ALPA to GA: Screw you

[Jim Logajan]

ALPA makes clear what they think of the riff-raff that they have to share their airspace with:

http://download.aopa.org/advocacy/ALPA_letter.pdf

What do they think of glider, sport, balloon, and ultralight pilots, I wonder, who've been flying in their airspace all these years? How many accidents were caused to commercial flights by medically unfit flyers of such aircraft?

Or recreational drone flyers? (Yeah, I know, there are GA pilots also throwing metaphorical rocks at those guys flying in their airspace.)

 

[Jim Logajan]

Perhaps I'm missing something here?? It sounds just like another letter with a different viewpoint. I don't see where ALPA has a financial interest in this, but maybe I'm wrong. I also don't see how it would hurt its members.
The way everyone is talking I expected much more.

My post may not reflect my personal view, I'm just trying to be objective.

No credible data has been presented that indicates that there is any measurable increase in risk with the elimination of the Class 3 medical. And credible data is theoretically available by examining how often medical incapacitation played a role in the accident and incident history of glider, balloon, sport, or ultralight flights that also involved commercial flights. But no such data has been presented even though such flights have been occurring for decades.

I do not know what motivated that letter from ALPA
[*], but it was relying on a perception of risk, not the actual risk, to maintain a long established restriction on an individual freedom. Perceived risk has no objective utility but many people use it to justify all sorts of restrictions on individual freedoms.


[*] Based on the other content of the letter that seemed to be complaining about this appearing as an amendment to another bill rather than as part of PBOR2, perhaps there was something in PBOR2 that ALPA desired to have pass that was not in the amendment and would therefore not have a chance to occur if PBOR2 became redundant. That is the most generous interpretation I can think of.

 

[Jim Logajan]

OK, this is about the third class medical going away, correct? ALPA saying that they oppose that is hardly saying "screw you" to GA.

"This legislation has the potential to allow medically unfit pilots unfettered access to the national airspace at altitudes up to 18,000 feet, which also includes commercial airline traffic carrying passengers and cargo."

What do you suppose motivates somebody to write something like that?

Do you think they are trying to invoke an image of a horde of sick old geezers suddenly taking to the skies, there to die at the controls of their planes and crossing the center dividers of airways into oncoming Airbus traffic, causing spectacular crashes with hundreds of deaths? Or do you think they they are being perfectly reasonable in making a claim that medically unfit pilots are somehow a danger to anyone else but themselves and their passengers and possibly people on the ground?

Do you think that maybe ALPA probably has a clue that a lot of private pilots are for the medical requirements to be relaxed? So that any opposing arguments they make had better do more than paint improbable claims of hazards, lest they be seen by some of us (well at least me) as being a group demanding priority claim to the national airspace?

 

[Jim Logajan]

I wonder if the airlines really want section 3, and are concerned that if class three medical reform is passed separately, they will loose the backing of the EAA and AOPA and have to lobby for themselves.

I went back and looked over section 3 (https://www.congress.gov/bill/114th-congress/senate-bill/571/text) and it definitely looks like ALPA members would have gotten benefit from it. But then I found that Aerospace Medical Association back in April noted ALPA's objection even to PBOR2:
http://www.asma.org/asma/media/AsMA...ical-Certification-Legislation-April-2015.pdf

So it appears ALPA has been opposed to PBOR2 for quite a while - or at least to the relaxation of Class 3 medicals.

By the way, I found the arguments put forth by AsMA interesting and worth closer examinations:

"The FAA’s Medical Analysis Tracking (MANTRA) Program maintains a registry of US pilots fatally injured in aircraft accidents and includes autopsy results for most cases. Data were extracted for 1,084 individuals involved in fatal accidents from January 2011 to April 2014. Subjects included 68 sport pilots flying legally without a medical certificate and 403 pilots flying with an FAA Third Class medical certificate. Moderate to severe medical hazards identified by autopsy were found in 25% of medically certified pilots but in 60% of uncertified pilots."

This is hardly surprising - in fact it is to be expected. The issue isn't whether sport pilots would be as healthy as private pilots when they die in a crash, but whether their state of health was causal to the crash. I'm sure if that claim could be made they would make it. They didn't. What they then state is:

"According to recent studies by Casas and Castro, pilots with FAA Third Class medical certificates have a lower accident rate than sport pilots who have no such certification."

Sport pilots also may attain their certificates with lower number of hours and fly a different class of aircraft than that available to private pilots. Nice try, though, at trying to imply a causal link. An honest scientific approach would have noted the confounding factors.

The following was, in my opinion, almost the best argument they made:

"Based on a study of driving statistics by Hendricks, et al., 1999, approximately 6.4% of driving crashes resulted primarily from driver incapacitations. According to the Aircraft Owners and Pilots Association (AOPA), this type of bill would affect 39,120 pilots. If the same 6.4% incapacitation rate occurs for pilots under driving license medical standards, up to 2,503 new aircraft accidents would occur."

But then I looked at the linked study, where it defines its categories, and found this: "INCAPACITATION (e.g. fell asleep) - 6.4%"
[EDIT: According to the study results, the 6.4% is the percentage of drivers contributing to causation, not 6.4% of crashes. In fact the original study says that 2% of driver contributed crashes were due to seizures and blackouts; 4.4% were due to falling asleep. Since driver contributed crashes accounted for 59.7%, the final tally for medical incapacitation as causal for accidents amongst drivers was .597*2 = 1.2%. And contrary to the bogus math used by the AsMA, you DO NOT multiply either 6.4% (or 1.2%) by the number of pilots to determine the increase in accidents. You multiply by the number of past accidents. In fact the number of accidents would increase only by 1.2% (or even 6.4% using their numbers.) An increase of about 15 new accidents a year, of which 3 would be fatal. NOT 2,503. That latter results from confused or deliberately deceptive math by the AsMA - their probability units are wrong.]

So they were reaching. Hard. Those kinds of "scientific" arguments probably have worked on a lot of congress people, though. On the pro side for relaxation of medical standards is the realization that risk is impossible to remove - the best one can do is find a balance between risk to others versus the benefits of freedom to act.

 

[Jim Logajan]

Yeah, it doesn't make sense to me either. I can't figure out what their opposition is based one.

Maybe they sincerely believe their claims?

We all must use heuristically derived rules to help us make our decisions in life - and most of the thinking we apply really isn't as logical as we'd like to think. Sometimes the status quo is favored over the unknown if we don't see personal benefit in some proposed change, but we can imagine, however improbable, some negative consequence.

 

[Jim Logajan]

a related (and arguably more important) question is: What is the safety improvement provided by the current third class medical process? What hazards are avoided and what is the reduction in probability of mishap?

In another post I noted that one study estimates that about 1.2% of automobile accidents are caused by medical incapacitation of the driver; e.g. stroke or seizure or similar. Assuming that going from a third class medical to the same standards as automobile drivers increases the accident rate proportionally, then one might see an average of 16 extra crashes a year with 3 of those killing about 5 people a year. Assuming further that, unlike automobiles, such incapacitation always yields fatal crashes, then there will be 16 extra fatal crashes a year with about 27 people being killed.

Data computed using average from 2 years:
2013: 1222 crashes, of which 221 were fatal that killed 387 people.
2012: 1471 crashes, of which 273 were fatal that killed 440 people.

(Obviously there are a bunch of caveats to all the assumptions.)

 

[Jim Logajan]

In another post I noted that one study estimates that about 1.2% of automobile accidents are caused by medical incapacitation of the driver; e.g. stroke or seizure or similar. Assuming that going from a third class medical to the same standards as automobile drivers increases the accident rate proportionally, then one might see an average of 16 extra crashes a year with 3 of those killing about 5 people a year. Assuming further that, unlike automobiles, such incapacitation always yields fatal crashes, then there will be 16 extra fatal crashes a year with about 27 people being killed.

Data computed using average from 2 years:
2013: 1222 crashes, of which 221 were fatal that killed 387 people.
2012: 1471 crashes, of which 273 were fatal that killed 440 people.

(Obviously there are a bunch of caveats to all the assumptions.)

Bad assumption. It's a bit harder to control a car from the passenger seat, and there are numerous examples of a passenger saving the plane. Also, the chances of taking out pedestrians in a plane is much less than in a car.

So I don't think you can just take the numbers from the cars and apply it to planes.

First, the assumption you bolded was my attempt to see what numbers would result if a critic of elimination of 3rd class medicals would make that claim. I think it useful to anticipate potential arguments to see where they lead.

Second, the idea of taking incapacitation statistics from car accidents and applying them to aviation accidents is not my idea, but comes from paragraph 4 of this document by the Aerospace Medical Association (AsMA) that was sent to the FAA opposing PBOR2: http://www.asma.org/asma/media/AsMA...ical-Certification-Legislation-April-2015.pdf

Their math in paragraph 4 made the egregious mistake of multiplying an incapacitation accident rate per year by number of pilots, which yields a number with units that make no sense. They mistakenly thought the number was a pure "accident" count. The fact that it came out to 2503, twice as large as the last two year's annual average accident rate of ~1347, should have made them realize their math was hosed. My (hopefully correct) math yields about 16 extra crashes per year.

Interestingly, in paragraph 2 of their document they claim 5 of 180 fatal accidents (~2.8%) are due to pilot incapacitation [they don't provide the source for this number.] This accident rate occurred under the current medical standards, so by their own math and arguments the accident rate due to pilot incapacitation might be expected to rise from 2.8% to 4.0% (2.8 + 1.2).

Interesting calculation, but was one of your assumptions that all crashes due to pilot incapacitation are prevented by possessing a third-class medical?

Yes, that is one of the assumptions. My assumptions were deliberately chosen to be somewhat pessimistic relative to the position I hold. Since the alleged rate on aviation accidents due to pilot incapacitation is already ~2.8% while the car driver accident rate is ~1.2%, it may be that the third class medicals aren't preventing incapacitation accidents in any measurable way. In fact the AsMA document inadvertently admits that autopsies on pilots who died in accidents but were medically certified as "fit" found that 25% had moderate to severe "medical hazards." That's a large percentage of pilots! Either the autopsies aren't terribly reliable or the general pilot population is pretty dang unhealthy.