Welcome to the General Aviation Advocacy Group of New Zealand

Archives for March 2013

Thank heaven! We are not alone

Take a look at this, and ask: Are they talking about our New Zealand Civil Aviation Authority?

CAA complaints 01
CAA complaints 02
The answer is, of course, no – it’s a summary of the results of a 2013 UK CAA customer survey undertaken by Clarity Research among 74 UK aviation companies, and it makes grim reading. We understand that as a result, the UK CAA is taking a close look at its complaints service.

These findings are reported on a website called CAA Complaints and this group appears so similar to GAA in New Zealand that we’re inclined to call them brothers and sisters.

Like us, CAA Complaints has been worried about the reluctance of British CAA victims to speak out, citing the fear of repercussions, and it’s done a little research on the subject, which we are delighted to report:

Many people told us the following in private:

“We see what you are doing and support you all the way, but please don’t let them know of my involvement as they will retaliate.”

We have spent a long time trying to understand how come otherwise outstanding professionals that have no reluctance in facing obstacles are so concerned with the consequences of speaking out about their beliefs and experiences, and then we stumbled on an explanation.

The Stockholm syndrome

Stockholm syndrome can be seen as a form of traumatic bonding, which describes “strong emotional ties that develop between two persons where one person intermittently harasses, threatens, abuses, or intimidates the other. Whereby the other person essentially mistakes a lack of abuse for an act of kindness.”

We are working to dispel this condition as we think that in a free society the regulator must be accountable, transparent and impartial.

Do you get the eerie feeling that you have heard all this before – perhaps in a recurring nightmare – and that we may not be alone?

And wouldn’t it be useful to conduct a similar survey of NZ CAA customers?

We’re working on it.

Seeing red? First, find the right bit of tape to cut

Oh, how easy it is for politicians and bureaucrats to make new rules and impose new levies.

And oh, how hard it is for ordinary people to find the route to any kind of redress or reversal.

When the CAA and Transport Minister Gerry Brownlee imposed their cost increases last year, some of the afflicted sought the help of the Commerce Commission.

No luck. “We don’t deal with that sort of complaint”, said the Commission.

Then GAA’s Des Lines (working with the support of 576 other signatories) sent a carefully researched set of submissions to Parliament’s Regulations Review Committee. After long deliberation (well, to be more accurate, a long time passed but the deliberation was short), his submissions were rejected by Chairperson Hon. Maryan Street, on the grounds that Des wasn’t specifying any particular regulation for the committee to review.

Back to the drawing board… and the submissions are now back on Ms Street’s desk for a second look by the committee. This time, though, there will be more for the committee to read, because Des has discovered additional evidence and precedents. And the signatories have risen to 620.

There are three complaints:

♦ A claim (under the Civil Aviation Act 1990 – Reprint as at 1 October 2012 Part 3 – Rules – Section 34) that the consultation process was flawed

♦ A claim (under Standing Order 315(2) (c) – Unusual or Unexpected Use of the Powers) that the $313 application fee for a medical breaches Standing Orders, and

♦ A claim (under Standing Order 314(4), relating to the Civil Aviation Charges Regulations (No 2) 1991 Amendment Regulations 2012) that new hourly charges clearly reflect unacceptably inefficient operation by the CAA

We are also taking a similar three-part case against the CAA to The Ombudsman.

GAA says that the review should be redone – and this time, properly – the medical application fee be abolished, and other charges reversed and refunded and (at the very least) Transport Minister Brownlee puts an end to the CAA’s inflation in general aviation costs, planned for the next two years.

In the meantime, please remember that if enough people put enough pressure on enough MPs, for long enough, statistics prove it can change minds – particularly as election time draws ever closer.

As one flying wit has remarked: “Brownlee and the CAA are making it even harder for me to buy back what I already own, such as Solid Energy and Mighty River Power…”

Per Ardua, add Astronomical insurance cover…

I hope you've got Third Party, Fire, Earthquake and Theft cover for that thing... Biggin Hill, where survival once earned a no claims bonus

I hope you’ve got Third Party, Fire, Earthquake and Theft insurance for that crate… A Spit at Biggin Hill, where survival earned a no claims bonus, sometimes valid for less than a few hours

When Hermann Goering’s Luftwaffe threatened to destroy Great Britain and cast the world into a new Dark Age, you only needed a few hours solo to pilot a Spitfire.

Per Ardua Ad Astra, or “Through Adversity to the Stars”, they used to say in those good old days…

But to fly your private aeroplane into Ohakea and view the remains of our Royal New Zealand Air Force during AOPA’s annual meeting events in April, you’ll need a lot more than that. To be precise, you will need:

♦ $2 million worth of liability insurance!

An update from AOPA about the AGM says:

“We’ve been in discussions with the Ohakea base regarding our planned fly-in for lunch. Ohakea have informed us that they require all aircraft to have $2mil of Public Liability cover before allowing access to the airfield.

We understand that some of our members will already have $2mil of cover, based on the similar recent requirements for DOC strips. We recommend that members look into increasing their cover, if not already done so, as the requirement for greater public liability cover is a growing trend.

If you don’t have $2mil of cover and you’re not intending to increase your policy, all is not lost. AOPA has investigated the potential of temporarily increasing your policy for this one-off event. Arden Jennings at Aviation Co-op and Bill Beard at Avsure have advised it may be possible to give aircraft the required temporary cover for the flight into Ohakea at no cost.”

How The Mighty Have Fallen, and the weapons of war perished… (2 Samuel Chapter 1 v.27) – right into the hands of daft and risk-averse bureaucrats.

Perhaps the RNZAF is worried that some feckless private pilot might crash into its new $771 million worth of Augusta Westland A109 choppers.

The motto means Defence Through Strength, now updated to Don't enter without enough insurance

The Ohakea motto means “Defence Through Strength”, now updated to “We’re a bit nervous. Don’t come here without enough insurance”

When about 30 private aviators flew into Ohakea on October 30 2011, there was no mention of insurance cover, and when the highly adventurous members of the Association of Women in Aviation did the same a while later, there were outrageous parties in the mess (and we have some potentially embarrassing photographs of the frolics) – but no mention of insurance cover or courts martial. Of course, way back then, the Westland helicopters were still in the factory…

How a few private aircraft could damage Ohakea is hard to fathom. This vast, uninteresting and empty bastion sits in a sparsely populated area and – in the absence of a credible air force – presents little in the way of risky assets. It’s one of the loneliest air force bases on the planet.

And it is more than likely to remain that way, especially on April 13 2013… a date that will live in infamy.

The Artful Dodgers’ Almanack (aka the New Zealand Aircraft Register)

It is a truth universally acknowledged, that a person in possession of an aeroplane must have a small fortune, and a house well worth burgling.

This erroneous statement makes two assumptions:

♦ That thieves can read and

♦ That thieves are stupid enough to think aircraft owners must be wealthy.

The CAA Aircraft Register puts owners at needless risk

The CAA Aircraft Register puts owners at needless risk

Nevertheless, the CAA has provided our nation’s kleptos with a ready-made shopping list of names and addresses, in the form of the Aircraft Register.

The hazards of the CAA’s register became clear after voices were raised against the authority allowing the use of it to a private company administering landing fees for client aerodromes.

The database was taken down when the Privacy Commissioner took an interest. But then it reappeared, and along with that action came a letter to owners from the CAA. It didn’t mention the kerfuffle over Greasr, but said: “The CAA is committed to adopting best practice in managing personal information it holds, in accordance with the Privacy Act 1993. Accordingly, individuals whose name and address are shown on the online register may now choose to have this personal information withheld.”

Clever wording, but slightly disingenuous because, under the law, those individuals have always had that right. Perhaps the CAA didn’t realise this until the Privacy Commissioner came knocking.

On February 23, we wrote to the CAA: “Private owners of aircraft – under your current regime – are publicly identifiable, as are their home addresses. Any half-witted thief in possession of an internet connection can easily identify aircraft owners and might target their addresses for burglary.”

Sue Holliday, Legal Administrator, replied on February 28:

“Section 74(3) of the Civil Aviation Act 1990 requires the CAA to make aircraft registry information available for inspection by the public free of charge, in accordance with the provisions of the Official Information Act 1982. Anyone meeting the eligibility criteria in section 12 of the Official Information Act may request access to personal information that the CAA holds on a person. The Official Information Act obliges the CAA to make the information available unless there is a good reason for withholding it. The Official Information Act requires us to balance a person’s privacy interests against many other considerations. Privacy interests may, therefore, provide good reason to withhold contact information in some instances.”

And in a letter to Des Lines on February 18, the CAA’s Chief Legal Counsel John Sneyd said:

“As we are bound by the Official Information Act, we are not able to ask for individuals’ permission to release their information. It is our obligation to assess each request and decide whether it is appropriate to release the requested information, that is, whether the public interest in releasing the information outweighs the privacy interests at stake.

“We are now confident that the operation of the aircraft register meets the requirements of the Privacy Act and the Official Information Act and comprises a good balance between owners’ privacy and the interests of organisations who need contact information for legitimate purposes.”

The problem here, of course, is that you don’t need to make a request. Anyone can simply access the register and grab personal details, without asking permission.

We have provided a good reason for withholding that information from all but legitimate organisations as a matter of policy. It’s the same reason why you and I cannot track down the owner of a vehicle. The New Zealand vehicle register used to be public, but that was changed by legislation a couple of years ago.

“For obvious reasons”, said Debbie of the New Zealand Transport Agency, when we called.

And it’s the same reason why the New Zealand Police will not allow you to find out who has a gun licence (and probably owns weaponry that might be useful to the criminal fraternity).

Where the law is skewed is in requiring aircraft owners to opt out of having their names and addresses on public view, rather than opting in.

So unless you’re vigilant, all your details will be up there on the Web, just waiting for a thief to build a database of places to raid.

We think that the law in this respect should be changed – and if it isn’t, the CAA should go one better than the law and show greater responsibility by asking its clients to opt in, or keep their details confidential by default.

Not only that: We’ve suggested to CAA that it includes an area on the ownership form where people can make a clear and conscious choice.

♦ To have your personal details removed from the register, email privacy [at] caa [dot] govt [dot] nz

Home-builts and Microlights: Our CAA threatens to turn back the clock

CAA thinking: Out of line with today's advanced home-builders

CAA thinking: Out of line with today’s advanced home-builders

Home-built and microlight aircraft enthusiasts are facing a huge threat to the liberties gained through all the hard work by many aviators over the years.

Many people are unaware that the CAA section that dealt with the AB (Amateur Built Aircraft, and Microlight) has now been taken over by the ACU (Aircraft Certification Unit), and it has already become very apparent that this unit does not (or does not want to) understand the concept of amateur building.

In the USA, of course, there has been wide acceptance of the technological advances and practical aircraft designs and modifications that have come through from Experimental Aircraft Association members.

It appears that the ACU wishes to return us to the draconian system that was in place in the early days, where every amateur-built aircraft had to comply with Type Certified Regulations.

The process of rewriting the advisory circular concerning Amateur Builds and Microlights (AC 21-4 Rev 1) began some time ago, before the departure from the CAA of some very helpful and knowledgeable administrators. This rewrite was designed to bring it up to date and give more advice to builders but it was never finished and the section was taken over by the ACU in a recent “re-structuring”.

Disturbingly (and this has been quoted to several people), there have been alleged comments from the ACU “that the FAA has got it wrong, and the ACU is going to correct it”.

At threat here is the continued acceptance by the CAA of the long-established FAA “51% rule”. If this rule is usurped because of a new “interpretation” by the ACU, it will have a severe impact on all home-builders.

In the words of a retired Civil Aviation Authority employee and home-builder: “We do need to safeguard the AB category. It was hard won and some tough decisions may well have to be made. I believe we have it better here than in the US. The SAA does need to be proactive in these areas.”

To fight this effectively, home-builders need to gather as much evidence of interference with the status quo as possible, so if any of you have recently had bad experiences with this unit (and this is not just limited to amateur builders) please contact Gavin Grimmer at grgrimmer [at] inhb [dot] co [dot] nz or email GAA.

Why Airways’ new pricing plans are aimed in the wrong direction

ATC - almost entirely for the benefit of commercial aviation

ATC – It is almost entirely for the benefit of commercial aviation

The proposed Airways new charging regime would see the doubling of ATC charges for arrivals, and the revisiting of that old chestnut about charging for VFR entry to controlled airspace. For those compelled to live on aerodromes with air traffic control, a doubled handling charge will be a serious and unavoidable imposition. So it’s demonstrably unfair in that respect alone.

But there’s much more to these proposed increases than meets the wallet.

Tim Dennis writes:

Access to the airspace in New Zealand is a right. I am sure that when Airways came into being in 1987 there was much debate and argument about the charging regime. Airways gave commitments and I believe part of its mandate with the Government was that it must facilitate access to the airspace for all users.

Controlled airspace and therefore Airways Corp exist for the sole benefit of the commercial users and fare-paying public. It provides no benefit at all to GA users (quite the contrary). Therefore all costs of its operations should be paid for by those who benefit – ie commercial users and fare-paying passengers. Since GA derives no benefit at all and is frequently frustrated or prevented from private activity by Airways’ presence, there should be no cost to GA.

The Australian and USA systems I have operated in actively promote and encourage GA users to be part of the system, thereby reducing airspace infringements and improving safety. Airways also does that, but the possibility of charges – no matter how small – will discourage it. People will modify their behaviour (often quite irrationally!) when there is a likely cost. This will lead to unsafe actions and decision-making, airspace infringements, non-compliance (turning transponders off, not talking on the radio, not asking for assistance when required, and so on).

Attempts to avoid charges will increase traffic in the narrow low-level transit lanes which are not suitable for high traffic flows.

Non-compliance which results in a mid-air collision will undo all of the savings and headlines such as “Airways charging regime root cause of mid-air disaster” will do nothing for the industry or the travelling public!

The costs to all parties of such a charging regime in administration will be prohibitive, thereby seriously diminishing the benefit. This will include arguments over whether or not a fee should have been charged, collection of small charges, refusal to pay, aircraft owners not being able to recover costs from pilots or not knowing if/when a charge has been incurred, and so on.

The correct actions would be:

1. Actively encourage not-for-profit GA use of the airspace and communication with controllers at no cost, and positively facilitate access.

2. Review the airspace in light of the modern commercial fleet of pressurised turbo-prop and jet aircraft which have steeper climb and descent profiles, higher cruise altitudes, GPS approaches etc, to free up all controlled airspace under 10,000 ft that is not actually required. All the areas outside the control zones should have their lower limits reviewed and the steps brought closer to the terminal.

3. Look to create VFR transit lanes over, as well as around, the large terminal areas that block large parts of the country, for example Auckland, Hamilton, Ohakea, Palmerston North, Blenheim, Nelson etc – wherever possible. I understand this happens in the USA.

 Tim is a CPL(A) D Cat with 40 years’ experience and about 4500 hours total time. He owns a PA18, teaches tail-wheel and flies a DC3 as co-pilot. He flew for Bell Air during early fights with Airways over charges in the late 1980s…

Write to Airways

In its latest newsletter, AOPA reminds us that hard lobbying from AOPA persuaded Airways to drop the proposed charge for VFR entry to controlled airspace for two years. “As expected, these charges are back on the agenda. The AOPA stance is that we object strongly to charges for lower airspace transit, aerodrome control zones and the like, but can live with reasonable and fair upper airspace charges, for controlled VFR. The logic is that we request the help in upper airspace, but in general have little option lower down. Members who fly often really should read the [consultation] document carefully to find out how much money they could be up for in a year.

“However we believe that private VFR presence in the main causes no extra cost to Airways. More work probably, but no extra cost. Commercial GA training traffic in Tauranga and Hamilton has led to extra costs for Airways and they see these charges as belonging to GA. They are looking to VFR transit charges as part of cost recovery for this. We regard this wholly unacceptable, and urge members to write to Airways to communicate this.”

Aye to that – and not only AOPA members!

There are only a few days left to tell Airways what you think of its plan. Submissions close on March 15.

♦ Airways failed to answer GAA’s invitation to provide a plain-English summary of its proposals for the website. It would have spread the explanation far beyond the confines of a few seminars that proved inaccessible to most people…

An urgent message to all owners of Rotax-powered Bell helicopters

The Civil Aviation Authority would like you to know that there may be a potentially serious leak in your chopper.

Gosh guys! This would be a really bad time to find holes in our trusty Rotax 912's cylinder heads

Golly gosh, guys! This would be a really bad time to find holes in our trusty Rotax 912’s cylinder heads

On March 7, it issued Emergency Airworthiness Directive EASA AD 2013-055EE, concerning reports of non-compliant cylinder head assemblies on a Rotax engine during a production test run. The envelope had a CRITICAL TO FLIGHT SAFETY imprint on it.


And the letter said that the Type Certificate Data Sheets (TCDS) for the UH-1 series aircraft required that FAA ADs applicable Bell models 204, and/or 205 series must be reviewed for applicability.

The cylinder heads “may have small machined through holes which can increase the oil consumption and can result in oil starvation and a loss of engine power in-flight engine.”

Most Rotax owners will already know of this AD – particularly if they’re signed up to the Rotax Owners website (which put out the AD at least 36 hours before CAA’s snail mail arrived). And they will know (from apparently more reliable sources than the CAA) that, in this instance, Bell helicopters are not applicable for applicability checking.

The CAA has caused a great deal of unwelcome distress to our significant community of Kiwi Huey helicopter gunship owners, who – until this terrible but false news arrived – had doubtless been looking forward to a pleasant weekend strafing the neighbours, innocent wildlife, or Featherston Street.

Postscript: Next year, aircraft owners living in rural areas might have to wait until the following week for any letter from the CAA, if NZ Post slashes deliveries as proposed by bean counters who have not the slightest notion of social responsibility. Tragically, some such pilots may have already bought the farm by the time the postie brings more bad tidings from the CAA (this time, we pray, somewhat more accurate).

There could be a claim for NZ Post Traumatic Stress Disorder.

Have you ever wondered? Part 2

Do what? That’s more than my job’s worth…

Why does Change seem so hard to achieve in New Zealand, while failure, mediocrity and conformity are accepted with barely a bleat?

The challenge of Change doesn’t just apply to aviation. With some councils, it also applies to repainting your mortgage-free dunny in a different colour.

Change almost always involves confrontation (and sometimes conflict) with Rules. And Rules are imposed to discourage Change. This suits the Rule-makers all the way down to the ground, because unwelcome Change involves loss (hopefully, theirs) and gains (very rarely, ours).

Pilot Peter L Collins has sent us some valuable warning references about what will be involved, if you were to be so rash as to poke your head above the fence – and suggest any sort of Change at the CAA.

He says: “Below, I list the headings of the rules process. Many of these pages are themselves lists of things the poor, long-suffering CAA staff have to attend to.

“In particular, see the Scholtens report, listed below, the key section being:


which explains why nothing can ever get done inside 20 weeks, even if two fully loaded 747s are about to collide.”

Peter warns: “Students, your task will be arduous. Begin it with two stiff gins and a vodka chaser, two paracetamol pills and a cup of tea, followed by ten minutes in a quiet, darkened room – perhaps with a pretty maiden pressing cold compresses to your forehead.

“Then read Scholtens.”

When following due process, Civil Aviation Authority personnel will always have at least 10 other things to deal with before Number 11 on the priority list (your issue) reaches the top of the pile. This means that nothing may get done within 10 x 20 = 200 weeks – which, when Peter went to school, added up to about four years. Present-day evidence seems to support his calculation.

Peter says: “I’ll bet you don’t have the patience to work your way through them and all their subsections. If you do, congratulations – you have the making of a genuine gadfly. You need to take a long view, but to be a truly great gadfly, you need real persistence and stamina.”

Here goes…


















Peter suspects that he may have missed something. “I have certainly suppressed all the links that most of those above contain, which really should be taken into account in the process.”

But that’s quite enough for the time being, Peter, thank you very much. Most of us will start with the gins and a bit more vodka than recommended, and leave it there.

The impossible task of getting blood from a stone

You may be very angry about the Civil Aviation Authority’s recent fee impositions on the General Aviation community, or you might be a microlight pilot worrying that you could be next in line for the CAA bean counters’ unwelcome attentions.

But no matter who you are, it’s a fair bet that you just cannot understand why the CAA took such a harsh approach.

Spain’s glossy Alicante airport. It’s picture-perfect, because there are no passengers. The nation is bankrupt, and every Spanish-based airline has gone bust

Part of the answer may lie far beyond our shores. For instance, the UK Government is pushing ahead – despite loud opposition – with a big increase in its already horrendous Airport Departure tax (APD), which varies between £13 and £184 per passenger.

A family of four Brits visiting New Zealand will face an APD bill of £500 (around NZ$910) from April. As far as we know, none of it goes to the UK CAA. It enriches the UK Treasury, and it stifles tourism – incoming and outbound.

You might also get some clues by looking at a couple of local indicators. For example, commercial traffic movements at Christchurch International are believed to be running at around half the previous high. And when our CAA lit a rocket under its charges to General Aviation, the airline passenger levy was quietly reduced.

This tells us that our Government is worried about the falling income from tourists, who are also scared off by the absurdly over-valued New Zealand dollar.

Associate Tourism Minister Chris Tremain: Our questions to him went to and fro in Wellington… and resulted in no coherent answers

Mindful of all this, on January 31 we sent an enquiry to Chris Tremain, the Associate Minister of Tourism:

“Commentators on GAA have suggested that rather than imposing such heavy CAA extra charges on the general aviation community, a 50 cent passenger levy on internal commercial airline flights could provide up to $4 million revenue per annum for the CAA, to support its activities.

“While these figures are speculative, what is your position as Associate Minister of Tourism on this subject? I would also appreciate your figures on the impact this might have on CAA finances and any possible downside to tourism that you or your department might perceive.”

On February 11, Mr Tremain’s Ministerial Secretary, Emma Stringer, replied: “Upon further consideration of the issue you raise, it has been decided the most appropriate Minister to respond to your email is the Minister of Transport, the Hon Gerry Brownlee. For this reason, I am transferring your email to Minister Brownlee’s office for consideration.”

So far, not so good. Minister Brownlee’s performance in answering GAA supporters is less than stellar and in one case, his response was baffling. It appeared to have been intended for someone else, on another subject.

Tourism Minister John Key’s young Associate seemed to handle an awkward challenge as deftly as father Kel did as an All Black. Quite why the Transport Minister should take control of a question about tourism was a mystery. What we do know is that at March 5 – almost five weeks after the initial GAA enquiry – no answers had been received from Mr Brownlee either. But that day, we did get an email from Mr Tremain’s office. It said: “As the matters you raise require consultation and input from other offices, it is taking longer than usual for a response to be prepared. Minister Brownlee’s office has asked that Minister Tremain responds [to your email]; you will not be receiving a reply from Minister Brownlee on this matter.” Emma promised a response before a scheduled meeting between Mr Tremain and myself, on March 15. And it came, on March 14: Take a look at Comments.

Iberia: A major air disaster, among many, that has left aviation authorities wondering how they can survive…

Mark Chesney is Head of Flight Operations Inspectorate (Aeroplanes) at the United Kingdom’s CAA. (He was also the author’s flying instructor.) We asked Mark about UK CAA charges, and what he said made us suspect that New Zealand GA might be a precursor for what could happen elsewhere. Mark said: “Because we are funded solely by the industry we regulate, charges are kept honest by constant challenge.

“However, a review is about to start, largely because we are the only EU member state with this funding model and it puts us at disadvantage in some respects with other countries.

“We are going through considerable change in business models and this will have an impact on regulators and fees.

“For example, Spain’s CAA used to be funded by taxation on its airlines, most of which have now gone bust. They [Spain] now put a 39c [about NZ 62 cents] levy on every ticket, irrespective of nationality.”

Ryanair boss Michael Ryan is furious at the rising cost of landings, and not just in the UK. But his airliners pay not a penny to the UK CAA

The biggest airline operating in Spain is now Ireland-based no-frills Ryanair, followed by easyJet, then Iberia, Spain’s former national carrier which merged with British Airways (which is, in turn, part of the International Airlines Group). At the end of February, IAG crashed to an £865 million (NZ$1.6 billion) pre-tax annual loss and will axe 3800 jobs at Iberia.

“Ryanair has 155 aircraft in the UK that the CAA has no safety oversight of and no income from”, says Mark Chesney.

To make matters worse, Ryanair – whose 2012 bid to buy Stanstead Airport, north of London, was acrimoniously rejected – reacted strongly when the new owners slapped a 6% increase on landing charges. It has slashed 170 flights a week, reducing Ryanair passengers through the airport by 1.1 million a year, and said 1000 jobs would go as a result. (Ryanair’s fiery chairman, Michael Ryan, would have 50 shades of hissy fits if he was operating in some of New Zealand’s airports, where landing fee rises of more than 60% have recently been recorded.)

So the UK CAA is cash-strapped, hosts airliners over which it has no jurisdiction, is suffering from airline financial crises beyond its shores or control, and will have to seek new income streams – or shrink.

It will be interesting to see how the UK CAA remodels its charges. Heaven help UK General Aviation, if the New Zealand model is copied.

Despite the best efforts of the UK and New Zealand CAAs, wherever they go looking for new money, that elusive crock of gold will vanish over the rainbow.


Because it doesn’t exist.

National CFZ network: Will CAA force a fizzer?

“The new framework will ensure the CAA is sufficiently resourced to continue delivering air safety benefits in a rapidly changing environment.”

Minister of Transport Gerry Brownlee, November 2012, explaining CAA fee increases

The Air New Zealand 777 pilot who briefly nodded off twice during a London-to-LA flight (causing international media shock-horror, barely two years after the non-event) might not be the only one revealed to be asleep on his watch, as far as aviation safety is concerned.

A remarkable CAA response to Massey University School of Aviation’s proposal for a national CFZ network has caused consternation in Palmerston North. It appears to quash any prospect of progress.

GAA has asked CAA Director Graeme Harris to provide the full text of CAA’s response to Massey, and he has told us that this will be done (but under the limitations of the Official Information Act).

However, we already know the headlines. Examine them carefully, and notice:

Nowhere in the little we know of the CAA response is there any mention of air safety.

CAA Manager Mike Haines told Massey (while giving them just seven days to respond):

♦ CFZs are not enabled under CAR Part 71 and there are no associated pilot requirements under CAR Part 91. For a rule change to progress, a CAA policy decision is needed and Ministry of Transport approval for the project and associated funding. Rules are developed by CAA under contract to the Ministry of Transport.

To which GAA says: So what? If CFZs are not enabled under CAR Part 71, why are they already in existence? Will the CAA now disestablish them? This is nothing more than lazy bureaucratic obfuspeak. Why not, instead, refine the idea, make a CAA policy decision in favour, talk to Brownlee, allocate the funds and get on with it?

The Manawatu CFZ was established by the CAA. Can you remember why? If not, consult the families of the dead. Or read the last paragraph of the press release about your authority’s own accident report into the crash.

♦ CFZs are a New Zealand-specific type of airspace, which means that overseas pilots operating here would not be familiar with them and that NZ pilots used to using them would not have these when operating overseas.

To which, GAA says: So we should not improve safety for thousands of New Zealand-based pilots simply because we might confuse a handful of visitors who would, in any case, be required by CAA to demonstrate knowledge of New Zealand operating conditions? And since when have Kiwi pilots been deemed incapable of adapting to different conditions offshore? This feeble comment displays an arrogance that is not matched by wisdom, and shows scant respect for New Zealand pilots.

♦ Establishment of multiple CFZs requires additional aviation radio frequency allocation, which lowers available aviation radio spectrum.

To which, GAA says: Nonsense. There is plenty of available spectrum for this, and there’ll be three times more if the CAA follows Eurocontrol’s new requirements for an 8.33 MHz radio system instead of the existing 25 MHz (aided and abetted by ICAO, whose edicts are invariably over-imposed by the NZ CAA at our expense). When that happens, guess who’ll be paying for your new radio? We have also been told that Airways has some innovative radio frequency solutions that could be used for CFZs, right now.

♦ The large number of frequencies raises human factors issues if pilots continually need to change frequencies.

To which, GAA says: That’s simply daft. They won’t. A CFZ in parts of Canterbury, for example, would cut the frequency changes from four to one. And, if CAA claims a large number of frequencies are involved, we have to ask CAA: How many frequencies might there be? And how could pilots become confused?

♦ The volume of CFZs and associated frequencies would be difficult to clearly put on visual navigation charts and may increase clutter.

To which, GAA says: The amendments can be created by a well-briefed graphic designer in less than two days. They are simple to impose on an EFB map, and pose no problem to any traditional printer. If you want to see what real clutter looks like, Mike, take a look at the South-East England VNC. Our NZ charts are jam-packed with empty space. And can you show us where, on a VNC, the boundaries of a FISCOM service are marked?

♦ A CFZ has no single monitoring agency and thus no alerting or emergency response.

To which, GAA says: Why do we need a single monitoring agency? Perhaps it’s to charge aviators for another dubious and unreliable service. This sounds like control freakery, written by someone who also doesn’t know about (or chooses to ignore) the emergency radio frequency and the other reporting options available to pilots. They do not want to talk to an overworked monitor, somewhere or other. They want to talk to each other. Like, Mike, this minute.

FISCOM is under-staffed (and probably under-funded). The system does not work reliably below 4000 feet (as CAA admits), which is where the danger usually lies. In some parts of our country, it does not – and cannot – exist. FISCOM introduces an unnecessary third party to the matter at hand: which is to ensure that pilot-talks-to-pilot on one local frequency in order to fulfil a primary responsibility: to seek, to locate and to avoid each other. FISCOM takes no responsibility for separation. For low-level General Aviation, the system is as useful as a cow with a box of matches. That is why practically no one uses it.

All this spurious nonsense from the CAA tends to confirm the widely-held view that some people in the authority are less interested in General Aviation safety than in balancing the books and trying to avoid the hard yards.

At Massey, they held an internal meeting to discuss the CAA message and it was agreed to first seek a longer time frame to respond, state that “we have big concerns with the document and lastly to respond to each of the issues they have raised as reasons why CFZs are not the best solution and FISCOM is.”

To quote Massey: “The real challenge is if CAA puts a document out for public submission that doesn’t really talk much about SAFETY, then people are unlikely to respond and the CFZs will die. We will be pushing hard to have people comment and tell it like it is out here in the real world of busy uncontrolled airspace. The wider this is spread, the better.

“In our opinion, FISCOM was not designed or intended for the aircraft-to-aircraft information which CFZ allows. We want a simple system that pilots can use to enhance their situational awareness about other traffic – after all, ‘Listening out’ is a vital part of ‘Lookout’.”

The 777 pilot nodded off and – two years later – a dopey ministerial outburst made Air New Zealand look unsafe

Gerry Brownlee was quick off the blocks to publicly and loudly condemn that sleepy Air New Zealand pilot. The UK’s Sun newspaper reported Brownlee as saying it “doesn’t look good” for the airline.

He said: “You’ve got big reputational issues here.” Mr Brownlee went on to advise the airline to “satisfy the public that you’re making sure your pilots are not asleep on the job”.

A Minister of Transport in full command of his portfolio would know that Air New Zealand (and most other airlines flying two pilots, long-haul) have for many years had procedures in place for “cockpit napping”. This has been agreed to by CAA and involves one pilot having half an hour’s sleep in the seat, while the other pilot minds the shop.

More alarmingly, Mr Brownlee also appears to be comatose when it comes to dealing with the more present and dangerous situations in which general aviation pilots in this country are placed – almost every time they fly cross-country.

Feel free to email the Minister at g [dot] brownlee [at] ministers [dot] govt [dot] nz, or Mike Haines at Mike [dot] Haines [at] caa [dot] govt [dot] nz to tell them what you think.

By the look of it, they both need a deafeningly loud wake-up call.

March 6 update from Mike Haines at the CAA

I wish to advise that the document being referred to in your email is still in draft form. The document requires feedback within the CAA, Massey and AOPA before it is finalised. Rather than sending you a draft document which is most likely to be revised, we prefer to send you the final discussion document as soon as it is ready. We anticipate that the document will be finalised in the next few weeks. You will be advised then of the submission process and closing date.