UK CAA allows medical self declaration (PMD) for certified aircraft within the UK

Currently, about 4k pilots are flying on the PMD which is some 20% of the UK PPL population.

Under a FOI request I made to the CAA several months ago well over 8500 PMDs had been made. My own PMD number is 8786.

I would imagine there are now over 10,000 PMDs in force.

It is perfectly possible to hold both a PMD and a class 2 at the same time. The problem only arises because the online application software for AMEs will not allow duplication, but this can easily be sorted out by the AME with the CAA over the telephone.
The CAA have had four years or so to sort the anomaly but unsurprisingly have thus far failed to do so.
The same issue applies to the listed licences which can be used with a PMD which have not been updated on the PMD form to take account of subsequent ORS4 exemptions.

And no cost sharing!! That last one alone is a show-stopper, because most of the UK rental community cost shares ~100% of flights.

There is no restriction on cost sharing using a PMD that I’m aware of.

Cost sharing not allowed on the PMD, per ORS4 1421.

I read this exemption and restriction as applying only to operation of G-reg EASA aircraft.

Silvaire wrote:

(1) private flying is not synonymous with recreational flying, and to assume some correlation between the two has no regulatory basis. I’m not sure the word recreational even exists in relevant aviation regulation.

I tend to agree. There is a chap who posts on the main UK GA forum (an IFR owner-pilot) who gets worked up about this and I have to say I agree with him. Private flying is just private flying, and whether you’re just getting up in the air for the hell of it or because you need to get from A to B is not a point that is covered in law and is therefore no business of the regulator.

‘Cost-sharing’ is another issue like this, where I don’t believe the concept has any proper basis in law and therefore attempts to regulate are woolly, inconsistent and largely unwarranted. What is a ‘cost-sharing’ flight? In order to define it, one would also have to define what is not a cost-sharing flight and if we follow the regulator’s logic that presumably means a flight where a private pilot pays the entire cost of that flight.

But of course, there is nothing in law or regulation to stop the costs of a private flight (and how do we define the costs of a flight, without inspecting people’s personal or business accounting?) being met by someone other than the pilot. I could ferry a club aeroplane for maintenance and not pay a penny myself, or I could borrow someone’s aeroplane for a day, perhaps (or perhaps not) making some contribution by topping off the tanks, or whatever arrangement you might imagine, but would anyone call these ‘cost-sharing’ flights? Of course not.

To achieve consistency in the way the regulator attempts to deal with ‘cost-sharing’ you would need to effectively have a regulation that required a private pilot to pay the full cost (how defined and assessed?) of each and every hour in their logbook unless that flight was operated under some sort of concession, i.e. within the CAA rules on cost-sharing. The FAA seems to go some way towards this position in defining logbook hours as valuable consideration, a position which is effectively “if you didn’t pay for them, then you were paid”.

All this sort of stuff is indicative of poorly conceived and drafted regulation. Especially in the UK, probably put together by people with a poor understanding of the law and how laws or regulations should be drafted, combined with poor logic and critical reasoning skills.

If the regulator feels it necessary to reach into finances when trying to separate the concepts of private and commercial aviation, a better approach would be to focus on the legitimacy or otherwise of a payment by a passenger rather than trying to define it in terms of operating costs. Of course these regulations only really affect things like Wingly, because most ‘cost-sharing’ is informal with no records kept, often done by buying beers/dinner/hotel room for the pilot, and people will keep doing it regardless because enforcement is impossible.

Cost sharing not allowed on the PMD, per ORS4 1421.

Well spotted Peter. I had a vague feeling I remembered such a restriction but of course it is not mentioned on the PMD guidance notes.

I read this exemption and restriction as applying only to operation of G-reg EASA aircraft.

So do I. I have no idea why that restriction was apparently newly imposed with that particular ORS4. Perhaps the CAA had Wingly flights in mind where the connection between pilot and passenger may be more tenuous, but of course they did not clarify this.

But what about G Reg EASA aircraft flown on a U.K. (FULL ICAO) PPL or NPPL?

You haven’t been able to fly an EASA aircraft on a U.K. national PPL or NPPL since April this year

That new guidance still doesn’t clarify differences within the CAA’s all-airspace remit, and devolved functions outwith the authority of the Cabinet Office.