Here's mine for those interested. It is a bit long winded and a little angry perhaps but it gets the point across I think.
Dear Mr Harris,
I imagine over the last short while you may have been inundated with comments from operators and pilots from throughout New Zealand. My comments are not likely to be the last either and I would appreciate a response regarding what i have to say below.
I have been involved in aviation for the last 20 years and hold a commercial license, B category instructors rating, and microlight instructor / testing officer / test pilot approval. I am Chief Pilot for Croydon Aircraft Company at Mandeville in the South Island and along with my commercial flight duties at CAC I freelance instruct, do biennial flight reviews and type ratings, airshow display flying, and test pilot work. A lot of this work I do for very little remuneration as i see it as a way to give back to aviation that has given so much to me and it is also getting more and more difficult to find suitably qualified people any longer who can fly a lot of specialised aircraft (such as high performance, aerobatic, taildragger, amateur built, warbird and vintage).
I have very, very strong objections to the direction the CAA and the government have taken to gain revenue (or recoup losses).
Just as a starting point I bring the fee associated with pilot medicals of $313. Currently I do a medical annually for my commercial pilots licence, this costs me approx $200 from the medical examiner, 1 days lost wages due to having to travel from Gore (where I live) to the nearest medical examiner (due to the lack of the aforementioned in the bottom of the South Island), and fuel for like. This works out to be approx $350 annually.
At the point I reach my 40th birthday, very soon, I have the great honor of visiting my medical examiner every 6 months for a medical (requirement for single pilot commercial ops) and as of this time my medical costs are likely to escalate to in excess of $1326 annually, incidentally this excludes any specialist fees such as ECG, hearing test or eye test which range in cost from $70-$200 and occur fairly regularly also.
Those pilot operating in two pilot crews, such as airline, are only subjected to annual medicals so this type of action strikes at the lowest earning sector of aviation and particularly at an area that is struggling to survive in the current economic climate, tourist aviation.
I have recently been in contact with several associates overseas (USA and Australia) where the medical fees, more to the point processing fees, range from $0 (USA) to $75 (Australia). The cost for the medicals themselves range from approx $100-through to $200 in their local currency. I can easily back these figures up if you would like. I struggle to see where CAA and the government have plucked such a random and over the top figure of $313 from for an essentially administrative process.
I do not know, but I assume that the medical examiners in question are charge some form of fee by CAA to maintain their status and I imagine the cost for the service charge by the examiners will also rise given the other increases in cost by the department.
If the answer to the fee by the department is that ever medical is reviewed by a select board of CAA medical staff in Wellington then why do we even have medical examiners if they are unable to make suitable decisions themselves.
This fee needs serious reviewing for, as I mentioned above, an administrative process.
The department hourly rate rise also smacks of extortion. Another example, the company I work for is a very small tourist operator. We fly a fleet of vintage aircraft for passenger joy flights around Southland on a Part 135 Air Operator Certificate, generally speaking we do approx 150-200 hrs per year and the cost for our surveillance, auditing and renewal of the certificate by the CAA is approx $5000-$8000. In the last two years tourist numbers have dropped to record lows and we have been lucky to average between 80-100hrs. Just by the increase in fees alone we are looking at an annual cost to maintain our certificate of between $10,000 and $16,000.
This is a totally unrecoverable cost and very likely will spell the end of the business as it stands, we are not alone in this and it is likely that several tourist operators will fold around NZ. these extra costs are just unable to be passed on to the end user (tourist) as we will essentially be pricing ourselves out of the market in an already badly hit and failing sector.
Again the fee increase is considerable out of square with other authorities worldwide. Australia for example have a tiered approach of $100, $130, $160, $190 with administrative and data entry at $100 and specialty services charged at $190. you may want to have a look at their website
www.casa.gov.au/scripts/nc.dll?WCMS:STANDARD::pc=PC_91512 . Even at these figures there was public outcry so you can imagine how annoyed we are at present.
Other fees that appear to be gouging.
Annual fee for maintenance of Register - $36.80 to $99
Change of registration - $87.91 to $394
Reservation or Allocation of a particular Registration Mark - $30.67 to $197
Foreign owner deregistration fee - $0 to $440
These figures are just disgusting. all for essentially administrative process that literally would take minutes of work on an already established database.
I can understand the CAA's need to be accountable to the government for its losses or earnings but the way this has been tackled is very questionable. The whole process has been aimed, whether intentionally or not, at the wrong sector of aviation and will be very damaging to the bottom sector which is where the skill base and personnel base begins for the upper sectors such as the airlines. By attacking the bottom end you are essentially cutting of NZ aviation at the knees.
There was a comment by Mr Brownlee and yourself in the media regarding users moving closer to paying the true cost of the actual services they use, you can't tell me that the cost to process a medical is $313. If that is the case then your processes need serious attention. There have also been comments made of this improving safety, utter rubbish.
I see the international passenger levy has been raised by $0.41 and the domestic actually dropped. There are approx 10 million passenger transits in this country, either internally or internationally, why not raise the international levy by another $0.50 and the domestic by the same. On the cost of a ticket it is nothing and it would net the CAA somewhere near $8 million dollars, instead of gouging everyone else with fees that do not reflect either the service provided or the work involved in the process.
It has been a long held belief that aviation, particularly from a private owner or pilots perspective, is a rich persons sport. This is most definitely not the case and I (and thousands of others) are highly offended that it is seen as such.
My income is approx $**,000 per annum net which is more than most instructors earn, more than most tourist pilots earn and not far below what most 3rd level airline pilots earn (Mount Cook or Air Nelson first officers), we just cannot afford to be attacked like this.
The general opinion held of the CAA within NZ general aviation is perhaps not the best and unfortunately by actions such as this it certainly wont be seen in any better light
At this time I have been in contact with Mr Brownlee, Mr English (whom I intend to having a meeting with towards the end of the month), I will also be contacting the Ombudsman and am working with several aviation groups to further this matter.
I do hope this does not fall on deaf ears as it is a very, very serious matter and I look forward to, and expect your reply in due course.
Yours sincerely,