Most of New Zealand’s aviators will know that the CAA is embarking on a review of its fees and charges.
It must do this because the CAA is committed to three-yearly reviews of fees and charges after admitting that it lost the plot for 15 years and neglected to review its costs until 2010.
This led to the most draconian increases – and some of the loudest user protests – in New Zealand aviation history.
The CAA plans a two-stage consultation process towards fixing charges for 2015 to 2018, which includes an initial set of explanatory seminars. The authority states that these will take place:
♦ in only six locations- Auckland, Wellington, Palmerston North, Christchurch, Nelson and Queenstown
♦ during the working week starting at 0930
and now, following GAA supporters’ protests,
♦ also at about 1800 (after, or the night before, the morning seminars)
The schedule shows that these seminars exclude a large number of CAA clients who live far from the planned locations. For example, someone in Wairoa would need to leave home by car at 0530 to reach the nearest seminar in Palmerston North by 0930. If you live in Whakatane, Rotorua or Tauranga, your only choice is Auckland and its frequent traffic chaos.
Aviators in New Plymouth are similarly isolated and marginalised, as are many people living south or west of Christchurch.
Your alternative? Drive to the centre the night before, and pay for overnight accommodation. An outlyer attending the evening sessions faces a similar challenge: drive home into the early hours, or pay for a motel bed. And, no matter how few turn up to listen, remember that every one of us will be paying something towards the CAA presenters’ overnight stays and incidental expenses.
For many attendees, this will also involve the loss of a day’s earnings and the CAA’s published schedule does not even promise them the opportunity of a Question and Answer session.
GAA believes that this part of the consultation is a charade, planned to suit CAA personnel and intended to discourage the involvement of general aviation users. It is in marked contrast to the annual AvKiwi seminars, traditionally held in many more locations and featuring “free” alcohol and sausage rolls afterwards.
Des Lines wrote to the CAA Director, Graeme Harris, and stated:
The published schedule of funding review seminars has been received with astonishment by aviators around New Zealand.
This schedule is discriminatory and unfair to a great number of interested parties.
If it was intended to be the beginning of meaningful consultation by the CAA, the Authority has fallen at the first hurdle.
The chosen venues and times are contrived to allow for minimum attendance by GA pilots and organisations. To make a 9.30am start at, for example, Palmerston North, a participant from Wairoa would either have to leave home at about 5.30am, or pay for overnight accommodation. The location of this limited number of venues seriously disadvantages those living far from them. Furthermore, attendance for many will incur the loss of at least one entire day’s earnings.
There was ample time for this schedule to have been better constructed, working with representative GA organisations. Why was this not done?
When the CAA promotes its annual series of evening AvKiwi safety seminars, they are designed to reach the maximum number of participants in GA, and the record shows that they do. This is in stark contrast to the funding review seminar programme.
I remind you of the Court of Appeal Decision 1992 regarding “Consultation”:
Wellington International Airport Limited and others v Air New Zealand  1 NZLR 671, at p. 675. Judgment of the Court of Appeal delivered by McKay J quoting McGechan J in the High Court in Air New Zealand and others v Wellington International Airport Limited and others, HC, Wellington, CP 403-91, Jan 6, 1992:
“Consultation must allow sufficient time, and a genuine effort must be made. It is a reality, not a charade. The concept is grasped most clearly by an approach in principle. To ‘consult’ is not merely to ‘tell’ or ‘present’.”
We request that you immediately withdraw this current schedule and instead work on a programme including the locations, venues and times that have previously been used for AvKiwi seminars.
Starting from the north and working down the country, AvKiwi seminars were held, for example, in:
Kerikeri (Bay of Islands Aero Club)
Whangarei (Recreational Flying Club)
North Shore (North Shore Aero Club)
Ardmore (Auckland Aero Club)
Hamilton (CTC Aviation Training)
Feilding (Flight Training Manawatu)
Hastings (Aerial Mapping Hangar)
New Plymouth (New Plymouth Aero Club)
Palmerston North (Massey University Campus)
Paraparaumu (Otaihanga Boating Club)
Masterton (ATC Building Hood Aerodrome)
Taupo (Suncourt Hotel and Conference Centre)
Gisborne (Gisborne Aero Club)
Tauranga (Tauranga Aero Club)
In the South Island, AvKiwi seminars were held in:
Motueka (Nelson Aviation College)
Nelson Aerodrome (Nelson Aero Club)
Omaka Aerodrome (Marlborough Aero Club)
Hokitika Aerodrome (Hokitika Aero Club)
Christchurch Aerodrome (International Aviation Academy)
Franz Josef Aerodrome (Air Safaris Terminal Building)
Ashburton Aerodrome ( Mid-Canterbury Aero Club)
Wanaka (St John Ambulance Centre)
Queenstown (St John Ambulance Centre)
Invercargill Aerodrome (Southland Aero Club)
Dunedin (Mercure Dunedin Leisure Lodge Hotel)
Oamaru Aerodrome (North Otago Aero Club)
Timaru Aerodrome (South Canterbury Aero Club)
Start times were scheduled at 7pm and this resulted in good attendances – which is what the CAA should be aiming for, if this round of consultations is not to look like a charade. The majority of GA aviators are in employment and they cannot attend daytime meetings during workdays without incurring a financial loss. Also affected are organisations, which have their daytime businesses to attend to – again precluding them from attending during a working day.
The president of one significant North Island aero club has already told us:
“Yes I had noted the CAA review locations. I had already decided not to go. Just too far and a day off work.”
You might also consider either shortening the seminar period to between 90 minutes and 2 hours (while providing comprehensive background documentation for later study and distribution to non-attendees) or bringing forward the start time to 6pm, to allow participants enough time to return home at a reasonable hour.
If your proposals are sufficiently detailed as to require a three-hour presentation that also allows for discussion, it follows that the series of seminars must also be redesigned to present them to the widest possible audience, with the minimum of cost and inconvenience to CAA clients. Your present plan does not meet these requirements. We therefore ask you to withdraw this plan and order it to be changed, and prepare a new set of venues that allows the CAA to present its ideas to a more representative audience. This also has consequences for your deadline for submissions.
Mr Harris neither acknowledged nor answered this personally addressed letter. Instead, he passed it to John Kay, General Manager, Policy and System Communications, who replied:
Your letter to the Chief Executive has been forwarded to me for reply. The Authority has received some replies to its recent email to over 29,000 members of the civil aviation community that have requested different approaches to our presentations. Those requests range from use electronic means for all engagement (e.g., email and web-based approaches) to minimize cost through the request you have made for a significantly greater number of presentations in more locations than planned.
After consideration we have determined to carry-out evening presentations in addition to those day-time sessions at the locations already advised. I appreciate this decision does not extend as far as you suggested in your letter with respect to locations. However, the cost of holding that many seminars in that many locations is prohibitive.
Further, the presentations are designed to present a summary of options that are canvassed in the discussion document, set to be released in the next few days. The primary means for participants in the civil aviation system to comment on the options canvassed in that document is by way of written submission.
This consultation period is the first round of consultation. Once we have received submissions to this first discussion document, a second set of proposals will be prepared and (subject to the agreement of the Government) will be released later this year or in the early New Year for consultation.
While I appreciate that your desire to see more locations has not been addressed in my response, I hope that the inclusion of evening presentations in addition to those day-time sessions at least partially addresses your concerns.
It did not. Mr Kay ignored the primary objection: that the scheduled locations were too far from users to be accessible without excessive cost and inconvenience.
Des Lines replied:
Your offer to carry out evening sessions as well as daytime sessions but without increasing the original six locations is, in our view, not a fair, good-faith and broad spectrum of consultation, and therefore is still unacceptable.
Your principal reasons for refusing to engage with a great many of your GA clients are, as stated in your letter, to “minimise costs”. You claim “the cost of holding that many seminars in that many locations is prohibitive”. We state that the cost of adequately consulting with CAA clients should have been properly allowed for and is – in any case – secondary to the importance of the exercise.
I find it bewildering that the CAA – in direct contrast to this all-important funding review – does not find the costs of holding AvKiwi safety seminars (including the free bar afterwards) “in that many locations” to be prohibitive.
Are we to assume from this that, in future, there are to be no more AvKiwi seminars because – to use the same rationale that you have used in the case of the funding seminars – they would be prohibitively expensive?
You should be aware that a great many of your GA clients live in outlying regions and that is why the CAA has, in the past, made conscious and deliberate attempts to engage with those clients. The positioning, as well as the timing, of these seminars is grossly inadequate and unless the scope is considerably widened, we will fairly claim that consultation was not properly carried out. Your failure to commit to holding these funding review seminars in the smaller provincial centres displays what can only be seen as an arrogant disregard for your clients’ wish to debate the issues.
It is all very well to use electronic means for engagement with your clients, to minimise costs, but it is equally important to recognise that a vast number of them want to see personal presentations from managers such as yourself. Your clients want to see and hear the CAA managers who are responsible for shaping the direction of NZ aviation and to be able to calculate the impact that these decisions may have. They want to see managers front up in person and answer questions from the floor. We would not need to tell you this if, in fact, the CAA was truly in touch with its client base.
Failure to listen to what your clients are telling you (we have been copied in on many of the letters to the Director on this issue, unlike you, obviously) would indicate a contemptuous attitude, which in my view is reprehensible. This is unfortunately prevalent in many corporations, particularly those with a “captive” client base such as the CAA. Management in SOEs and large corporations know full well that their clients are unable to take their business elsewhere because “they are the only game in town”.
In my letter to the Director, I commented that “there was ample time for this schedule to have been better constructed, working with representative GA organisations”. I then asked the question “Why was this not done?”
Your letter provides no answer to that question and one can only draw the conclusion that the CAA continues to make purely rule-orientated, bureaucratic decisions where information may be ignored and messengers are neglected or at best tolerated.
To use the Just Culture model as espoused by Hale (2000) Westrum (1993), Reason (1997) and Hudson (1999), an organisation has only reached a “true” just culture when it has attained the generative level of culture put forward in the Westrum typology below. In my opinion, the actions of the CAA fall short of achieving a generative culture on several counts and remain principally within the Pathological and Bureaucratic models.
|Information is hidden||Information may be ignored||Information is actively sought|
|Messengers are “shot”||Messengers are neglected or at best tolerated||Messengers are encouraged and trained|
|Responsibilities are shirked||Responsibilities are narrow and compartmentalised||Responsibilities are shared|
|Sharing information is discouraged||Sharing information is tolerated but neglected||Sharing information is encouraged and rewarded|
|Failure is covered up by finding a scapegoat||Failure leads to taking a prosecution||Failure leads to an inquiry into all aspects|
|New ideas are actively crushed||New ideas cause problems||New ideas are welcomed and implemented|
If the CAA is as cash-strapped as you appear to indicate, and since the planned seminars cannot possibly reach a truly representative audience, the authority should consider cancelling them entirely, properly distribute the discussion document and use the money saved to provide a more credible series of user meetings in the second stage.
Your “quick fix” solution will not satisfy the considerable number who we know have opposed the initial seminar plan. You would be well advised to reconsider.
The GAA’s position is: Unless this schedule is either radically revised, or scrapped in favour of a genuinely inclusive series of meetings in Stage Two, GA aviators will rely on it (and the resulting attendances) to claim that the consultation process was flawed.
We’ll keep you posted – and to everyone who has sent feedback directly to the CAA, thank you for your support.
♦ To access the CAA’s discussion document, please click here