AOPA submitted comments on January 18 supporting the FAA’s proposal to expand BasicMed for those who want to serve as safety pilots and to change medical certificate requirements for individuals completing medical flight tests.
In a November 28 notice of proposed rulemaking, the FAA proposed two changes that would alleviate confusion and burdens for individuals operating under BasicMed and those obtaining medical flight tests. Specifically, the FAA is proposing to allow pilots who operate under BasicMed to serve as a required pilot flight-crewmember when not acting as pilot in command, and to allow individuals to receive medical flight tests while not holding a medical certificate.
The proposed amendment to expand BasicMed privileges to those not acting as PIC—namely safety pilots—would alleviate an illogical restriction experienced by many pilots and AOPA members. Currently, pilots may operate under BasicMed while operating as PIC; however, they cannot use the same privilege as a required flight-crewmember when not acting as PIC. This change would now allow an individual who takes advantage of BasicMed to serve as a safety pilot.
AOPA believes the proposed change will provide many more opportunities for individuals to gain experience and maintain proficiency. More than 70,000 pilots have used BasicMed privileges since the program’s inception, and many who are currently operating under BasicMed could easily serve as a safety pilot for any of the 316,000 instrument-rated pilots, not including the unknown number of instrument applicants-in-training. Additionally, this can all be done without any increased risk or threat to safety as there has been no significant difference in accident rates between pilots operating under BasicMed and those who hold a third class medical certificate, according to the FAA’s Civil Aerospace Medical Institute and the AOPA Air Safety Institute.
AOPA also supports removing the requirement for pilots receiving a medical flight test (e.g., statement of demonstrated ability or special issuance) to hold a medical certificate. The FAA determined that requiring an aviation safety inspector to act as PIC during medical flight tests put an unnecessary burden on the inspector. AOPA agreed and highlighted the reduced time and cost of finding and scheduling an evaluation flight with a willing inspector.
Additionally, AOPA recommended the FAA allow designated pilot examiners (DPEs) to perform exams while utilizing BasicMed. Doing so would significantly reduce turnover and training, create a wider pool of well-qualified DPE applicants, and increase use of DPEs for pilot applicants. In June 2021, AOPA, along with other industry groups, similarly recommended that the FAA allow individuals who utilize BasicMed to complete examinations as a designee.
The FAA is reviewing all public comments, including AOPA’s, and is expected to publish a final rule by the end of the year.