“The new framework will ensure the CAA is sufficiently resourced to continue delivering air safety benefits in a rapidly changing environment.”
Minister of Transport Gerry Brownlee, November 2012, explaining CAA fee increases
The Air New Zealand 777 pilot who briefly nodded off twice during a London-to-LA flight (causing international media shock-horror, barely two years after the non-event) might not be the only one revealed to be asleep on his watch, as far as aviation safety is concerned.
A remarkable CAA response to Massey University School of Aviation’s proposal for a national CFZ network has caused consternation in Palmerston North. It appears to quash any prospect of progress.
GAA has asked CAA Director Graeme Harris to provide the full text of CAA’s response to Massey, and he has told us that this will be done (but under the limitations of the Official Information Act).
However, we already know the headlines. Examine them carefully, and notice:
Nowhere in the little we know of the CAA response is there any mention of air safety.
CAA Manager Mike Haines told Massey (while giving them just seven days to respond):
♦ CFZs are not enabled under CAR Part 71 and there are no associated pilot requirements under CAR Part 91. For a rule change to progress, a CAA policy decision is needed and Ministry of Transport approval for the project and associated funding. Rules are developed by CAA under contract to the Ministry of Transport.
To which GAA says: So what? If CFZs are not enabled under CAR Part 71, why are they already in existence? Will the CAA now disestablish them? This is nothing more than lazy bureaucratic obfuspeak. Why not, instead, refine the idea, make a CAA policy decision in favour, talk to Brownlee, allocate the funds and get on with it?
The Manawatu CFZ was established by the CAA. Can you remember why? If not, consult the families of the dead. Or read the last paragraph of the press release about your authority’s own accident report into the crash.
♦ CFZs are a New Zealand-specific type of airspace, which means that overseas pilots operating here would not be familiar with them and that NZ pilots used to using them would not have these when operating overseas.
To which, GAA says: So we should not improve safety for thousands of New Zealand-based pilots simply because we might confuse a handful of visitors who would, in any case, be required by CAA to demonstrate knowledge of New Zealand operating conditions? And since when have Kiwi pilots been deemed incapable of adapting to different conditions offshore? This feeble comment displays an arrogance that is not matched by wisdom, and shows scant respect for New Zealand pilots.
♦ Establishment of multiple CFZs requires additional aviation radio frequency allocation, which lowers available aviation radio spectrum.
To which, GAA says: Nonsense. There is plenty of available spectrum for this, and there’ll be three times more if the CAA follows Eurocontrol’s new requirements for an 8.33 MHz radio system instead of the existing 25 MHz (aided and abetted by ICAO, whose edicts are invariably over-imposed by the NZ CAA at our expense). When that happens, guess who’ll be paying for your new radio? We have also been told that Airways has some innovative radio frequency solutions that could be used for CFZs, right now.
♦ The large number of frequencies raises human factors issues if pilots continually need to change frequencies.
To which, GAA says: That’s simply daft. They won’t. A CFZ in parts of Canterbury, for example, would cut the frequency changes from four to one. And, if CAA claims a large number of frequencies are involved, we have to ask CAA: How many frequencies might there be? And how could pilots become confused?
♦ The volume of CFZs and associated frequencies would be difficult to clearly put on visual navigation charts and may increase clutter.
To which, GAA says: The amendments can be created by a well-briefed graphic designer in less than two days. They are simple to impose on an EFB map, and pose no problem to any traditional printer. If you want to see what real clutter looks like, Mike, take a look at the South-East England VNC. Our NZ charts are jam-packed with empty space. And can you show us where, on a VNC, the boundaries of a FISCOM service are marked?
♦ A CFZ has no single monitoring agency and thus no alerting or emergency response.
To which, GAA says: Why do we need a single monitoring agency? Perhaps it’s to charge aviators for another dubious and unreliable service. This sounds like control freakery, written by someone who also doesn’t know about (or chooses to ignore) the emergency radio frequency and the other reporting options available to pilots. They do not want to talk to an overworked monitor, somewhere or other. They want to talk to each other. Like, Mike, this minute.
FISCOM is under-staffed (and probably under-funded). The system does not work reliably below 4000 feet (as CAA admits), which is where the danger usually lies. In some parts of our country, it does not – and cannot – exist. FISCOM introduces an unnecessary third party to the matter at hand: which is to ensure that pilot-talks-to-pilot on one local frequency in order to fulfil a primary responsibility: to seek, to locate and to avoid each other. FISCOM takes no responsibility for separation. For low-level General Aviation, the system is as useful as a cow with a box of matches. That is why practically no one uses it.
All this spurious nonsense from the CAA tends to confirm the widely-held view that some people in the authority are less interested in General Aviation safety than in balancing the books and trying to avoid the hard yards.
At Massey, they held an internal meeting to discuss the CAA message and it was agreed to first seek a longer time frame to respond, state that “we have big concerns with the document and lastly to respond to each of the issues they have raised as reasons why CFZs are not the best solution and FISCOM is.”
To quote Massey: “The real challenge is if CAA puts a document out for public submission that doesn’t really talk much about SAFETY, then people are unlikely to respond and the CFZs will die. We will be pushing hard to have people comment and tell it like it is out here in the real world of busy uncontrolled airspace. The wider this is spread, the better.
“In our opinion, FISCOM was not designed or intended for the aircraft-to-aircraft information which CFZ allows. We want a simple system that pilots can use to enhance their situational awareness about other traffic – after all, ‘Listening out’ is a vital part of ‘Lookout’.”
Gerry Brownlee was quick off the blocks to publicly and loudly condemn that sleepy Air New Zealand pilot. The UK’s Sun newspaper reported Brownlee as saying it “doesn’t look good” for the airline.
He said: “You’ve got big reputational issues here.” Mr Brownlee went on to advise the airline to “satisfy the public that you’re making sure your pilots are not asleep on the job”.
A Minister of Transport in full command of his portfolio would know that Air New Zealand (and most other airlines flying two pilots, long-haul) have for many years had procedures in place for “cockpit napping”. This has been agreed to by CAA and involves one pilot having half an hour’s sleep in the seat, while the other pilot minds the shop.
More alarmingly, Mr Brownlee also appears to be comatose when it comes to dealing with the more present and dangerous situations in which general aviation pilots in this country are placed – almost every time they fly cross-country.
Feel free to email the Minister at g [dot] brownlee [at] ministers [dot] govt [dot] nz, or Mike Haines at Mike [dot] Haines [at] caa [dot] govt [dot] nz to tell them what you think.
By the look of it, they both need a deafeningly loud wake-up call.
March 6 update from Mike Haines at the CAA
I wish to advise that the document being referred to in your email is still in draft form. The document requires feedback within the CAA, Massey and AOPA before it is finalised. Rather than sending you a draft document which is most likely to be revised, we prefer to send you the final discussion document as soon as it is ready. We anticipate that the document will be finalised in the next few weeks. You will be advised then of the submission process and closing date.