Welcome to the General Aviation Advocacy Group of New Zealand

Archives for August 2013

Colour deficient pilots: Is there light at the end of this tunnel?

GAA supporters will be aware that the CAA is at last taking a serious look at the way it handles colour deficiency in pilots, following a vigorous campaign by Colour Vision Aviators, led by Nelson-based Tim Woods. But you may be unaware of the detailed background to this issue, and how it generated the CVA campaign.

GAA CVATim Woods reports:

It has been a very interesting journey over the past two and a half years since we formed Colour Vision Aviators. Over this time we have worked to understand the real issues, those affected and the less than satisfactory performance of those responsible for governing the processes involved.

We are pleased to now be able to provide a substantial and current report.

The NZ CAA Medical Unit and the various Principal Medical Officers employed over the past 25 years have placed restrictions on NZ colour deficient pilots. This is for both Class 1 and Class 2 medicals. A range of testing methods has been used and classifications used to describe to what extent limitations have been placed on the certificates.

The basis for these restrictions, in most cases, has been found to be simply the opinion of the PMO at the time. This has evolved over many years and typically these restrictions are:

♦ No night flying
♦ No IFR
♦ Not valid for ATO air transport operations with passengers
♦ Not valid for special air operations

Over the years, CAA has also provided ‘dispensations’ to many pilots ranging from minor constraints to the use of their pilot licence to fully unrestricted certificates, even with the licence holder having a colour deficiency that CAA today would severely limit the pilot in exercising the privileges of their licence.

Fortunately during our research we discovered the work that Australian Dr Arthur Pape had done with regards to Colour Deficiency amongst pilots and its relevance to aeromedical significance.

Dr Pape, a licensed and experienced pilot with multi-engine IFR qualifications (and with a CVD) was initially denied anything but a day VFR medical certificate. Dr Pape challenged CASA over this ruling and after many years took his case to the Australian Administrative Court of Appeals. Dr Pape presented significant scientific evidence supported by practical flight test data. In this case he demonstrated that colour deficiency has no ‘aeromedical significance’. The court found in his favour.

Since this ruling was made, CD pilots within Australia can fly unrestricted (with the exception of an ATPL as Pilot in Command on Air Transport operations). Once a person passes the Control Tower Signal Light Gun test, they are then issued an unrestricted medical certificate.

CVA published advertisements in NZ domestic aviation publications in order to see just how many pilots, and/or those who want to be pilots, have been affected by CAA policy on colour deficiency with their medical certificates. What was received was an overwhelming response from CD pilots. Many live in New Zealand with severe certificate restrictions. Many pilots work offshore with no restrictions as they hold a CASA licence. Most would love to return home to work in New Zealand.

Each pilot had a unique story to tell as to how they had been treated by the NZ CAA and the PMOs’ decision over the years. Many inconsistencies by the CAA have been disclosed through our research. What CVA has discovered is clear examples of discrimination towards pilots with CVD.

There are many CD pilots who are currently flying commercially, unrestricted, based and employed here in New Zealand with either foreign registered airlines or Air New Zealand. These pilots are safely carrying passengers on domestic and international routes. In some cases these pilots have received a dispensation from a previous CAA PMO. Some have simply been allowed to undertake the Control Tower Signal Light Gun Test. (This is currently used by the Canadian CAA, FAA and CASA Australia.)

Now we would like to bring you back to the beginning of this update. We noted that the basis of CAA medical certificate restrictions was the concern of CD pilots being able to fly safely in New Zealand skies.

The question exists, if the entire basis of placing restrictions on CD pilots is safety, then why are some pilots allowed to fly in New Zealand and others are not because they happened to have applied for a medical certificate at a time between the changing of opinion of PMOs, or they fly a foreign-registered aircraft?

This is a blatant case of discrimination!

CVA has also uncovered in our investigation that the current PMO, as early as 2009 and without consultation, changed and added new restrictions on two commercial student pilots’ Class 1 medical certificate. Upon their first annual renewal, both of these student pilots had just completed their CPL Rotary Licence. Each obtained $100,000 student loans. Because of these new added restrictions, both of these pilots have been unable to obtain work here in New Zealand and were forced to travel to Australia. There they secured CASA Class 1 medical certificates in order to utilise their licences.

We have recorded many more cases for future evidence when needed, but want to now move on to the most current activities.

In February of this year, we approached MP Winston Peters with the evidence and research that we had compiled.

After reviewing the situation, Mr Peters had us provide him with three relevant questions that he would present during Q&A in the month of May in Parliament, directed to the Minister of Transport, Gerry Brownlee.

After correspondence between the MOT, Mr Peters and the CVA, we then directed our concerns to the Director of the CAA. A General Directive soon surfaced from the CAA for public submissions regarding the policies towards colour vision.

During all of this, we have been sharing the evidence with the leaders of the whole of the aviation community in order to keep them informed with the developments.

On August 2 2013, representatives of NZAIA, NZAOPA, NZALPA and NZ Aviation Federation attended a meeting with the Director of CAA along with three of his officials in Wellington. Dr Pape came from Melbourne (with his costs covered by CVA) to attend and provide his expert opinion. Dr Pape is recognised as a world expert on colour deficiency in aviation.

At this meeting, and after much discussiion, everyone including the CAA admitted that there were some serious concerns with the obvious inconsistencies that currently exist and that we would meet again in a few weeks time to discuss in more detail the outline and framework of these concerns.

It was decided that the CVA would submit all evidence and concerns along with the presentation to the Australian Administrative Court of Appeals to the CAA via a submission by Nov 28 2013 where it would be recognised and reviewed by a committee of experts in the field, and the CAA Director.

This is an opportunity and stage to present evidence professionally and in open and transparent forum for all to see. The main objective of CVA is to ultimately remove all of the restrictions placed on CD pilots and eliminate discrimination.

In order to achieve all of this, the CVA originally received some small as well as two substantial financial contributions to assist with the expenses incurred to run this campaign. These funds have now been exhausted and we urgently require contributions from those to who will benefit from the work that has and is still being performed to overturn these restrictions.

Any amount of donation will be appreciated and constructively used to obtain our goal. The largest expense to run this campaign is the cost of travel and accommodation, not to mention the ongoing cost of telephone charges.

All of my time along with the efforts of others have been and are continuing to be donated in the hope and desire to achieve our goal. I have confidence that we will reach it!

To help, we suggest the following as a value for contributions:

♦ Aviation Organisation, large membership – Diamond $3000
♦ Flying School/Aviation Company – Platinum $1500
♦ Private Pilot/Individual – Gold $300

Please make payments of any donations to the CVA account below:

Colour Vision Aviators
Bank of New Zealand
Papakura Branch
Account number 02 04000096 144000

Following this news update, we will press on with the submission to CAA. We will provide further information as we proceed.

Thank you for your support and interest. We hope to achieve the changes with CAA to allow you or the person who wants a career in aviation with CVD unencumbered, free to enjoy the privileges of an unrestricted medical certificate.

To find out more about this subject, visit Colour Vision Aviators or email
info [at] colourvisionaviators [dot] co [dot] nz

Phone (03) 5285470
Mobile 021 978 939

PO Box 388, Motueka, Nelson 7143

Crisis in the airline hangars: A badly tuned piece of anti-social engineering

There's an airline boom in Asia and the Pacific - but New Zealand cannot compete

There’s an airline boom in Asia and the Pacific – but New Zealand cannot compete

Hot on the heels of a claimed skills shortage of pilots, in which an application by Air New Zealand and PricewaterhouseCoopers said that only eight people in our great nation qualify for an interview for airline pilot positions, Air NZ now threatens up to 190 redundancies in its team of wide-body aircraft engineers.

In stark contrast, at Singapore Airlines, SIA Engineering is benefiting from industry growth driven by airlines expanding their fleets. Carriers from Air Asia (Asia’s biggest budget airline) to Tiger Airways have ordered at least 1000 new aeroplanes in the past five years. About 15 low-cost carriers began flying in the past decade in the region.


Boeing has stated that “the demand for trained maintenance personnel will grow in proportion to the expanding global fleet. There will be a strong need for basic skills training in these emerging markets to develop a local source of technicians.

“The need for maintenance personnel will grow most rapidly in the Asia Pacific region, which will require 247,400 new personnel. China’s requirement will be the region’s greatest, with an expected need for 108,300 maintenance personnel.”

So what’s going on? And who is now planning a career as a New Zealand aircraft engineer? The Careers NZ website suggests that your chances of gaining employment as an aircraft engineer in NZ are at best “average” due to steady numbers of workers and low staff turnover.

In spite of burgeoning world demand for aviation maintenance, Air New Zealand cannot compete because the Kiwi dollar stubbornly refuses to fall to a sensible value. This may lie behind Air New Zealand’s demand to the engineers’ union. No details have been released, but it probably reads: Work longer and earn less.

Since there is no other Kiwi airline of choice, can you guess where all these skilled people are going, apart from the dole queue (which will not happen because engineers, like pilots, are highly motivated people)?

The announcement comes alongside Air New Zealand’s request to have Aeroplane Pilot added to the list of Essential Skills in Demand – countered by GAA’s evidence that there is no such shortage. NZ First MP Denis O’Rourke questioned Steven Joyce (Minister for Economic Development, Minister of Science and Innovation, Minister for Tertiary Education, Skills and Employment, Associate Minister of Finance – in fact, Minister of Almost Everything) about the implications of this for pilots wishing to return to work in New Zealand, or airline jobs for student pilots. Mr Joyce smugly retorted that there seemed to be a current skills shortage in the Labour Party, and did not seriously address Mr O’Rourke’s questions.

Those facile jibes may indicate the importance our own government attaches to alleged skills shortages and real unemployment.

New Zealand’s economy remains largely reliant on the dairy industry. The bad news is that the tit-tuggers’ virtual monopoly outlet, Fonterra, has allegedly failed to guarantee 100% pure products and is wrecking the country’s pristine reputation.

The good news for Air New Zealand engineers, and the rest of us, is that Fonterra’s failures are also affecting our dollar. If it falls far enough, the airline might gain a few maintenance contracts without really trying.

Strachan Crang, from the EMPU, says the airline’s engineers had worked hard to remain productive. “Over the past three years, they’ve delivered productivity gains in the double figures but this has all been eaten away by the high value of the New Zealand dollar.” Unless the dollar fell under US70c, it would be impossible to remain competitive against cheaper Asian engineering facilities.

Unfortunately, by the time the dollar has dropped sufficiently, these aircraft engineers will probably have been absorbed by other engineering-related businesses in New Zealand, will have become gainfully self-employed here or will have accepted employment in other countries.

We almost forgot that other snout in the trough: the CAA and its compliance costs. They must be affecting the airline, just as they are wounding smaller operators.

You can rest assured that there are no redundancies being signalled in the CAA.

GAA supporters versus PwC and Air New Zealand: We rest our case.

GAA supporters say Air New Zealand is taking a turn for the worse

GAA supporters say Air New Zealand is taking another turn for the worse

Submissions for or against the PricewaterhouseCoopers/Air New Zealand application to have Aeroplane Pilot added to the list of Essential Skills In Demand for immigrants closed on Friday August 9.

GAA met the extended deadline with 24 hours to spare, thanks to an astonishing response from supporters who – within the space of 14 days – provided a wealth of evidence and comment to combat this proposal.

We sincerely thank them all because, without their help, it would not have been possible for GAA to credibly oppose PwC and Air New Zealand.

The GAA submission runs to about 17,000 words (much of it written by the potential victims) and more than 100 pages. Many long hours were spent collating, organising and refining the GAA argument, during which Des Lines fronted on Sky Television News, Brian Mackie argued the case on Radio New Zealand National, and The DominionPost (seemingly undaunted by fears of lost advertising revenue) also covered the story.

We ran a rapid survey, in parallel with one conducted by NZ ALPA, and discovered that you can easily add a nought to the claimed number of pilots meeting Air New Zealand’s entry qualifications (which PwC and Air New Zealand ludicrously stated as just eight). We discovered 77 pilots meeting the requirements, a further 32 almost meeting them and 49 in training to meet them. And this was not an exhaustive piece of research.

Almost 240 people added their names as co-submitters to our case against the application.

To download a PDF of the GAA case, click > GAA MoBIE submission Public version

To give you the gist, here’s our introductory summary:

This submission by the General Aviation Advocacy Group of New Zealand to the Ministry of Business, Innovation & Employment

♦ opposes the application by PricewaterhouseCoopers, on behalf of Air New Zealand, to have “Aeroplane Pilot” added to the ESID lists and

♦ requests preservation of the status quo.

GAA and its supporters reject the applicants’ claim that

“The New Zealand Aviation industry is experiencing a pilot shortage of significant proportions”

In this submission, we seek to establish that

♦ the application must be rejected because it does not meet the criteria, and

♦ no such skills shortage has been proved.

For the application to succeed, it must meet several important criteria, which PwC and Air New Zealand have failed to do. They must show, among other things, that:

♦ The shortage is not employer-specific

♦ There is evidence of employers having difficulty employing staff (note our emphasis on the plural)

♦ The shortage must be across all geographic regions in New Zealand

♦ It must be a current shortage, not an anticipated one

♦ There must be an ongoing and sustained (absolute) shortage, both globally and in New Zealand.

The claim by Air New Zealand and PricewaterhouseCoopers that “The New Zealand Aviation industry is experiencing a pilot shortage of significant proportions” is entirely their own.

It is not supported by any credible third party evidence in the proposal, and the allegation is rebutted in our submission (which relies on verifiable evidence gathered over a very short period).

Moreover, we see no evidence that local operators independent of Air New Zealand are suffering from a shortage of pilots. On the contrary, it appears that they enjoy a very low level of pilot turnover. If the roughly 33 operators we list were experiencing a shortage, it would be reasonable to have expected them to support the PwC/Air NZ application (had they been aware of it) but there is, again, no evidence of such support – or even general awareness of the proposal.

There is no evidence, within the application, of PwC/Air NZ having consulted with the wider ‘Aviation industry’ over its proposal. To the best of our knowledge, no subjective survey of the industry was carried out by the applicants before the PwC/Air NZ proposal was filed.

The Aviation Industry Association, led by its CEO, Irene King, is known to have been involved with Air New Zealand in supporting the application; but there is no evidence in the application that the AIA consulted its members on the issue.

We also know that this application was made without the knowledge or involvement of the New Zealand Airline Pilots Association, a body which – perhaps above all others – could have been expected to have an interest and involvement. GAA seriously questions the manner in which this application was made, because it is clear that few potential stakeholders had any knowledge before GAA exposed it to the wider public. It is alarming that submissions to this proposal would have closed on July 26, had not NZ ALPA stepped in to achieve an extension of the deadline. This strongly indicates that the application was not adequately promulgated to interested parties.

Some industry pundits predict that during the next 20 years, there may be a worldwide shortage of pilots and technical support staff. For example, we refer to a Boeing study of 2012:


However, this forecast has no relevance to the contemporary New Zealand scene, or the application.

We can see from the application that it is Air New Zealand-focused, and even if the Ministry were to regard the regional airlines as separate businesses, the application must fail purely because the Air New Zealand Group recruitment system is the single entry point for those with the skills that are claimed to be in short supply.

Air New Zealand claims to support the training of future airline pilots, through its links with five training establishments. However, while Air NZ has a well-established “sponsorship” and monitoring system for the training schools, it fails to meet demand in one very significant respect:

It fails to provide a bridge between the flying school’s product, the Commercial Pilot Licence holder, and his or her career with our national carrier as an Airline Transport Pilot Licence holder.

Instead, a newly qualified holder of the Commercial Pilot Licence is cast adrift to find a job somewhere else, in order to build enough hours and gain additional experience and qualifications to meet the airline’s requirements for a recruitment interview. This is an extremely onerous challenge.

If there is any shortage at all, it boils down to this:

♦ Young CPL holders are forced to take employment in poorly-paid positions in New Zealand in order to build their hours or

♦ they go overseas, find somewhere to develop their skills, which then reach the stage where they pursue their careers in another country, with promotion and salary prospects that Air New Zealand fails to match.

♦ There is a large and verifiable constituency of expatriate New Zealanders who are well-qualified to fill positions within the Air New Zealand Group, but (as we show) find the Air NZ terms of employment unacceptable.

This is, in fact, the real shortage: Air New Zealand pays lip service to professional pilot training, but fails to follow through by committing itself to develop the resulting output – then “identifies” a local staffing crisis for which it is, in large part, responsible. Moreover, it does not meet the career expectations of qualified New Zealanders working abroad.

In this submission, we demonstrate that

♦ there is an enormous enthusiasm for careers with Air New Zealand amongst New Zealand flying students and

♦ this is not matched by a formal Air New Zealand career path from flying school to the airliner cockpit, with committed and long-term investment from the airline in a cadetship scheme. Air New Zealand has always rejected such a scheme, but there is new and compelling evidence from Australia that they are worth investing in. We provide the report, for the guidance of the Ministry and the airline.

♦ Because of this dreadful failure on the part of Air New Zealand, many of our most promising and ambitious students leave New Zealand, taking a very important pool of talent away from our nation. This has been occurring for many years and the record shows that most of this expertise is lost forever.

♦ Unless Air New Zealand adopts globally competitive remuneration, working conditions and more realistic promotion paths, to become an “employer of choice”, it is unlikely to either persuade current ex-pat pilots to come home, or to attract the “right stuff” from other nationalities.

♦ Given its uniquely privileged position in our country’s economy, Air New Zealand has a duty to adopt a more responsible employment policy than a privately owned, budget airline.

The PwC/Air New Zealand submission is, in short, an opportunistic attempt on the airline’s part to abrogate its responsibility (as the monopoly controlling force in this country’s commercial aviation) to fully support and develop training opportunities for young New Zealanders, recruit eligible New Zealand pilots living here, and make it more attractive for expatriate pilots to return.

It is also disturbing to note that advertisements for aircrew whose qualifications closely match the requirements of Air New Zealand began to be posted on an international recruitment website in July – long before this application came to be considered by the Ministry. They could only have come from one source.

False predictions of pilot shortages are not new.

Take, for example, this one from 2003, which features the Aviation Industry Association and its then chairwoman, Irene King, a supporter of the current PwC/Air New Zealand application:

from The New Zealand Herald, in which it is stated

Pilot shortage looms as fewer train

5:00 AM Monday Nov 17, 2003

The aviation industry is predicting a pilot shortage within four or five years following a Government cap on the number of students next year.

In response to the looming shortfall, the Aviation Industry Association (AIA) has suggested several strategies to reduce the impact of the move.

AIA chairwoman Irene King said that for the past decade about 300 new pilots a year had entered the market having received their commercial pilot’s licence. With the cap – restricting total student numbers to 775 fulltime equivalents, including a new entrant limit of 350 – the number of people receiving their commercial licences in 2005 was predicted to drop to 130, she said.

On present predictions, by 2007 there could be problems finding enough experienced pilots for “lower end” services, such as scenic flights.

The AIA is predicting that pilot shortages will start to filter through to heavy commercial aviation by 2009/10.

It pointed out the problem had arisen at a time when demand for pilots was at an unprecedented high with major scheduled operators ramping up services, and a new entrant about to enter the market.

AIA president John Funnell said taxpayers had every right to ask why they should be lending more than $30 million to students and funding tertiary institutions only to see students disappearing overseas.

“It would be good in view of the upcoming demand to keep more of these people here in New Zealand.”


None of this happened. In fact, quite the contrary.

Fast-forward to 2009, and an article in the Sunday Star-Times:

Air NZ pilots face demotion, pay cut

Sunday Star-Times, January 17

MORE THAN 30 senior Air New Zealand pilots flying the airline’s largest jets face demotion to smaller aircraft and reduced pay as the company looks for ways to avoid large-scale redundancies in the difficult economic climate.

The Sunday Star-Times understands 32 pilots currently flying 747s, 777s and 767s on long-haul routes will be “down-trained”, meaning they will fly smaller aircraft on domestic routes and have their pay and rank lowered. The airline has about 850 jet pilots, of which about half fly long-haul routes.

Air New Zealand is also offering pilots alternative roles within the company, leave without pay, flexible flying arrangements and enhanced retirement packages. According to a government career advice website, pilots who fly internationally earn up to $250,000.

Company spokeswoman Tracey Palmer said the initiatives were because of an 8% reduction in long-haul capacity as a result of the world economic downturn. Among the long-haul services Air New Zealand cut last year were flights to Japan and Hong Kong from New Zealand.

She said the airline had also made long-haul cabin crew redundant, offered reduced hours to corporate staff, not replaced non-safety sensitive roles and frozen executive pay.

“We have not made any pilots redundant and remain committed to maintaining a workforce of highly skilled and trained professionals to ensure the airline is quickly able to adapt to changing market conditions,” she said.

Tim Robinson, head of the Air New Zealand pilots’ council, said the union supported the company’s initiatives. Although down-training was disappointing for pilots, it was preferable to being made redundant.

Robinson said the airline had also made inquiries about jobs with other airlines on behalf of pilots, although those opportunities were drying up.

Rick Mirkin, executive director of the Airline Pilots Association, said as far as he was aware, the other airlines that had pilots based here, Pacific Blue and Jet Connect, had not made cutbacks, although they flew mainly domestic and regional routes.


GAA asks the Minister of Business, Innovation and Enterprise to reject the PwC/Air New Zealand application.

We also invite the Minister to order further study into how the needless haemorrhaging of expensively acquired, home-grown talent can be reversed.

In our view, this continuing loss of expertise is a far more important issue.

As the majority shareholder (on behalf of the public) in this airline, the Government is ideally placed to remind Air New Zealand that its privileged position as a monopoly supplier requires a higher standard of ethical behaviour than usually applies in more competitive business environments.