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Archives for April 2013

Grim signs of GA’s decline, thanks to dogma and the bloody-mindless

Formation from the New Plymouth Aero Club, in happier times

Formation from the New Plymouth Aero Club, in happier times

We see the first omens of serious trouble for General Aviation in New Zealand, caused by a deadly combination of political dogma and bureaucratic stupidity. The artificially high New Zealand dollar, ill-considered changes to student loan policy and rocketing CAA charges have severely damaged at least two aero clubs.

After more than 80 years, the New Plymouth Aero Club is facing liquidation. In Nelson, the city’s aero club is in crisis, and has closed its training operation – handing it over to a Motueka-based college.

New Plymouth Aero Club General manager Peter Budden said the club and its flight training school ceased trading in mid-April and a meeting would be held in May to determine the club’s future.

This closure has been blamed on a decline in student pilot numbers, a high Kiwi dollar and rising Civil Aviation Authority compliance costs.

Peter said voluntary liquidation was an option, but he remained optimistic.

“I think there will be enough will in members for it to continue running. We have a really proud record; we’re all pretty disappointed it’s come to this.”

Two full-time staff and up to three part-time flight instructors were employed by the club. It had been struggling to attract trainee pilots since 2011, when the Tertiary Education Commission stopped granting students funding to train at New Plymouth.

“I think the TEC decided it was the bigger ones that had the infrastructure for it – we didn’t,” said Peter. “We had a very good training record, but we missed out.”

Many foreign student pilots, mostly from India, used to train at the club but they were now training in other countries because of the high New Zealand dollar, he said.

Civil Aviation Authority compliance and administration costs were also climbing.

The club had been selling down its assets to reduce debt, including selling its hangar and an aircraft. Flight training was still being run at the club using three privately owned aircraft and existing instructors, but it was not part of the club’s business.

“We’re still operating out of it. The aero club hasn’t locked up.”

About 10 students were still learning to fly at the club.

People who wanted flight training could still contact the club to learn to fly but it would not be an aero club operation, Peter said. “If we had more people learning to fly, we might have been able to ride this out.” The club had a long and proud history and was highly regarded as a quality flight training provider.

Peter told GAA: “There are a number of issues that have affected our finances over recent years, but the loss of our domestic pilot training programme via TEC has been the most significant.

“I’m gutted about what is happening, however recent developments from CAA cumulatively have an adverse effect on all of us”.

New Plymouth Aero Club operations manager Wayne Harrison, who has been with the club for 41 years, said it was disappointing the club was in this situation.

He said rising CAA costs would see a lot of other aero clubs finding themselves in a similar situation to New Plymouth’s.

Nelson Aero Club: Almost defeated, badly beaten but still unbowed

Nelson Aero Club: Almost defeated, badly beaten but still unbowed

At Nelson’s troubled aero club, president Maurice Tighe confirmed its flying school has closed and will be taken on by the Motueka-based Nelson Aviation College.

“We are adapting for the times to ensure the livelihood of the Nelson Aero Club,” he said. The club has sacked both its instructors.

Mr Tighe, who has been associated with the 80-year-old club for more than 20 years, said its flying school had fallen victim to the tight economic times, along with increased administration and compliance requirements.

“We need 80 flying hours a month to break even. Last year, the average per month was 60 hours. We had a huge increase in our costs and by the end of the year the club had only increased the hours by two a month.

“The flying simply did not materialise, and we were at our wits’ end with what to do next.”

Mr Tighe said the club was very sorry that it had to lay off its instructors, but in the end it had no choice.

“It’s very sad because they’re two very good men.”

GAA noted further evidence of declining GA activity when Z Energy announced the closure of its fuel facility at Taumarunui, and a future study of airports where landing fees have been dramatically increased (such as Napier and Gisborne) will doubtless show that higher charges result in fewer movements.

Nelson and New Plymouth cite CAA charges as a major factor in their predicament. Perhaps the key to survival will be to get back to grass roots activities by re-equipping with microlights and LSAs – eliminating many of the CAA’s heavy costs and regulations. At Hawke’s Bay and East Coast Aero Club, a refurbished Tecnam Echo microlight has accounted for 20 percent of fleet hire hours within the first six months of operation, and is more often than not fully booked at weekends. There’s talk of that club buying another microlight.

As for student loans, the government claimed to have cracked down on abuses, and it’s true that there have been cases of flight training students walking away from courses with much of the funds in their back pocket. But the “corrective” action is beginning to look like a case of throwing the baby out with the bath-water.

As for CAA charges, the book has already been written here on GAA, but public servants and Transport Minister Gerry Brownlee refuse to read it.

As for the high dollar, which is causing mayhem among exporters, the tourist industry (and clearly, flight training organisations), the National-led Government – which is still borrowing $300 million from foreigners every week – wrings its hands and says it can do nothing. Tell that to Japan, which issued a gigantic heap of new money in April, effectively devaluing its Yen by 25 percent. This hurt a large number of currency speculators, but will probably provide a much-needed economic boost.

Financial commentators say that Japan has only one way out – a massive devaluation. A devaluation of 40 percent can restore Japan’s competitiveness against Germany and South Korea, which will lay the foundation for recovery.

Andy Xie of Caixin Magazine says: “The day of reckoning for the Yen is not distant. Japanese companies are struggling with profitability. It only gets worse from here. When a major Japanese company goes bankrupt, this may change the prevailing psychology. A weak Yen consensus will emerge then.”

For Japan and its Yen, substitute New Zealanders and our dollar. And for a major Japanese company that may go bust, substitute any significant New Zealand business that springs to mind.

National CFZ network: The CAA, Airways (and the rest of us) are flying blind

On April 12 2013, the CAA published a discussion document discussing “Radio frequency use in uncontrolled airspace” or Class G uncontrolled airspace where pilots are responsible for their own separation and collision avoidance. This was in response to Massey University School of Aviation’s proposal for a national CFZ network.

The CAA’s alternative proposal for the development of FISCOM to resolve what everyone recognises to be a serious problem has become a problem of its own, because the CAA has admitted it cannot cost the proposal, put a timeframe on it, provide any technical detail or offer any clear idea of what it might achieve.

Pilots have little trouble in understanding how the CFZ proposal from Massey will work in practice, but they are in the dark as to how the CAA’s preferred FISCOM service will work in its “enhanced” version.

From enquiries to the CAA and Airways, it would appear that:

♦ Airways currently has no idea of how CAA’s FISCOM proposal would work and

♦ Neither does the CAA

So it might be unwise for the authority to take what the CAA describes as a “final decision” on the Massey proposal after submissions close on May 24. A CAA commitment to an extended period of research and discussion might prove more fruitful.

Meanwhile, the GA pilots who are the users of the FISCOM system have a window of opportunity to stipulate their requirements of any proposed FISCOM-based solution. The complete answer might include a modified version of the Massey proposal – perhaps an introduction of new CFZs in identified critical areas – along with development and innovation within FISCOM.

Des Lines put his personal views and criteria for an enhanced FISCOM service to the GAA supporters on our database:

1. There must be the capability for aircraft-to-aircraft blind transmissions of their positions, altitudes and intentions.

2. There must be good low-level capability from the upgraded aerial system.

3. The FISCOM frequency areas should cover clearly defined geographical areas in a similar manner to the way CFZs are portrayed on our visual navigation charts.

4. There should be a good separation of frequencies so that the transmissions in a particular FISCOM area will pertain to traffic in that area.

5. A FISCOM operator will monitor all aircraft transmissions but only respond to those prefixed in a particular manner such as we do now by using for example “Christchurch Information”. Other aircraft-to-aircraft or blind transmissions could perhaps be prefixed with something like “FISCOM traffic”.

6. The FISCOM service must be available at no cost to the users of that service.

GAA is receiving some extremely positive feedback to this survey – including some novel ideas – which we now feature on the site, and will add to as further comments come in.

Meanwhile, Massey’s Frank Sharp has told GAA: “It may be that CFZs are not the most appropriate for absolutely every area of the country. However, we believe CFZs are the way ahead for the main trunks and majority of areas – also, under the KISS rule, going with CFZs would keep it easily understood by users. There is little doubt that the FISCOM could do with a revamp, but that would still not solve the immediate safety issue of ‘broadcast and be seen’, as a vital component of LOOKOUT and traffic avoidance.”

GAA has already published the Massey and CAA cases, and Frank Sharp urges GAA readers to compare them and make suggestions. Please send them either as comments to the website, or to admin [at] caa [dot] gen [dot] nz

CFZ network, Option 1: Your feedback

Option 1 is: That the CAA adopts the Massey CFZ proposal for aircraft-to-aircraft communications, and keeps FISCOM for aircraft-to-ground information.

Comments:

I have difficulty in understanding how the CAA/Airways proposals would work in practice.

I came up with a number of reasons why the CAA/Airways solution would create a negative safety factor. I’d been considering for some time that Masterton aerodrome (to name but one location) would benefit from a CFZ.

On busy weekends, whilst ‘meat bomb’ dropping, I’m having to contend with not only communications with Ohakea Control, which works better on the frequency assigned for the Manawatu Gorge area at altitude, rather than that published for the Wairarapa … Hence, not always hearing the other traffic in the area that originate calls to Control. Not a big problem in controlled airspace, as long as traffic information is relayed from Control etc.

More important is the fact that I can hear most of both Islands’ traffic on 119.1 MHz when at altitude, making it sometimes a little difficult to assess the ‘relevant’ traffic situation around Masterton. This is irrespective of the argument whether these stations should be operating on 119.1 MHz in the first place.

Now consider the situation where aircraft outside of a 10 nm radius, operating on the assigned FISCOM, may or may not switch to 119.1 when overheading the airfield. Which, as I believe was suggested, was that there was no need for them to do so if above 3000 ft AAL (or lower). This potentially occurs a number of times a day, and when parachute dropping, I at least get to know of their presence on 119.1 (or a CFZ) and can advise them to remain clear when a conflict would occur.

1. Therefore, the use of FISCOM whilst en-route could/would increase the possibility of an aircraft/parachute conflict. (I’m not monitoring FISCOM.)

2. Using a dedicated CFZ would cut down on all the extraneous radio traffic currently on 119.1, limiting it to only aircraft within the operational area.

3. The use of FISCOM, then ‘local’ frequencies’ of airfields within 10 nm, may actually increase the workload for the transiting pilot.

4. As with the use (overuse or inappropriate use?) of 119.1 MHz, how would FISCOMs handle the radio traffic and again, the potential of radio ‘overload’ and pertinent information not being heard (by both pilots and FISCOM controllers)?

5. FISCOM handled by remote towers such as Dunedin, Napier, Gisborne etc: Can they handle it? Maybe not, especially when dealing with scheduled aircraft movements in and out of their aerodromes.

6. Use FISCOM for safety and ‘flight following’ where required. Again, a chance to miss vital information if everyone is operating on these frequencies for general position reporting.

7. If CAA/Airways have to define physical geographic areas for FISCOM boundaries, why not just use these boundaries for new dedicated CFZs. Keep it simple!

8. The argument that CFZs are not mandatory is fallacious. It’s good airmanship to use the CFZ frequency… just make it mandatory. Simple again!

9. Your comment concerning coverage is extremely valid and I very much doubt that can be improved without a big increase in radio infrastructure nationally.

10. As to the lack of frequency availability for dedicated CFZs… again, I don’t believe this is a problem; even if CFZs somewhere in Northland, southern Hawke’s Bay and Southland shared a frequency, would this be a problem for most traffic in these areas below 9500 ft? Certainly much better that the current 119.1 MHz.

11. What happens in the event of Christchurch going ‘off-line’ again, as in the last big earthquake? Having been in upper airspace on survey that day, most things came to a halt. Imagine this happening to all airspace if the FISCOM proposal went ahead.

Mike Haines may wish to consider this, which I see as a major potential problem and not unique to the Masterton area.

Further points:

1. The Massey CFZ proposal for aircraft-to-aircraft, and FISCOM for aircraft-to-ground. Provided CAA were to accept this concept, it would be the quickest and most cost-effective proposal to implement. Implement CFZ boundaries, assign either dedicated or non-adjacent frequencies and leave the FISCOM for emergency and flight-following.

Which is what a lot of pilots understood its purpose was and, I believe, are still being taught.

There will be large areas of NZ where there are no requirements for CFZs, so the use of a FISCOM frequency makes sense, in addition to overlapping CFZ boundaries where established.

2. An enhanced FISCOM service using new Airways frequency technology to separate adjoining, re-drawn FISCOM areas and to eliminate, as much as possible, “out of area transmissions”. This possibility could merge the two proposals together and thus get the best of both. It is, however, unknown at this stage whether it is feasible both technically and operationally.

Option 2 re-invents the wheel to an extent and does not resolve many issues. Plus, new radio equipment may be required to utilise the new radio technology, especially 8.33 KHz channel spacing. Everyone would need to change to new radio equipment, as in Europe.

3. Keep FISCOM as it is as present, do away with all CFZs thus eliminating radio “clutter”, which would then encourage pilots to remain more vigilant with their lookouts rather than becoming complacent and relying on a radio call in a CFZ to disclose other traffic.

Option 3 would be a retrograde step all-round, especially from a safety point of view (i.e. my example of parachute dropping and not knowing who is ‘lurking’ over the drop zone… not to mention me meeting them on the descent).

As an afterthought, the ideal emergency ‘service’ for aircraft might resemble the UK’s Distress & Diversion function on 121.5 MHz. As you may know, this relies on reception by at least one ground station (but the more the better as each ground site has direction-finding capabilities). This allows for triangulation of received signals, which also has assistance from the still-extensive primary radar coverage for identification and diversion purposes.

NZ may not be in a position to fund the D&D type system (minus radar, of course); however, what a great safety net for flyers! Leaving just ‘flight-following’ to FISCOM frequencies… This may aid aircraft not fitted with a transponder but that carry EPIRBS/ELT/PLBs etc to be ‘tracked’ on 121.5 (as well as being monitored by a lot of passenger aircraft).

I believe there needs to be more thought on this matter; however, I firmly believe the Massey/CFZ proposal to be by far the best solution.

Steve Holder

I am very pro-CFZ; it has worked really well for us here in Hastings. It is simple and robust. Have not got a lot of experience with FISCOM, hardly ever use Chch Information.

MS

The Massey proposal seems reasonable, the CAA appears to be suggesting a similar idea can be enabled using FISCOM frequencies. I think the Massey idea is better – gives local operations a frequency and leaves FISCOM clear for necessary and emergency communications. Most of us use local frequencies in flight, and refer to FISCOM as required (either switching or monitoring on a second radio).

CAA’s ‘key issues’ are a bit of a reach:

1. CFZs not established in legislation: So what? and we have them already (see 2 below), establish them OR just use them as suggested as a ‘suggested frequency in this area’. They are non-compulsory anyway and there can always be Nordo traffic about, but providing a designated frequency for an area makes sense.

2. CFZs are NZ-specific: Again, so what? We’ve already got them, so where’s the problem? And there are different procedures between countries. CAA and Airways trot out this ‘it’s not ICAO’ whenever it suits, but happily operate outside ICAO if they want to (eg, Airways won’t accept an ICAO VFR Flight Plan).

3. Available frequencies: Would use more, have more, but can’t use more because we might need them sometime?

4. A large number of frequencies raise HF problems: And the current ‘guess the frequency’ system doesn’t?

5. Chart clutter: Have they seen a chart from the UK?

6. That’s what our fees pay for.

7. That’s what FISCOM is for, plus many of the frequencies already in use fit this category- City/Hauraki Traffic in Auckland, all the training and low flying areas etc that don’t require monitoring of ATC of FISCOM (North Shore – training area above 2500′ below 3500′ is in TMA but is on local traffic).

AS

Strikes me that the CFZ proposal will be both SIMPLER and CHEAPER , and without the “blind spots” problem of any FISCOM (as exists with CHCH coverage).

FB

Both systems have merit; however, the Massey proposal seems to tick all the boxes. I get around the country from top to bottom VFR and note a hell of a lot of radio chatter on 119.1 that you pick up from areas way distant from where you are.

This has, in my opinion, led to many pilots not listening to all radio transmissions due to the irrelevance of many radio calls. I have many instances where the local traffic does not hear your close position report or intentions with the non-listening aircraft manoeuvring into conflict with your flight path even though you have transmitted intentions. Transiting through Taumarunui two weeks ago at 4000 ft and 2 miles east, a light aircraft climbed directly in front of me into my path. He was either on the wrong frequency or didn’t hear me. This happens all the time.

The CFZ or MBZs in and around Palmerston North work well, with designated areas having their own frequency. You know that any radio transmissions are for your area rather than possibly being miles away. With two comms or a monitoring function, it is very easy to monitor your local traffic and any traffic in the next area you’re flying into.

There are local frequencies used down here such as the Mt Cook, Fiordland, Milford, Timaru areas and the system works well. I don’t use FISCOM at all in my flying nationwide. It is far easier to get WX via your phone via Metflight on the web. The FISCOM channel is often crowded and also has a lot of one-ended transmissions to other areas. This has led to GA pilots using 119.1 everywhere. CAA is out of touch with the issues here and needs to start listening to those of us who are actually flying. I don’t think there are many CAA staff who actually get in an aircraft any more!

Breaking NZ into different CFZs would be a big help. You will know that transmissions heard are for your area.

The FISCOM changes are all well and good, but there will still be a lot of transmissions on air that are not relevant to you and thus you have the same problem over time of pilots tuning out due to too much radio chatter.

Whatever changes are made need to be simple. CAA has a habit of over-complicating things and I think would be better to adopt the Massey proposal.

HR

Around the early 2000s, we at Wellington used the FISCOM frequency in effect as a CFZ in the Southern Wairarapa, prefixing South Wairarapa Traffic to calls (a mouthful). It worked quite well, as I recall.

CR

I agree with Massey University that improvement is long overdue to facilitate better communications between aircraft outside of controlled airspace and the need to separate the frequencies to avoid the over-talk that currently goes on from anywhere in the network.

We have a particularly difficult terrain problem in NZ along with the associated adverse weather that frequently prevails to make VFR difficult. Good communications are essential to safe flight.

I am amazed that it has taken this long for this problem to surface and get discussed. I have been microlighting in the lower levels now for five years in airspace that is frequently Class G. I use controlled airspace when I can as it is definitely safer but I am also aware that many are not taught to use it and are fearful of it. It is just as fearful in Class G when the weather is adverse and I have heard many a surprising tale since I have been involved in microlighting.

Overall, I feel we are still back in the 70s with VFR flying and as we observe ADSB coming prominent in overseas areas we definitely need change and education of our VFR fraternity to increase our safety levels. I am impressed with the activity in VFR flying that goes on and the freedom that we all have. I am also impressed with the aircraft building activity that I see in NZ.

I feel the need to comment on the safety levels in the same breath. I fly a bug smasher but observe many who dream to fly something fast and sleek. All very good in CAVOK weather but deadly when coupled with the extremes of NZ conditions. Too fast, no knowledge of controlled airspace and how to use it so subsequently under the base, low flying in bad weather without the knowledge to reduce speed and configure accordingly and often communicating on incorrect frequencies. Recent accidents prove this to be the case.

I have been an early adopter of iPad use (forced upon me, I might add) but have become an evangelist within the flying community to ensure as many people as possible adopt similar technology to increase their situational awareness in flight and overall safety to themselves and others. Look at AIR NAV PRO and see what we get. This is only one avenue; there are many others that are available for aviation use including EFBNZ which is fantastic within the confines of small aircraft cockpits. A free weather service like the boating marine forecast would also help.

WP

I agree with the points you have made, particularly with regard to low level coverage and unnecessary, uncontrolled, traffic that will not only overload the FISCOM operators, but may even interfere with their normal duty. The FISCOM boundaries will have to be more positively delineated, too, at the moment it doesn’t really matter which one we use, I “suck it and see” sometime, to see which has the best reception in my position, but this is no good if all aircraft in a specific area need to hear each other, which is the whole point of the Massey proposal.

The only advantage I can see from the CAA proposal is that all calls are logged – or recorded ? – so that in the event of an aircraft reported missing at least its last reported position will be known, even if not on a filed flight plan and SARWATCH. The Massey CFZ suggestion doesn’t address this issue.

In brief: I support the proposal of the Massey University School of Aviation that a series of Common Frequency Zones should be created nationwide, with clearly defined boundaries, so that all uncontrolled VFR traffic has the potential to be aware of conflicting traffic in their vicinity, and that the use of 119.1 should be restricted to traffic passing near to unattended aerodromes.

In detail: The CAA comment that all traffic using a FISCOM freq. is logged and could be of use if an aircraft is subsequently reported missing, as a reason to support their FISCOM proposal, has some merit but also some disadvantages:

1) The present FISCOM boundaries are not clearly defined. I can only speak definitively with experience of Northland, but flying South from Kerikeri towards Whangarei, equidistant from either coast, one of two FISCOM frequencies could be selected, 118.5 or 124.9 – see GEN 3.4-2 The boundary of the 124.9 segment is very loosely delineated on the present FISCOM advisory chart, and not at all on the present VNC B1- Northland. As a result two VFR, uncontrolled, opposing aircraft could be transmitting on either one of the FISCOM frequencies shown, and whilst both would be heard by the FISCOM operator they would not hear each other, and being uncontrolled the FISCOM operator would have no mandatory responsibility to advise of each others’ presence.

2) The volume of recreational, uncontrolled, and almost ‘conversational’ local reporting on the FISCOM frequencies would be a distraction for the FISCOM operators, and detract from their ability to properly carry out their core business.

3) The CAA GAP booklet Plane Talking pg. 32 advises that – quote: “The VNCs show the FISCOM freqs… based on VHF coverage at 4000 ft.” In my experience, few recreational pilots on short local flights fly above 3000′, so reception difficulties might also be a consideration.

AM

I am pleased that this discussion is finally getting official “air-time” as the problem has been around a long time. Dave Brown, Chief Pilot/CEO of Christian Aviation made a similar proposal many years ago of essentially similar nature, and I agree with Massey and Dave Brown’s proposals.

New Zealand aviation took a large step forward when the CFZs were first introduced, and I commend CAA for introducing them. They have been very beneficial, in my opinion, especially as I was hearing aircraft operating into Kaitaia Aerodrome while operating around the Coromandel Peninsula.

So in this submission, I wish to contribute on the three issues raised.

1. The Massey University School of Aviation nationwide CFZ proposal.

I propose that CAA accept the proposal, and let the industry as a whole grind out the finer details. The details are best decided by airspace user groups who are experienced in their own particular geographical area. What they decide should be accepted.

2. The CAA proposal to reinforce that FISCOM is to be used in uncontrolled airspace, unless within an MBZ, CFZ or the vicinity of an aerodrome.

I propose that Airways provide a better service by giving pilots access to full meteorological data while airborne, such as TAFs and METARs. Following this, I propose that FISCOM be used for air-to-ground communication and that the proposed CFZs be used for air-to-air communication. With regard to emergency transmissions, I believe that an immediate transmission on the frequency in use, and then changing to an appropriate second (or third) frequency will make best use of the available resources. I have personally responded to two Mayday and two Pan-Pan calls which were on unattended frequencies.

3. Amending AIPNZ ENR 1.1 Section 6.2 for the broadcast area to be below 3000 ft AGL to below 2000 ft AGL.

Agreed, and perhaps 10nm is too far if the aircraft is transiting the area and not going within 3-5nm of the aerodrome. For example, measure the boundaries of the Ardmore MBZ and you’ll find it is much smaller than 10nm.

CD

I would advocate for the CFZ-type system, and if CAA or Airways want to monitor those frequencies, at NO COST to the pilots, then that would most likely work fine.

We operate around Nelson, and I cannot imagine “blind” calls being acceptable on the Tower freq, as it is busy enough at times to make it impossible. In Golden Bay, at low level, on Nelson freq, you already can talk over other aircraft who are low in Tasman Bay, because Nelson is the area’s FISCOM.

What I can see happening with the introduction of charges, just to ask for a transit clearance, (which I am sure will happen sometime in the next year or so) is that people will be doing everything they can to avoid talking with ATC unless absolutely necessary. Therefore, if one is required to operate on a freq that is also used by a local ATC, then folks will not talk.

CFZs, clearly marked on all the charts, and yes, with frequencies well separated, is all we need.

Very disappointed to attend an Avkiwi seminar a year or so back, about radio, to find that the basic message was: “Unless you have 100% skills, and know exactly what to say, you should not be there, and need to spend time with an instructor sorting it out”.

The presenter, an RNZAF pilot (nice guy, but I was in the RNZAF, and the environment is utterly different) was giving us all the impression that you are dangerous and not professional unless you have perfect radio skills!

As a civilian trained pilot and instructor, I was appalled to hear what he was putting across.

“Safety” is what we do. The CAA just talks about it.

Afterwards, I caught up with a couple of local recreational PPLs and reassured them that they would be MUCH better off to say something, even if they are not sure if the phraseology is correct.

We had two CAA staff here a year or so back, talking about national frequency issues, and they said that the mess (now the Manawatu CFZ area) was always going to kill people, and that one of them had even said so, prior to the mid air’s. Being lowly staff, they of course were ignored!

I have had a couple of very near misses in areas with multiple frequencies. One was South of Darfield, when I had left just left the Cant CFZ, and along with visually ensuring I was away from the TMA, and looking for glider traffic from Hororata, and wondering if they would be on 119.1 or 133.55, met a Cherokee heading opposite, probably doing the same things.

The other, operating around an unattended strip, just South of Nelson (that is, inside the zone, but uses 119.1 whilst in the cct) and had a helicopter leaving Nelson almost come through the windscreen. I called, but am pretty sure he/she would have been on Nelson.

I don’t have the answers, but there are places in NZ now (and Manawatu is right up there) that if I can avoid going through, I do, unless I can get Controlled VFR. But even that option will be less attractive once we get charged for making contact.

Vincent

CFZ network, Option 2: Your feedback

Option 2 is: An enhanced FISCOM service using new Airways frequency technology to separate adjoining, re-drawn FISCOM areas and to eliminate, as much as possible, “out of area transmissions”. We suggested that CAA explores the possibility of merging the Massey and CAA proposals and thus get the best of both.

Comments:

I operate a flying school in Nelson and have about 5000 hours and 25 years experience in flying in NZ (and elsewhere). I remember those Sundays, in the days when flight plans were compulsory for >25NM flights – and I well recall the comms chaos on the CH Info frequency with numerous aircraft calling over each other and general reception and clarity difficulties.

Oddly, since then, I have stridently kept to the rules and maintained listening and position report contact with FISCOM. It has been pleasantly placid on FISCOM and often I seem to be the only other flier out there aside from those IFR aircraft out of controlled airspace who receive their clearances via FISCOM. I have kept to the recommended procedures and not flown about on 119.1 as, as far as I could ascertain, this has never been the default position report frequency – except when in the vicinity of some unattended aerodromes.

I have always instructed my students that when within 5 to 10 miles/3000′ proximity to a published aerodrome to make the appropriate call on the appropriate frequency. And when clear of the area to return to FISCOM. I have encouraged this procedure because it is stipulated in the AIP as recommended practice – and has been for as long as I can remember. I don’t really see why anyone has any problem with it – the procedure is well stated and the FISCOM frequencies have been clearly shown on the FISCOM chart. I believe the wiggly line changeover point to be a sensible display of the fuzziness of reception and also relevant to operational considerations. The instructions even recommend trying one of the alternative frequencies if one doesn’t work. The only issue I can see is the unwarranted fear that some pilots have, of talking to official personnel (i.e. ATC or FIS) or that there may be some cost involved.

All any pilot has needed to do to clarify the issue is to read the AIP, read the Vector articles or talk to any educated instructor (and perhaps get some coaching in radio calls). Of course, all pilots must also accept that below 3000′ (or below 1000′ AGL – whichever is higher), there is increased risk of collision because there is no requirement for specific cruising levels or tracks. One must endeavour to be well aware of possible conflicting traffic and your proximity to aerodromes.

I have had one or two people mention the issue of the increasing number of private, unmarked aerodromes – many of which are becoming popular “hubs” for microlight pilots. One thing I abhor is the increasing separation between the microlight and “normal” aeroplane communities (I loathe to use the term “GA”, as this another misnomer). In answer to the unpublished aerodrome problem, I believe the CAA should endeavour to increase the representation of these unpublished aerodromes on all new charts. Ideally, the frequency that is expected to be used at these aerodromes should be indicated as well – I know of a few that are outside of any CFZ, yet use frequencies other than 119.1.

You may argue that the pleasant placidity I have been experiencing on the FISCOM channel is because everyone else is on 119.1 (by a mistaken convention). I advise all my people about this possible anomaly (which has some element of truth, particularly down parts of the West Coast) and to monitor 119.1 whenever possible (all NPT aircraft have radios with the capacity to monitor a second frequency).

Another salient point is that, even though I do not personally use and don’t much encourage the use of Airways flight planning services (as we have a satisfactory in-house alerting service), I remind students and clients who hire our aircraft that FISCOM (and en-route ATC) offer one of the few free-of-charge services to aviators; that the Airways operators are paid to listen and will note down a pilot’s position reports and any other information – so that you have, in case of emergency, a measure of protection; with information for SAR and confirmation of workable air-ground comms.

The Massey proposal essentially isolates pilots from this service. CFZs are certainly important for concentrated areas of activity where instant air-air communications may be critical for proximate traffic avoidance – such as training zones and VFR tourist traffic areas. But FISCOM provides pilots with a professional information and emergency contact service, and has the capacity to provide QNH, weather and NOTAM information.

As an example, I recently gave a normal position report to CH Info on 118.5 while at cruising level abeam Hokitika, and monitored clearances given to a B1900 on a scheduled flight out of HK at about the same time. Traffic information regarding the Beech and myself was then passed on to each of us, and I also confirmed passing beneath that traffic by making direct contact with the Beech on the FISCOM channel. The radio calls were simple, polite, accurate and expedient. This acts as a simple example of how FISCOM can, and should, be used. I believe a timely use of FISCOM for position reports would be to call on climb to a cruising level once leaving a departure aerodrome frequency, and again before commencing descent. And, if cruising below 3000′, a least once or twice per sector and particularly after changing frequencies.

I am pleased to hear Airways are planning to improve the FISCOM reception in remote areas. I have, at times when I have been unable to raise CH Info, made “blind” position reports – without any problem (simply stated callsign Position, Altitude, and track). And this is, again, the recommended normal practice. As far as communication “holes” such as down the West Coast, most of these are served by CFZs and any improvements to reception of FISCOM for areas beyond the CFZs is welcome.

My key points to this discussion are:

1. FISCOM is an established and suitable communications and information channel

2. FISCOM is free, available, and useful – and this should be part of a pilot’s education

3. FISCOM should ideally be the best method to establish en route situational awareness regarding other (participating) traffic

4. FISCOM coverage needs to be enhanced

5. As many of the popular unpublished aerodromes that are used as a base for regular GA ops should be identified and included in charts

6. It must be accepted that there will always be traffic that operates NORDO or chooses not to communicate, or will not give position reports in a timely manner

7. A plan for contiguous CFZs is not the best idea, as it means that the continued use of FISCOM by VFR pilots would become greatly diminished in practice, or would mean an additional requirement for monitoring yet another frequency (it is unlikely that the alerting and information service is to be withdrawn totally as it is required, at minimum, for IFR flights).

If you look at it in this light, and with the promise of upgraded aerials providing better coverage, then your criteria for retaining FISCOM as the preferred en route is well met.

David Marriott, CFI, Nelson Pilot Training

I have read your thoughts on what you think should happen on the enhanced FISCOM SERVICE; sounds good, as long as they don’t expect us to pay for it.

TH

I am happy to have my name attached to a generic response as outlined as it will undoubtedly improve the service if implemented. It will be interesting to see if Airways brings up the question of cost and who will pay. I raise this as the matter of charging for a service when landing within controlled airspace but off the actual airport and charges for even crossing through any part of controlled airspace (will incur a charge) is still very much on their agenda even although there is very little cost/benefit to them and considerable downside risk for safety when bad boys turn off their transponders when sneaking through airspace.

JT

I have been out of GA for a while now, but do have some connection via my work on the NZALPA tech committee which covers third level ops as well as Part 121 ops. Personally, I agree with your comments and I am in favour of the FISCOM proposal with at least the conditions you stipulate.

If it is not entirely free, then there will not be the participation level and therefore a continuance of the status quo which, of course, defeats the whole purpose.

Maybe an alignment of the QNH zones and the FISCOM coverage areas could be looked at, as they are quite similar.

Country-wide CFZs would require a rule and the NPRM could take an age. With the current CAA resources, they can only manage four NPRMs per year and I’m guessing this one would not be high on the priority list.

Also mentioned by the CAA was a request for feedback on the lowering of the ceiling of an unattended airfield from 3000ft to perhaps 2000ft.

What are your thoughts on this? As we no longer seem to have IARAs, perhaps this is inappropriate considering the potential mix of VFR traffic and IFR aircraft on a let-down. They need to be on the same frequency. I would consider 3000ft to be the minimum and possibly increased to say 5000ft to cover those airfields with a higher initial approach to cover this scenario (would need to survey those Class G aerodromes where regular instrument approaches are conducted).

SH

I am happy with what you have written as being a sensible “middle ground” which gives the opportunity to use FISCOM if required (with more defined frequency use) and allows air-to-air communication for best effect, as well as resisting CAA’s seeming interest in making everything chargeable – whether we want it or not.

CP

I think we may all be barking up the wrong tree with the Kiwi love of separation by radio chatter.

I had a recent experience where non-stop position reporting of arrivals traffic from 30 miles out prevented me separating myself from another aircraft that had clearly not seen me and was heading to the same landing.

In my opinion, we need less position reporting, not more! I have posted a short discussion paper/comment on the GAA website.

Gavin Wills

Well thought out. Pilots need to have a frequency to make blind calls on; if we need a reply when making calls, then fewer blind calls will be made and safety will be compromised.

Another thought, maybe if [FISCOM] blind calls should be started like 119.1 calls now, with ” …… traffic” as it is more likely to get the attention of nearby pilots.

GM

I would like to add my vocal and moral support. Please feel free to quote me as being supportive of your proposals.

1. There must be the capability for aircraft-to-aircraft blind transmissions of their positions, altitudes and intentions. YES!

2. There must be good low-level capability from the upgraded aerial system. YES!

3. The FISCOM frequency areas should cover clearly defined geographical areas in similar manner to the way CFZs are portrayed on our visual navigation charts. YEP.

4. There should be a good separation of frequencies so that the transmissions in a particular FISCOM area will pertain to traffic in that area. DITTO.

5. A FISCOM operator will monitor all aircraft transmissions but only respond to those prefixed in a particular manner such as we do now by using for example “Christchurch Information”. Other aircraft-to-aircraft or blind transmissions could perhaps be prefixed with something like “FISCOM traffic”. YES AGAIN.

6. The FISCOM service must be available at no cost to the users of that service. YES AND YES AGAIN, IN THE INTERESTS OF SAFETY!

Guy Clapshaw

(1) I like the mooted option of being able to make a ‘FISCOM TRAFFIC’ call. Much quicker than having to converse with an ‘Information’ person just to get a QNH read back to you.

Having it monitored may stop some of the gasbagging that goes on during weekends etc, too.

Greater Transponder Mandatory requirements would be good to go along with this (help us and help FISCOM for monitoring).

118.5 is gonna get a hammering. Maybe would be smarter to have one frequency for above AA and one for below AA.

Hopefully would sort out confusion about what frequency to be on in certain areas, eg between WR and Springhill.

(2) I think the FISCOM proposal by CAA is the better option. The fact it is a monitored frequency appeals.

(3) I agree with the CAA’s proposal, rather than the Massey idea.

I agree to the six points you have detailed in your survey and would support a service heading along those lines; the key is clear boundaries with everyone knowing what frequency they should be on, in what area.

The frustrating thing I find is the confusion on what frequency to be on, so by default there is a tendency to use 119.1.

RH

I agree with your recommendations. Better defined FISCOM areas with better coverage allowing blind transmission along with FIS transmissions, at no cost.

I have just completed the Air Safaris around NZ which did bring out some interesting issues regarding position reporting amongst the 31 aircraft all going the same way. Particularly important was the large number of overseas pilots taking part and their ability to report their location accurately. We had our own frequency, so that made it safe to avoid Air Safari aircraft but dangerous to avoid others!

Therefore it calls for more visual reporting points, easily identifiable, easily pronounced, easily understood, easily recognisable and situated along common flight tracks away from control zones.

This would have taken out a lot of confusion with mispronounced Maori names and made blind transmissions so much more helpful. We should be on the same frequency and should be able to more accurately convey position if everyone knows a waypoint.

TW

CFZ network, Option 3: Your feedback

Option 3 is: Keep FISCOM as it is, do away with CFZs, thus eliminating radio “clutter” to encourage pilots to remain more vigilant with their lookouts rather than becoming complacent and relying on a radio call in a CFZ to disclose other traffic.

Comments:

I have not read the proposals and don’t intend to. I am sick of the endless changes and procedures to make an unforgiving activity safe. If you can’t accept the risk, try golf.

Any procedure will fail if you don’t spend 98% of your flight time LOOKING for other aircraft and no amount of new procedures will alter that.

Changes to procedures locally almost got me killed. The use of different frequencies between local traffic resulted in a pilot not changing to the correct frequency and therefore not hearing my calls. He was relying on his TCAS to warn him of other traffic while programming his GPS for a autopilot-coupled approach into West Melton on a CAVOK day. He overtook me from behind about three feet higher than me and I had to wait for his wing to go past and roll /dive away with my wing passing between his wing and elevator.

My point: if he had been looking out the window, he would have seen me! How do new procedures help in situations like that?

The use of radios: When I get airborne from West Melton tracking via the Waimak climbing under the TMA for the gorge, I don’t want six aircraft in the New Brighton training area to all reply at once with half of them in a foreign language.
My point: If we are 60 miles apart and travelling in opposite directions, I don’t want to know.

When an aircraft transmits its position and intentions, EVERY aircraft on that frequency calls up. If I am heading in a certain direction, I only want to hear from aircraft that can possibly cause a conflict, NOT every aircraft airborne.

Transmit only if required. Of course, that would require a pilot to think and picture the relative positions, decide and transmit if required. Rather than the trained monkey response, instead of clattering up the airways with useless calls, for which I blame the local instructors.

So for dummies like me, it amounts to maintaining a lookout, sensible use of the radio and flying mag track/ altitudes (when did a local pilot think of that last?)

Bugger, that’s the procedure now. WHY are we changing?

Murray

I probably do as much GA flying as anyone in NZ. I have never heard more inappropriate radio practice than over recent years since the advent of foreign student training. (This is not just limited to overseas students, as some local training organisations seem as bad at over-reporting their position).

The over-use of the radio to make almost continual running reports is the main problem NZ-wide. I do not want to have more rules, frequencies or operational procedures imposed and I believe the existing system works perfectly well if people make the minimum required reports. I don’t want to hear some LSA report over Oxford heading Burkes Pass then five minutes later report over Springfield, then Methven etc, etc on 119.1.

Instructors need to be reminded and trained how to correctly use the existing system. I am opposed to further enforced procedures whilst the existing system is being corrupted with incorrect reporting procedures.

I applaud your initiative and management of GAA and thank you for giving GA a voice and a proactive advocacy group.
With consideration of my above-mentioned comments, I am very happy to add my name to your presentation to CAA.

Dave Horsburgh

National CFZ network: A Canadian alternative?

One of our readers with experience of flying in Canada has contributed the following:

“In Canada, unattended airfields are on the same frequency, which is 123.2, like our 119.1. But they only use it within 5 nm from the unattended airfield. Outside of that 5 nm, we go onto a transit frequency of 126.7 which is used for air-to-air and everyone should be on that.

Best part is, if you are wanting to talk to someone at a Flight Information Region, it is on the same 126.7 air-to-air as well but you hit the transmit button (I think it is 7 times within 3 or 4 seconds) and it sounds like you are making a phone call, which it is: a cellphone link via aviation frequency. You get connected to flight service and talk as per normal on the radio. Everyone in the area can hear the conversation; all the while you are maintaining a listening watch on the air-to-air, it’s all on the one frequency. Once your conversation is over, flight service closes the link so they don’t get bugged with the general air-to-air radio calls and chit-chat.

[Editor: This cell service is only available in mountainous areas, which is of particular interest to us Kiwis…]

Flight Service can also open the link in a specific area to give out reports and warnings etc.

This way, there are only two frequencies (Airfield or Transit) and it is clear when to be on those frequencies, yet still get all the information you want when needed with the one radio box. These same frequencies are used right throughout Canada, as I understand it, in Class G airspace.

Which is unlike NZ, where here we have about 10 or 11 different frequencies throughout the country to get general flight information when in transit in Class G airspace. What we could do in those 10 or 11 areas: be all on the same frequency still, but have a phone call link as in Canada, to talk to Christchurch Info.”

In response to this, GAA has done some preliminary research on the Canadian equivalent of FISCOM.

The Canadians are in the process of re-designing their Flight Information Service and have identified their problems as:

♦ In most areas of the country FISE services (Flight Information Service En-Route) were provided on one frequency, 126.7 MHz.

♦ This is also the frequency designated for use by pilots (both VFR & IFR) to broadcast their position and intentions while operating in uncontrolled airspace. A large demand for FISE service in combination with high levels of pilot broadcasts has resulted in frequency congestion and interference on 126.7 MHz. This has an impact on the safety of flight operations. In addition, some RCOs (Remote Communication Outlets) are close enough that they interfere with each other or result in coverage overlap while in some areas of the country there are large gaps in RCO coverage.

The Remote Communication Outlet System

A Remote Communications Outlet (RCO) uses VHF transmitters/receivers to provide a remote communications link between pilots and Air Traffic Services (ATS) facilities. Flight service specialists at Flight Information Centre (FIC) facilities use the RCOs to communicate with pilots and provide the following services:

♦ FISE (Flight Information Service Enroute), which includes the provision of aviation weather information, NOTAMs, accepting flight plans, position reports and pilot reports (PIREPs)

♦ Aeronautical broadcast service, which consists of broadcasting information that could impact flight safety but that may not have been available to the pilot prior to takeoff, such as SIGMETs and urgent PIREPs

♦ Communication searches by flight service specialists to determine the status of an overdue aircraft and

♦ Relay IFR clearances, wind and altimeter information to conduct an instrument approach and special VFR authorisations at aerodromes within control zones.

The solution to the Canadian problem

To resolve the safety concerns and to improve the overall provision of flight information service, NAV CANADA is redesigning the RCO system as follows:

♦ Five frequencies dedicated to FISE (122.375, 123.275 MHz, 123.375 MHz, 123.475 MHz and 123.55 MHz) will be used for most RCO sites.

Note that radios do not need to display to three decimal places to use these new frequencies. For instance 123.275 = 123.27 (See TC AIM – COM 5.3)

♦ RCOs will be located approximately 220 nm apart, along airways, air routes and VFR flyways. The 220 nm separation guideline was based on a requirement for a pilot to get a weather information update once an hour while flying an aircraft at 3000 feet above ground at 120 knots. In mountainous areas, spacing of RCOs will be closer in
order to meet coverage requirements for VFR flyways in valleys.

♦ At most RCO sites where a discrete FISE frequency has been established, FIC flight service specialists will no longer monitor 126.7 MHz. However, they will have the ability to transmit and receive on 126.7 MHz, when required, to provide the aeronautical broadcasting service (safety messages such as SIGMET, urgent PIREP) and to conduct communication searches for overdue aircraft. Note that when the FIC selects 126.7 MHz, the FISE frequency transceiver is activated also, resulting in simultaneous broadcast on both frequencies. RCO sites with this configuration for 126.7 MHz will be published in the CFS and on maps and charts as “126.7 (bcst)”.

♦ At a few sites where lower traffic levels and less demand for FISE permits, 126.7 MHz will remain the sole frequency for both FISE and aeronautical broadcasts.

♦ Some new RCOs will be established and some will be decommissioned in order to provide more uniform and effective en route communications coverage.

Rather than re-invent the wheel, as we are apt to do in our New Zealand CAA, some more research should be carried out into the way the Canadian system works, to determine if it may be an alternative solution to our problems.

National CFZ network: CAA sticks to its guns and shoots down Massey

The Civil Aviation Authority has issued a virtual thumbs-down to Massey University School of Aviation’s proposal for a national Common Frequency Zone network.

On April 12, the CAA published its consultation document on Radio frequency use in uncontrolled airspace.

The deadline for submissions (before the CAA makes its “final decision”) expires on May 24.

The CAA sticks to its original objections to Massey’s proposal, as revealed earlier on this website. Then it proposes a development of the current FISCOM including uncosted hardware improvements to expand coverage, a probable (also uncosted) increase in Airways staffing to handle the system and a possible but undefined change in operations to permit aircraft-to-aircraft messaging over the FISCOM frequencies.

No costs or timeframes have been provided for the FISCOM development. On April 14, GAA asked Mike Haines, CAA Manager, Aeronautical Services, the following questions:

1. Is it possible, using the existing FISCOM network, to carry out a trial of “blind position reporting” transmissions without them being directed through a FISCOM operator?

2. In the case of the FISCOM service being handled by existing Tower staff such as Dunedin, Nelson, Napier, Gisborne etc, will they be able to cope with monitoring specific calls to them as well as ignoring those “blind transmission” calls between other aircraft in the area without it impacting on their other duties?

3. What is the timeframe for Airways to upgrade aerials, frequency coverage and staff numbers?

4. Within the inevitable blind spots of low-level FISCOM frequency coverage in the mountainous areas (around 500′ to 1000′ AGL), what frequency will you be advocating that pilots use? This is an important safety issue where pilots are transitting through valley systems and mountain passes low level, in bad weather.

He replied:

“These are relevant questions, however most cannot be answered until we have the information from industry to see what requirements would be needed to amend the current FISCOM.

“Airways have begun upgrading of the FISCOM aerials and when this is complete (expected mid-year) they will be reviewing coverage and any staffing changes. CAA would look at asking them to undertake a trial on coverage areas with the increased coverage anyway as they are required to provide an flight information service

“If the FISCOM proposals proceed it may be that some Tower FISCOM monitoring may be undertaken by the Flight Service from Christchurch. Until we have feedback from industry on both proposals and issues to be addressed it is premature to sort out some of the more detailed issues.

“The FISCOM coverage is going to be improved – if there are low-level areas where an MBZ or CFZ is needed this will be looked at on a case by case basis.”

This puts opponents in an impossible position. They have less than six weeks to argue against a proposal from CAA that the authority admits it cannot explain in detail until long after the deadline for submissions expires and a “final decision” is made.

Unless CAA is able to provide detailed costings, timeframes and outcomes for its alternative proposal, a rejection of Massey’s proposal could amount to an abuse of process and be open to legal challenge. Curiously, one of CAA’s objections to a national CFZ network is the time it could take to implement.

The CAA says: “CFZs were introduced into New Zealand to assist by providing a common radio frequency at locations where several frequency areas overlap. CFZ are not mandatory and are advisory in nature. These areas are not designated airspace under Civil Aviation Rules Part 71; they are common frequencies that have been allocated in order to enhance safety. CFZs signify areas of concentrated aviation activity, generally recreational aviation. [Our emphasis]

“It is not mandatory to use a radio on the specified frequency within a CFZ, but it would be very poor airmanship not to use the advised frequency and to not comply with expected local radio procedures when radio equipped to do so. As a minimum, pilots should broadcast their position and intentions on entry and exit from a CFZ.”

The consultation document then goes on to demolish its own comments supporting existing CFZs that the authority established, and instead suggests further investment in FISCOM for the benefit of General Aviation – which, under the current User-pays philosophy also leaves the door open to eventual charges on the sector for the service.

GAA understands that Massey is discussing how to respond, and we hope to carry their reaction on this website.

In the meantime, please read the consultation document and remember the deadline. We’d also appreciate your feedback, as GAA supporters plan to file a group submission.

We’d make a further prediction: If CAA rejects the CFZ proposal and presses on regardless with FISCOM, it will still be ignored by many pilots who – purely for reasons of personal safety and lacking something more sensible – will defy CAA advice and keep talking to each other on 119.1.

Government to clean up GA red tape

redtapeNo, not our government, you silly aviator.

UK Minister without Portfolio Grant Shapps is calling on the General Aviation sector there to tell the government how it can make their lives easier by cleaning up regulations and removing red tape.

The government launched its Aviation Red Tape Challenge last year, looking at regulations that affect the sector – almost 60 percent of which will now be scrapped or improved.

It now wants to go further and look in more detail at the problems that afflict SMEs (small and medium sized enterprises) and other people operating in the general aviation sector. Anyone with an interest in general aviation has the opportunity to share their views on the regulatory issues that affect them and use their experience to tell the government how it can make things better.

The Red Tape Challenge site is at

http://www.redtapechallenge.cabinetoffice.gov.uk/themehome/general-aviation-theme/

Shapps said: “A flourishing aviation sector is vital to Britain winning the global race and that includes general aviation as well as the large commercial operators. That’s why today we are launching the General Aviation Red Tape Challenge specifically aimed at the smaller operators and businesses for whom regulatory issues can be frustrating and restrictive.

“We want to help generate jobs and prosperity so I hope everyone in the sector from pilots to mechanics to training organisations to airfield owners take part in this challenge and let us know how we can help you to succeed.

“The Red Tape Challenge is a cross-government programme to tackle unnecessary, over-complicated regulation. The default is that regulation should go unless it can be well defended (such as on safety grounds). Even where it stays, we aim to reduce burdens in its implementation.”

Charles Henry, Chairman of the General Aviation Awareness Council, said: “I fully endorse this initiative and urge all involved in the industry to identify those rules and regulations that do nothing to enhance the safety of general aviation but add unnecessary cost. All pilots and engineers should respond to this unique opportunity and help UK GA regain its reputation for having the finest pilot training and highly skilled engineers in the world.”

On the Red Tape website, there’s a stark remark: “The purpose of this exercise is to open government up to the public.”

The only sign of opening government up to the public in our neck of the woods is a seemingly endless series of leaks and breaches of privacy…

♦ All those in favour of a Red Tape Challenge in New Zealand, please email GAA or leave a comment. That includes any ambitious politician who would like to dramatically increase their popularity.

The Medical Application Fee: It’s just a camouflaged levy

stethoscopeWhat do you get in return for the $313 fee to apply for a medical examination? It’s a question that has puzzled everyone except the CAA and Transport Minister Gerry Brownlee since the new charge was introduced in November 2012.

The answer is:

You get nothing at all, but you’re paying something for literally everything to do with the Central Medical Unit.

It has taken several long months to wring the truth from the CAA.

We all know that when we buy a packet of Corn Flakes from the local supermarket, there are overheads in the price.

The difference between a supermarket and the CAA is that with Pak N Save and Countdown, you are offered a limited choice of purchasing power (given that New Zealand is a tiny economy, there are only two major supermarket operators and – like electricity prices – competition is largely a myth).

But here, we are talking about a government department, where users have no choice whatever.

So, forget about what you receive in return for the medical application fee, and remember that the justification for all those increases was the National Party’s flawed notion of User Pays.

We can now reveal what you are paying for, and it turns out that you will never use much (if any) of it.

In a series of exchanges with the CAA, it has become clear that the $313 medical application fee is not based on the principle of User Pays in relation to a specific service supplied. It is merely a disguised levy intended to bolster the income required to pay for the entire costs of the Medical Unit.

But the culprits could be in for some unexpected trouble because of these precedents:

From p49 of the Regulations Review Committee Digest – 4th edition

Report of the Regulations Review Committee “Inquiry into the Civil Aviation Regulations 1953, Amendment No 31” [1991] AJHR I16B.

D Fees……………….

If a user of a service is required to pay a fee then, as a general rule, the user must receive the benefit of that service. If the user is paying for something which he or she does not receive, then the regulation setting the fee may have constituted an unusual or unexpected use of the relevant regulation-making power. Two reports of the Committee illustrate the point. First, the Civil Aviation Regulations 1953, Amendment No 30, increased licence fees payable by flight crews and aircraft maintenance engineers.[162] Part of that fee was to offset the cost of research into training methods for pilots. The Committee found that existing pilots would receive no benefit from the research being undertaken and, therefore, requiring them to contribute to this research represented an unusual and unexpected use of the regulation-making power.

Secondly, the Land 43 Transfer Amendment Regulations 1998 increased fees for its services.[163] These increases were to cover the cost of a new automated land information system. Again, the problem was that current users were paying for something they may not receive any benefit from. Thus, people buying a property were required to pay for a system they might never use. Consequently the regulations were deemed to be in breach of this ground. The Committee recommended that the regulations be reviewed to ensure that the costs of the system be passed on to those who would actually benefit from it.

This latest levy is based on what the CAA describes as “expected transactions”. In trying to explain what the $313 covers, CAA Official Information and Privacy Officer Jo Beckwith stated:

The information provided outlines all the activities that are undertaken by the medical unit. The functions of the medical unit have not changed since the introduction of the medical application fee.

However what has changed is the way the CAA funds its activities. This was as a result of the CAA implementing existing Government Policy requiring us to recover funds from aviation participants. The old framework did not meet the costs of the CAA and contained a number of cross-subsidies. The government believes that those who choose to fly, or operate airlines and aircraft, should meet the full cost of regulating these operations. The new framework has moved toward full cost recovery for most services.

Therefore, although the medical examination fee is “new” in terms of only recently being introduced, the fee is not as a result of the medical unit undertaking any “new” functions.

As already stated the information provided to you outlines all the activities that the medical unit performs and includes activities associated with the medical application fee. The system that was used to calculate the fee calculates the time, people costs and overhead costs against the need to spread those costs over the number of transactions related to medical applications expected to be received. [Our emphasis]

Now ask yourself: “What happens if the number of transactions related to the medical application fee falls?” The answer must be that the “system” which was used to ascertain the original charge (and which apparently took the CAA two years to create) will be revisited. We could then find that a reduced number of applicants face an even further increased charge to meet the shortfall in income.

So, what does your $313 pay for?

The full details can be found under Costs in the top toolbar. We have replicated all the information supplied by CAA in support of its costs for the Medical Unit. To summarise:

The $313 comprises a proportion of the unit’s costs as expressed in hours worked. To get a genuinely accurate cost of the unit’s operation, we would need to know how many people are currently employed in it and how much space in Planet Asteron they occupy, but we don’t yet have that information.

Your $313 helps to pay for, among other things (as described by CAA in the arcane language beloved of bureaucrats):

♦ Production of ME newsletters

♦ Maintaining contact with CASA

♦ Digitisation of Medical Information (converting paper-based records into electronic records)

♦ Planning and Risk Management

♦ Receiving and processing information queries directed from the Publishing team for queries that are sent to CAA via the CAA website and CAA e-mail address

♦ The Training, Appointment and management of the medical Examiner Training programme

♦ Special leave, responding to official information requests, accommodation pack/unpack, Jury/Witness service, industry liaison and external relations

♦ Activities for other Groups/Units within CAA that have involved medical unit staff

♦ All absences from the workplace

♦ Those aspects that have a wider organisational focus or management aspects not covered in other management group operating plans

According to the CAA, the expected funding requirement for the Medical Unit will be $2.2m per annum for the next few years. In correspondence with the AIA in October 2010, it said:

“The medical unit has a staff complement of three doctors, six licensing advisers and one executive officer.

The costs of the Medical Unit reflected in the Funding Review consultation documents were estimated as the same proportion of estimated CAA costs as the Medical Unit costs were to total CAA costs in the 2008/9 year. This included the salary cost of the Medical Unit together with overheads.

Specifically, total personnel and training costs represent 51% of medical unit costs, other direct costs 4% and CAA allocated overhead costs 45%. The medical unit is not charged directly with legal costs, but it is, in common with all of the operational costs centres within CAA, allocated a proportion of the costs of the legal unit as overhead.”

Do you detect an element of cross-subsidy in all this?

In his November 2012 statement attempting to justify the increased costs to aviation, and in his subsequent utterances, Gerry Brownlee has made great play of the phrase “those who choose to fly” – with the implication that only those wealthy enough to do so would choose to fly.

Gerry Brownlee is not in touch with reality. Some people must fly because it is their livelihood, and this includes people who are not employed by airlines and cannot recover the levy. For others, it is a hobby for which they should not be unduly penalised in comparison with, say, boaties.

What the medical application fee proves is that it is not possible to lump together and fairly apply such crudely calculated User Pays rules to everyone involved in aviation. By following this simplistic mantra, the CAA and John Key’s National-led Government have done everyone – including airline passengers – a gross disservice.

A GAA correspondent spent some time talking about this with pilots at the Omaka Classic Fighters air show and he commented that in his straw poll, about 50 percent of Class 2 pilots said they would not be renewing because of the new levy. This supports the view that either the CAA will see sense and drop the charge, or it will face the law of diminishing returns and further punish those who remain in the system.

The medical application fee is a classic example of the faults in the blunderbuss theory of User Pays. The application of this silly idea to general aviation is patently unfair, unjust and harmful – and one way or another, it must come to an end.

Send in the Clowns: The CAA’s $8.5 million Asteronomical fiasco

Wellington's Asteron Centre, with 45,000 square metres of space, 33,000 of them lettable and a rates bill of almost $2 million, some of it paid by aviators along with the annual $1.8 million in rent. CAA occupies part of floor 14 and the entire penthouse (with some of the best views). It's truly asteronomical

Heads in the clouds? Wellington’s Asteron Centre, with 45,000 square metres of space (but just 33,000 m2 lettable) and a rates bill of almost $2 million, some of it paid by aviators along with the CAA’s annual $2.4 million in rent. CAA occupies part of floor 14 and the entire 15th floor penthouse (the best views don’t come cheap, as any pilot will tell you)

Back in the 70s when I was a Boeing 737 F/O with NAC, we had a simulator instructor named Jim Hutchison, who had a quirky sense of humour. Jim would sit behind his two crew, and whilst setting up his simulator control panel, he would quietly hum away the old Stephen Sondheim song made popular by Barbra Streisand, “Send in the Clowns”.

The subtlety of the song, which begins…

Isn’t it rich?
Are we a pair?
Me here at last on the ground,
You in mid-air.
Send in the clowns

… was usually lost on the crew, who were about to begin their proficiency check ride and had other things on their minds!

So, where is this preamble headed?

We have seen many clowns amongst our politicians, CAA board members and past directors of the CAA. They have introduced wide-ranging changes and policies that have affected us all (and will continue to do so) before nimbly stepping away from their wreckage.

A case in point, which I have been investigating, relates to the relocation of the CAA offices from the comparatively low rent district of Petone to prime real estate in the heart of the Wellington CBD.

In October 2007, with leases on its premises due to expire and space constraints being experienced (due no doubt to an expanding bureaucracy) the CAA began a process to determine its accommodation options. In August 2008, the Authority made a decision to lease space in a building under construction at 55 Featherston St, Wellington for Asteron Life, an insurance company. This project would culminate in the CAA moving out of its premises in a previously converted warehouse in January 2011 to the central Wellington location to “provide a more productive and efficient work environment”. In the words of that classic Tui beer ad, “Yeah right”!

At the time of the decision by the CAA Board and the Director, a Labour-led Government was in power. In true “Yes Minister” style, where the tail wags the dog, the then Minister of Transport Annette King signed off on it.

We recently asked the CAA some history questions. In a letter dated February 25 2013, Jo Beckwith, the CAA Official Information and Privacy Officer, replied:

Q. Who were the members of the CAA board in August 2007 who made the decision to relocate the CAA offices to 55 Featherston St, Wellington?

A. Rick Bettle (Chairman), Errol Millar, Darryll Park, Susan Hughes and Ross Crawford.

Q. Was the decision of the CAA board unanimous or were there any dissenting members who questioned the wisdom and financial cost of the move?

A. No dissenting view was recorded.

Q. How many of those 2007 CAA board members are still sitting on the board?

A. None of the abovementioned board members are currently on the CAA board.

The Director of the CAA at the time was Steve Douglas, who also departed subsequent to implementing this decision to relocate.

So, in essence, all the major players make an expensive decision to relocate, then bail out before the repercussions occur, or in the vernacular, the brown stuff hits the fan! Similarities exist in the way former Prime Minister Dame Jenny Shipley and other independent directors resigned from the Mainzeal board, a day before the company was placed in receivership.

The only person still with the CAA (and who would inevitably have had an input into the decision) was the present Director, Graeme Harris, who was Chief Operating Officer at that time.

There was, however, one lone dissenting voice to this very expensive relocation that we are all now paying so dearly for. It came from the Hon Steven Joyce – recently tasked with fixing the Novopay teachers’ pay debacle.

The general election and change in government resulted in Labour’s Minister of Transport, Annette King, departing the scene, and the Hon Steven Joyce assuming the role of Minister of Transport. In a press release of 30 April 2009, he made his views clear.

Minister not impressed with CAA relocation costs

Transport Minister Steven Joyce says he is “not at all impressed” with the $8.5 million cost for the Civil Aviation Authority to move from its current Petone location to a new, multi-storeyed building in downtown Wellington.

The rental costs in the new building will be considerably higher on a per square metre basis than the CAA’s current facilities in Petone.

The decision to relocate was made last year, prior to the general election, and was supported by the then Transport Minister Annette King. The move is scheduled for the end of next year.

”I am not impressed that these costs are being incurred to this level and at this time when New Zealanders are having to tighten their belts in the current global economic recession,” says Mr Joyce.

About 90% of CAA revenue comes from industry fees and charges, including the domestic passenger levy.

Mr Joyce says he has made his views on this matter very clear to the Civil Aviation Authority.

“I have tested the options to amend or not go through with this move over a period of time with the Chair of the CAA. Unfortunately commitments were made with the support of the previous government that are unable to be changed.

“The CAA has assured me that everything possible will be done to contain costs going forward from here.”

Then Mr Joyce, in comments to ONE News on Tuesday June 30, 2009, said:

“The CAA say moving to Featherston Street means they will be closer to other industry players and to Parliament.

“There is no need for the Civil Aviation Authority to be based within a stone’s throw of Parliament and [in] brand new premises.”

ONE News discovered that in July 2008, Audit New Zealand had questioned whether it was appropriate to use passenger levies to pay for the new premises. The CAA got around that by paying higher rent over time instead of a lump sum.

Steven Joyce became a minister later that year, but by then it was already a done deal and they had to carry on or be sued for around $27 million.

“It is the lesser of two evils,” said the Minister.

A further question put to the CAA and answered by Jo Beckwith:

Q. The old premises in Lower Hutt were stated as being “no longer suitable for the purposes of the CAA”. In what ways were they considered unsuitable?

A. The CAA’s former premises in Petone were considered unsuitable for the following reasons:

1. The building’s plant was beyond the end of its useful life cycle. The heating, ventilation and cooling plant was failing and could not adequately heat or cool the building. In addition, the roof was leaking creating hazards in the workplace and the plumbing was failing causing damage to both the CAA and the landlord’s property.

My comment:

I would have assumed that there was a contractual lease agreement that obliged the landlord to repair/replace these deficiencies and that most landlords would have done their utmost to keep their building tenanted by a government SOE such as the CAA.

2. The premises were not conducive to attracting and retaining staff.

Comment:

In the past, we have had some good people working for the CAA, but the comments from ex-employees were generally that they left because the culture and bureaucracy stifled their ability to achieve any meaningful change to systems and practice – not because of the “un-conducive premises”

3. Staff were located in two buildings.

Comment:

In Christchurch, post-earthquake, many large businesses have found little hindrance to continuing effectively whilst located in separate buildings. In fact, many have decided that there are distinct advantages to their clients and staff in no longer being located in the CBD.

4. The premises were not large enough to accommodate the then forecast growth in staff numbers.

Comment:

It would appear that there were moves contemplated to increase staff numbers but little mention of any efficiencies gained by the relocation that would lead to a reduction in staff.

The cost and funding of the relocation

As disclosed above by Steven Joyce, the cost of the relocation amounted to $8.5 million.

The hard fit-out of Levels 14 &15 of the Asteron Centre at 55 Featherston St was funded by a term loan from the Crown agreed to by Cabinet. CAA funded the capital work-in-progress from its cash reserves, with the loan drawn down in December 2010.

This differs from the original concept, which was based on funding the hard fit-out by a sale and leaseback option with the landlord (challenged by Audit NZ).

While the details have not yet been disclosed, the loan was to have a term of four-and-a-half years. The financial projections assume the principal repayments will reflect the nine-year term of the lease, with any outstanding principal repayable as at June 2015. The CAA has stated:

“The levies, fees and charges introduced on 1 November 2012 have been calculated to cover the outgoings on the loan through to June 2014, the end of the three-year period covered by the Funding Review.

“It is assumed that outgoings for subsequent years will be covered by a combination of re-financing and revision of levies, fees and charges depending on the fiscal position and operating conditions prevailing on the CAA at that time.”

Comment:

Whilst we considered that the new fees, levies and charges, introduced on November 1 2012 were exorbitant, it has been clearly signalled from the above that there is potentially still worse to come if there is a continuing decline in the fiscal position of the CAA.

Speech by Steve Douglas, Director of Civil Aviation

In an address to the 59th Annual Aviation Industry Association Conference in Blenheim on July 27 2009, Steve Douglas said:

“Yes, the relocation will mean that we pay more in rental than we do at present. In the CAA’s case, the increase in rental is as much to do with the site that we are moving from, as it is the building we are moving to. The increase in rental from 2011 will need to be funded from future revenue, and this was taken account of in the funding arrangements put in place in the decision to relocate.

“I have pointed out that the CAA will need increased funding if it is to retain and build the capability it needs to undertake its role as an effective and responsive aviation safety regulator. These strategic projects, rather than the relocation, are likely to determine the future funding requirements of the CAA.”

What about that statement by ONE News that the shift will hit you in the back pocket?

“Well, if the domestic passenger levy were to be the only source of funding, the increase would be of the order of 20 cents per passenger sector. I’m sure that is not the impression you were left with as the result of TV One’s treatment of the issue.”

Comment

Rather than increasing the domestic passenger levy by 20 cents per passenger sector as suggested by the ex-Director Steve Douglas as a means of mitigating the increased costs, the CAA reduced the domestic levy to $1.97 (incl GST) from $2.00.

Comparison of rental costs

In order to research the previous Petone rental costs as opposed to those at 55 Featherston St in the Wellington CBD, I once again sought information from Jo Beckwith. In her letter of April 3 2013, she forwarded the following information:

“Please see our response below to your request for a cost comparison of the lease costs of the Petone and Wellington CBD premises.”

PETONE RENTAL COSTSCost per m2Total m2Annual Rental
Aviation House192.873376.00 $661,140.00
Home Ideas Centre146.53476.28$69,789.31
TOTAL3852.28$730,929.31
[Average rental per m2 = $189.74]
WELLINGTON CBD RENTAL COSTS
Asteron Centre (part level 14)5501567.55 $862,152.50
Asteron Centre (level 15)5602841.10$1,591,016.00
TOTAL4408.65$2,453,168.50
[Average rental per m2 = $556.44]
Rental increase$1,722,239.19

All figures are exclusive of GST

In the 2009-10 Annual Report of the Civil Aviation Authority, section 7.2, there is information regarding the relocation of the CAA. Under the subject heading of identified internal risks, it is stated:

“The CAA has exposed itself to financial risk associated with new buildings, fit-out costs, etc, at a time when its revenue flows have diminished.”

The way in which the CAA planned to manage those risks was stated as below:

“The costs estimated by the CAA for relocation have been rigorously reviewed, managed to reduce costs below its budget, and monitored within the budget set for the relocation. The funding of the ongoing accommodation costs is considered as part of the analysis of future revenues and costs being undertaken as part of the Funding Review mentioned in Safety Levy Revenue risks.”

The identified risks from the Safety Revenue were:

That Levies may not be sufficient to finance the required CAA capability in the medium term.

So, having identified that risk, the CAA then reduced the Safety Levy imposed on the airlines (which, incidentally, had the means to recover their costs from their passengers should the levy have been raised).

To sum up this investigation, it is my contention that no prudent Board of Directors or CEO of a business would willingly increase the overheads of that business by locking in a rental increase of more than 300% unless:

1. That business was in the privileged position of being a SOE Regulator.

2. The client base of that business was “captive” without having any options of taking their business elsewhere should they not wish to accept increases in fees, levies and charges.

3. The only means of objection that “clients” had to increased fees, levies and charges was the daunting prospect, for most people, of laying a complaint using legislative channels such as the Regulations Review Committee, the Office of the Attorney General or by Judicial Review.

Coupled with a global economic slowdown, the prospect of a falling client base as more pilots move away into lower-cost areas of general aviation and existing small aviation businesses either close or do not start up, the expensive relocation of the CAA does not make sound economic sense – except perhaps to a few clowns!

So, back to that old refrain…

Isn’t it rich?
Isn’t it queer?
Losing my timing this late
In my career?
And where are the clowns?
Quick, send in the clowns.
Don’t bother – they’re here.