Primarily for general aviation discussion, but other aviation topics are also welcome.
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By Edward Bellamy
#1827828
flybymike wrote:The sub 2k category has been around a lot longer than that. I’m pretty sure it was introduced within a few weeks of the initial 2016 introduction of the PMD.


It was indeed...
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By oldbiggincfi
#1827891
Edward Bellamy wrote:@ls8pilot are you saying that 20% of qualified pilots would not be able to do PMD on Part-21 with the current wording?


Probably more because if you consider there will be a lot " Qualified Pilots" who have never had anything more than a " doctors driving sign off " .
By Forfoxake
FLYER Club Member  FLYER Club Member
#1829883
ls8pilot wrote:
Forfoxake wrote:
G-BLEW wrote:FWIW, I think that @ls8pilot summarises the situation accurately heree

Ian

Agreed, but I still have one query.

The recent CAA 'clarification' on SkyWise states that:

"Existing PMDs remain valid for the type of licence(s) and aircraft weight limits specified at the time of a declaration."

Does this mean that only those having to make a new PMD are affected by this problem?

If so, is a 2000kg declaration made by a LAPL(A) holder before the wording was changed (or only before 2021?) still valid till expiry date as long as no new or recurring relevant medical conditions occur?

PS I only want to fly G registered non Part 21 aircraft in UK airspace atm!


Good question and I suspect a bit of cunning dissimulation by the CAA

The pre-Jan 2021 PMD has a preamble which reads as below. As you can see it only validates the PMD for use with non-EASA aircraft . Even though a Covid exemption temporarily extended this for while, I suspect the CAA could maintain that the previous scope applies and you cannot take advantage of the earlier PMD to fly Part 21 aircraft.

Applicable Licence Types

EU Part-FCL PPL to fly non-EASA aircraft,
EU Part-FCL LAPL to fly non-EASA aircraft,
National Private Pilot Licences (NPPL),
UK Private Pilot Licences (UK PPL), or
UK Commercial Pilot Licence (CPL) Balloons that is restricted to commercial operation and to the privileges of a UK PPL (Balloons and Airships)
,

So yet another bit of confusing and vague wording to go with "any.. medical treatment" and "a history of... recent surgery" . I can only assume maybe they have a trainee or work-experience person putting this stuff together!


Having read through this and my own PMD, I am reassured because I only want to fly non-Part 21 aircraft atm. However, hopefully the CAA will clarify the situation for flying Part 21 aircraft before leisure flying is allowed again!
By Forfoxake
FLYER Club Member  FLYER Club Member
#1831453
nickwilcock wrote in the OSR4 No,1471 thread:

"I asked the CAA about this and was assured that the 'sub 2000 kg' was a medical alleviation applicable to national licence holders (not Part-FCL) and the non-Part 21 restriction was a licensing restriction rather than a medical one.

So when the Part 21 restriction was alleviated under ORS4 No.1417 derogation, it mean that national licence holders using 'sub 2000 kg' PMD terms would thenceforth be able to use the same terms on Part 21 aeroplanes and/or TMGs"

In response to these comments, which are probably more relevant to this thread, I have had a closer look at the new online PMD, and I am even more confused!

At the start, you are asked to tick one or more licence types.

However, it does not seem to matter which or how many licence types you tick. You are still asked at the end to sign up to the full, confusingly worded, medical requirements needed to fly aircraft less than 5700kg MTOM.

The only other option is to withdraw a previously submitted declaration.

There is no mention in the actual declaration of the no greater than 2000kg alleviation even if you only tick National Private Pilot Licence (NPPL) or UK Private Pilot Licence (UK PPL).

And I cannot understand why, for example, you can tick either UK Part-FCL LAPL to fly Part 21 aircraft or UK Part-FCL to fly npn-Part 21 aircraft when it does not make any difference. At the moment, I believe (although I hope I am wrong, at least for PMDs made before Brexit) that you cannot fly ANY aircraft in the UK on a UK issued LAPL using the 2000kg alleviation, even though the LAPL only allows you to fly aircraft no greater than 2000kg!

I am still hoping that the CAA/DfT will clear up this mess up before leisure flying is permitted again.
By C1FF
#1831460
Forfoxake
My understanding is the same as yours. At present, if you have a FCL licence (Lapl) you are not allowed to use the <2000kg PMD criterior but you can fly using the <5700kg PMD criterior.
However, if you have an NPPL you can use the <2000kg PMD criterior for all <2000kg G Reg aircraft in the UK.

Great logic !
By Forfoxake
FLYER Club Member  FLYER Club Member
#1831462
Steve Slater, LAA CEO, writing in this month's Light Aviation, also agrees:

"Exemptions
Another post-EASA black hole surrounds changes to medical self-exemptions which have enabled many pilots to fly sub-2000kg (sic) aircraft so long as they met the requrements of a DVLA car driving licence. Revised wording has changed the rules for holders of UK Part-FCL licences (LAPL and PPL), who can now only fly with a PMD in accordance with the former sub 5700kg criteria."
By welkyboy
FLYER Club Member  FLYER Club Member
#1831497
patowalker wrote:With all due respect to Steve, until the CAA indicates my PMD is no longer valid, it remains valid until expiry.

But not in Channel Islands airspace as PMD’s are not approved!
By jaycee46
#1831745
I just came across this thread, and it got my attention. Apologies if it has been covered somewhere else in the 27 pages, but I don't fancy trawling through that amount of posts.
It's a simple query. I fly a G - reg PA28 on a formerly EASA now I assume UK PPL, and my SEP is still current. My class 2 medical was due to expire shortly after the plague hit, so I filled in and got the PMD as was suggested at the time, so I flew on that medical last year, backed up by the fact that my LAPL medical was also still valid. I'm over 50, so needed my class 2 done every year, but the LAPL is for 2 years.
I was just about to try and book a class 2 for the coming season, when I spotted this thread, which seemed to imply that I could save the expense of a class2 and continue on the PMD.
I do find it a little strange that up till last year we had to go through a pretty thorough medical test, and now we can declare ourselves fit on a website.
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By ls8pilot
#1831747
I'm assuming you have a Part-FCL licence as you had an EASA PPL, so provided you meet the criteria listed "Under 5700kg" in the PMD and only fly in the UK (plus the other restrictions listed) you can electronically declare using a PMD (or use an existing PMD) and fly a PA28 with no problems. I think what it shows is that basically if you are fit and well enough to safely drive to the class 2 medical, you're most likely fine for flying a light aircraft - at least in terms of the risk to other people!
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By flybymike
FLYER Club Member  FLYER Club Member
#1831748
I do find it a little strange that up till last year we had to go through a pretty thorough medical test, and now we can declare ourselves fit on a website.

You’ve been able to medically self declare since 2016. (U.K. flying only)
By Forfoxake
FLYER Club Member  FLYER Club Member
#1831753
ls8pilot wrote:I'm assuming you have a Part-FCL licence as you had an EASA PPL, so provided you meet the criteria listed "Under 5700kg" in the PMD and only fly in the UK (plus the other restrictions listed) you can electronically declare using a PMD (or use an existing PMD) and fly a PA28 with no problems. I think what it shows is that basically if you are fit and well enough to safely drive to the class 2 medical, you're most likely fine for flying a light aircraft - at least in terms of the risk to other people!


Oh I wish it were that simple!

The present 'Under 5700kg' online medical declaration is so confusingly worded, as has been discussed in this thread previously, that many Part-FCL licence holders who are perfectly capable of driving safely to (and in most cases , passing) a class 2 or LAPL medical cannot, imho, comfortably make an online PMD at the moment.
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By ls8pilot
#1831764
Forfoxake wrote:
ls8pilot wrote:I'm assuming you have a Part-FCL licence as you had an EASA PPL, so provided you meet the criteria listed "Under 5700kg" in the PMD and only fly in the UK (plus the other restrictions listed) you can electronically declare using a PMD (or use an existing PMD) and fly a PA28 with no problems. I think what it shows is that basically if you are fit and well enough to safely drive to the class 2 medical, you're most likely fine for flying a light aircraft - at least in terms of the risk to other people!


Oh I wish it were that simple!

The present 'Under 5700kg' online medical declaration is so confusingly worded, as has been discussed in this thread previously, that many Part-FCL licence holders who are perfectly capable of driving safely to (and in most cases , passing) a class 2 or LAPL medical cannot, imho, comfortably make an online PMD at the moment.


Yes quite true, I was really referring to the underlying rationale rather than the pigs ear the CAA have made of the implementation!
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By russp
FLYER Club Member  FLYER Club Member
#1831765
Forfoxake wrote:The present 'Under 5700kg' online medical declaration is so confusingly worded, as has been discussed in this thread previously, that many Part-FCL licence holders who are perfectly capable of driving safely to (and in most cases , passing) a class 2 or LAPL medical cannot, imho, truthfully make an online PMD at the moment.


I honestly think that's partly the point, I can't make the under 5700Kg declaration on (at least) a couple of the points but I do get a class 2 medical although it did take a fair bit of toing and froing to get the initial issue. I can truthfully make the under 2000Kg declaration (and have). The point is that if you have those things then it needs further consideration not that you are automatically unfit to fly.

It's clearly patently ridiculous though that I as a NPPL holder can fly my (non Part 21) aircraft with a under 2000Kg PMD but a Part FCL LAPL/PPL holder can't and may need a medical if they are unable to fulfil the criteria for the 5700Kg declaration.
By NickA
#1831781
I suspect that the NPPL and FCL privileges with respect to the PMD and sub 2000 conditions are in the process of being harmonised and that it won't be too long before the ridiculousness of the divergence that you note will be eliminated. Obviously it is not helpful in the short term.

On the other hand, the wording of sub 5700 conditions are so vague that I think it would be hard to prove a case against someone who had already been issued with a class 2 and whose health has not deteriorated since and who made a PMD in good faith.
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