John,
There is a lot to unpack in your response.
1. I am not a pilot. I do treat pilots. I am not an AME. I am a Board-Certified Psychiatrist. If it means anything,I served in the military and believe I understand the pilot culture.
2. I would say I came into this topic naive. I am not now. It has been a slog to learn the process, with a numbing level of byzantine details that continue to evolve. The terminology I use will, no doubt, convey I am a psychiatrist and not a pilot. Moreover, I am an "outsider" looking into what has been "standard" within the aeronautical medical world and, frankly, is very wrong.
3.
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.
Please be specific.
4.
One of the single biggest delays in getting FAA approval isn't the FAA's backlog...
The FAA has data that they do not share that tracks "average" times to issuance. They could and should disclose it, if only to manage pilot expectations. Moreover, a large part of the time required to process Deferral applications is due to the FAA's own processes. By not releasing data, their is no accountability. As I have stated in the Blog, mental health deferrals often take over a year and are know to go as long as three years. Using the IG data from 2019-20, I calculate 328 days on average. I also calculated from the same data that 43% of the mental health deferrals are closed out as "Fails." If this is the case, it is a pretty devastaing data point and something the FAA has not disclosed. To the contrary, they publish a "0.1%" Fail rate or, in another source, a "96%" success rate on Deferrals.
Yes, I agree the delays in getting the required reports and exams is a major time sink. In addition, the notion of 6-months on a unchanging dose of an antidepressant before any approval process can be started is a huge burden. I am focussed on mental health issues and am not sure if there is a similar rule for other medical conditions, such as antihypertensives. Do you know?
5.
...failure to submit all the necessary documentation.
Yes, I also agree that you need to line your ducks up before entering the process. Before going to the AME and disclosing depression or anxiety disorder, I would recommend paying for a lawyer that specializes in assisting pilots/ATC with FAA goverance.
6.
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.
I really don't spend much time considering the "moral ground." I would just like to make the skies a bit safer. The current system that relies on a heavy stick and false promises is failing. When you observe that pilots are 40-times less likely to get antidepressant than the rest of the US public, you know there are epidemic levels of undertreated illness. The FAA has a problem -- hell, even the Agency acknowledges it has a problem -- but doubling down on enforcement is not solving anything. And arguing that pilots are acting immorally by not signing "yes" on the 8500-8 may be true. But they are also acting rationally. There are better solutions.
7.
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).
You are correct. See:
https://www.faa.gov/air_traffic/publ...tion_1.15.html. If you KNOW the medical issue is a problem, then "
The Federal Aviation Regulations prohibit a pilot who possesses a current medical certificate from performing crewmember duties while the pilot has a known medical condition or increase of a known medical condition that would make the pilot unable to meet the standards for the medical certificate." The question is what you knew, or should have known. The FAA advises consulting an AME if you are unsure. I'll look in the blog to correct this item. Do you recall in which part I wrote it?
Thanks for your extensive comments.