness (VFR Day only). We have critical training to remember and properly execute in emergency situations (airplane with simple mechanics, not "complex"). We don't just keep a vehicle between two painted lines, we have three dimensions plus time to worry about. (And nobody paints lines in the sky for us to follow like sheep.) Don't forget how much harder it was for you to get your private pilot's license than get your driver's license. There's a lot more to do to fly a plane, and a whole lot more ways to kill ourselves. Don't forget about medications that impair judgment, adding to the accident chain (1 passenger limit and small light airplane to minimize risk to passengers and folks on the ground). Any idiot can drive a car. This isn't apples and oranges.
 
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Another small factor.....

was brought up by our instructor at our last DAR seminar in Ok City.

The "sport pilot" certificate is a U.S. only certificate.

The private pilot certificate is recognized internationally.
It would be much more difficult to get the "no medical" passed.
 
The push for medicals at that time was by the AME doctors (more business?), and the SSA was pushing back. The doctors lost.
Caveat: I have not read the article referenced in the original post, so I am not commenting on the merits of any specific proposal.

Speaking for myself: this AME is not pushing for more business. Maybe in the 1970's they were.

Flight physicals are not a money-making proposition for most of us.

The FAA, even though it is a difficult bureaucracy to change, has become in my opinion very reasonable with regard to issuing medical certificates to individuals with significant medical problems (coronary artery disease, diabetes, etc.) Granted, the process for these special issuances can be painful.

Honestly, here is the way I think about it: if someone has a medical condition that does not permit the issuance of a third class medical certificate, I would not want him taking my child on a Young Eagles flight (for example). Yes, the risk of incapacitation is small, but if it is your child or grandchild in the right seat.....

I do believe the FAA's primary concern is for public safety.
 
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The FAA, even though it is a difficult bureaucracy to change, has become in my opinion very reasonable with regard to issuing medical certificates to individuals with significant medical problems (coronary artery disease, diabetes, etc.) Granted, the process for these special issuances can be painful.

Honestly, here is the way I think about it: if someone has a medical condition that does not permit the issuance of a third class medical certificate, I would not want him taking my child on a Young Eagles flight (for example). Yes, the risk of incapacitation is small, but if it is your child or grandchild in the right seat.....

I do believe the FAA's primary concern is for public safety.

That's a good point, Troy. Denials of a medical certificate are often (usually?) due to the existance of a condition that makes it unwise for you to act as PIC. We probably do need to accept that there is some limit where restrictions on flying are probably necessary.

Maybe putting a better system in place to evaluate and process special issuances with minimal red tape delay would be a better proposal.

...and I'd like to see another 250 lbs allowed under LSA rules.
 
Take a look at Sport Pilot limitations and why they're there. Pilots have to be healthy enough to deal with altitude and loss of air pressure/hypoxia that goes with it (10,000 foot Sport Pilot limit). We need to see traffic (slow cruise speed). We can't suffer from vertigo or dizziness (VFR Day only). We have critical training to remember and properly execute in emergency situations (airplane with simple mechanics, not "complex"). We don't just keep a vehicle between two painted lines, we have three dimensions plus time to worry about. (And nobody paints lines in the sky for us to follow like sheep.) Don't forget how much harder it was for you to get your private pilot's license than get your driver's license. There's a lot more to do to fly a plane, and a whole lot more ways to kill ourselves. Don't forget about medications that impair judgment, adding to the accident chain (1 passenger limit and small light airplane to minimize risk to passengers and folks on the ground). Any idiot can drive a car. This isn't apples and oranges.

All I am saying is let's look at the data. Emotional arguments will always make them error on the conservative side. I also believe people are perfectly capable to self grounding themselves if they feel they are not medically fit to fly. If you fly while impaired you are already violating the FARs (FAR61.53 to be exact) regardless of whether you have a valid medical.
 
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Honestly, here is the way I think about it: if someone has a medical condition that does not permit the issuance of a third class medical certificate, I would not want him taking my child on a Young Eagles flight (for example). Yes, the risk of incapacitation is small, but if it is your child or grandchild in the right seat.....
.

In Missouri we put our our child or grandchild on a school bus everyday with a driver that has no medical certificate from any government agency. Your state may vary.
 
Capable, yes.

But how many actually do so????

Last comment.
More people may self report if they had less fear of losing their medical. I know a dozen pilots that refuse to go to the doctor or have tests done for fear of what they may find out.
 
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Capable, yes.

But how many actually do so????

Philip, I'm with Mike on this, I have seen way too many people playing the Sport Pilot rules to get around that nagging little coronary, vision, neurologic, or whatever, issue that has kept them from seeing an AME. Yes the number of accidents is very small, but it only takes one ugly one to put us all at risk.

Another point, at least in my home state, any physician can void your driver's license with a simple form sent to DMV.

John Clark ATP, CFI
FAAST Team Representative
EAA Flight Advisor
RV8 N18U "Sunshine"
KSBA
 
Philip, I'm with Mike on this, I have seen way too many people playing the Sport Pilot rules to get around that nagging little coronary, vision, neurologic, or whatever, issue that has kept them from seeing an AME. Yes the number of accidents is very small, but it only takes one ugly one to put us all at risk.

Another point, at least in my home state, any physician can void your driver's license with a simple form sent to DMV.

John Clark ATP, CFI
FAAST Team Representative
EAA Flight Advisor
RV8 N18U "Sunshine"
KSBA

As I mentioned before, the existing pool of glider pilots has been operating for decades under a self-reporting rule, and don't seem to have many medical related accidents.

In Arizona, any "concerned citizen" can cause a medical examination of a driver -

http://www.azdot.gov/mvd/MedicalReview/MedicalRequirementsDL.asp

But the physician rules seem to be different from CA.
 
The thing is, EVERYBODY is essentially "self reporting" on their medical condition, unless they have a physician perform a medical evaluation immediately before every flight. The medical says that on the day you visited the Flight Surgeon, you met the criteria. You might have sprained your ankle (and therefore be unable to properly control the rudder on your tail dragger) as you walked out of the doctor's office, and technically, it is up to you to ground yourself.

At work, if we are doing something where physical condition is important (such as an altitude chamber run, diving operation, special test flight), we have a quick medical exam by a surgeon THAT MORNING. I don't think any of us wants the FAA to be that intrusive...so when it comes right down to it, the whole system we fly under is based on our trust that pilots will self report. The Medicals are just very coarse screenings.

Paul
 
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Next week i am goona by plane & it's my first journey as i heard before journey by plane passenger have to medical check-up, is this mandatory?..?
I am not aware about rules so is there some one who can solve my this big prob....:...:)
 
Predicting "sudden incapacitation"

Isn't that the stated purpose of the medical? It is not for the benefit of the pilot as much as for those that have to be protected on the ground (Chicken Little Syndrom) or passengers in the aircraft.

Except for "walking time bombs" (e.g., Obese smokers with diabetes), who even those of us without medical training could predict, does a 3rd class medical reasonably find other "at risk" individuals?

I will go with the epidemiological study from the SSA. The number of incidents is miniscule compared to my SWAG of 100,000 x $115 = $11,500,000 year spent on 3rd class medical exams.

LarryT
Larry Tompkins
N544WB RV-6A
W52 Battle Ground WA
 
This may be of interest. It seems a new category of licence is about to be introduced here in Australia that will only require a drivers licence medical.

The restrictions that would apply are:-
single engine piston aircraft and rotary wing aircraft
1500Kg (3,307 lb) MTOW and below
Outside CTA
Day VFR only
No more than 2 seats being occupied.

Outside CTA is possibly not as big a problem here as it would be in the USA as there are not that many CTAs in Australia.

Fin
9A
 
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The way I see it is that we essentially are giving the FAA permission to restrict our flying. This is unacceptable. It is not incrementally beneficial to most of us. What do we gain? Very specific flying conditions and many aircraft that do not fall under the exemption. The medical has no connection to skills required to fly an airplane, regardless of number of seats or HP of engine.

The only outcome that I would be in favor of is the elimination of the third class medical completely, with the stopgap measure of it being available to those who want to fly internationally (as Mel mentioned).
 
Other Options

Several other ways to improve the process are:

1) Allow your own doctor to determine if you are medically fit to fly. Here in MO in order to drive a school bus you need to have on file a letter from a physician that says you are medical capable to drive. Why not something similar for flying? For a private pilot you must have a recent (use same time periods as current third class) medical letter from your doctor. Argument against is that a "regular" doctor does not know the things that makes you not able to fly, not an aeromedical expert. My answer to that is the same things that would not allow you to drive would not allow you to fly. I do not believe that flying makes things any different due to speed, altitude, or stress. Those are training issues and not medical.

2) Maintain the current system except let your AME approve all special issuance medicals. Issue I see with this is that he is not an expert in all fields. So. He can read the letter from your own specialist and decide if he believes it or not. Not doing anything different then the doctors in OK City. At least you are standing in front of him and the guy in OK city has never seen you. Let the AME charge another $200 to make the determination so he can spend another 20 minutes thinking about it or making a call to your specialist. Still better then waiting 3-6 months for someone that has never seen you try to get to your paperwork in his pile.
 
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The way I see it is that we essentially are giving the FAA permission to restrict our flying. This is unacceptable. It is not incrementally beneficial to most of us. What do we gain? Very specific flying conditions and many aircraft that do not fall under the exemption. The medical has no connection to skills required to fly an airplane, regardless of number of seats or HP of engine.

The only outcome that I would be in favor of is the elimination of the third class medical completely, with the stopgap measure of it being available to those who want to fly internationally (as Mel mentioned).

I'm not sure how providing pilots more options (in essence allowing Recreational Pilot privileges with no medical) could be considered "giving the FAA permission to restrict our flying". Do you think the Sport Pilot certificate gives the FAA permission to restrict our flying?
 
I mean categorically restrict private flying.

What I am afraid of is the FAA saying, for example, "well, now you have these easy methods of flying medical-free, we're going to make getting a medical for your other flying needs harder", or something to that effect.

AOPA/EAA simply wussed out.

As I said, I will only support a measure that eliminates the third class medical for all private flying. What does the number of passengers, number of horses, or time of day have to do with being fit to fly?
 
Take a look at Sport Pilot limitations and why they're there. Pilots have to be healthy enough to deal with altitude and loss of air pressure/hypoxia that goes with it (10,000 foot Sport Pilot limit).
This part of the SP limitations is totally bogus. I can fly to 17,9999ft (higher, if I get a ATC window) on my Commercial-Glider certificate with no medical requirements whatsoever, other than to self-certify that I am fit to complete the flight at PIC. So why are SPs limited to 10k MSL? Oh, yeah, oxygen and hypoxia training aren't included in the SP written exam. Dumb....

TODR
 
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