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Post by jasenz on Oct 23, 2012 16:56:05 GMT 12
Anyone know of any Medical Examiners countrywide with a spare appointment before the start of November? Have tried numerous in the South Island but so far non available. Willing to travel nationwide if needs be!
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Post by Bruce on Oct 23, 2012 20:23:54 GMT 12
Anyone know of any Medical Examiners countrywide with a spare appointment before the start of November? Have tried numerous in the South Island but so far non available. Willing to travel nationwide if needs be! Waikato is all booked out - I had to do a renewal early Nov anyway, but I was fortunate there was a cancellation at one of the examiners - I grabbed that one real quick!
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Post by DragonflyDH90 on Nov 4, 2012 19:06:17 GMT 12
A submission is being put forward to the Office of the Auditor General currently regarding this matter with substantial numbers as co-signees. Below is the submission, please feel free to contact Des Lines on the email shown with your name, address. I have left out the appendices and the table of fees as it was a little to big. Also the NZ Airline Pilots Association is working on a petition to the Regulations Review Committee where they have had considerable success in the past. There is considerable momentum on this currently.
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Post by DragonflyDH90 on Nov 4, 2012 19:07:03 GMT 12
Fellow aviators,
The introduction by the CAA of the exorbitant new fees, levies and charges has riled me into action to protest the unfairness and the damaging effect it is going to have on GA in New Zealand.
Having seen the replies some people have had back from Peter Lechner on behalf of the Director, they have just contained rhetoric, obviously pre- prepared by the CAA "spin doctors" in anticipation of a backlash, and are nothing more than a fob off. Amongst other things he also attempts to justify the cost of the newly imposed "medical application fee" because it costs $2.2M a year to operate just the medical unit !! This has to be a prime example of mind boggling, bureaucratic inefficiency, given that the majority of medical certifications are done by our AME's.
There is another avenue of protest that is available to us, and that is through the Regulations Review Committee which is set up within the Office of the Clerk of the House of Representatives.
The Office of the Controller and Auditor General oversees the operation and charges of State entities to ensure that they are delivering value for money to the public in a cost efficient manner. If the public feel they have a legitimate complaint against a State entity, they can then file this complaint through the Regulations Review Committee.
There is a set format for making a complaint and I have attached a pdf relating to the process, and a further pdf relating to the functions of the Office of the Controller and Auditor General. The greater number of either individual or collective complaints filed with the Regulations Review Committee, the greater the chance of it being taken seriously.
It may well be that if you agree, and are comfortable with the sentiments expressed in my own letter of complaint, you would prefer to be listed as a co-complainant. If so, I will attach your name and address in an Appendix B to the document.
If you feel as incensed as I do regarding the actions of the CAA I would urge you to help create a groundswell of opposition by passing this information on to other fellow aviators that you have in your email contact list.
A previous generation reached a point where they had to make a stand against the tyranny of Nazi Germany. In my view, we have a similar fight on our hands against the CAA.
Kind regards,
Des airfabrico@xtra.co.nz
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Post by DragonflyDH90 on Nov 4, 2012 19:08:35 GMT 12
30 October 2012
COMPLAINT ABOUT NEW CHARGES, FEES, LEVIES, SET BY THE CAA AND EFFECTIVE 01 NOVEMBER 2012
CIVIL AVIATION ACT 1990 – REPRINT AS AT 1 JULY 2011
To the Regulations Review Committee
Introduction
This complaint is from:
Desmond James Lines 1199 Tram Road Swannanoa RD6 Rangiora 7476 03 312 6732 Email airfabrico@xtra.co.nz
Executive summary
I am making a complaint about the regulations under the grounds of Standing Order 315(2).
My complaint is in three parts, as set out below:
1. The introduction of an exorbitant “Medical Application Fee” for what is mostly, on the part of the CAA, a purely administrative function. 2. A 109% increase to the hourly rate charged by the CAA from $135.70/hr in 2012 to $284/hr by 2014/15 3. A 309% increase in administrative “fees” charged for the issuance of various types of aviation licences, even though the written and oral exams, flight tests, etc are carried out by a third party company (Aviation Services Limited).
Arguments under specific grounds
1. Medical Application Fee. The medical Unit of CAA appoints independent Doctors as ME’s (Medical Examiners) and AME’S (Aviation Medical Examiners). With reference to the latter, an AME is authorised and appointed by the CAA to carry out aviation physical examinations. If the candidate is able to meet the required standard, the AME is able to write out a new Medical Certificate for the licence type, period of validity and any waivers that may be required (such as wearing glasses).
If the CAA does not have confidence in the AME’s that they themselves appoint, then any audit costs should be borne by the CAA. A case could be made for completely eliminating the CAA from all medical decisions (other than setting the standards required by ICAO) and the responsibility should rest with the doctors who issue the certificates.
To be required to pay this $313 “application fee” on top of the cost of the medical examination with an AME, has pushed the level of costs beyond the threshold of affordability for a very large number of pilots. As an example, for a professional pilot of over 40 years of age, where medicals are required to be renewed on a six monthly basis, the yearly medical costs will increase from approximately $450 (two AME consultations of around $250 each) plus two “filing fees” of $313, making a total of $1076 pa.
New Zealand is the only country out of the UK, USA, Canada, and Australia, which requires a six monthly renewal of a Class 1 Medical Certificate for professional pilots aged over 40 years. The other countries have an annual renewal requirement. Even with a six monthly renewal period, a pilot is really only certified as being “healthy” on the day of the medical examination. At all times outside of that, we are required to “self certify” our medical fitness on a daily basis and in a responsible manner. There is no reason why that couldn’t be extended to a one-year renewal period in line with the other countries. On that basis, there would probably be little statistical difference in medical problems, but there would be a loss by the CAA of $313 per individual in “filing fees” under this newly introduced levy. Cynically speaking, there would be nothing to stop the CAA doubling the “filing fee” in order to generate more revenue, as more and more pilots decide to relinquish their Class 2 Medical Certificate and opt out of the CAA medical certification system. After speaking to a number of General Aviation private pilots, the overwhelming view is that they do not intend to renew their Class 2 Medical Certificate, but to continue flying on a RPL licence (Recreational Pilot Licence) with an LTSA Medical Certificate which does not require the CAA involvement and subsequent “fees”.
It is surely nothing short of a blatant rort (and I use the word in its true context) to be charging an administrative fee, which is far in excess of the fee charged by the medical examiner for the actual professional examination.
2. Increase in the hourly rate charged by the CAA. The CAA have increased the hourly “charge-out” rate from the current $135.70/hr in increments to a rate of $284/hr effective in the 2014/15 year. This amounts to an increase of 109% over current rates and which far exceeds any projected increases in the CPI over that period.
A major part of the work that the CAA does for its “client” base is of a purely administrative nature and does not require any high level of technical expertise. To be charging an “across the board” fee of $284/hr for data base entry, and general office work is not only outrageous, but will discourage new participants from entering the aviation industry or cause existing operators to leave. In contrast, CASA, the Australian regulatory authority, recognises and differentiates between the charge-out rate for “administrative” functions and that for work which requires a degree of technical expertise. A comparison of CASA charges is set out in Appendix A attached to this submission. Below, are two examples of administrative functions that should require very little time to process, but which incur a substantial “fee”.
1. From time to time I am asked to carry out a CAA regulatory requirement and act as a test pilot on home built aircraft, which are in the Experimental Category. Each time this occurs, I have to re-submit an application for a test pilot approval with a resume of my experience on similar types of aircraft before an approval is granted, despite having been through the process numerous times. The CAA charge out rate is always for an hour’s work ($135.95) even though the time spent on actioning this should not have taken longer than 15 minutes.
2. I have also been asked to ferry an aircraft on a short, ten minute flight to an airfield for its routine annual inspection. The aircraft was a few weeks outside a period of grace allowed for renewing this annual inspection, and to do this legally, it was necessary to apply for a “Special Flight Permit”.
After receiving a Special Flight Permit, the aircraft must then be certified as being safe to fly by a Licensed Aircraft Maintenance Engineer. There is no CAA involvement in this airworthiness certification process and the responsibility in determining the airworthiness of the aircraft, rests solely with the engineer and not the CAA. The cost of what was once again a principally administrative task, involving perhaps a quick check of the aircraft records on file from the previous year, should have been able to be accomplished in minimal time. However, the invoice for this “Special Flight Permit” amounted to $169.95 or the equivalent of one and a quarter man-hours at the present charge-out rate. This would increase to $287.50 under the new hourly rate.
The General Aviation community has continually suffered by the inefficiency of the CAA and which it would seem, has an undisclosed policy of a minimum of a one hour charge-out by its administrators, for every job regardless of whether the particular task took only a matter of minutes to accomplish.
3. Administrative “Fees” charged for the issuance of licences and sitting exams. The CAA charges a fee of $56.22 for the administration involved in the issuance of various classes of aviation related licences. This could be considered to be fair and reasonable, however, as of 1 November 2012, this fee is going to increase by 309% to $230, in the case of Flight Crew licences, and to either a greater of lesser degree for Air Traffic Controller or Aircraft Maintenance Engineer licences.
An increase of this magnitude is without precedent, is not related to the CPI, and is far in excess of what other aviation regulatory authorities such as CASA charge. The fee for the issuance of a PPL by CASA amounts to NZ$73 and an increase to that same figure, by the CAA would have still amounted to a substantial 30% increase in the issuance fee.
In an efficient organisation, the administrative process involved in confirming that the licence issuance criteria has been complied with, should not take the equivalent of 0.75 man hours per applicant. In contrast, the USA aviation regulator, the FAA makes no charge for the issuance of an aviation licence. On the subject of the cost of sitting aviation exams, they also range from being a minimum of 27% more expensive to 254% more expensive (in NZ$ terms) than that which the Australian regulator CASA charges.
The CAA has contracted out the regulatory function of aviation exams and flight-testing to an outside company (Aviation Services Ltd). Whereas other regulatory authorities charge a standard rate per subject, (in the case of CASA, NZ$65 per subject) the rates ASL charge are substantially more expensive. The table in Appendix A has a comparison of the rates.
Recommendations
1. Medical Application Fee The medical application fee should be cancelled and an in-depth review of the role, operation and overheads of the CAA medical unit be carried out. I would suggest that the current practice of the regulator appointing independent Aviation Medical Examiners (AME’s) is an excellent one and should be expanded to use their collective expertise and knowledge. At present, the CAA Principal Medical Officer has the power to refuse an application for a medical certificate on grounds some other ICAO regulatory authorities such as the FAA, CASA etc have no such problem with. In the case of a professional licence holder, who has a medical certificate declined, this amounts to a catastrophic, life-changing event, which can only be challenged through a District Court Appeal and / or a Judicial Appeal.
There are several cases where the applicant, and his AME have furnished numerous reports from surgeons, specialists etc in support of the re-issue of a medical certificate, only to have it declined by the PMO. What I would recommend is a tribunal of our most experienced AME’s be set up, to examine precedents on a case by case basis, that have been set by other regulators such as the FAA. A recommended course of action that is evidence based, could then be conveyed to the PMO for implementation. Apart from the PMO, it should be possible to trim the CAA Medical Unit down to a predominantly clerical function, and thus substantially reduce overheads and costs to pilots, whilst still maintaining high medical standards. Further efficiency could be achieved by the implementation of an electronic medical filing system such as MedXpress, which is used by the FAA to achieve cost savings.
2. The CAA hourly charge-out rate. The hourly rate should be held at the current level pending a review of the present inequitable system of charging a rate for clerical administrative tasks that is far in excess of what other similar organisations charge. As I have stated before, it is ludicrous to suggest that a charge-out rate of $284/hr for purely clerical administrative tasks is “fair and reasonable”. The CAA is not taking into account the “ability to pay” of its client base as a driver for these hourly rate increases and the impact of the multitude of other charges that have also increased, threatens the sustainability of the entire NZ aviation business from recreational pilots through to commercial operators.
For the training organizations which endeavour to attract overseas students, this exorbitant increase in charges for audits etc, may well be the tipping point and comes on top of other external factors such as the high exchange rate and escalating fuel and maintenance costs. Many organizations do not have the ability to pass on these cost increases without also risking losing their customer base in what is already a shrinking market, due to other factors such as the recent changes to student loans etc.
This is most certainly the case for the general aviation recreational flying sector and is contributing to the expansion of the largely self-regulated sport aviation organizations. These organizations however, cannot provide the same professional level of pilot training that is provided by the regulated flight training organizations that are currently under threat by these increased CAA charges. Nor do the sport aviation organizations provide helicopter training, multi engine training, instrument flight training and other specialised ratings. The increased cost of maintaining a professional Commercial Pilot Licence, Instructor Rating, Instrument Rating etc will ultimately cause many experienced Instructors to re-consider staying in the Flight Training business when they are already on minimal salaries or hourly rates. Once that experience has left the industry, the impact and flow on effect will be significant.
I would therefore request an immediate review of the CAA by the Office of the Controller and Auditor General, to examine:
1. The efficiency of the CAA in regard to giving good value for money to its client base. 2. Ensure that the charging of fees for public sector goods and services meets not only good practice guidelines, but also are fair and reasonable and are comparable with other similar aviation regulators.
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Post by DragonflyDH90 on Nov 4, 2012 19:21:51 GMT 12
To all members of SAA NZ CAA Fees Last Thursday I attended the regular meeting of the Aviation Federation in Wellington to which we invited Graeme Harris, the Director of CAA to attend and speak to us on the subject of the significant CAA fee increases that take effect on the 1st of November and our concerns that they are unjustified and place an unfair burden on the Recreational sector of aviation. Graeme was very open and clarified the process they have used to calculate these new charges. It appears that the formula for the so called sharing of the cost to the users, “us” is a formula set by the treasury and not the CAA. All of the members of the Aviation Federation disagree strongly with this methodology and we are asking the Minster for a meeting to further this discussion. Graeme also volunteered that he recognises the new fee of $313 for an application to obtain a class II medical is unjustifiable and that he is in the process of taking action to rectify this situation. The process to have the Recreational Pilots Licence delegated to a part 149 organisation is in progress and this, when effected will offer a much lower cost for medical renewal. Concern was also discussed over various communications seen recently that indicated the recreational flying organisations had been consulted and had agreed to the new charges. I would like to make it absolutely clear that we were consulted but at no stage has the SAA agreed to any increase in charges and we had, along with AOPA, Flying NZ, Aviation Federation and AIA, written formal opposition to the proposed charges. The Minister in his replies to various letters challenging the new charge does appear to believe there was agreement; this will be rectified. I have confidence that Graeme Harris, new in the position of Director, does understand our concerns and will make changes where feasible to further the interests of Recreational flying. I suppose time will tell! Regards Bill Sisley President SPORT AIRCRAFT ASSOCIATION NZ INC. 870 Omaunu Road RD 2 Kaeo 0479 Phone: 09 405 0553 www.saa.org.nz
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Post by DragonflyDH90 on Nov 6, 2012 7:24:00 GMT 12
Anyone wishing to be listed on a submission to the Office of the Auditor General please contact Des lines, his address is in one of the above postings. He needs just a name and address.
Its not a lot of effort to go to but may make a huge impact overall, so please get involved.
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Post by dakdriver on Nov 6, 2012 17:32:16 GMT 12
Also from Des: Back in the late 1980's there was a similar revolt against the CAA fee for licence renewals. On that occasion, Brian O'Neil an Air NZ pilot in AKL led the revolt and his tireless work resulted in our present system of a permanent licence but renewed medical certificates. CAA were going to charge $280 (in 1980 $ terms which interestingly would be similar, if not more than $313 in todays money) for a yearly "licence renewal" on top of our medical renewal. This was another fight which most of our younger aviators would have no knowledge of, and led to the toppling of the Deputy Secretary of Transport at the time, Brian Lynch.
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nzpilot
Leading Aircraftman
Posts: 6
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Post by nzpilot on Nov 14, 2012 22:17:12 GMT 12
Hi all. New here, was told about this site by a mate. So we are all aware of the fees, and also what Des is doing. AIA introduced Des and myself as I am also trying to collect as many names as possible of those who oppose the new fees. Together, we have 600 names of individuals and companies. But we need more! Please feel free to email me, or PM me on here if you want and will allow us to use your name. We all need to band together on this on. So get in touch with me, and I will add your name also. (if you haven't all ready to myself or Des). Hope to hear from you soon, and thanks for the support!
Cheers
Kurt
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Post by DragonflyDH90 on Nov 15, 2012 7:33:58 GMT 12
Good job Kurt, the more the merrier.
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Post by baz62 on Nov 15, 2012 11:41:42 GMT 12
Yep Des has my details Kurt. I'll be making a donation to the fighting fund as well. Wont be much unfortunately but every little bit helps.
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Post by Peter Lewis on Nov 15, 2012 20:09:55 GMT 12
Please feel free to email me, or PM me on here Difficult to email you when your email address is hidden, but PM sent.
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nzpilot
Leading Aircraftman
Posts: 6
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Post by nzpilot on Nov 16, 2012 13:25:29 GMT 12
Thanks guys. Sorry about the email hidden.
This is my email
kurt270@hotmail.com
Please feel free to pass my email on to any pilots you know that may not be on here.
Thanks guys
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Post by Peter Lewis on Dec 18, 2012 15:37:45 GMT 12
From Des Lines:
"GAA is the General Aviation Advocacy group. We are an informal group of people who are hopeful of collecting opinions on matters of interest and concern, and addressing and/or referring those concerns appropriately. It is our intention to share collected knowledge and expertise with everyone. Even though GAA has hardly left the starting blocks, some misconceptions have already arisen about its motives and aims, particularly amongst the established organisations that represent the interests of private aviation. So, to explain: GAA is not an organisation. It's a social network. The group is a collection of people who have spontaneously risen up in opposition to CAA actions and policies. It has no constitution, no formal membership, no fees - nothing that remotely approaches the form of an organised body. What has developed in recent weeks is not a club and it is not a structured organisation. There is no cost to join, and all are welcome to take part - including the CAA. We have named the forum GAA - the General Aviation Advocacy group of NZ - to try to avoid any misunderstanding that this is a formal club or action/protest movement acting in competition with existing organisations. So GAA is merely a forum for the exchange of views and verifiable experiences - an online clearing house for information that ideally could best be used as support by all the established aviation organisations in this country who have to deal with the CAA. Currently, no such universal forum exists. A constantly recurring subject of conversation amongst aviators is the lack of a unified voice, and the fact that the CAA is able to divide and rule a wide range of organisations, some of them single-interest and some of them tied to the CAA - for example, Part 149 organisations. Conversation tends to cease when the question arises: How are we to get a united voice? Well, given the varying interests of the various factions, a formal organisation that keeps in close and constant touch with its users seems highly unlikely. Instead, and again I stress the word "spontaneously", an informal alliance of like-minded people has sprung up like a virus, through the internet. It has gained more participants in a matter of weeks than the entire membership of RAANZ, an association that has existed for decades.
It would be of great assistance to us, if you could continue to pass on the information to fellow aviators regarding the emergence of our advocacy group. By creating an extensive database of names, we can very quickly pass on important information and legislative changes that might otherwise have been slipped through "under the radar". Any new people wishing to be included, can email me at airfabrico@xtra.co.nz"
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nzpilot
Leading Aircraftman
Posts: 6
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Post by nzpilot on Dec 26, 2012 21:31:57 GMT 12
Going to give this a bit of a bump guys. We are still needing support on this, if you haven't been in touch with Des or myself, please give me a PM or a email on kurt270@hotmail.com Cheers all
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Post by Peter Lewis on Feb 7, 2013 17:29:44 GMT 12
Class 2 medical completed today.
Totting up the bill: CAA application fee . . . $313.00 Full Optician check . . . 90.00 Blood test (cholestrol) . . . 24.00 ECG . . . 63.00 Doctors fee . . . 165.00 Assessment fee . . . 110.00
Total: $765.00
No wonder people are not doing this any more.
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Post by flyjoe180 on Feb 8, 2013 9:21:07 GMT 12
That's a comprehensive medical Peter. I would not want to be in a position where I have to pay for it myself now days, it just would not be possible.
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Post by Peter Lewis on Feb 12, 2013 7:31:20 GMT 12
Talking of fee rises, I see in this mornings Herald that Ardmore Airport Ltd. are proposing to increase its charges (being facility fees, night flying fees and parking fees) by 10% from April 2013 to March 2014 and then for each successive 12 month period commencing on 01 April 2014 and ending on 31st March 2018 by 5% per annum.
Landing fees are not specifically mentioned, so I don't know if there are affected.
Oh I wish I had control of a monopoly.
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Post by flyjoe180 on Feb 12, 2013 8:10:05 GMT 12
How to kill an airport.
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Post by scrooge on Feb 12, 2013 8:38:01 GMT 12
Put up the fees, drive away the pesky low return tenants, 'lose' income, put up the rent to compensate, drive away the rest of the tenants, 'lose' remaining income, shut airfield, build houses, sell houses, walk away rich.
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