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Advocacy - Submissions

Submission numbers reduced reflecting impact of Covid-19 but much more informal interaction with agencies through the development of Covid responses

The number of discussion documents released by the Government in 2019 continued in 2020, especially in the workforce development space.  Consequently we were involved in an increasingly wide variety of work with different agencies.  To cope with this, our relationships with ally organisations became even more important. Submissions included:

  • MBIE - Tank Wagons unattended

  • Ministry of Education - EFTs, International students, future shape of skills training

  • CAA - Levies, NPRM 19-04, Flight and Duty Time in Pt 135 ops, assistance for ADS-B installations, AC66-1, AC43-1

  • Regional bodies - Milford Opportunities Project and Selwyn District Council on aviation access

Meetings and input to agencies/organisations including

Government agencies including Ministries of Defence, Education, Education NZ, Primary Industries, Foreign Affairs and Trade, and Transport, NZ Trade & Enterprise, Climate Change Commission, DOC, FENZ, MfE, ServiceIQ, Metservice, TAIC and Airways; Regulatory agencies including CAA, NZQA, TEC, MPI, EPA and Worksafe; Aviation sector organisations including ACAG, ALPA, Aviation Federation, BARNZ and NZ Airports Assn; Business associations including Business NZ, Business Councils, Federated Farmers, Fertiliser Assn of NZ and Tourism Industry Aotearoa, Chambers of Commerce; and  Regional Councils. 


A number of improvements to aviation activities proposed for various Covid Alert levels were achieved.  Notable achievements included most agricultural activity allowed at Level 4 (working with Federated Farmers and MPI), much aviation engineering activity added to Level 4 constraints (working with MoT and CAA), confusion over UAV use at alert levels resolved (with CAA) and pest eradication budgets increased as part of Covid-19 recovery (working with DoC and MPI).  Draft safe work instrument developed for Worksafe covering tank wagons, Government contributions towards costs of installing ADS-B in GA began, Flight and Duty schedule developed for Pt 135 VFR ops with Sleep Wake and supported by CAA, appointed to represent GA on Climate Change Commission Transport Technical Group.  Guidance and input from many of the Executive Committees has ensured practical and relevant advice to CAA, even if the progress we might want to see has been slow. and we’ve seen some barriers in the Airworthiness area in particular come down. 

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New Zealand