Comment to ‘Notice of proposed amendment (NPA) No.2/2004’

Kaz Shimada, M.D.

Japanese Delegate to FAI-CIMP

1．Up to Question 2 (or clause 11) is about the framework.  It is hard to understand the description without EU background.

2. Question 6 (clause 21) deals with the UAV operation.  Remote control operator of heavy UAVs should have some kind of proof of fitness, which could be demonstrated during flight skill test.

3. Questions 8 and 9 (clause 27-28) deals with third country aircraft.  Because an air sports event invites quite a number of third country aircraft, there should be a mechanism to smoothly accept those aircraft.  Please note that many are under experimental category.

4. Question 11 (clause 31) deals with recreational and sport aircraft operator license.

  Question 11 a) – Definition of air sport aircraft is not easy by aircraft type.  While gliders (in some countries registered as aircraft) and motorgliders are easily classified by JAR22, power aerobatics and precision flight entity airplanes and rotorcraft are considerably high-powered and sometimes not small.

5. Question 12 (clause 32) directly describes aeromedical certification. 

  Question 12 a) (corporate or heavy motor-powered aircraft physical)  Yes, corporate or heavy motor-powered aircraft operators medical certification would be better handled by wider area authority, to eliminate border crossing issues.

  Question 12 b) (light recreational or sport aircraft physical)  Yes, recreational aircraft medical licensure should be of easier access; for air sport events where some higher powered airplanes/rotorcraft are flown, special provision should be clearly written so medical certificate would not become a issue.

  Question 12 c) (national accreditation of AMEs)  Yes, accreditation of aeromedical examiners by the Commission only would in the first place need uniform training syllabus.  Only after a uniform syllabus comes EC accreditation.