Would the last PPL holder out of here please turn off the clubhouse lights?

30 September 2013 / by Brian Mackie / Adventure, Consultation, Costs, Employment, Governance, Medical, Opinion, Privacy, Safety
Icarus, created by the mythical inventor of a wooden cow, which also never flew

Icarus, said to have been created by the inventor of a wooden cow. Both, like many in our CAA, had little aviation experience

Without wishing to tempt fate, this is a semi-serious request. When it comes to GA, fate needs no tempting because the GAA survey of aviators has already revealed alarming statistics that include a major switch by PPLs to either the RPL or to microlights, and provides evidence of serious damage to general aviation. Many PPL holders say they have given up altogether because they can no longer afford to fly.

The vice-president of a leading New Zealand aviation organisation has sold his aircraft and now occasionally hires an aeroplane with an instructor aboard, because to do otherwise no longer makes financial sense.

GAA created its first survey to obtain information from Civil Aviation Authority clients about their experience of the CAA’s consultation process, and to discover how the 2012 regulatory changes – and the increases in CAA fees and charges – have affected their flying.

The detailed results will be sent to the Regulations Review Committee, to help answer what the Ministry of Transport brought in its defence to the committee’s table. The MoT had nine months to prepare its response to submitters, and delivered it at 0830 hours on September 19, a few minutes before the committee convened. This indicated that the Ministry is either incompetent or it regards the submitters and the committee with contempt. Or both.

The committee responded by offering objectors another two weeks to reply to the Ministry.

Right now, GAA supporters have little time to examine or criticise the MoT’s behaviour (but eventually, you will, along with seeing the results of the GAA survey).

The majority of users choose email as their preferred option

The majority of users choose email as their preferred option for advice of a consultation process

We created a simple internet-based opinion poll that is evidently beyond the capabilities of either the Ministry of Transport or the CAA – which professes to have our interests at its expensive heart but finds all sorts of excuses for not contacting clients by email (claiming a distrust of the internet and spuriously fretting about privacy concerns). It has no trouble sending ADs and copies of Vector by post, but cannot advise its funding base about consultation processes, even by snail mail, preferring hard-to-spot methods including tiny adverts in newspapers read by a handful of the general public.

The result of the RRC hearing is eagerly awaited by GAA, AOPA and NZ ALPA. Whatever the outcome, this case has exposed serious weaknesses in the consultation process, the rules of which seem to have been laid down long before the dawn of the internet – and the consequences of which leave stakeholders ignorant, bewildered, fearful, disillusioned or rebellious.

When it comes to maintaining accurate records that might be used to communicate effectively with clients, according to the CAA’s current advice, bear this in mind:

“Address for Service

As a pilot, engineer, air traffic controller, or a person operating an aviation organisation, you will hold an ‘aviation document’ – your licence or certificate. This is a reminder of an important obligation for all New Zealand aviation document holders.

Section 8 (2) of the Civil Aviation Act 1990 requires every applicant for a New Zealand aviation document to supply an “address for service” in New Zealand including, where applicable, telephone and facsimile numbers.

The Act also requires aviation document holders to promptly notify the Director of any changes to the address for service, telephone number or facsimile number.”

Notice how, decades after the Internet was invented, the CAA still hasn’t got around to including “email address”? And that it hasn’t yet realised that nowadays, no self-respecting, cool and connected person admits to owning a fax machine, let alone using one? And if it demands this information, surely that can only be to enable the CAA to communicate with, and keep track of, the subjects of Section 8 (2) of the Civil Aviation Act 1990? Which can only mean: Us.

Very few CAA customers believe that they have been properly consulted

Very few CAA customers believe that they have been properly consulted

We know from the initial survey results that 86 percent of respondents do not believe that consultation procedures are satisfactory. We know that 76 percent of them would prefer to be notified by email and 20 percent want a letter from the CAA. We also know that more than 50 percent have never made any submission to a CAA consultation process, and that almost 19 percent of them have declined to submit because they fear CAA repercussions. A formerly docile and divided constituency now questions the CAA’s commitments to openness, transparency and the Utopian notion of a “Just Culture”, in which we are expected to dob in any alleged offender and consign them to that warm, sensitive and positive-thinking bunch of faceless bureaucrats at the CAA.

The majority believe that the time to respond is too short

The majority believe that the time to respond is too short

We now know that 35 percent of respondents have declined to renew their medicals because of the Medical Application fee.

More than 17 percent say they have given up flying altogether, while 18 percent have moved to microlights and more than 13 percent have opted for the RPL, where the medical requirements relate more closely to the real world of flying and self-certification before the responsible pilot clambers into the cockpit.

The damage done is already evident

The damage done is already evident

We know that 34 percent of respondents say that their aero club has suffered from CAA charges, and almost 29 percent of respondents who answered a specific question said their businesses have been damaged.

Ponder now the fate of the NZ PPL holder or budding student, under current CAA strictures. It is clear that what the CAA is doing – perfectly legally under Minister Gerry Brownlee’s regulatory approval – is raising the cost of obtaining and holding a New Zealand PPL beyond the pockets of many. It is also breaking the wallets of many private pilots who cannot maintain their PPL, in many cases because of the $313 medical application fee.

Compare this blatant revenue-gathering policy with that of the UK CAA, which is about to review its PPL curriculum. As you read about it, recall how the New Zealand CAA suggested that GPS should not form part of flight training studies and ask why New Zealand’s CAA cannot even provide consistency in PPL curricula with Australia, when its offspring and delegated authority, ASL, controls the examinations for both countries.

In conjunction with key representatives from the GA pilot training community, the UK CAA has started work on a new training syllabus for private pilots. The project aims to help ensure future pilots are better prepared for flying safely in the UK.

The current syllabus for the private pilot licence (PPL) for aeroplanes is used by flying schools to train pilots and help them to pass both ground and flight test exams. However, both the CAA and GA community have highlighted areas that could be improved (such as more information on the use of transponders, GPS, and the airspace system) and also information that, although in the syllabus, most PPLs will never need to know (e.g. purely theoretical or academic information without practical application).

The CAA will liaise with colleagues in the European Aviation Safety Agency (EASA) and other EU National Aviation Authorities to develop the new syllabus, which will continue to fully meet the requirements of the International Civil Aviation Organisation (ICAO).

Mike Barnard, the CAA’s GA programme manager, said: “This work is part of a larger project to take a fresh look at the oversight of GA and to seek ways in which we can both enhance safety and reduce regulatory burden. We want to empower GA to take on much more of the responsibility for the sector’s safety and for the CAA to get involved only where there is a need for oversight that no other organisation can undertake.”

Jeremy Pratt of Airplan Flight Equipment, one of the GA representatives helping to draw together the new syllabus, said: “This is a great opportunity to get a training syllabus that removes some of the items that we all know a PPL holder will never need to know or use, and replaces these with really important safety knowledge that a pilot needs to have but currently may not be well covered in the current syllabus.”

The UK CAA hopes to be able to provide the new syllabus to EASA by early 2014.

As you digest this, be aware that Airways is proposing enormous increases in its “maintenance” charges for aerodromes operating IFR procedures. One of them faces an annual charge of $17,200 – a truly astonishing rise of $13,400. This scale of increases will impact every organisation that trains pilots to IFR standard. It will affect your pocket as a licence holder and it will add yet another needless expense to anyone training to fly.

What we can see clearly here is an assault on general aviation by those whom we might have assumed to be employed to protect and promote its grass roots. They are politicians, Airways, the CAA and powerful interest groups, supported by bureaucrats who – when confronted – say that they are merely obeying orders.

This continuous damage is backed by a National-led government that says it champions personal freedom, the rights of individuals, the progress of private enterprise and the development of our economy.

The AIA, which claims to represent the industry and has recently rebranded itself as “Aviation New Zealand” says it seeks to create an industry worth $16 billion a year by 2015.

It is hard to see how that can be achieved – particularly if you are a student sitting alongside a poorly paid instructor in a Tomahawk on a rainy day and wondering how you could ever get an interview, let alone an ATPL, for a job at Air New Zealand.

It is even harder to see how the increasing raft of Airways and CAA charges – along with a growing burden of proposed new compliance measures – can dissuade anyone with an ambition to fly from choosing something easier to do with their life.

♦ The survey results mentioned here are preliminary and are based on the responses from 425 people. The final results will be analysed and submitted to the RRC, and they will be published in a future GAA article. We appreciate the assistance of Flying NZ and many aero clubs in promulgating this survey, and we thank everyone who took part in it.