July 16, 2002
The Aircraft Owners and Pilots Association has petitioned the FAA to allow pilots to use a driver's license as a medical certificate, provided those pilots limit themselves to recreational pilot privileges. The petition formalizes a suggestion AOPA made in its comments on the FAA's proposed sport pilot rule.
"The FAA itself argues in its sport pilot proposal that a driver's license, which allows men and women to drive an automobile at high speeds just inches from other automobiles, provides an equivalent level of safety for recreational purposes," said Phil Boyer, AOPA president. "And AOPA's own analysis of GA accidents over the past 20 years supports that contention."
In fact, a July AOPA Air Safety Foundation analysis of accident data for airplanes, compared to an FAA analysis of accident data for gliders and balloons (for which no medical certificate is required), shows no significant difference in the ratio of medically induced accidents to total accidents for "no medical required" and "medical required" operations. The AOPA petition pointed out that regulations require that pilots ground themselves if not medically qualified, whether a medical certificate is required or not.
AOPA's formal petition, filed July 15, asks for the driver's-license-as-medical for sport pilot and recreational pilot privileges only, in part to boost acceptance of the lower cost recreational pilot certificate and in part to allow the FAA to gain experience with the new privilege. Once operational experience proves its validity, AOPA anticipates asking that the driver's license medical be extended to those exercising private pilot privileges.
The recreational pilot certificate, introduced by the FAA in 1989 after years of discussion and study, requires a minimum of 30 hours of flight instruction and practice. But the recreational pilot certificate has had limited appeal, in part due to the requirement for an FAA medical certificate. The latest FAA records show only 343 recreational pilots, comprising less than 0.1 percent of all pilots in the United States.
"AOPA believes one of the biggest reasons so few would-be pilots seek a recreational pilot certificate is the third class medical requirement," said Boyer. "Changing the medical standard to a valid driver's license while expanding recreational pilot privileges to match sport pilot privileges would greatly increase the utility and popularity of the recreational pilot certificate."
However, if AOPA's petition were granted, any certificated pilot would be able to use a current, valid state driver's license as a medical provided his or her flying was limited to recreational pilot privileges.
Those privileges limit pilots to fixed-gear, Normal category aircraft up to 180 horsepower, with four or fewer passenger seats. Pilots exercising recreational privileges may not fly at night, in IFR weather conditions, above 10,000 feet or 2,000 agl (whichever is higher) and may carry no more than one passenger. They are expressly prohibited from flying for any purpose other than sport or recreation, identical to the requirement for the proposed new sport pilot certificate.
AOPA has been examining the data for years to see if there is a correlation between medical certificates and accident prevention. There is no strong link.
For example, a just-completed AOPA Air Safety Foundation analysis of accidents caused by medical problems shows no meaningful correlation between FAA medical certificate requirements and GA accident rates.
ASF researchers analyzed 37,946 GA accidents that occurred from 1983 to 2000 involving fixed-wing aircraft under 12,500 pounds gross weight and operated under FAR Part 91. All such aircraft require a valid FAA medical certificate for the pilot in command.
Of that total, they found 120 accidents caused by medical incapacitation, just 0.316 percent of all accidents. (Heart attacks were the most common accident cause.)
A similar FAA study of accidents in gliders and balloons (whose pilots are not required to have a valid medical certificate), found only two medically induced accidents in the 10-year period from 1990 to 2000. With a total of 609 glider and balloon accidents shown in the ASF database for that period, the no-medical-certificate-required ratio works out to 0.328 percent, essential the same ratio as that for pilots requiring an FAA medical certificate.
ASF's study confirms a smaller study done in the mid-1990s by the FAA's own Aviation Rules Advisory Committee. That study, based on GA accidents from 1986 to 1992, found an even lower ratio of medically induced accidents: 0.198 percent in operations requiring an FAA medical certificate, and just 0.131 percent in operations that did not.
"The statistics strongly support AOPA's petition to allow pilots to exercise at least recreational pilot privileges by using a current, valid state driver's license," said Andy Cebula, AOPA senior vice president of government and technical affairs.
The Aircraft Owners and Pilots Association is the world's largest civil aviation organization. Some two thirds of the nation's pilots are AOPA members.
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