Welcome to the General Aviation Advocacy Group of New Zealand

Archives for December 2013

2014 is the year General Aviation tells them exactly what we think of the CAA

We begin 2014 with the first in a series of online surveys to give users an opportunity to have their say on the issues that currently affect GA, and client relationships with the CAA.

Our survey of CAA users is similar to what many commercial organisations do amongst their own client base to gain feedback so they can improve systems and service – and retain customer loyalty.

To the best of our knowledge, such a series of opinion surveys has never been done by the CAA.

Our aim is to highlight those areas of greatest concern to you, so GAA can concentrate on those issues in particular.

Because these matters are many and varied, we start with a short survey on just two topics. The questions cover the present system of pilot access to meteorological information, and the affect the hugely unpopular and contentious “medical application fee” has had on your flying activities.

Whilst anecdotal comments are always valuable, we must be able to back them up with some statistical data and that’s where a substantial response to our surveys is vital.

To enable the widest possible coverage, we encourage you to forward the links to our surveys to other pilots and colleagues so that we can get the greatest possible feedback from CAA clients.

Forthcoming survey subjects include audit costs (and the manner in which audits have been carried out) and the level of customer service and co-operation that you have received as a CAA client.

We have kept the number of questions to around 20 per survey so that it doesn’t become tedious and we’ll provide you with the results of a previous survey as we release details of the next one.

Please take part in the Met and Med Survey – it only takes a few minutes. Here’s the link:

https://www.surveymonkey.com/s/met_n_med

Thank you – and we look forward to telling the CAA precisely what you really think of it, in great detail.

Pilot shortage? MoBIE tells Air New Zealand: We can’t see one

Air New Zealand’s application to have Aeroplane Pilot added to the Immediate Skills Shortage List has been rejected.

This is an encouraging result for GAA, the New Zealand Airline Pilots Association and – most important of all – every Kiwi whose ambition is to fly for their national airline.

GAA submitted a 17,000-word rebuttal of the airline’s claim (much of it written by students and Kiwi airline pilots working overseas) along with almost 240 co-signatories. NZ ALPA provided statistical evidence reinforcing the GAA argument that there is no current shortage of potential airline pilots in this country. Also objecting were:

♦ The Federation of Air New Zealand Pilots (a union representing pilots employed by Air New Zealand, Mt Cook, Air Nelson and Eagle Air)

♦ CTC Aviation Training (NZ) Ltd (flight instructor group) and three aero clubs (the Hawke’s Bay & East Coast Aero Club Inc, Tauranga Aero Club and the Royal New Zealand Aero Club Inc)

♦ 24 individual submissions, the majority of which were from either pilots or the parents of people who were (or who had trained to be) pilots and were based in New Zealand or overseas.

The application, made by PricewaterhouseCoopers on behalf of the airline and supported by the Aviation Industry Association, was turned down in a decision released in mid-December.

The ministry said it could not establish proof of an immediate skills shortage and “There are other immigration options that would be available in the event of an emerging shortage of pilots, e.g. Essential Skills work visa policy (subject to advertising and demonstrating that there are no suitable New Zealand citizens or residents available), Approval in Principle (where a batch of positions need to be filled), Accredited Employer (Air New Zealand is an accredited employer) or the Skilled Migrant Category. The latter two options should be more relevant to airlines in that their focus would be on long term employment, rather than a temporary work visa that could be obtained under an ISSL listing.”

GAA thanks everyone who helped to oppose PwC and Air New Zealand, at very short notice. Without your support, it would have not been possible to create a submission in the less than two weeks we had before the deadline passed.

Alas, the airline still shows no inclination to commit itself to the kind of cadetship scheme common elsewhere that provides a bridge between CPL and airliner cockpit.

♦ While this application was being considered, Air New Zealand also applied to the Ministry of Business, Innovation and Employment for employer accreditation to allow the company to employ foreign specialist engineers.

The employer accreditation programme is run by Immigration New Zealand and allows employers who are “unable to find suitably qualified or experienced New Zealand workers” to recruit non-New Zealand citizens or resident workers.

The application to employ foreign aircraft engineers “defies belief” in light of recent staff redundancies, says the Engineering, Printing and Manufacturing Union (EPMU). A spokesman said the union was “gobsmacked”, bearing in mind a recent threat of engineering redundancies at the airline.

Last August, GAA reported on the threatened job cuts in this article.

You’d like a trial flight? OK, but just one smile, and you’re nicked

The latest Vector magazine contains an article headlined Adventure Flights are not Trial Flights, and says “A so-called trial flight, or flight instruction, should not be used as a backdoor method for conducting commercial activities such as adventure or scenic flights without certification”.

What follows is a rather baffling piece of work, based on Part 115 – itself inspired by panic and created in haste – which seems to indicate that trial flights (for which there is no provision in the Civil Aviation Rules) are adventure flights in the CAA’s eyes. And what’s more, there can be no instructional flight if any part of it includes recreation (which the American Heritage Dictionary defines as “Refreshment of one’s mind or body after work through activity that amuses or stimulates”).

The following comment is from an instructor who wishes to remain anonymous because he or she fears retribution by CAA personnel:

Oh dear. This student appears to be enjoying herself... which is against the Rules (Image: Flysafe in Australia)

Oh dear. This student appears to be enjoying herself… which is against the Rules (Image: Flysafe in Australia)

CAA demonstrates a complete failure to understand what it means to offer flight training on a commercial basis, outside of a student loan-funded or military environment.

To suggest that if a flight is primarily enjoyable, it cannot be flight training and must therefore be Adventure flying gives absolute clarity to a lack of understanding within CAA of the reality of selling flying to people.

When I have taught instructor ratings, one of the very first things I have hammered home to the prospective instructors is that they must understand that they are now in “sales” – whether they like it or not. Every single flight with someone who is paying as they go is potentially the last one they will pay for, if they fail to enjoy the experience.

In fact, I couldn’t count the number of people who have flown with me, who have reported exactly that. “I did start flying lessons, but it was boring, so I stopped”.

CAA contends that if the flight lesson is a “recreational experience” (or includes an element of that) then it is not an instructional flight. This is absurd.

It is the right of anyone to pay for a trial flying lesson, be it for themselves, or as a gift for someone else. As long as the flight is carried out in accordance with the rules, by an instructor with the appropriate ratings, in an appropriately certified aircraft, then there is no reason it should not occur. Note, this is a right, not a privilege; there are no prior conditions that have to be complied with, other than that the person is physically capable. I would argue that insisting that everyone who comes into our office should fill out some questionnaire, and that if they are not judged as being a potential airline pilot they cannot do a lesson is a fundamental breach of human rights.

If this rule was extended to other activities (and there is no reason why it shouldn’t) then no one could go to a golf club and try a golf lesson if some element of “recreational experience” was involved. Equally this would apply to a potentially hazardous horse-riding lesson, a rope-climbing lesson, or possibly even a lesson in a second language. One could go on listing activities where people charge for teaching; but just think of any of them, spot the recreational element, and the CAA position is revealed as utterly ridiculous.

There is almost no better example of the CAA being completely oblivious of reality than to suggest that if there is a “recreational” component, it is not a genuine flight lesson.

Further, if the CAA looked objectively at this suggestion, it would have to question if it is appropriate to give someone (that is, sell them) a lesson on night flying, or mountain flying, or stalling, or steep turns, or landing on floats or even instrument flying unless that person is already licensed and passes some arbitrary test of their “intentions” as to what they will do with the learning they get (apart, of course, from enjoying it)!

How does this apply to a Part 141 operation which sells a flight lesson that includes some aerobatics (or mountain flying etc) to anyone who comes into their operation and asks about doing a flying lesson? Will they now have to get Part 115 certification as well?

Ask Flying NZ if the sole purpose of any instruction given by aero club instructors precludes a “recreational experience” and is only for “flight instruction”. We all know that the aero club movement in NZ is being killed by a number of factors including the CAA, but it existed primarily for people to “enjoy” aviation, which means that the sole purpose of the aero club movement was for flying to be shared and promoted as a “recreational experience”.

It is time for CAA to actually listen to those of us in the industry who make a living from selling people on the idea that they can fly an aircraft. We know what it actually takes to get people involved (outside of student loan-funded sausage machine flying schools or the air force). Not only are we operating in accordance with the rules, but we are advocates for the industry, and provide a significant educational service based on many years (and thousands of hours) of doing so safely.

To which, GAA adds: Since there is no definition of Trial Flight and it therefore cannot be legally described as an Adventure Flight (or not one), we can only work on a principle in law that is about 1000 years older than the Civil Aviation Rules.

It is: What is not prohibited is permitted.

SIGMET: The CAA responds

We invited the CAA to comment on GAA articles criticising its decision to follow ICAO rulings on SIGMETs, which in our view has made GA MetFlight forecasts even more difficult to decipher. Chris Ford, General Manager Aviation Infrastructure and Personnel, has kindly responded and his answer is reproduced exactly as received:

The CAA recognises the importance of ensuring information on hazardous meteorological conditions is available to the General Aviation community. While the CAA is responsible for ensuring New Zealand’s compliance with international requirements, it endeavors to facilitate a good level of information on hazardous meteorological conditions for the General Aviation community. While the international requirements for SIGMET have changed in response to demands from international civil aviation, the CAA has worked with MetService and Airways to ensure that Airways can provide SIGMET in-flight to domestic traffic with the co-ordinates translated to listed place names whenever possible. In addition, and for preflight planning purposes, the CAA has encouraged MetService to allow a third-party SIGMET place name translation on its Metflight-GA website.

The CAA has also provided reference material on this matter and look-up tables on its website to assist pilots to translate SIGMET co-ordinates pre-flight. This has been available at http://www.caa.govt.nz/Meteorology/sigmet_ref.pdf since 18 October and was highlighted under the “What’s New” section of the CAA website when first posted online. This site is also referenced in the latest edition of CAA’s Vector magazine. Also the weather panel in the MetFlight-GA product contains general plain language information on significant weather for each Area Forecast region reflecting the content of any SIGMETs in force at issue time. That MetFlight-GA information is updated should the expected significant weather conditions change materially (and new SIGMET issued).

The CAA’s mandate with respect to the services offered by meteorological service providers such as MetService in New Zealand to domestic general aviation is limited to regulatory oversight as set out in Civil Aviation Rule Part 174 – Meteorological Service organisations. The initiatives outlined above are outside of the CAA’s regulatory mandate, but have nevertheless been pursued recognising the needs of the General Aviation community and the overall objectives of the CAA.

Lastly for your information, around mid-2014, MetService will introduce a graphical SIGMET product in response to its contract with CAA to provide ICAO standard information to international aviation. This parallel product should allow easier pre-flight assimilation of the particular hazardous meteorological conditions for all operations. The graphical SIGMET will set out both the NZZC (New Zealand domestic) and NZZO (Auckland Oceanic) FIRs, a coastal outline of the country on a standard grid, and contain polygons depicting areas of observed or forecast hazardous meteorological conditions. This graphical SIGMET product should be accessible through MetFlight-GA. The alpha-numeric form of the SIGMET will continue to be produced.

It’s good news that pilots can expect a “product” containing graphical representation of hazardous meteorological conditions, just in time for winter 2014. In the meantime, abandon all hope of CAA support in creating your more paperless cockpit.

The CAA is also tragically mistaken in assuming that GA pilots flying in uncontrolled airspace will be talking to (or even monitoring) an air traffic controller. Quite the contrary. They are on 119.1 most of the time, and keeping a good lookout.