The CAA funding review, Stage 1 – or was it Faze 1?

25 November 2014 / by Brian Mackie / Consultation, Costs, Governance, Medical, Opinion, Overview, Safety
The CAA summary: for a PDF copy, click on the link at the end of the story

The CAA summary: for a PDF copy, click on the link at the end of the story

When two opposing mindsets approach collision, they may mirror the laws of magnetism; the closer they get, the more strongly they’ll repel one another.

We are talking about – on the one hand – pen-pushing and bean-counting bureaucrats who do not fly but instead toil and fret beneath leaden Wellington skies and – on the other – free-thinking aviators who rejoice in loosing the surly bonds of Earth and perhaps touching the hand of God, when God (Who is free to all applicants) and MetFlight (which is not) indicate suitable conditions.

General aviators and the CAA are poles apart.

In this particular case, we are talking about Stage 1 of the CAA’s Funding Review process. It was designed to derive customer opinion on how the CAA should be funded. The Authority claims to have sent emails to 29,000 addresses and it promoted the feedback request on the CAA’s unfriendly website.

The CAA also funded a limited number of seminars at Nelson, Christchurch, Palmerston North, Queenstown, Auckland and Wellington. Despite GAA’s efforts to get the CAA to run seminars at the same venues that it uses for AvKiwi seminars, it declined on the grounds that this would be too expensive. GAA said that GA pilots in the outlying provinces should have been given the opportunity to participate in these seminars without having to travel long distances or pay for overnight accommodation.

What were the results?

From the (alleged) tens of thousands of people who were told about the consultation:

  • about 170 attended the 12 seminars (an average attendance of 14)
  • 133 submissions were sent to the authority and
  • a handful of people completed the consultation questionnaire. We can’t quite work out the precise number, but it appears to be less than 100.

This exercise in consultation was a serious failure. When the lowly, totally unfunded GAA mounted a campaign against Air New Zealand, which sought to import foreign aircrew, almost 240 supporters signed the submission (and we won). The number of GAA co-submitters opposing the 2012 CAA increases – 620 – was almost five times that of those submitting to Stage 1 of this funding consultation.

So why did this expensive first phase of consultation, in statistical terms, crash and burn?

We can see the fault lines in what was intended to be an inclusive process but ended up serving no one’s interests except those who initiated it: the CAA, guided by the Treasury.

First, the Stage 1 consultation document proved that what the CAA needs is not more policy analysts. It needs a competent sub-editor. The document was far too long, it contained needless repetitition and the author(s) sometimes wandered off-topic, introducing issues that seemed to be (and remain) irrelevant to the main concern: who should pay to maintain the CAA?

The survey document failed at the first hurdle of any trainee journalist’s first exam. Will it be interesting? No, it was not. It lacked purpose. It lacked a story and it was not objective. It lacked a good headline and a short summary. It made assumptions and it was lazily constructed. It contained (and wasted) too many words. It was very boring.

Whoever wrote that document also managed to reverse the concept of a multi-choice examination by offering multiple questions but only a single means of reply. Sometimes three questions were asked, with only a Yes/Substantially/Partially/No/ tick-box covering all three. It was impossible to answer.

The result was a dog’s breakfast for any prospective respondent and for the poor, anonymous person at CAA tasked with unscrambling the resulting mess.

Little wonder, then, that so many felt very ticked off indeed and, in despair, consigned the thing to their waste paper bin.

A second reason was the CAA’s insistence that its national seminar programme to explain the process was entirely satisfactory – and its subsequent refusal to revisit what was without doubt a serious problem, despite widespread warnings. The audiences voted with their feet, parked them in front of the telly and stayed well away.

The CAA seems incapable of accepting that its powerful position as a Wellington-centric organisation must be balanced by respect for, and investment in meeting, the geographically diverse challenges faced by its customers. In its somewhat obtuse response to complaints about this seminar issue – and that of the future cost of audits to remotely based clients – the authority said that it had heard. But it is clear to all that it will not listen.

The third and perhaps most important challenge for CAA in dealing with this failure is old and simple.

People in GA do not trust the CAA and many would prefer to have as little to do with it as possible.

The authority has alienated itself from its customer base by presenting an authoritarian, rather than an administrative, image. It should not be surprised by poor feedback, either on funding for the CAA or the reporting of incidents. It may prefer to run meetings at Asteron House with its approved aviation-related organisations. But it is disconnected from the core constituency.

The CAA cannot rest content by merely claiming that it made every effort to consult. It sent 29,000 messages, around 28,750 of which went unanswered. This statistic alone shows that the CAA needs to work further on reducing waste and improving efficiency.

In the CAA feedback report, the authority claims it has done much to improve efficiency and reduce costs. Some months ago, GAA asked for the precise detail about cost-efficiency progress at the CAA, but was told this would take more than 40 hours to research and the CAA would need to charge GAA more than $3000 for them to find out how well they were doing, so that we could tell you, their customer, just how much smarter they have become.

Is it any wonder that many aviators in New Zealand feel powerless to speak against an opaque authority that they believe has been unfairly ripping them off since 2012 and has done serious damage to flight trainers, lower-level business operators and their own flying pals, some of whom threw in the towel when they saw how much it would cost to apply for a medical examination?

The CAA cannot expect to hear from people who do not trust it. Crucially, these clients don’t believe the authority trusts them either, and the Director has so far failed to promote an inclusive and honest spirit of partnership between his authority and GA, or what is known as the Just Culture where regulator and aviator unite to promote safety – without the threat of blame.

No one in general aviation can help the CAA to improve itself, when they see behaviour patterns based on blind regulation which, for example, requires one pilot to dob in a colleague who might be prosecuted and lose either his hobby or the roof over his family’s head. All of this is the responsibility of a Director backed by a bewildering museum of rules and regulation, yet apparently lacking the courage to pursue a collaborative approach.

The Stage 1 summary’s author also seems to reject any role for the CAA in promoting a vibrant aviation sector in New Zealand, when he or she states that the CAA “is a safety regulator not an economic regulator”.

This is sophistry. Everyone in the CAA contributes to the gross domestic product, along with doctors, nurses, care workers, panelbeaters, funeral directors and you and I. The author knows full well what damage the authority’s misguided actions, which were exclusively based on funding the CAA in line with Treasury’s user-pays dictat, have done to economic activity in New Zealand’s general aviation sector since 2012.

What is even more troubling is that the author seems to be out of touch with colleagues elsewhere, who know better how the world actually turns.

For example, the UK CAA has enthusiastically adopted its role as a key player in developing an expanding and innovative aviation industry. This welcome epiphany is based primarily on the fact that the UK CAA realised that it had to cease damaging its own customer base through relentless, heavy-handed regulation and spiralling costs of compliance.

Regulation (rightly based on safety concerns) and innovation for the public good (which involves the acceptance of risk) are no longer officially considered to be mutually exclusive in the United Kingdom.

It will also come as no surprise that the New Zealand CAA Board is quietly positioning itself to reject the most popular feedback suggestion for CAA funding, which is based on the purest application of user-pays in aviation: A fuel levy.

♦ We’ll try to analyse this curious response in the next part of the story. There is also, potentially, some good news.

Here’s a shortcut to the CAA’s 2014_funding_feedback

(It bypasses the CAA website.)