Jerald,

Do you treat pilots, or are you a pilot? I ask, because your comments do not sound as though you are familiar with aviation, the FAA, the certification process, the airman medical process, or airman medical standards. You make a series of references, or statements, which are not correct, in your blogged articles, beginning with basic terminology, and continuing through the certification process.

I am not unsympathetic to the special issuance process, having recently completed a round with it myself. Presently, special issuance times have been dropping considerably, but it's difficult to stipulate an "average" given the variety of cases for which a special issuance is needed. One can't really compare two unique conditions or cases and average them; an apples-apples comparison is needed between similar or same-type diagnoses, such that a common denominator is found between them. Diabetes is not the same as a cardiac issue, and one even among diabetics, for example, the extent of the condition, medical intervention, and other factors may have a significant impact on both the probability of a special issuance, and the timeline.

Those who use a dedicated service when applying for their special issuance tend to have faster returns on their paperwork, vs. attempting to go it alone. One ought not attempt to navigate the legal system without retaiining an attorney, and one ought not navigate the special issuance process without seeking assistance from those who specialize in handling special issuances and FAA medical issues. One of the single biggest delays in getting FAA approval isn't the FAA's backlog, but failure to submit all the necessary documentation. The matter gets kicked down the road repeatedly as the FAA asks for more documentation. In many cases, the applicant would have been done, had (s)he sought guidance through the process and submitted all the documentation at the outset. This guidance costs, but so does a lengthy delay which can cost a job, keep one from applying or interviewing, or from earning a living while deferred. Pay now, or pay later, as they say. In my own case, I was told to expect four months, but had a fresh medical in hand after seven weeks. It would have been much longer had I attempted it without specialized assistance.

I don't disagree with your base premise that the FAA, or the threat of the FAA's action, intimidates many pilots from stepping forward. I do believe, however, that many who are afraid of being medically grounded don't have the moral ground to crow foul: if the pilot does not meed the medical standard, then the pilot is not airworthy. If one is afraid to tell the FAA about a grounding condition, one is already in posession of an invalid medical certificate. The rear of the certificate itself reiterates the regulation. A pilot who does not meet the medical standard may not exercise the privileges of his or her medical certificate, whether (s)he reports it or not. (A pilot is not required to report every medical deficiency between examinations, incidentally. Your articles suggest otherwise).

Your overall point is well-taken: a pilot may not get the medical care (s)he needs, for fear of the treatment, or revelation of the condition, impacting medical certification. Many pilots confer within the community as to which doctor or AME to see, who is "pilot-friendly," and most of us understand the implications of putting anything "on the record," whether with a general practitioner, specialist, or aviation medical examiner (AME). That said, that concern also doesn't change the fact that a pilot who is afraid to seek treatment for a grounding condition, and elects to continue operating unsafely and illegally, knowingly violates the regulation just as much as taking an unairworthy airplane into the air. One might say he was afraid to seek maintenance for the airplane, lest the FAA find out the airplane is broken...a very bad idea. We all experience medical issues. We can hide them and operate unsafely and illegally, or seek help, and accept the outcome. If we're not medically fit, then we're not medically fit, and until we are, the medical certificate we may have in our pocket isn't legally valid. It's only valid when we meet the standard for which the certificate was issued, under 14 CFR Part 67. Outside of that, it's invalid, regardless of whether the pilot reports it, seeks medical assitance, or is investigated by the FAA. This is as true of a sinus infection as an extensive medical condition; one may be temporarily grounded, pending returning to an airworthy state, or one may be grounded for an extended period of time. While there are many conditions which must be reported and which require medical intervention (and medical certificate intervention), there are also many temporarily-grounding conditions for which a pilot is required to exercise the responsible act of refraining from flying on his or her own. In this case, the pilot also determines when (s)he is able to return to flying.

Please don't take my comments as an attack on your efforts; I'm not in disagreement that some standards, and the means by which they're applied, need some reform, not the least of which include mental and emotional health issues. The ARC's work is but a part of that long-term reform, and it may well be that professionals such as yourself will be the activists that create and promote better change. I can only hope so. It is, however, a cautious hope. I am not anxious, in the zeal that surrounds this topic, to see those put into the air who ought not yet be there, and it is my sincere hope that those who can be there, and should be there, find an expediated path to fly.

I will be interested to read your continued posts.