The PwC/Air New Zealand application for Aeroplane Pilot to be included on the Immediate Skills Shortage list

Submission by GAA

The General Aviation Advocacy Group of New Zealand

August 9 2013

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Contents

Summary of the GAA position

Part 1 - Rebuttal of Air New Zealand's Supporting Information

List of New Zealand Air Carriers

Part 2 - In pursuit of a career in aviation

Evidence and opinion from co-submitters

Pilot data from the GAA survey

Background to the lead submitter

List of co-submitters

Australian ATSB Pilot Experience Study 2013

Acknowledgements

2 Summary of the GAA position

This submission by the General Aviation Advocacy Group of New Zealand to the Ministry of Business, Innovation & Employment

opposes the application by PricewaterhouseCoopers, on behalf of Air New Zealand, to have “Aeroplane Pilot” added to the ESID lists and

requests preservation of the status quo.

GAA and its supporters reject the applicants' claim that

“The New Zealand Aviation industry is experiencing a pilot shortage of significant proportions”

In this submission, we seek to establish that

the application must be rejected because it does not meet the criteria, and

no such skills shortage has been proved.

For the application to succeed, it must meet several important criteria, which PwC and Air New Zealand have failed to do. They must show, among other things, that:

The shortage is not employer-specific

There is evidence of employers having difficulty employing staff (note our emphasis on the plural)

The shortage must be across all geographic regions in New Zealand

It must be a current shortage, not an anticipated one

There must be an ongoing and sustained (absolute) shortage, both globally and in New Zealand.

The claim by Air New Zealand and PricewaterhouseCoopers that "The New Zealand Aviation industry is experiencing a pilot shortage of significant proportions" is entirely their own.

It is not supported by any credible third party evidence in the proposal, and the allegation is rebutted in our submission (which relies on verifiable evidence gathered over a very short period).

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Moreover, we see no evidence that local operators independent of Air New Zealand are suffering from a shortage of pilots. On the contrary, it appears that they enjoy a very low level of pilot turnover. If the roughly 33 operators we list were experiencing a shortage, it would be reasonable to have expected them to support the PwC/Air NZ application (had they been aware of it) but there is, again, no evidence of such support - or even general awareness of the proposal.

There is no evidence, within the application, of PwC/Air NZ having consulted with the wider 'Aviation industry' over its proposal. To the best of our knowledge, no subjective survey of the industry was carried out by the applicants before the PwC/Air NZ proposal was filed.

The Aviation Industry Association, led by its chairwoman, Irene King, is known to have been involved with Air New Zealand in supporting the application; but there is no evidence in the application that the AIA consulted its members on the issue.

We also know that this application was made without the knowledge or involvement of the New Zealand Airline Pilots Association, a body which - perhaps above all others - could have been expected to have an interest and involvement. GAA seriously questions the manner in which this application was made, because it is clear that few potential stakeholders had any knowledge before GAA exposed it to the wider public. It is alarming that submissions to this proposal would have closed on July 26, had not NZ ALPA stepped in to achieve an extension of the deadline. This strongly indicates that the application was not adequately promulgated to interested parties.

Some industry pundits predict that during the next 20 years, there may be a worldwide shortage of pilots and technical support staff. For example, we refer to a Boeing study of 2012: http://www.boeing.com/boeing/commercial/cmo/pilot_technician_outlook.page

However, this forecast has no relevance to the contemporary New Zealand scene, or the application.

We can see from the application that it is Air New Zealand-focused, and even if the Ministry were to regard the regional airlines as separate businesses, the application must fail purely because the Air New Zealand Group recruitment system is the single entry point for those with the skills that are claimed to be in short supply.

Air New Zealand claims to support the training of future airline pilots, through its

4 links with five training establishments. However, while Air NZ has a well- established "sponsorship" and monitoring system for the training schools, it fails to meet demand in one very significant respect:

It fails to provide a bridge between the flying school's product, the Commercial Pilot Licence holder, and his or her career with our national carrier as an Airline Transport Pilot Licence holder.

Instead, a newly qualified holder of the Commercial Pilot Licence is cast adrift to find a job somewhere else, in order to build enough hours and gain additional experience and qualifications to meet the airline's requirements for a recruitment interview. This is an extremely onerous challenge.

If there is any shortage at all, it boils down to this:

Young CPL holders are forced to take employment in poorly-paid positions in New Zealand in order to build their hours or

They go overseas, find somewhere to develop their skills, which then reach the stage where they pursue their careers in another country, with promotion and salary prospects that Air New Zealand fails to match.

There is a large and verifiable constituency of expatriate New Zealanders who are well-qualified to fill positions within the Air New Zealand Group, but (as we show) find the Air NZ terms of employment unacceptable.

This is, in fact, the real shortage: Air New Zealand pays lip service to professional pilot training, but fails to follow through by committing itself to develop the resulting output - then "identifies" a local staffing crisis for which it is, in large part, responsible. Moreover, it does not meet the career expectations of qualified New Zealanders working abroad.

In this submission, we demonstrate that

there is an enormous enthusiasm for careers with Air New Zealand amongst New Zealand flying students and

this is not matched by a formal Air New Zealand career path from flying school to the airliner cockpit, with committed and long-term investment from the airline in a cadetship scheme. Air New Zealand has always rejected such a scheme, but there is new and compelling evidence from Australia that they are worth investing in. We provide the report, for the guidance of the Ministry and the airline.

Because of this dreadful failure on the part of Air New Zealand, many of our most promising and ambitious students leave New Zealand, taking a very

5 important pool of talent away from our nation. This has been occurring for many years and the record shows that most of this expertise is lost forever.

Unless Air New Zealand adopts globally competitive remuneration, working conditions and more realistic promotion paths, to become an "employer of choice", it is unlikely to either persuade current ex-pat pilots to come home, or to attract the "right stuff" from other nationalities.

Given its uniquely privileged position in our country's economy, Air New Zealand has a duty to adopt a more responsible employment policy than a privately owned, budget airline.

The PwC/Air New Zealand submission is, in short, an opportunistic attempt on the airline's part to abrogate its responsibility (as the monopoly controlling force in this country's commercial aviation) to fully support and develop training opportunities for young New Zealanders, recruit eligible New Zealand pilots living here, and make it more attractive for expatriate pilots to return.

It is also disturbing to note that advertisements for aircrew whose qualifications closely match the requirements of Air New Zealand began to be posted on an international recruitment website in July - long before this application came to be considered by the Ministry. They could only have come from one source.

False predictions of pilot shortages are not new.

Take, for example, this one from 2003, which features the Aviation Industry Association and its chairwoman, Irene King, a supporter of the current PwC/Air New Zealand application:

from The New Zealand Herald, in which it is stated

Pilot shortage looms as fewer train

5:00 AM Monday Nov 17, 2003

The aviation industry is predicting a pilot shortage within four or five years following a Government cap on the number of students next year.

In response to the looming shortfall, the Aviation Industry Association (AIA) has suggested several strategies to reduce the impact of the move.

AIA chairwoman Irene King said that for the past decade about 300 new pilots a year had entered the market having received their commercial pilot's licence. With the cap - restricting total student numbers to 775 fulltime equivalents,

6 including a new entrant limit of 350 - the number of people receiving their commercial licences in 2005 was predicted to drop to 130, she said.

On present predictions, by 2007 there could be problems finding enough experienced pilots for "lower end" services, such as scenic flights.

The AIA is predicting that pilot shortages will start to filter through to heavy commercial aviation by 2009/10.

It pointed out the problem had arisen at a time when demand for pilots was at an unprecedented high with major scheduled operators ramping up services, and a new entrant about to enter the market.

AIA president John Funnell said taxpayers had every right to ask why they should be lending more than $30 million to students and funding tertiary institutions only to see students disappearing overseas.

"It would be good in view of the upcoming demand to keep more of these people here in New Zealand."

http://www.nzherald.co.nz/nz/news/article.cfm?c_id=1&objectid=3534549

None of this happened. In fact, quite the contrary.

Fast-forward to 2009, and an article in the Sunday Star-Times:

Air NZ pilots face demotion, pay cut

Sunday Star-Times, January 17

MORE THAN 30 senior Air New Zealand pilots flying the airline's largest jets face demotion to smaller aircraft and reduced pay as the company looks for ways to avoid large-scale redundancies in the difficult economic climate.

The Sunday Star-Times understands 32 pilots currently flying 747s, 777s and 767s on long-haul routes will be "down-trained", meaning they will fly smaller aircraft on domestic routes and have their pay and rank lowered. The airline has about 850 jet pilots, of which about half fly long-haul routes.

Air New Zealand is also offering pilots alternative roles within the company, leave without pay, flexible flying arrangements and enhanced retirement packages. According to a government career advice website, pilots who fly internationally earn up to $250,000.

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Company spokeswoman Tracey Palmer said the initiatives were because of an 8% reduction in long-haul capacity as a result of the world economic downturn. Among the long-haul services Air New Zealand cut last year were flights to Japan and Hong Kong from New Zealand.

She said the airline had also made long-haul cabin crew redundant, offered reduced hours to corporate staff, not replaced non-safety sensitive roles and frozen executive pay.

"We have not made any pilots redundant and remain committed to maintaining a workforce of highly skilled and trained professionals to ensure the airline is quickly able to adapt to changing market conditions," she said.

Tim Robinson, head of the Air New Zealand pilots' council, said the union supported the company's initiatives. Although down-training was disappointing for pilots, it was preferable to being made redundant.

Robinson said the airline had also made inquiries about jobs with other airlines on behalf of pilots, although those opportunities were drying up.

Rick Mirkin, executive director of the Airline Pilots Association, said as far as he was aware, the other airlines that had pilots based here, Pacific Blue and Jet Connect, had not made cutbacks, although they flew mainly domestic and regional routes.

http://www.stuff.co.nz/sunday-star-times/latest-edition/799577/Air-NZ-pilots-face- demotion-pay-cut

GAA asks the Minister of Business, Innovation and Enterprise to reject the PwC/Air New Zealand application.

We also invite the Minister to order further study into how the needless haemorrhaging of expensively acquired, home-grown talent can be reversed.

In our view, this continuing loss of expertise is a far more important issue.

As the majority shareholder (on behalf of the public) in this airline, the Government is ideally placed to remind Air New Zealand that its privileged position as a monopoly supplier requires a higher standard of ethical behaviour than usually applies in more competitive business environments.

8 Part 1: Rebuttal of Air New Zealand's Supporting Information

This part deals with Air New Zealand's Supporting Information for its application for Pilots to be included on the Immediate Skills Shortage list.

PwC/Air New Zealand statements are italicised in black

GAA statements are in blue

Criteria for adding an occupation to the ESID lists are italicised in red

We comment on the document, page by page.

Page 2 - Overview

“The New Zealand Aviation industry is experiencing a pilot shortage of significant proportions”

This is the comment of Air New Zealand and PricewaterhouseCoopers - not the ‘Aviation industry’ - and it is not supported by any credible evidence in the PwC/Air NZ proposal documentation.

The names, addresses and contact phone numbers of 33 air operators are listed at the end of this Part 1. (This list is not exhaustive.)

GAA suggests that the MoBIE assessors of the application contact each operator to ask if they have an existing shortage of pilots and if they have any vacancies for pilots. These operators might also be invited to comment on whether they anticipate a pilot shortage of “significant proportions”.

CF: http://www.pilotcareercentre.com/Search-Air-Carrier-By-Region-And-By- Aircraft-Type/35/Oceania/New+Zealand+-+Charters+-+Medevacs

CF http://www.pilotcareercentre.com/Search-Air-Carrier-By-Region-And-By- Aircraft-Type/154/Oceania/New+Zealand+-+Airlines+-+Regionals+-+Cargo

“Air New Zealand alone has current and projected recruitment needs that exceed the total number of available pilots in the local market”

See Table on Page 6 of the PwC/Air NZ submission. From what they have presented, a shortage of six pilots appears to be no dire or threatening situation.

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“Having pilots included on Immigration New Zealand’s skills shortage list would significantly simplify the recruitment process and benefit the industry and New Zealand economy as a whole”

Having Aeroplane Pilot listed on the Immigration skills shortage list is not permitted merely in order to simplify the internal recruitment process of a business such as the Air New Zealand Group, which is the only recruitment entry point for a number of passenger carriers.

Furthermore, the applicant must satisfy this requirement:

There must be an ongoing and sustained (absolute) shortage, both globally and in New Zealand.

The words "ongoing", "sustained" and "absolute" are critical to the success of the PwC/Air NZ application. We submit that the PwC/Air NZ proposal fails on all three terms, even when applied only to the New Zealand scenario. PwC/Air NZ cannot sustain its argument on an international level, either. For example:

CF: Singapore Airlines releases Cadets from Bond arrangements due to downturn. http://www.stjobs.sg/career-resources/hr-updates/excess-pilots-sia- waives-cadets-bonds/a/119693

“This means that in 2013, an estimated 210 pilots will be required to support expected growth within the industry”

There is nothing in the New Horizons report, regarding pilot numbers required, to support this prediction for the entire industry. If true, the industry leader has failed to anticipate the shortage:

Industry is committed to training New Zealanders in these occupations.

The "industry" is not committed to fully training New Zealanders to fill airline occupations. The industry leader merely supports training to Commercial Pilot Licence standard, which falls far short of Air New Zealand entry-level qualifications.

Industry is committed to fully utilising the domestic labour market before considering employing overseas workers.

The industry leader has shown that it is not committed to this goal, and Part 2 of our submission provides ample evidence of this.

10 “New Zealand’s aviation industry however has the potential to grow at 9% per annum... Using estimates for the Asia Pacific region published by Boeing 1 and by International Air Transport Association 2 (IATA), a conservative rate of 5% and an optimistic rate of 7% growth was used for calculation” [source - New Horizons Report] ”

This growth is pure speculation. To be valid, the application is required to be about a present existing pilot shortage in New Zealand, not one in the future.

Furthermore, the data used is from the Asia Pacific region. The rapid economic growth occurring in the Asian countries such as China cannot with any degree of reliability be extrapolated as being valid for the Pacific area.

It is conceivable that local or world events could prevent this prediction from becoming a fact, as has happened in the past. For example:

Conflict - eg the Iraq war

Terrorist event - eg Sept 11

Viral disease of zoonotic origin - eg SARS, Swine Flu, Bird Flu

Global recession

11 Page 3

“As an estimate, one additional unit of airline capacity can require up to 16 additional pilots. This is because each aircraft operates potentially up to 16 hours per day, and at a minimum requires 2 crews of 2 pilots”

Only long-haul jet aircraft require 16 crew.

CF: http://www.airnewzealand.co.nz/fleet Ref Daily Utilisation column

“Two further factors are of relevance to creating the current and expected pilot demand. The New Zealand pilot population is ageing, with 23% of the commercial pilot population over the age of 50, and 8.5% over 60. In addition, global industry expansion means there is increased demand for pilots offshore, and across the New Zealand industry, accelerated exit rates to offshore positions. This net effect of this is that it is highly likely that the estimated annual industry need for 220 pilots in 2013, increasing to 240 pilots in 2014, is conservative and the real need will be higher”

If there are accelerated exit rates to offshore positions, it is fair to ask: Why are career prospects overseas more attractive?

Ageing Air NZ pilots refuse to retire: http://www.stuff.co.nz/business/industries/4882356/Ageing-Air-NZ-pilots-refuse- to-retire

“In summary, insufficient new pilots are entering the New Zealand market to be able to address current, projected and potential industry needs”

No consideration has been given for pilot numbers trained in previous years, or during the years when Air NZ did not hire at all. In the past, leave without pay has been offered to pilots to find alternative employment when Air NZ has had a surplus of pilots.

During the “lean years” when Air NZ was not hiring, many NZ pilots left the country to work for other airlines overseas because they could not get a job in New Zealand. A large number of these ex-pat pilots would like to come back to New Zealand and work for Air NZ, but they are reluctant to return. Why?

“At the other end of the scale, the removal of age restrictions on pilots in 2007 has inhibited pilot career progression, and resulted in an ageing population.

12 There has as a consequence been an increased attrition rate of young pilots into overseas employment, and the industry will likely soon have a high retirement rate, requiring replacement”

We refer again to "Ageing Air NZ pilots refuse to retire":

http://www.stuff.co.nz/business/industries/4882356/Ageing-Air-NZ-pilots-refuse- to-retire

The principal factors for our young pilots seeking employment overseas are:

1. No employment opportunities in NZ. The struggle for our young pilots to gain further experience in an over-supplied market during what we call the “gap years” between leaving a training organisation and meeting the CAA regulatory experience requirements, and the requirements of Air New Zealand, are evidenced by the comments in Part 2 of the GAA submission.

2. The difficulty of obtaining employment with Air NZ, due to various factors such as rigidly applied educational qualifications, which take precedence over flying qualifications. This is also evidenced by comments in Part 2 of the GAA submission.

3. Low salaries in Air NZ Regional. The starting salary for a First Officer in one of the Air NZ Regional groups (Eagle) is less than the threshold of $45,000 used as a proxy indicator for skill level.

“It however takes on average an investment of 32 years before a pilot becomes a wide body jet captain under the present regulatory and employment agreements prevailing in New Zealand”

It is relevant to ask Air NZ if any attempt has been made to change the terms of this investment?

This extreme length of time for career progression is one of the reasons why Air NZ is not an attractive employer. Here, the following condition to satisfy the skills shortage criteria is important:

The shortage is not due to recruitment and retention issues arising as a result of terms and conditions of employment

13 Page 4

No reference is supplied to substantiate 210 pilots as being required for the whole “industry” for each of three years.

This again is pure supposition and crystal-ball-gazing, and it is a prediction which may not happen.

The table shows no consideration has been given for pilot numbers trained in years prior to 2012, or from times when Air NZ did not hire at all, including those working for other airlines overseas looking to transfer to Air NZ.

Past years training data (note numbers of Kiwi nationals):

http://www.aia.org.nz/site/aianz/files/FlightTraining/2011/June/Aeroplane%20CPL %20issued%202010.pdf

Total available pilots qualified and active with a Class 1 medical, NZ CPL(A)+NZ ATPL(A) at July 27 2013 shows 2592 pilots.

This web link is dynamic and the latest data is shown upon viewing. http://www.caa.govt.nz/Script/busy.asp?Dest=PilotLicStats.asp

Comparative data (last page) http://www.aviationinstitute.co.nz/ai/assets/AirNZ%20Booklet.pdf shows that in Feb 2012, Air New Zealand Group employed 1248 pilots, 850 of them on jets.

“The typical pathway to becoming a qualified employable pilot for a carrier such as Air New Zealand is outlined in Appendix 1. The requirements outlined there are industry minimum requirements which are determined by the New Zealand Civil Aviation Authority”

As per evidence against Appendix A below, the above contradicts the assertion of two years training required.

“On receiving a commercial pilot’s licence (CPL) a “pilot” is not yet employable by carriers such as Air New Zealand, Virgin Blue etc. There are additional flight time requirements set out by NZCAA to ensure appropriate experience and safety for carriers”

This is contrary to Appendix A as provided by Air NZ, which shows that a pilot is

14 legally employable by the Air NZ Group company Eagle, with flight hours attained fresh from qualifying from one of our New Zealand training organisations.

The same low-time pilot could also be legally employed as a cruise relief pilot (Second Officer) on Air NZ Mainline (long haul jet fleet).

A 2013 Australian report, which addresses pilot training and experience, is attached to this submission. A précis is copied below:

Safety summary from the Australian Transport Safety Bureau

Why have we done this report

Significant debate has occurred within the aviation industry regarding the issues of pilot training and experience, particularly with regard to the introduction of new pilot training programs that are focused on training cadet pilots. The main concern being presented by some sectors of the industry that are not in favour of these concepts is that these low-hour co-pilots are not as competent as their high-hour peers.

The ATSB gathered data from three airlines to explore the issue of pilot performance as a function of both flight hour experience, and entry pathway. Entry pathway analysis compared cadet pilots (who generally had not accumulated prior flight hours or experience) to those pilots who entered an airline after accumulating flight hours in other areas of the aviation industry.

Data were collected on a number of metrics from simulator check flights, which covered non-normal operations, and line checks, which covered normal day-to-day flight operations.

What the ATSB found

The overall performance of cadets and low-hour pilots matched that of their direct entry and high hour peers. All pilots were marked as proficient at the completion of the check flights, with the only differences between the groups being a function of how many exceeded the required standard. The differences between the low and high-hour pilots in ‘meeting’ and ‘exceeding’ the standard across all metrics were variable within airlines and inconsistent across all three airlines. This suggests that the differences between the groups were not of a systemic nature that would highlight an area of concern for industry. While the metric normal landing showed a difference across two of the three airlines, none of the other required regulatory manoeuvres or technical metrics were significantly different in more than one airline. For non-technical metrics, both leadership and situation awareness were significantly different in all three airlines.

Although this is understandable given the low experience of cadet and low-hour pilots, focused exposure to those metrics during initial airline training may reduce this difference as was seen in the data for cadets collected at the 5-year mark in one airline.

15 “To train one fixed wing pilot, however, takes a minimum of 2.0 EFTS i.e. 2.0 years of training. That number increases to or 2.4 EFTS if the pilot completes the NZ Diploma in Aviation (Airline Preparation); or 4.0 EFTS if the pilot qualifies through the Bachelor of Aviation (Airline Transport Pilot). Taking the 450 student cap into account and allowing for approximately 20 EFTS allocated to helicopter pilot training, the maximum potential annual student loan funded intake of fixed wing pilots is therefore 215; but a more accurate number taking into account the EFTS value of the two major funded qualifications is approximately 160. Taking into account the reality of a less- than-100% graduation rate, a more accurate figure is 130”

Employable flying qualifications can be attained in less than one year.

The aviation industry offers courses including a Diploma course or Massey University Degree that require additional time to complete, and funding over and above minimum flying qualifications for employment. This, in effect, decreases the number of students who can be trained on a yearly basis for a set amount of EFTS available.

If all pilots did not do this extra academic study, the yearly number of pilots could be doubled to 430+.

The benefit of this extra academic study in the making of a good airline pilot has neither been conclusively demonstrated nor supported by substantiated evidence from Air NZ.

An Instructor Rating and more advanced training, and any academic study, are ‘extra’ to the minimum employable qualifications.

Excerpt reads: “Note below table; Fees quoted are based on full programmes, including completion of instructor ratings and other more advanced training.”

http://www.aia.org.nz/site/aianz/files/FlightTraining/2011/July/Tuition%20fees%20 charged%20by%20flight%20training%20organisations.pdf

16 Page 5

“As the accumulation of flying time is not student loan funded, an individual must fund this themselves over typically a 3-5 year period. This creates further attrition, hence in 2012 only 101 pilots fully qualified to be employed”

Pilots are very resourceful. They instruct, go overseas to fly to gain the extra experience, get some sort of flying job (paid or not) and in only very rare cases do they give up completely.

“From 2013, the amount a student pilot is able to borrow under the student loan scheme will not cover the full cost of flight training (not including the additional hour requirements). The government is concerned about how slowly pilots pay back student loans, and may restrict the loan amount granted to enable easier repayment. Unfortunately the consequence of such an action is likely to be that the majority of student pilots will no longer be able to afford to study full time, and qualifications will thus take longer to complete. This is therefore likely to further decrease the number of employable pilots per annum”

A Cadetship course with guaranteed employment into Air NZ would assure the airline of a sustained resource. It would also serve to fulfil the criteria below:

Industry (Air NZ) is committed to training New Zealanders in these occupations.

Industry (Air NZ) is committed to fully utilising the domestic labour market before considering employing overseas workers.

The shortage (by Air NZ) is not due to recruitment and retention issues arising as a result of terms and conditions of employment.

“Air New Zealand, as the country’s largest employer of pilots, is heavily impacted by the lack of pilots available to the industry”

Air NZ has provided no supporting evidence of widespread flight cancellations or difficulties in crewing due to a lack of pilots. Conversely, in recent years Air New Zealand has been known to offer unpaid leave to pilots to reduce crewing surpluses. The number of pilots currently on unpaid leave is a question which should be posed to Air New Zealand.

17 “50% of Air New Zealand’s current jet fleet of 850 pilots is over 50 years, and there are 110 pilots (15%) currently over 60”

There appears to have been no change in trend or statistics from this 2011 article: http://www.stuff.co.nz/business/industries/4882356/Ageing-Air-NZ-pilots-refuse- to-retire

18 Page 6

“With expected fleet expansion of new Boeings from 2014, Air New Zealand predicts its new pilot recruitment demand for the next few years to be significant and will nearly exceed, if not exceed expected available pilots in the New Zealand market”

The table provided by Air NZ contains the following information:

Years 2013/14/15 inclusive

Jet Fleet requirements 98 pilots Regional Fleet requirements 260 pilots Total required by the Air NZ Group 358 pilots

Total pilots trained in the NZ Market 360 pilots

These figures as provided by Air NZ show there is NO critical shortage out to 2015.

The table shows no consideration given for pilot numbers trained in previous years prior to 2013, or from times when Air NZ did not hire at all, including those working for other airlines overseas looking to transfer to Air NZ.

It is not explained whether the Regional Link carrier requirements are because of:

new aircraft (only 4 new ATR planes on order at this level)

pilots dissatisfied with pay and conditions and going overseas for a better deal

a vacancy on the jet fleet filled by a Link pilot moving up. If this is the case, there is only one vacancy and not two to be filled by new pilots.

2 Boeing B777s replacing 2 Boeing B747s (0 change) 9 Airbus A320s replacing 11 Boeing B737s (-2, over 3 yrs) 10 Boeing B787s replacing 5 Boeing B767s (+5, over 4 yrs) 4 ATR - 72 (+4 domestic, over 3 yrs)

This gives an overall increase of +3 jet aircraft, but +5 long-haul that have Second Officers. Looking at the worst case scenario, based on 5 jet long-haul jet aircraft:

5 x16 crew = 80 pilots over four years for the jet fleet. Air NZ submits 98 required on the jet fleet.

19

Ref aircraft on order30/6/2013:

http://www.airnewzealand.co.nz/fleet

Ref: Air NZ will add two long-haul 777-300ERs and bolster its domestic position with A320s and ATR-72-600

http://centreforaviation.com/analysis/air-new-zealand-poised-to-deliver-on-go- beyond-strategy-still-facing-stiff-competition-103058

http://www.airnewzealand.co.nz/press-release-2009-airnz-replace-domestic- boeing-737300s-03nov09

http://www.airnewzealand.co.nz/press-release-2011-airnz-invests-in-regional- growth

“This is largely due to commercial airlines pilots requiring a specific set of technical, cognitive and personal attributes which can’t easily be trained”

Cadetship courses would solve this.

Current tests involved in Air NZ interview for technical, cognitive and personal attributes include:

An in-house-designed Psychometric test. This is in contrast to an internationally recognised provider called SHL which is used by a number of airlines, Qantas group included.

Shouting at pilots in role-play to test customer service skills/response.

Flipping a piece of paper every 15 seconds for several minutes, marking one side with “0” or “X” while answering aviation maths questions on the other side.

Flying an Instrument Approach in the Simulator while answering aviation law questions (note: this is highly unusual, and airlines normally ban discussion when flying an Instrument Approach in real operations).

“The Aviation Industry is an ever-changing and challenging environment. With the increasing demand of people travelling and expanding fleets to meet this demand, the need for pilots will continue to increase”

20

Aircraft fleets are not changed without extensive forward planning. There is a sufficient lead-in time to consider how best to utilise the pool of experienced pilots. It would, however, be prudent to plan as an industry from the training organisations upwards rather than have “knee jerk” reactions such as this present application.

The shortage is not due to recruitment and retention issues arising as a result of terms and conditions of employment

“While Air new Zealand and the industry continues to lobby the government on student loan issues to make flying a more accessible career pathway to New Zealand citizen and resident pilots, it would be of great benefit to have pilots included on the Immediate Skill Shortage list to allow the industry to grow at its potential”

Increasing funding by way of student loans will definitely increase the potential for more students to be trained. However, there also needs to be a corresponding increase of support by way of employment opportunities for these pilots during the years that they are gathering further flying experience. This additional support in gaining employment is necessary to provide surety to the government that these young pilots will begin paying back their substantial student loans.

Unless Air NZ introduces a cadet scheme, to give them an ongoing and stable supply of pilot numbers of the standard it desires, there will always be years where the airline has either too many pilots available or insufficient numbers. A long-term, permanent solution is preferable for our general aviation pilot training organisations and what they produce in the way of highly skilled young men and women.

21 Appendix A

Please note, as supplied from Air NZ, the qualifications and courses required to be employable in Appendix A.

Using course durations as per the following websites as examples, you find course lengths of less than one year. This is contrary to the two-year duration asserted in the PwC submission.

With course durations of less than one year, there is a flow-on effect on the actual student numbers that could be trained under equivalent full-time students (EFTS). Although at present capped at 450 EFTS per annum, there is the potential for this policy to be varied as required, depending on industry demand.

Longer course lengths are usually predicated around those involving diplomas and degrees.

http://www.airhb.co.nz/flight-training/courses-and-licences/ http://www.flighttraining.co.nz/What-We-Offer/our-courses-for-20092010.html

22 Appendix B

“8.5% (245) of the active “commercial” pilots are over 60 years of age. The majority are likely to retire in the next 5 years. 23% (630) of the population are over 50 years of age”

See "Ageing Air NZ pilots refuse to retire":

http://www.stuff.co.nz/business/industries/4882356/Ageing-Air-NZ-pilots-refuse- to-retire

The Industry demographics graph shows a combined total of 200 CPL(A) +ATPL(A) over 60. Not 245 who are over 60 years of age as stated above by PwC/Air NZ.

The graph shows a combined total of 330 CPL (A) and ATPL(A) in the 51- to 60- year age group. When this is added to the 200 CPL(A) and ATPL(A) who are over 60, this gives a combined total of 530. Not 630 who are over 50 years of age as stated above by PwC/Air NZ.

If evidence is to be presented in this form as part of an application, it should portray an accurate representation of data.

New Horizons Report

“Pilot Training is the most difficult area to analyse of the aircraft and air service related activities. Pilot Training is part of sector 101 in our economic model designated Other Education. This sector includes activities such as language schools, police and fire-person training, secretarial schools, hairdressing and other personal services, modelling schools, training of public servants in special programs, various types of school education (e.g. Pre School) as well as driver training and pilot training. As at February 2009, total employment in this sector was estimated by Statistics NZ at 15,410. Current estimates of persons involved in Pilot Training in NZ are 700 or just 4.5% of total employment in sector 101. As a result, the technology of this sector in the model is not especially specific to Pilot Training, and the listing of the top ten sectors for example (see Tables 12 and 13 below) reflects this.”

This report is dated three years ago (2010) and relies on data going back as far as 2005. There have been many changes since this report was published - not least the changes to student loans and capped equivalent full-time students (EFTS).

We refer to Appendix F, Page 16, or Page 80 of the PDF.

23

Pilot-related statistics are not clear and are hidden amongst other activities.

We also refer to Page 34 of the Document, or Page 38 of the PDF, entitled C. Limitations.

The data was not accurate, as outlined below. Key issues arising were:

C. Limitations

A number of challenges were identified prior to project commencement, and other areas became apparent as the work progressed. Key issues arising were: Statistics New Zealand and the Department of Labour were key data sources. The available datasets (on their own) fell short of meeting the information requirements. Key reasons for this were:

the aviation market sectors and sub-sectors specified in order to provide an appropriate level of detail for the Project do not match the Australia New Zealand Industry Classification 2006 (ANZSIC 06, the classification standard for most data capture); only 3 out of the 500 ANZSIC 06 industry classifications are unique to aviation

“collecting sufficient data to provide an adequate basis for establishing figures at the sector and sub-sector level”

“comparing primary data with other datasets because they related to different time periods or were compiled on different bases, or data was incomplete or based on estimates”

“collecting data at the regional level was challenging because of the difficulty in obtaining sufficient information, even where respondents were willing to assist”

“The regionalisation of data was limited to allocating data on the basis of the regional aviation employment data. This approach had some accuracy limitations but provided a broad measure”

“comparing primary data with other datasets because they related to different time periods or were compiled on different bases, or data was incomplete or based on estimates” “collecting data at the regional level was challenging because of the difficulty in obtaining sufficient information, even where respondents were willing to assist”

“The regionalisation of data was limited to allocating data on the basis of the regional aviation employment data. This approach had some accuracy limitations but provided a broad measure”

24 “in the case of the ‘Air and Space Transport’ classification, data was not made available because the small number of organisations would breach confidentiality rules”

ICAO Global and Regional 20-year Forecasts

This graph includes Asia and is not specific to New Zealand. However, we offer the following comments:

The experience level required for a pilot to work in Asia is higher than Air NZ pilot minima, and working rights are also dependent on having 500 hrs on aircraft type, for example the Airbus A320.

In contrast to the general thrust of this application by PwC and Air NZ’s contention that the aviation market is rapidly increasing, Singapore Airlines has experienced the opposite. The report below is very current (May 21 2013):

SINGAPORE Airlines, which has too many pilots amid a business downturn, does not expect the surplus to ease any time soon.

Cadet pilots have been told that until Sept 30, those who quit may have their bonds waived.

The usual payback for leaving before serving the seven-year work bond can be more than $250,000, pilots said.

There are 95 cadets currently in training, said SIA, which froze fresh recruitment early last year.

About a third who have completed their flying training are now doing ground work, The Straits Times found out.

They have not been told when they will be able to start flying.

The cadets as well as 76 captains on expatriate terms which will be terminated by the end of next month or when their contracts expire - whichever is sooner - are among those affected by the surplus manpower situation.

25 Singapore Airlines releases Cadets from Bond arrangements due to downturn. http://www.stjobs.sg/career-resources/hr-updates/excess-pilots-sia-waives- cadets-bonds/a/119693

26 New Zealand Air Carriers

Company Address Phone Contact Air Gisborne Gisborne Airport, Gisborne 0800 866 006 A & B Reid Air Milford 1 Tex Smith La, Queenstown Airport 03 442 2351 Air Napier Hawke's Bay Airport, Napier 4144 06 835 6182 Gary Peacock Air Safaris PO Box 71, Lake Tekapo 03 680 6880 Air Wakatipu Lucas Place, Queenstown Airport 03 442 3148 Air West Coast 189 Heaphy Rd, Greymouth 7840 03 738 0524 Air2there Paraparaumu Airport 0800 777 000 Air Post PO Box 72516, Papakura 1733 09 275 0804 Aoraki Mount Cook Ski Planes PO Box 12, Aoraki/Mt Cook 8770 03 430 8034 Aspiring Air PO Box 68, Wanaka 03 443 7943 Barrie McHaffie Christian Aviation 457-459 Airfield Rd, Ardmore 0800 AIR TAXI FlyMySky PO Box 53-033, Auckland Intl Airport 09 256 7025 Keith McKenzie Garden City Helicopters Christchurch Airport 03 358 4360 Golden Bay Air PO Box 256, Takaka 7142 03 525 8725 Golden Wings 27 McLaren Drive, Nelson Airport 03 545 9924 Great Barrier Airlines PO Box 53 091, Auckland Airport 09 275 9120 Mark Roberts Island Air Charter Tauranga 027 484 4673 Izard Air Taupo Airport 07 378 7835 Kiwi Air Ltd PO Box 2087, Gisborne 06 867 9081 Air Manawatu PO Box 328, Feilding 06 323 3641 Skydive Franz Main Street, Franz Josef Village 03 7520 714 NZ Aerial Mapping PO Box 6, Hastings 4211 06 873 7550 Pionair Wigram Airfield, Christchurch 03 343 3333 Real Journeys Limited PO Box 1, Te Anau 964 03 249 7416 Ridge Air 97 Aerodrome Road Omaka 03 578 3724 Norm Clifford Salt Air Limited PO Box 293, Paihia 09 402 8338 Skyline Aviation PO Box 2347, Stortford Lodge 06 870 8700 Mike Toogood Sounds Air Picton Airport, Koromiko 03 520 3080 Andrew Crawford Stewart Island Flights PO Box 860, Invercargill 03 218 9129 Sunair Aviation AS Hangar 11, Tauranga Airport 07 575 7799 Vincent Aviation 95-109 Tirangi Road, Wellington 04 920 9638 Jill Hatchwell Volcanic Air Safaris Memorial Drive, Rotorua 07 348 9984 Phil Barclay JetConnect Limited PO Box 73-156, Auckland Intl Airport 09 256 7634

27 Part 2 In pursuit of a career in aviation

An insight into the career paths of young NZ pilots endeavouring to find employment

Preface

This is Part 2 of a submission to the Ministry of Business, Innovation & Employment

to oppose the application by PricewaterhouseCoopers, on behalf of Air New Zealand, to have “Aeroplane Pilot” added to the ESID lists and

to request preservation of the status quo.

It is attached as further evidence to be considered under Paragraph 5. Other factors relevant to determining whether a change to the ESID lists is appropriate.

Introduction by a former Air New Zealand Captain, Desmond Lines

The pursuit of a career as an airline pilot involves in the first instance a passion to fly. Along with that passion, I tell my students that a young pilot must also possess direction, dedication, determination and discipline.

The ultimate success in their journey to becoming a pilot is predicated around the possession of those qualities. However, for the young pilots who possess those particular qualities, their ultimate success in gaining employment as an airline pilot is not well assured in the current New Zealand General Aviation environment.

For a number of years, our pilot training organisations have been turning out high-quality young men and women pilots with all the necessary qualifications to gain employment.

However, the supply of pilots has vastly outstripped the demand from the smaller aviation companies in New Zealand which would largely have provided them with their first employment opportunity.

Recently there has been a marked decrease in the growth of what are generically called “general aviation” organisations within New Zealand due to the impact of significant increases in compliance costs, fuel and maintenance and in fees and charges imposed by the CAA as of 1 November 2012.

28 The flow-on effect of that contraction has, in turn, resulted in our young pilots having to seek employment offshore.

A further problem facing these young pilot graduates is that although they are, at this stage, highly skilled young men and women, those skills do not attract a suitable recompense within New Zealand until they eventually get into “mainstream” airline employment.

The struggle for our young pilots to gain further experience in an over-supplied market during what I call the “gap years” between leaving a training organisation and meeting the CAA regulatory experience requirements, and the requirements of Air New Zealand, are evidenced by the comments in Evidence and opinion from co-submitters.

29 Evidence and opinion from co-submitters

The co-submitters’ names have been withheld because many of them do not want their comments to adversely impact on future employment opportunities with Air New Zealand by being made a matter of public record. They are, however, verifiable from the submitters’ files.

The comments have been copied directly from emails.

I fully support the GAA submission opposing the inclusion of Airline Pilot to the ESID list.

I have several points I wish to be considered.

1. Air NZ is at the top of a pyramid of "feeder" operators - including the ANZ- owned subsidiaries Air Nelson, Eagle and Mt Cook who operate on the regional routes. These second and third tier ATO operators have been selective regarding their hiring requirements and have a de facto policy of hiring only when in "crisis mode" i.e. when they face severe difficulty in covering their rosters. This has, understandably, been a fundamental business policy for controlling costs in a highly competitive market. However it also leads to a delay in meeting demand. Supply will always lag demand under these conditions. There have been calls to increase, support and integrate flight training from within NZ to encourage training and provide experience opportunities to cope with the mismatch of demand and supply. Initiatives such as the "Air New Zealand Aviation Academy" have effectively been simply a marketing tool for the "sausage factory" type training schools which supply pilots who are qualified but who have reduced experience that is insufficient for commencing piloting on ATOs. These graduates invariably head overseas to gain employment in other countries - often gaining the requisite ATO experience with operators in the Third World. I personally travelled to the UK to work for an ATO operator which hired newly qualified graduates direct into turbo-prop operations. Such an impasse as exists between the experience gained by fresh graduates and that required by the regional operators in NZ could be solved if there was a commitment, by operators such as Air Nelson, to providing better hiring and training opportunities. This will essentially provide a leg-up for graduate trainees and allow more availability of experienced pilots from the regionals.

2. I personally know very experienced regional pilots who are available and have applied for ANZ pilot positions but are not considered suitable, for unstated reasons. The unsuitability is suspected to be their resistance to move to Auckland - the primary base of ANZ Mainline operations. Rather than provide financial support for relocating pilots and their families and/or facilitate rosters and providing positioning flights, ANZ would rather hire direct-entry pilots from overseas.

30 3. It is well known that Air New Zealand has a demand for pilots in an intermediate period as they upgrade to the B787 fleet. They wish to reserve additional experienced pilots for the start of operations in this type and therefore are making the request for Essential Skills in Demand Lists. This strategy is to compensate for the lack of forward planning - but may well be more financially expedient, regardless of the interests of New Zealand pilots.

Please add me as a co-submitter. FYI, I meet the Air NZ group entry requirements.

I am writing with regard to the submission to add Pilot to the perceived skills shortage list for NZ. Can you please add me as a co-submitter to your submission.

It is also noteworthy that the government recently stopped providing student loans for flight training as there are a significant amount of people completing the training and then unable to find any employment in the industry, or cannot afford to – for example flight instructors at some schools are paid $20 per flight hour yet expected to be at the premises for a full work week and do not earn 40 hours of pay.

I personally exceed the requirements being mentioned. I have 3000 total hours, 2600 gained on multi engine turbo prop aircraft on air operations, 100 night hours. I am a New Zealand Citizen, hold a New Zealand Commercial licence with some written ATPL examinations completed, and Multi Engine Command Instrument Rating.

I went overseas to gain employment as there were no opportunities in New Zealand upon completion of my training. I tried for years to return to New Zealand but was unable to gain meaningful employment. Some smaller companies such as Sun Air require you to pay for your training and aircraft type rating and then do not even pay a salary or a wage that would suffice to live on. I am also led to believe the starting pay at Eagle Airways is less than the advertised $45,000 in the submission.

There are many people overseas who would gladly return to New Zealand to work for Air New Zealand, should they be given the opportunity. As a suggestion, perhaps they could visit Australian Capital Cities to conduct interviews or even hold interviews on the weekends so that people from Australia could travel to New Zealand for them.

I would like to add my name to the list.

I am working in Papua New Guinea on a Twin Otter as a co-pilot , I currently have most of the Air NZ requirements, missing a couple night hours- that's pretty much it. So many pilots I know have applied and failed the group tests in the interviews. I applied two months ago and have heard nothing back from Air NZ. I have close to 400 hours on the Otter and 330 hours in NZ doing various things, and am working on my night hours and ATPLs . My current company looks to

31 upgrade me to Dash 8 where several pilots from Air Nelson and Eagle have joined our company due high wages and only working six months a year. I had to go offshore to Oz to find work and managed to find better in PNG. I personally wanted to come back to a relative First World country, even with the pay drop but it is a hefty pay drop. To me, I don't think they are willing to pay for training etc since they yet still have not done a cadetship type scheme, which is why I'm still in PNG paying off my student loan.

You can have an 'A' cat instructor with 3000 hours 'instruction' experience and he doesn't qualify for 'air operations' - meanwhile a kid who has flown newspapers from Gisborne to Napier VFR for 100 hours does. The regulations and system are caught up somewhere in the middle of last century and it's time for things to get real.

I am a NZCPL holder currently living in Australia. I had to move abroad (five years ago) as there was a serious lack of job opportunities within NZ at the time, and have been looking at returning for the past two years.

I meet all the requirements for Air New Zealand (second officer) and have had my application in with them for 1 1/2 years and am still waiting to receive an interview date.

This so called lack of trained personal within NZ is a crock! Allowing foreign nationals in to take New Zealanders' jobs will be of huge detriment to Air New Zealand and the country.

Please don't let this review of ESID be passed.

I was shocked to find out that Air NZ is trying to add "Aeroplane Pilot" to the list of jobs with skill shortages. Please add me as a co-submitter.

I am already employed by Air New Zealand as a 737 first officer. Several times in the last four years, I have been told by the company that they have too many pilots, and have been offered leave without pay and threatened with down- training and even warned of possible redundancy. We are currently experiencing a period of growth, but I find it very hard to believe that there aren't New Zealand residents out there to fill jobs, and I know of many people in GA who are working towards qualifications for a job with Air NZ.

32 I strongly suspect that Air NZ will be trying to use the excuse of skills shortages to hire foreign pilots at reduced salaries and conditions, and thereby increase its profits.

Hi, I fail to see the relevance of the UE requirement. [Currently, this is an Air New Zealand requirement for interview.] It's more than 25 years since I left school, and like many others failed to see the importance of it at the time. It was not a question of our not being intelligent enough to pass the exams. Since leaving school, I have sat and passed many exams, including ATPL subjects, heavy aircraft type ratings and engineering papers. I know that I am capable of getting through the training at Air New Zealand.

I suspect that Air NZ will not be dismissing the currently employed pilots who do not have UE and replacing them with foreign pilots who do meet the requirements, or asking them to complete UE.

Perhaps given the low hour requirements, Air NZ needs some way of determining that the 500hr pilot has the ability to complete the training. It is often life skills and the ability to deal with people that is more important.

As my uncle once said to me, we can train the pilot, but we can't train the person. Funny thing, he was the Fleet Captain for both the Electra for TEAL and the Fleet Captain on the DC10 for Air NZ. Haven't things changed?

Please add me as a co submitter.

While at university, I was working two jobs on top of full-time study in order to fly each weekend. I then had to leave university early, to beat the cut-off for the changes made to the student loan funding, an issue entirely of its own. I have taken on the hefty student loan to chase the dream, only to find there are no jobs here; all the carriers I have spoken to in Oz want to you have minimum flight experience higher than what you get as part of training, and that getting into a company that will take you, either in PNG or SE Asia, is a gamble at the very least. I have been fortunate enough to get a position on a C Cat course which has the potential for employment upon completion. But I think it is a sad reflection that the only reason this school is flourishing is because it predominantly trains foreign pilots who return to their native countries and spend three months in a pool before being taken on by one of the budget carriers.

In order to fund the course, and keep food on the table, I have had to take on a menial job and my parents have re-mortgaged their house. For years, it has been the case that our passion to be aviators has been exploited by the few companies willing to take on fresh CPLs. And now we are told even this is not

33 good enough, but foreign-trained (and often sub-standard) pilots are to be considered before us.

Aviation is an amazing career, but it seems the industry is determined to do everything in its power to crush our dreams of flying.

From a fresh CPL, struggling to find an aviation job.

I am writing this email to you to express my concern about international pilots joining Air NZ as Air NZ claims there is a shortage of pilots in New Zealand.

I am 20 years old, I have my CPL, and am currently doing my MEIR. I have 270 hours and the next year of my training/looking for a job is something that worries me.

It is hard enough currently, trying to bridge that gap between CPL and a job... anywhere. I have considered going down the route of a C-Cat, but with the way student loans are now, I have seen a HUGE drop in numbers at my flight training organisation. So I really don't want to add another $15-20,000 onto my loan if I won't have any students to train so I can build my hours. I would rather save that money and build my Multi Engine or Single Engine hours. Within, the next six months, I will begin looking for a job. On top of flying 8-10 hours a week, either in the simulator or in the air, I work 40 hours a week so I can fund the 120-kilometre daily round trip to the airport .

It's the way my Dad did it back in the 1970s so I think I should do it the same way. It's a little bit disheartening, when you put in all this work to achieve your dream, only to see that when you're so close, it may become that much harder.

I appreciate what you are doing on behalf of the young pilots of New Zealand.

Please attach my name to your submissions against Air NZ's effort to take direct entry foreigners due to the apparent skill shortage within the industry.

I am absolutely disgusted that our national airline wishes to put New Zealanders on the dole queue whilst employing the very types who splatter 777s all over seawalls. However, it hardly comes as a surprise from the airline that employs slave labour cabin staff to service its Chinese routes.

34

Thank you for your great work in support of fellow Kiwi pilots. I am happy to share my experiences.

After completing my CPL/MEIR in Christchurch during 2004, followed by a 50- hour mountain flying course in Wanaka, the only employment I could find was working for a rag-tag skydive outfit in Picton. After forking out close to $70,000 for flight training, I was appalled at the working conditions and pay. As soon as I gathered a few hundred hours, I fled for the Fiji Islands, where again I was employed as a skydive pilot, but on far better conditions. As I closed in on the 1000-hour mark, I moved to Papua New Guinea flying Cessna Caravans and Twin Otters for nearly four incredible years.

Currently I fly for the Canadian Government's forest fire programme during the Summer months on great money and excellent conditions. My total time is close to 4000 hrs, half of which is multi turbine IFR PIC.

The whole New Zealand general aviation scene is such a farce that I encourage pilots to leave New Zealand as soon as possible to fast-track their flight experience and make money. It's sad to watch my fellow classmates back home flying single engine pistons as instructors, skydive, whale watching and scenic pilots, struggling to pay rent, credit cards, student loans and maintain vehicles. Some give up entirely.

I believe that, like myself, most ex-NZ pilots are so disgusted by the conditions they faced while in New Zealand, they are actually put off permanently from returning to fly in New Zealand. Most are now working for large airlines in South East Asia and the Middle East.

It is the role of the major airlines and our government to work harder to prevent Kiwi pilots from fleeing - although working overseas can be a great learning experience. Perhaps Eagle Airways / Mt Cook / Air Nelson could do this by offering cadetships, work experience, jump seats (ie hiring pilots on the ramp and moving them into first officer positions right after flying school).

Another difficulty for pilots overseas is that most NZ airlines don't recognise converted foreign Airline Transport Pilot Licences, so if I was to return to NZ, I would need to take a four-month course (unemployed) to sit the seven exams.

The New Zealand flying attitude needs to change to meet up with the rest of the world.

35

I request that my name be added as a co-submitter.

My story is I currently work for Qatar Airways as a First Officer on the 777. I left NZ in 2004 knowing that my aviation future was too limited to stay at home to compete with the rest of the GA community for that elusive airline job. I flew in Botswana for four years before ending up in India on a B777 contract. I flew in India for two and a half years and gained more than 1500 hours on the 777. When my contract was eventually terminated due to India's own nationalisation, I applied to Air NZ with the hope of finally returning home to work and live. The answer I got was that unfortunately without UE I could not work for the airline. So with all this experience flying abroad and good right hand seat time in the 777, I was still refused even the opportunity to conduct an interview unless I was prepared to jump through hoops of enrolling in a University course to gain the required credits. Needless to say, with the opportunity I have been given at Qatar Airways, I haven't looked back. I will be doing my command in less than two years and I will stick it out in the desert to secure a future for my family.

I totally support this opposition. I have many friends who have been in the boat of being qualified pilots and unable to make it work in NZ with other life commitments taking priority. Going into what they were led to believe was a professional career with great prospects, only to discover the truth about flying jobs in NZ. The idea now that the future generations of pilots will also miss out on airline opportunities because of foreign pilots in our already over-populated pilot community is just ridiculous.

Please find attached completed pilot survey. I want to congratulate you on this survey, as this is an excellent response to a ridiculous situation. I will be making my own individual submission to the PEIR. Given that after years of struggle I am about to be in the position of gaining an interview with Air NZ, I find this turn of events more than just a little bit concerning. For your own interest, my background is a follows:

Having started flying later in life (31) I was never in the position of just leaping into fulltime flying once I gained my CPL. By this stage, I had a mortgage and family, therefore couldn't afford to quit my day job. A few years and some forward planning later, I was able to quit my reasonably well-paid job to complete a C-Cat course, and then go on to do my MEIR. Jobs were far and few between, but eventually I did work for a year in a Part 135 organisation doing scenics and charters, and finally in June of last year started fulltime instructing. I have since completed almost 500 hours instructing. Like I said, I started flying a bit later in life and therefore due to responsibilities it took a bit longer. However, I am now in the position where I expect to get an interview by the end of the year. My total experience and qualifications to date are...

36

1100 hours total 870 hours PIC 20 hours multi 17 hours night 480 hours instructing MEIR Bachelor of Arts Degree, University of Canterbury

Currently I am doing night flying when time and conditions permit to complete the 25 hours required, studying for my last ATPL exam, and getting recurrent on IFR. Therefore I will have 25 hours night within the next two weeks, all my ATPL exams within three weeks, and expect to renew my IFR rating (adding GNSS and ILS endorsements to my VOR/NDB rating) at the end of next month. I am pretty sure I am the type of person Air NZ is looking for, and I know I am not alone. The eight suitably qualified people which they mention must all be my friends, as I know at least this number of people who are good to go.

Once again, thank you for taking this action.

I would like to be put down as a co-submitter for the ESID submission. I am currently a C-Cat flight instructor who has a CPL, MECIR, and all ATPL subjects complete.

Having just gone through the rigmarole of trying to find a job in New Zealand, my view is that there seems to be a shortage of pilot jobs in New Zealand instead of a shortage of 'qualified pilots'. Seven of the nine people I trained with have had to move overseas (mainly Australia) to find work. They all left with a CPL, MECIR and ATPL subjects and most had 250+ hours, all very close to the part 121 requirements. As for the people I currently work with, at a training organisation, a large proportion have 500+ hours, a MECIR ,100+ instructional hours, and also have an application in with Air New Zealand. I imagine that, should the ministry look at this training organisation and in fact most of them around New Zealand, that they would indeed find more than enough 'suitably qualified pilots' for the job.

I currently have 330 hours, with an instructor rating, an uncurrent (but able to get current) MECIR and all my ATPL subjects. At my current organisation, I would have the requirements for Part 121 in six months time.

I would like my name to be added as co-submitter in the submission to MoBIE to fight against the intake of foreign pilots in NZ. The general

37 aviation industry is an extremely tough market. Both my partner and I trained in NZ but have had to flee our beautiful homeland and families to get jobs in Australia where not only will they take us on, but the pay is significantly better and I now actually have a shot at paying back my student loan. We would love to come home, but we just would not have the opportunities or living conditions that we have here. In Perth, we are surrounded by Kiwis who have come here for the same reason. I dread to think what will happen to Air NZ's pristine reputation when it tries to achieve an influx of non-English-speaking foreigners.

I am currently a commercial pilot with multi engine instrument rating and C-Cat instructor rating. I have just read your article and I find it hard to believe what was written. I have a loan of upwards of $100k+ and see no current vacancy available in any of the flight schools in NZ. It is due to the fact that Air NZ is still not taking senior pilots from flight schools, therefore resulting in no movement in the aviation industry in NZ. I am disgusted by the fact they want to hire foreign pilots instead of giving opportunity to senior pilots installed in many of our flight schools in NZ, which could probably help my chances in getting an open vacancy in one of these schools. I am pretty much aware of the politics behind this decision and the advantages this new rule will have for Air NZ, but the magnitude of this decision on new young Kiwi pilots like me would be unbearable.

What is happening here is outrageous with regard to New Zealand aviation employment. I guess I have an interest in this as I have a daughter and future son-in-law who have invested a heck of a lot of money into being qualified as New Zealand pilots, only to be faced with what is looking like a bleak future. They, like many of their generation, are considering going overseas.

Also as I see it, Air New Zealand is owned by New Zealanders (since they got bailed out to close on a billion dollars when they hit the wall over the Ansett debacle) and New Zealanders have spent a small fortune loaning to prospective pilots through the student loan scheme, only to be now told that the kids they loaned the money to are no good and the airline that they own (and like to call their own) is going to hire foreigners, with foreign licences and foreign certificates.

We all know that this is really just a lot of sabre-rattling towards the likes of ALPA to lower pilot costs. No one would deny them that, but they could do it in a less destructive manner to an innocent party, which is New Zealand's struggling General Aviation community.

38

Please add my name to the co submission. I am an ATPL with 4300 hours, 3000 of which is multi crew. I have a type rating on the B1900.

After gaining my CPL, I did some volunteer work towing gliders in Taupo to keep current and was looking vigorously through employment options in Africa and Australia for about nine months before finally finding work as an instructor in Hamilton. I have had my application in with Air New Zealand for about four months with no request for an interview, yet I meet all their requests and have UE.

Within the Link group, we have hundreds of qualified and suitable pilots to fly the jets. They are good enough to represent Air NZ on the Links; it is unfathomable to believe they are not suitable to represent us on the jets. Within GA, we have plenty of pilots who need nothing more than a small leg up to get that first job, then they are away laughing. To employ offshore pilots will no doubt bring GA in NZ to a halt. Many aero clubs are already struggling or have failed. Air NZ, which prides itself on being Kiwi, is turning its back on the part of the industry in NZ that has supplied it for so many years.

Please add me as a co-submitter in your submission to the MoBIE. I hold a New Zealand CPL and an Australian ATPL.

I trained in New Zealand a number of years ago and then moved to Australia when the opportunity to attend an Australian University Aviation Programme came up. Once I completed my degree, I moved back to NZ to look for flying work. I did not hold or have any interest in an instructor rating. I soon found that job opportunities were basically non-existent to a person in my position. Any job that was going - even scenic flying - had an additional requirement for an instructor rating, mountain flying course or ATO time which I simply did not have or could not afford. After a year of looking and saving my pennies doing other work, I left for Australia again where I quickly got my first flying job. In five years, I accumulated around 3000 hrs and an Australian ATPL.

There is no valid excuse for hiring foreign pilots. I would love to fly in NZ again and for the National Airline; however, they have to start paying better salaries to encourage those experienced pilots overseas to come home. If they did this, they would have no problem finding experienced crew.

39

I have been awaiting an interview date from Air New Zealand since February this year. My application has been listed on the Air New Zealand Careers site as "In Progress" since that time. After repeated emails to Air New Zealand HR, I have not had any reply about when I could expect an interview.

As I moved overseas to seek work as a pilot three years ago, I have returned many times back to New Zealand over the last year to pursue my ATPLs and get my licence re-current (have yet to renew my IFR within NZ) specifically for entry into Air New Zealand. I have more than 1700hrs TT and 1000 PIC on the Cessna 208B Caravan, meeting all the requirements.

For Air New Zealand to turn around and say there are not enough pilots is a blatant lie. Within the company I work for in Indonesia, there are Kiwis who want to return home and have applied to Air New Zealand and we all meet or exceed the minimums required by the company - at least six pilots.

I'm disappointed in Air New Zealand for requesting to have aeroplane pilot added to the skills shortage list. There are many Kiwis who were forced overseas to find work, with the goal of returning home to fly, and Air New Zealand has decided to prevent them from returning through this endeavour.

Very sad day for New Zealand aviation and Air New Zealand...

I would like to be a co-submitter against the proposal to place Aeroplane Pilots on the ESID list. I hold a NZ CPL and have found it extremely difficult to find any flying jobs at all, with very few jobs advertised.

I would be so damned angry if I had to start competing with foreigners for flying jobs. It would feel like I'd been betrayed by my own government. I have stayed in NZ to tough it out, stayed when I've watched countless friends go worldwide and do so much better. The rewards for sticking it out and being loyal to NZ should be beginning to appear in good pilot job opportunities soon, but not if we have an influx of foreign pilots! What sort of image is it when they're advertising for "Air New Zealanders" while they're actively pursuing foreign pilots?

And to be shafted by this nation's airline, too, makes me reluctant to choose that career path. They want us to have "UE". What does University Entrance matter or mean? I got 6th form cert and unit standards; I don't even know if I have "UE". I started by instructing part time for three years, whilst working night shift at a sawmill. I then got the 500 hour minimum and scored a parachute drop job for a 12-month contract. I was without a job for a few years as there were very few available due economic downturn. I then did an aircraft engineering course so I

40 could at least work in the industry and hope to meet employers that way. I then worked another year parachute dropping but the money was so s**t (less than $29,000 for the year), I've returned to engineering.

I now work assembling kitset aircraft full-time, and instructing in the weekends, and contract out to skydive companies for temporary work.

I wait and watch for more flying jobs.

I am very close to having Air NZ Group requirements. I have more than times the minimum total hours.

I have more than 1200 turbine hours, 26 hours multi. I passed two ATPL exams, but they may have expired.

To fulfil Air NZ group requirements, I would have to sit IFR flight test and do 15 hours of night flying, all of which is beyond my financial means.

I am currently in the MEIR phase of my training. I will shortly be moving onto the CPL phase. I would like to be added as a co-submitter.

This news came as a great surprise to me as my course is strictly audited by Air NZ, so that when we finish we are effectively ready to become FOs on the Beech. It begs the question of why Air NZ would have us training to their SOPs when it has no interest in hiring us!

Another thing that worries me is that if Air NZ does go offshore for hiring, all the highly skilled pilots already in our GA industry will get overlooked. This will make it harder for me to find a GA job in the future. New Zealand is well known for its standard of pilots and it is disgusting that Air NZ would want to look elsewhere when other airlines often look here!

Thank you very much for helping and alerting everyone to this.

I would like my name to be added as a co-submitter in support against hiring offshore pilots in New Zealand.

I have recently completed my commercial licence and multi engine instrument rating with IAANZ and I am being forced to seek work overseas to build hours to enable myself to be accepted into any airline back here in New Zealand.

41

The only difference between being hired and not being hired for me is the sake of a few hundred hours. It seems wrong that I have to go out of my comfort zone with such big debt to obtain what I need to come back, jeopardising myself financially, my lifestyle and quite possibly my health. Also, once I step out of the country, interest starts on my student loan so I’m really in a lose-lose situation! No wonder people think twice about coming back. After making such a major completion here, with a $100,000 loan, then having to be forced to take the hard road!

I have worked for an airline for 13 years and as my father was a pilot I share his same passion for flying. One of my goals in life is to fly for the same airline that my father flew for and carry on the legacy. As close as I am now, it seems that my dream could be taken away in an instant by hiring offshore. I am not the only one in this situation, I know dozens of GA pilots ready or very close to being ready to work for the Air New Zealand Group but it seems we will not be taken into consideration before outsourcing. One of the tedious qualifications: some people may not have is UE and if this is the only thing holding them for flying for their own country and jobs get outsourced, then this particular airline really does have no heart, which I may well have found out over the years anyway!

Isn’t Air New Zealand about NZ citizens flying for the airline? Having our own local knowledge to give to the passengers over a PA. International maybe a different story but domestic flights are also the most scenic in the world. If I flew the length of the South Island, I think I could talk continuously.

I would like my name to be added as a co-submitter. I am female and 21yrs old.

I am currently working at a flight school, previously worked as an Aeronautical Engineer Apprentice to gain enough money for my study towards gaining my PPL, CPL and then C Cat. I have dreamt of being a Commercial Pilot since I was 11. I have been flying since my 16th birthday, but have not been able to make my dream of getting my CPL come true due to financial difficulties. The change in student loan rules and regulations hasn't made the journey any easier. I am currently working a full-time job as an Aviation Operation Support, and work after hours (20+ hrs) at a local pub to be able to pay for my flying. I would be terribly disappointed if Air NZ or any other NZ airline were to get their pilots from overseas while there are my many competent New Zealanders who could do the job, and would love to do the job, but are hindered by student loans and getting their foot in the door. I plan to gain my 300 hrs by getting a PPL, CPL and C Cat and then going to South Africa, flying single engine over there to gain the hours I need to apply for Air NZ.

42 It's a tough road, but I'm willing to do anything to make my dream come true of being a Commercial Pilot, even if it means having to leave the country I love.

I am currently completing my MEIR at Canterbury Aero Club and finished my CPL(A) there last year. Please could you add my name to the list of co- submitters.

I attended the University of Canterbury after finishing school as many in the airline industry who I'd talked to recommended that a university degree would stand me in good stead for a career as a Commercial Pilot. I ended up studying two degrees: engineering, BE(Hons) and commerce, BCom(Hons). Now, working an engineering job four days a week while I complete my MEIR (I am a self- funded student) I'm looking dejectedly at my career opportunities in aviation compared to becoming an Engineer or an Economist.

To see that there is some question involved in the skill level required to be a pilot also astounds me; I'm working just as hard if not harder to complete my flying training as I did at uni and the skill level required is every bit as high, in my opinion. However, given that pilots start earning about 50-70% of a university graduate salary, it is easy to see why a salary comparison may indicate that pilots are less skilled. In my opinion, this certainly doesn't reflect the truth!

As part of my commerce studies, I had a work experience placement with an Investment Banking firm. I was in the Corporate Advisory department and the project I was assigned to involved advising a major SOE (not Air NZ). Much of the advice/information we put in to the presentation came straight from Google searches. I was astounded. I'm sure this Investment banking firm was charging the SOE a small fortune for this "corporate advice". When I asked the senior advisor why the SOE didn't just do some Google searches themselves, he replied that it was all about building relationships with clients. Obviously a high level of skill is involved there (YEAH RIGHT!)

Thank you for taking on this challenge.

I request that my name be added as a co-submitter in relation to stopping Air New Zealand in its attempt to add pilot to the Immigration skills list.

I am a young pilot with a massive student loan, more than 1000 hours including more than 50 night hours, all my ATPL theory completed, instructing experience, ATO experience and currently sitting in New Zealand unemployed desperately seeking work in the aviation industry.

43 I have been through the interview process for the Air New Zealand Regionals almost one year ago and was asked to gain some extra life experience and customer service skills and then come back to them again in one or two years. I understand that completely and to me it indicates that they have a good selection of pilots meeting their requirements and can afford to be quite discerning as they would temporarily turn away a suitably qualified New Zealand pilot like myself.

I have previously gone offshore to find aviation employment and gain experience to try to join Air New Zealand at some stage.

Recently, remaining in the South Island has been important to me but finding aviation employment down here has been fruitless to the point where I have even spent a small period of time on the unemployment benefit. I will now have to move offshore once again to hopefully find employment in the aviation industry and move on with my career.

From my experience flying and meeting pilots from around the world, New Zealand-trained pilots are amongst the most highly regarded in the world and to think that Air New Zealand desires to look elsewhere when there are local pilots like myself with huge passion for the industry, the experience and the skill does not sound right to me at all.

I wish to put my name forward and added as a co-submitter. I believe it is highly unfair that Air NZ is overlooking Kiwi pilots and planning to employ foreign pilots. With a slight change, a step could be made to train newly qualified CPL students to the airline industry standards without having Air NZ and Kiwi pilots both going overseas for employment opportunities and new pilots.

I am currently studying at IAANZ as a AIC student and I am working towards gaining the requirements needed. I am about to sit my PPL flight test and have almost finished my CPL subjects. I know we are not promised any job at the end of the AIC course but the term “foot in the door” has been thrown around every now and then. I understand the complications that are involved in being hired as a low hour pilot but if we are having to compete with pilots worldwide for a job in our airline our “foot in the door” is an over statement in my opinion.

We have plenty of C, B, A CATs more than worthy to have the right hand seat in the Air NZ fleet; the shortage of pilots Air NZ is due to experience

44 can be overcome with a little creativity and a helping hand from Air NZ to train young pilots and recycle the instructors at training organisations and promising reasonable employment within the country.

I find it outrageous that Air New Zealand will be potentially looking for overseas pilots. Please add my name to the list of concerned pilots. My experience and qualifications are more than sufficient for all the Air NZ roles; they include NZ passport, all ATPL subjects, 2000 command hours, more than 1100 hours of that IFR in high-performance twin turbines and more.

I have been flying in Australia for the last five years and would love to return to New Zealand and be close to my family, but the competition for jobs there is too much and I have been unsuccessful in my attempts.

The drop in pay would also be an inhibitory factor in that the NZ aviation scene is devoid of fair and just pay. However this is because of the oversupply of qualified and willing workers.

I am 23 years old and have lived in NZ for the past 14 years. I was born in Mumbai, India but I am a New Zealand Citizen. I completed my flying training at Ardmore flying school and hold a CPL, MEIR, Frozen ATPL, more than 430 hours total flying time and I am currently completing a Bachelor of Aviation degree with Griffith University in Brisbane.

I personally think that this [proposal] is highly unnecessary due to the fact that there are so many qualified pilots in NZ. I agree we may not all have the hours but if companies in our own country won't give us the chance to build them, then who will? We work and study hard to gain all these qualifications, not to mention take on a heavy loan just so we can achieve our dreams. It is very disheartening to see that NZ companies won't support their own students.

I have been searching for a job as a pilot for the past couple of years and still haven't managed to get my first break. All we need is a break so that we can build our hours and achieve our dreams. I would love to stay and support the

45 country I've grown up and give back to the community by serving for the national carrier but if this falls through then I may never get a job as a pilot in New Zealand and I will be forced to leave the country and look for employment elsewhere.

This is my view on this situation. I vote strongly against having foreign pilots to fly for Air New Zealand as I think there are enough qualified pilots sitting around with nothing to do, as no one wants to give us an opportunity. The government gives us student loans of up to $100,000 to support us and our own national carrier doesn't want to promote its students and employ us. I think this is unfair and leaves us with no other choice but to leave the country.

I oppose this proposal. I am 18 years old and currently hold a PPL with around 80 hours flying time, and am working towards my CPL part-time. I am paying for it as I go rather than by getting a student loan, as I am also studying at Massey University via distance learning. I have just completed my Bachelor of Applied Economics, minoring in Finance, and have just started a Master of Management.

My goal is to fly as a commercial pilot for Air New Zealand, and feel that this proposal will significantly reduce my chances of achieving this. I look at this situation from an economic perspective (due to my tertiary study); one point to note with the aviation industry is the long training time required in order to meet Air New Zealand's employment standards. Consequently, when there is a shortage of pilots and more people decide to pursue this career, it will be some time before any new pilots are in a position to be hired; this means that there would be no long-term shortage of pilots.

Another point is that any foreign pilots that Air NZ does decide to hire (if this proposal is successful) are possibly the ones who do not get hired in their own country, and are subsequently "from the bottom of the barrel"? Are these the types of pilots that the New Zealand aviation industry needs?

I hope my point of view is helpful, and would appreciate it if my name could be added to the list as a co-submitter.

46 From my point of view as an A Cat with 30 years in the industry, it's not that we don't have enough pilots; it's the gap between our new CPLs and their first job. We have sold the sizzle to hundreds of students that the airlines are looking to employ. What they are not told is the requirements to get that interview or the job.

I have CV after CV arriving from these 20-22-year-old new CPLs who have been trained by the large sausage factories. If Air NZ puts its name to these large schools, then maybe as a small solution it might consider taking these kids on in a cadet programme as 2nd officers on a reduced salary and bond them for a number of years. GA in NZ is a hard road and the jobs just aren't there as they were once. I know a number of highly qualified pilots who have gained experience overseas (2000+ Twin Turbine etc) and have sent applications to Air NZ and have been turned down because they do not have a Degree or UE. Ask yourself! I have noticed that since Air NZ contracted its recruitment outside, things have changed.

Our industry once had an apprenticeship where we all started and worked our way through. Today generation expects to go from CPL straight to the left seat and when they can't, they just give up. How many of these new CPLs from the past few years are working as pilots? I have a young instructor working for us who was one of 94 that went through the sausage factory in Canterbury and of the 94 graduates only three are working full time. These poor kids have huge student loans and no hope of a job because there's no pathway in NZ for them. This is the real issue. Maybe Air NZ can re-think its system.

Can you please add my name as a co-submitter. My son had to move overseas after completing his pilot training as companies in NZ were not taking on inexperienced pilots and as a result he doesn’t meet the listed requirements to gain employment in New Zealand now – he has had to stop flying and retrain in another career in an attempt to repay his very large student loan which was taken out to train as a pilot. Also, the government is no longer giving student loans to fund the whole of the pilot training which will prevent the majority of people who wish to train doing so.

It’s devastating that he hasn’t been able to continue flying as it is his passion and lifelong dream and having flown overseas means he doesn’t have the requirements to fly here and financially can’t afford to fly for a small company with such a huge student loan. I’d much prefer him to be here in NZ instead of overseas doing something else.

47 My son has spent 100k + getting his CPL etc. In NZ, we have lots of small flying clubs and a lesser number of flight training schools; whichever way you choose to attain your CPL requires a lot of time, money and dedication. As far as I can see, for many years Air NZ has reaped the benefit of these clubs / schools, giving minimal support.

This is just another kick in the guts for the pilots and GA from a piss-poor company. On another point, I am appalled in the new attitude by the CAA regarding "best meeting the needs of its clients" thus crippling GA with huge and ridiculous charges.

As parent of a young commercial pilot (struggling with a massive student loan) who meets all of Air New Zealand's current employment requirements but still cannot get a foot in the door with our national carrier, I would appreciate your advice as to how to add my name as a co-submitter to your group submission to the MBIE's Preliminary Indicator Evidence Report.

Please add my name to your submission regarding the skills shortage list. I am a 3500hr flight instructor and meet Air New Zealand's requirements.

Some of the lowlights of my experiences in the New Zealand aviation industry include:

- Spending my first year as an instructor working close to 100 hours per week at three jobs to earn less than $200 most weeks.

- Being offered a "job" paying $10 per flying hour (less than the minimum wage, and in effect also payment for only a fraction of the hours one would spend at work).

- Having to move to the other end of the country to get a job paying enough to live on (still barely more than minimum wage).

- Taking a 25% reduction in work hours and therefore salary; whilst still working a rolling roster pattern thus prohibiting secondary employment.

- As a multi-engine IFR B-Category flight instructor with 3500 hours and seven years instructing experience, still earning less than the $45,000 salary required for an occupation to be considered "skilled;" working a minimum of nine hours a day, usually without breaks; and holding out little hope of ever being able to own a house, pay back my still huge student loan, or retire.

48

If there is such a shortage of pilots, then why are so many of us, after investing so much time and money, living and working in such unreasonable and in many cases downright illegal conditions?

Two friends of mine who well exceeded the reqs for regionals have just had interviews last week and missed out. Got told to go away and try again in 12 months. HR wouldn't say why... it all sounded a bit fishy to me. They need to stop being so picky. It seems a lot is based on if a senior pilot doesn't like a candidate, he only has to whisper to the interviewers that the candidate is 'whatever' then he/she gets a big black mark from the start and viewed with tinted glasses.

I was fortunate not to have annoyed anybody with clout in Air NZ in my career to date. A personality issue with ONE PERSON already employed by Air NZ should not completely influence a candidates chances of a job, yet it does. I know at least three people in this category, careers blown to pieces. Or the other thing: someone who knows someone important or having a daddy who works for Air NZ getting an easy ticket in over someone with more experience; it happens all the time. This is something everyone has just had to come to terms with as the status quo.

My personal theory is that Air NZ HR has been deliberately hard on candidates recently and failing them so that it can prove that there are not enough pilots with the right qualifications to be hired, and thus get its immigration proposal approved as a back-up for the future when Air NZ runs out of the 'cream of the crop' pool of NZ pilots. Maybe I am being a bit 'conspiracy theorist' about this, but I wouldn't put it past management to pull a stunt like this. They can be smart and cunning when they want to be, as I've seen as an xxxxxxx in Auckland for four years.

I have three good mates who meet the min reqs and have put in applications months ago and have heard nothing.

Air NZ doesn't need pilots with thousands of hours for regionals. My friend got into Qantas Link with 400 hrs total time five years ago on their training programme. He is now captain of a Q400. There would have been a lot of good pilots out there in NZ on a good wage and career a long time ago if Air NZ had its act together. Apparently a 3000 hr instructor isn't good enough...

The pendulum has now swung in favour of pilots, and Air NZ doesn't like it because it means they don't hold all the cards anymore. This really worries them I think, especially at wage negotiations. Tough. It's now time for them to come to the party.

49

I am a 20-year-old pilot, CPL, all ATPLs, MEIR, BGT, C-Cat and am currently working as an instructor in Fiji, away from friends and family purely to build hours. I would much prefer to be in Air New Zealand as I know people with similar experience to me in the Link system.

This proposal by Air New Zealand is unfair, shocking and disappointing and does not make me want to continue updating my application to them when they want to hire foreigners. The whole belief in Air NZ is we have the best pilots, long trained in the system in NZ so that by the time they are jet captain they have huge amounts of experience, from GA all the way up.

Seeing that replaced by foreigners will only degrade a reputation which has stood for many years. Three of my immediate family have flown / are flying for Air New Zealand and none of them knew about this.

I am totally opposed to the Air New Zealand proposal to employ overseas pilots. This is because I am aware that there are a number of flying schools in New Zealand that currently have good quality students that fulfil these requirements and it is outrageous that these students, after having racked up huge debts, in most cases, to become pilots now may struggle to get employment with their national carrier and be forced to look offshore for work.

As an Air New Zealand frequent flier and Koru Club member, I am really disappointed in this proposal and hope that Air Zealand will continue to take locally trained and sufficiently qualified local pilots in preference to overseas candidates. I would have thought that Air Zealand would have been keen to continue to support locally qualified suitable candidates and continue to work with the flying schools and local communities that provide these people.

I am a New Zealand-born pilot living and working as a training captain on a 30- seat turbo prop in Perth, Western Australia.

I am disappointed that Air New Zealand feels the need to go down this avenue when there is an abundant pool of pilots who meet its experience requirements and aren't getting called up for interviews. I believe that I am one of these pilots.

50

I am 29 and was born and raised in Auckland. I completed my CPL at Ardmore flying school. Upon finishing, I found it hard to obtain flying work so I moved to Australia where I found fast progression due to the vast general aviation scene in regional Australia. I do not regret this move and was happy to go down a path that was different to my father, who incidentally is a [xxxxxxxxx] at Air New Zealand.

At this point, I have 3000 hours, training captain experience on a regional turbo prop, an ATPL and have even demonstrated my abilities to undergo jet training by obtaining my B737NG type rating through Boeing directly.

Growing up as part of the Air New Zealand family, I had always dreamt of continuing the legacy of working for our national carrier. This is another kink in the road that myself and I'm sure many other budding Air New Zealanders have to contend with, while our CVs and resumes sit gathering dust in the depths of the HR department.

I can understand that the industry is vastly different to the good old days when Air New Zealand was hiring at will; however, I believe that there is still a steady stream of pilots eagerly looking to join Air New Zealand with potentially more experience than many of the pilots they hired back then.

I was shocked to find out that Air NZ is trying to add "Aeroplane Pilot" to the list of jobs with skill shortages. Please add me as a co-submitter.

I am already employed by Air New Zealand as a [xxxxxxxx]. Several times in the last four years, I have been told by the company that they have too many pilots, and have been offered leave without pay and threatened with down-training and even warned of possible redundancy. We are currently experiencing a period of growth, but I find it very hard to believe that there aren't New Zealand residents out there to fill jobs, and I know of many people in GA who are working towards qualifications for a job with Air NZ.

I strongly suspect that Air NZ will be trying to use the excuse of skills shortages to hire foreign pilots at reduced salaries and conditions, and thereby increase their profits.

51 Air New Zealand has known that there was going to be a squeeze on recruitment years ago, hence why you've seen the start of the "preferred pilot scheme".

Air New Zealand at the time of this document was seeing its Link pilots leave in droves to the likes of Pacific Blue/Virgin Australia, Jetstar and JetConnect because there was no movement to "the mother ship". I know of other stories where guys in the Link carriers stayed there for years after passing a Mainline interview and passing up other jet opportunities, only to be told on re-interviewing that "they were not dedicated enough" to go to Air New Zealand Mainline. (Air NZ HR department is nothing short of corrupt and unethical, in my opinion.)

Whatever the smoke and mirrors they're playing at, this "shortage" is self-inflicted and their manipulative practices should be exposed.

To add more fuel to the fire, I currently work for a Part 121 jet operator flying internationally out of NZ and we are losing several people to Air NZ Mainline.

I was sent some very disturbing news from my wife that Air NZ is recruiting pilots outside of New Zealand. I have spent the last seven years working abroad because I was told that although I met all the requirements to get an interview, I was getting too old...I was 32.

I was told I would never be a captain and with so many people on yes letters, by the time I could be interviewed, younger people would be more likely to get interviewed instead. I have more than 7000 hrs of which over 3000 on B777, NZATPL (I even did my ATPL and type rating with Air NZ on the B777), unrestricted B Cat, Bachelor of Aviation, two years with Eagle Air, 14 years commercial flying and I still can't get an interview.

Are people in New Zealand really going to believe that Air NZ can't find local pilots? This is incomprehensible.

I would like to add that I unsuccessfully interviewed for the role of FO for Air New Zealand last year. I felt the breakdown of my perceived deficiencies supplied to me in the phone debrief was flawed and inconsistent with my performance in the interview and felt the HR person was struggling to verbalise the reasons why I was not successful. I strongly feel that my age (41) was the main reason why I was unsuccessful; however, this would be near on impossible to prove. There were other unsuccessful pilots of varying experience in my same interview session who were also not successful.

At the time of my interview, the night requirement was not essential and for most pilots with the basic CPL night rating it would have meant minimal flying to achieve the desired 25 hrs.

52

I still feel I am more than qualified for the role of FO in ANZ Link. I have now taken a sabbatical from flying after nine years in the industry, as it is virtually impossible to get a chance to advance in New Zealand. I hope to return to flying in the next year or two.

I will be eligible for an Air NZ role with more night hours, BGT and other ATPL exams and IFR renewal, all relatively straightforward and am working on these now. My 2 cents: Pilots in New Zealand are aware of Air NZ's recruiting drive and the movement it will create in the industry and are quickly gaining the experience to be eligible to apply to local airlines. Many others are currently overseas gaining experience because, in the past, getting a good airline job in New Zealand was difficult. These expats and pilots here will be trying to get into Air NZ and it would be a pity if they were turned away in favour of slightly more qualified foreign nationals.

In regards to pay bracket, Eagle Air does not qualify for the minimums of 45 grand a year for the skilled labour application although Mount Cook and Air Nelson currently do. Eagle pays the FO $44k If they have ATPLs or $42k if they don't have frozen ATPL, as the starting wage.

I am opposed to this, as the world is full of Kiwi pilots who could not get a look in with regards to a flying job back in New Zealand. To imply there is a shortage of qualified NZ pilots is simply false.

I myself have spent the majority of my aviation career abroad obtaining the required qualifications along the way from different countries, in addition to NZ qualifications, and logging 1000s of hours in airline transport aircraft.

I now suspect age is a factor preventing me from getting an interview. I am 48; a colleague of mine also 48 and with 10,000 hours is finding the same situation.

Currently I am a Q400 Captain with 7800 hours, 2000 hours on jets, an ATPL from JAA, Australia, PNG, and NZ CPL with ATPL subjects.

Please add my name as a co submitter and thank you for addressing this issue.

53

From my own experience attempting to gain overseas employment as a pilot, I know that every national, flag-carrying airline is fiercely supported by its own government's policies to protect their own locally born and trained progeny. There is almost nothing more sacred than nationals flying as pilots in a national airline. It is normally not possible to even receive a reply as a foreigner to an employment application from such a foreign carrier. I cannot understand the logic of this new idea.

NZ would surely be globally alone in allowing the hiring of foreign-trained crew members. Are we as New Zealanders not proud of our nationally trained product?

Do the flight training schools who train these NZ pilots not support regional economies with their requirements? Do these schools not involve other NZers by using fuels, by having maintenance and avionic work done, by using local builders and other tradesmen, and do those student pilots not eat and sleep in NZ? They are all people who will vote in NZ elections and pay taxes to the NZ government, which owns the majority equity stake in Air New Zealand, so that same government-owned airline can repay those loyal folk by NOT offering them well paid jobs in a prestigious position.

It is an outrageous idea to open the Essential Skills in Demand List to include "Aeroplane Pilots". As a New Zealand voter and pilot, I strongly oppose the move.

As a trainee commercial pilot at the International Aviation Academy, when I finish my course (Diploma in Aviation - Airline Preparation) I will have PPL, CPL, MEIR (around 200hrs), ATPL subjects, a CPL night rating and a $100,000 student loan.

But in order to get into the airlines, I need a full ATPL, 100hrs Air Ops, 25 night hours and 500hrs total at the bare minimum and it seems to me that there is a huge gap in the training process.

I want nothing more than to be a pilot for Air New Zealand; it is my dream and the reason why I decided to train as a pilot. It's going to be difficult for me to try to get all the requirements for an interview with Air New Zealand without heading offshore and with this new proposal to hire pilots from overseas, the job I hoped would some day be reachable is now something for which I will have to compete with all nationalities for a job as a pilot in my

54 own country’s airline.

I understand the reason behind this change but disagree that there are not enough pilots available in New Zealand for hire. There are hundreds of pilots like me who want nothing more than to fly for their national airline, Air New Zealand, one of the best and most highly regarded airlines in the world, but are unable to even get an interview because we are struggling to get the requirements.

This gap in the training of pilots between a training organisation and the first air operations job is the reason behind the shortage of pilots available and I believe that rather than just give up on us and go for the easier option of hiring pilots from overseas, Air New Zealand needs to make the first step at fixing a problem that has been around for many years and is the main struggle of pilot training. I believe that cadetship programmes and further introduction and integration into an airline job should be encouraged by airlines and I’m sure the required pilots will follow.

I meet all the domestic fleet's requirements many times over, but I actually applied for the jet fleet with "confirmed positions for 2013." I met all of their requirements for those jobs when they were posted, too (I can't seem to find them online now).

They've just scared a friend of mine off. He's thrown his 'start date' letter in the bin and will be heading back overseas soon, so that's one less pilot in the pool.

55

The GAA pilot survey

The GAA pilot survey followed the same format as the NZ ALPA survey of its members. It contains responses and data from not only NZ-domiciled pilots, but also many ex-pat NZ pilots.

In summary, it comprises:

A list of the names of some pilots who currently meet the Air New Zealand experience requirements. These names were obtained by a survey carried out within the space of seven days and are only from pilots who had the opportunity to be notified and to respond. The individual survey forms are held on file and are easily verifiable.

A list of the names of just some of the pilots who are close to meeting the CAA and Air New Zealand experience requirements.

A list containing the names of a very small sample of pilots currently in training.

A list of names of the other co-submitters to this submission, and verifiable email addresses.

To aid the reader in understanding the abbreviations used in the comments of pilots, and in the pilot survey form that was used for data collection, these are listed below:

ATO - Air Transport Operations Part 115 - Adventure Aviation – Certification and Operations Part 121 - Air Operations – Large Aeroplanes Part 125 - Air Operations – Medium Aeroplanes Part 129 - Foreign Air Transport Operator – Certification Part 135 - Air Operations – Helicopters and Small Aeroplanes MEIR – Multi Engine Instrument Rating BGT – Basic Gas Turbine Rating ATPL (A) – Airline Transport Pilot Licence (Aeroplane) – required before being promoted to a Captain ATPL (H) – Airline Transport Pilot Licence (Helicopter) CPL – Commercial Pilot Licence – required before a pilot is permitted to be employed for hire and reward. PPL – Private Pilot Licence – the first basic licence which enables a pilot to carry passengers, but not for hire and reward. C Cat – C Category Flight Instructor B Cat – B Category Flight Instructor A Cat – A Category Flight Instructor

56

A copy of the pilot survey form that was sent out:

Question Answer Do you hold any of the following? An Airline Transport Pilot Licence (the ATPL) Any Airline Transport Pilot Licence subjects A Multi Engine Instrument Rating (MEIR) A Basic Gas Turbine Endorsement A Foreign Pilot Licence

How many hours do you have on single engine aircraft? How many hours do you have on multi engine aircraft? How many hours of Air Transport experience do you have?

Please select the applicable "Parts" of the CAA Act you have flying experience in: • Part 125 • Part 121 • Part 129 • Part 135 • None of the above (tick the box)

Do you aspire to fly any of the following? (select as many as you wish) • Beechcraft B1900 • Dash 8 Q300 • ATR 72 • Boeing 737 • Airbus A320 • Boeing 767 • Boeing 787 • Boeing 777 • Boeing 747 • None of the above (tick the box)

Please indicate your current immigration status: • NZ Citizen • Australian Citizen • NZ Residency or holder of a work permit • Married to a NZ Citizen or a Resident

Are you employed as a pilot by: • Jetstar NZ • Qantas NZ • Virgin NZ • Air NZ (including Air NZ Link) • Other… provide details below, or on a separate sheet Do you meet the amended requirements of Air New Zealand for Regional Aircrew roles? Please carefully read the attached sample information from Air New Zealand.

57 Pilots meeting Air New Zealand experience requirements (77)

Details not included in this version of the submission for reasons of privacy

58 Pilots almost meeting the Air New Zealand requirements (32)

Details not included in this version of the submission for reasons of privacy

59 Pilots in training or gaining experience (49)

Details not included in this version of the submission for reasons of privacy

60 Background of the lead submitter, Desmond J Lines

Started learning to fly in 1959 aged 16 while at Ranfurly District High School

First solo flight on June 14 1960 aged 16

Obtained a Private Pilot Licence on March 27 1962

Obtained a Commercial Pilot Licence on February 14 1964

Employed by NAC as a First Officer on September 15 1964

First Officer Douglas DC3 Dakota from Dec 26 1964 to Dec 26 1965

First Officer Fokker F27 Friendship from Dec 30 1965 to May 8 1971

First Officer Vickers V807 Viscount from Jun 1 1971 to Nov 23 1973

First Officer Boeing 737–100 from Dec 9 1973 to Feb 22 1975

Captain Fokker F27 Friendship from Mar 11 1975 to Dec 30 1983

Captain Boeing 737–200 from Jan 17 1984 to May 7 1989

Captain Boeing 767–200 from Jul 28 1989 to Jan 4 1992

Captain Boeing 747–200 from Feb 14 1992 to Mar 24 1999

Captain Boeing 747–400 from Jun 28 1999 to Aug 19 2004

Post-retirement from Air New Zealand, I have been involved in many educational aviation-related activities which encourage young people (intermediate school children and upwards) to seek a career in aviation.

61 List of co-submitters (239)

Details not included in this version of the submission for reasons of privacy

62 Australian ATSB Pilot Experience Study 2013

This report relates to pilot experience and performance in an airline environment.

The study was released by the ATSB (Australian Transport Safety Bureau) on July 17 2013.

63 InsertPilot experience document and title performance in an airline environment

Location | Date

ATSB Transport Safety Report InvestigationResearcn [InsertAviation Mode] Research Occurrence Investigation Investigation XX-YYYY-####AR-2012-023 Final – 17 July 2013

Authors: Melanie A. Todd, ATSB & University of South Australia

Dr Matthew J.W. Thomas, Central Queensland University & University of South Australia

Released in accordance with section 25 of the Transport Safety Investigation Act 2003

Publishing information

Published by: Australian Transport Safety Bureau Postal address: PO Box 967, Civic Square ACT 2608 Office: 62 Northbourne Avenue Canberra, Australian Capital Territory 2601 Telephone: 1800 020 616, from overseas +61 2 6257 4150 (24 hours) Accident and incident notification: 1800 011 034 (24 hours) Facsimile: 02 6247 3117, from overseas +61 2 6247 3117 Email: [email protected] Internet: www.atsb.gov.au

© Commonwealth of Australia 2013

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Addendum Page Change Date

Safety summary

Why have we done this report Significant debate has occurred within the aviation industry regarding the issues of pilot training and experience, particularly with regard to the introduction of new pilot training programs that are focused on training cadet pilots. The main concern being presented by some sectors of the industry that are not in favour of these concepts is that these low-hour co-pilots are not as competent as their high-hour peers. The ATSB gathered data from three airlines to explore the issue of pilot performance as a function of both flight hour experience, and entry pathway. Entry pathway analysis compared cadet pilots (who generally had not accumulated prior flight hours or experience) to those pilots who entered an airline after accumulating flight hours in other areas of the aviation industry. Data were collected on a number of metrics from simulator check flights, which covered non- normal operations, and line checks, which covered normal day-to-day flight operations.

What the ATSB found The overall performance of cadets and low-hour pilots matched that of their direct entry and high- hour peers. All pilots were marked as proficient at the completion of the check flights, with the only differences between the groups being a function of how many exceeded the required standard. The differences between the low and high-hour pilots in ‘meeting’ and ‘exceeding’ the standard across all metrics were variable within airlines and inconsistent across all three airlines. This suggests that the differences between the groups were not of a systemic nature that would highlight an area of concern for industry. While the metric normal landing showed a difference across two of the three airlines, none of the other required regulatory manoeuvres or technical metrics were significantly different in more than one airline. For non-technical metrics, both leadership and situation awareness were significantly different in all three airlines. Although this is understandable given the low experience of cadet and low-hour pilots, focused exposure to those metrics during initial airline training may reduce this difference as was seen in the data for cadets collected at the 5-year mark in one airline.

Safety message The evidence in this report indicates that the cadet pathway for low-hour pilots is a valid option for airlines. There was no evidence to indicate that cadets or low-hour pilots within the airlines studied were any less competent or proficient than their direct entry and high-hour peers.

Contents

Context ...... 1 Literature review ...... 3 General Aviation pilots 3 Airline pilots 4 Methodology ...... 6 Data sources 6 Design and procedure 6 Data sources 6 Independent variables 7 Dependent variables 8 Statistical analysis 10 Results ...... 11 Airline A 11 Simulator proficiency check 11 Line check 14 Airline B 16 Simulator proficiency check 16 Line check 20 Airline C 22 Simulator proficiency check 22 Line check 24 Discussion ...... 27 Simulator proficiency check results 28 Line check results 29 Limitations 30 Conclusion ...... 32 References...... 33 Sources and submissions ...... 35 Submissions 35 Australian Transport Safety Bureau ...... 36 Purpose of safety investigations 36 Developing safety action 36 Glossary ...... 37

ATSB – AR-2012-023

Context

Significant debate has occurred within the aviation industry regarding the issues of pilot training and experience, particularly with regard to the introduction of the Multi-crew Pilot Licence (MPL) by the International Civil Aviation Organisation (ICAO).1 The main concern being presented by sectors of the industry that are not in favour of the MPL concept is the possibility that low-hour pilots are not as competent as their high-hour peers. As part of this debate, two main issues are currently attracting attention and discussion. The first is a focus on the hours a pilot has accumulated, generally with an inherent assumption that these hours ensure a level of individual skill. The second is a focus on competency, both as an assumed result of flight hour accumulation and because competency-based training is quoted as the cornerstone of aviation training, in particular with regard to MPL. These issues and assumptions have received considerable attention following two high profile international aviation accidents in 2009, one involving a Bombardier DHC-8 at Buffalo, New York, and the other an Airbus A330, operating as Air France flight 447 (AF447), en-route from Rio de Janeiro, Brazil to Paris, France.2 The AF447 accident highlighted the issue of competency and, in particular, the relevance of current simulator and non-normal operations training for pilots, as well as raising issues around automation use and systems knowledge, both of which are subsets of pilot competency. Of interest is the fact that the flight crew of AF447 had a high number of flight hours, which appears at odds with the assumption that high flight hours will ensure adequate performance in a non- normal event. In response to the DHC-8 accident, which was viewed in part as being the result of an hours/skill issue, the United States Congress enacted legislation to increase the amount of flying experience that first officers would need, in order to enter an airline, to 1,500 hours. The Australian Senate held an inquiry into pilot training3 at the end of 2010 to explore the need to enact similar legislation in Australia. In response to the Australian inquiry, submissions from flight training organisations and airlines highlighted the importance of cadets as a recruitment option for the airlines, a system that has been in place around the world for a number of years. Cadets are pilots who, generally, have limited or no prior flight training prior to starting their cadetship, and are trained specifically for an airline at a flight training organisation. After training, these pilots enter the airline as a second or first officer, depending on the airline and its requirements. Those supportive of cadet schemes emphasise the ability of the airlines to ‘mould’ the pilots to the airline environment, thereby shaping their behaviours and instilling the required performance from the start of their training. Part of the justification from ICAO in relation to the introduction of MPL also highlighted these benefits, along with the use of competency-based training as a mitigator of the risks associated with changes in the training program, and the introduction of multi-crew cooperation techniques such as crew resource management (CRM) and threat and error management (TEM) as strong benefits of the changed program. Those who are not supportive of cadet schemes are of the view that in order to be a successful airline pilot, an individual needs to have accumulated flight hours either with the military, in general aviation or other (often smaller) airlines, prior to entering a major airline as a second or first officer.

1 ICAO (2006). Annex 1 – Personnel Licensing (10th edition). Montreal, Canada 2 NTSB (2012). Loss of Control on Approach Colgan Air, Inc. Operating as Continental Connection Flight 3407, Bombardier DHC-8-400, N200WQ, Clarence Center, New York, February 12, 2009. National Transportation Safety Board, Washington, US. BEA (2012). Final Report on accident on 1st June 2009 to the Airbus A330-203 registered F-GZCP operated by Air France flight AF447 Rio de Janeiro – Paris. Bureau d’Enquêtes et d’Analyses pour la sécurité de l’aviation civile. Paris, France. 3 Parliament of Australia Senate. (2010). Pilot training and airline safety. Canberra, Australia.

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Despite the on-going debate and regulatory guidance on pilot training, which outlines the minimum hours required and the areas that must be covered, there is very little research on the differences, if any, between pilots in airlines who have entered from these various pathways, including as a cadet. While there are some studies which have examined the effect of flight hours on accident risk; judgement; ability to interpret weather and one on the effect of flight hours on performance in normal flight operations, there is very little looking at performance in non-normal scenarios, specifically as a function of both flight hours and entry pathway. In this report, ‘entry pathway’ refers to the difference between cadets and direct entry pilots. Direct entry pilots enter an airline having already been licensed and have generally accumulated a number of flight hours. Direct entry pilots typically build up these hours in the military, general aviation (non-airline flying) or other airlines. This report differentiates between normal events, which are routine, expected events that do not require additional training or specific targeted intervention by a pilot; and non-normal events, which involve a non-routine event or problem with the aircraft, its systems, other crew, or the environment, which is not routine and is outside of what is expected in a ‘normal’ flight. The aims of this study are to: (1) test for a difference in performance in the simulator proficiency check for normal and non- normal operations, based on the entry pathway to the airline (2) test for a difference in performance in the simulator proficiency check for normal and non- normal operations, based on the hours experience of the pilots (3) compare the results with the authors’ previous study (Todd & Thomas, 2012), in examining if there are differences in pilot performance in the line checks based on entry pathway or hours. This study will also address some of the limitations of the previous study, which did not consider simulator proficiency data and entry pathway. It can be expected that if the concerns of sectors of the industry relating to low-hour/cadet pilots are valid, that high-hour/direct entry pilots will perform better. If ICAO’s stance on MPL and the airlines’ defence of cadets is valid, there will be no difference in performance or cadets will perform better than their direct entry peers.

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Literature review

There have been a number of studies into the effect of experience on performance of pilots, including the non-technical areas such as decision-making (Wiegmann et al, 2002; Wiggins & Bollwerk, 2006; Wiggins & O’Hare, 2003; Todd & Thomas, 2012), with many studying the link between experience and accident rates (Goh &Wiegmann, 2002; Groff & Price, 2006; Bazargan & Guzhva, 2011; Li et al, 2003; O’Hare & Chalmers, 1999). It is important to note that most of these studies use pilot populations that are quite different to airline pilots. In particular, most of the low experience groups in the following studies did not receive the same standard of training as airline cadets who, after initial accelerated competency based training, are transitioned to multi-crew operations in large, complex aircraft. One area of interest to researchers in the experience/performance debate is accidents involving flight into instrument meteorological conditions (IMC) by visual flight rules (VFR) rated pilots. That is, pilots who are not qualified to fly in instrument conditions, which require them to fly with sole reference to instruments such as when in cloud, instead of conducting the flight with reference to visual cues outside the aircraft. The focus of this research has typically centred on the aspects of decision making and pilot experience, with some studies finding an effect of low experience on accident risk (Goh & Wiegmann, 2002; Wiegmann et al, 2002).

General Aviation pilots The propensity for pilots of different experience levels to be involved in accidents has been studied with a number of different pilot cohorts. In general aviation, a review of 72 accidents which occurred in degraded visibility found no effect of total flight hours, nor years of experience, although they did find that pilots in the younger age group were involved in a smaller proportion of these kinds of accidents (Groff & Price, 2006). In a similar type of study, the effect of low experience on accident risk for New Zealand pilots in general aviation was reviewed with a particular focus on the concept that pilots with around 100-200 hours total time had a ‘special vulnerability’ compared to their colleagues with more than 200 hours total time (O’Hare & Chalmers, 1999). The same comparison was conducted for pilots with about 100-300 hours total time compared to the rest of the pilot population. Both studies found no evidence of increased accident involvement of low-hour pilots (O’Hare & Chalmers, 1999). Another study of general aviation pilots examined the effect of age, experience and gender on accident causation and found that lower experience pilots were more likely to make errors that resulted in an accident than their more experienced peers (Bazargan & Guzhva, 2011). However, they found that while lower experience pilots were more likely to be in an accident, the more experienced pilots were more likely to be involved in a fatal accident. The sample used by the authors included pilots with less than 100 hours and less than 100-300 hours, meaning while it may cover some commercial pilots, the sample is not representative of air transport operations. The authors also defined air transport pilots with 300-2000 hours of total time as ‘...newly licensed airline transport pilots’; 2000-5000 hours of total time as ‘...moderately experienced airline transport pilots’; and 5000 hours or more total time as ‘the most experienced pilots’ (Bazargan & Guzhva, 2011). Also in general aviation, a beneficial effect of experience on performance was found, particularly in the performance of older pilots (Causse et al, 2010). It was found that older, more experienced pilots outperformed older low-hour pilots who had around 90 hours total flight time. A similar study also found a ‘protective’ effect of experience against age related deteriorations in performance (Kennedy et al, 2001). However, contrary to their hypothesis, they did not find improved decision- making with increased expertise, although the results of their study may have been influenced by the expertise groups being very close (moderate versus high expertise, all with instrument ratings with VFR pilots excluded from the study entirely) (Kennedy et al, 2001).

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One study examining both retrospective and prospective indicators of accident risk also used flight hours as a metric, grouping them into hours flown in the last 6 months, 12 months and a pilot’s entire career. The author found that single-engine time in the last 12 months; piston-powered time for all three hours measures; and landings in the last 6-12 months were all significantly related to accident involvement (Hunter, 2001). However, an important caveat issued for this study was that the outcomes may well have been an effect of exposure and in particular ‘a pilot cannot gain the experience that is usually regarded as a protective factor’ without this exposure (Hunter, 2001). A significant effect for expertise was found when differences in perception of weather images as a function of expertise was examined (Wiggins & O’Hare, 2002). To differentiate between experts and novices, they classified experts as pilots who had accumulated greater than 1,000 hours cross-country flying (mean cross country experience 5,520 hours, mean total experience 6,873 hours) and novices as pilots who had accumulated less than 1,000 hours (mean cross country experience 281 hours, mean total experience 801 hours). In a later study examining heuristic-based approaches to in-flight decision making, it was noted that ‘greater levels of experience tend to be associated with the selection of more optimal alternatives, irrespective of the information acquisition strategy employed, but that this experience is defined by the hours accumulated as pilot in command rather than by the number of flight hours in total’ (Wiggins & Bollwerk, 2006). The authors also found a significant effect of the hours accumulated in the 90 days preceding the testing resulted in an increased likelihood the optimal alternative would be selected, thereby concluding that ‘...recent experience, rather than total experience, the license held, or performance during the familiarization scenarios, is most predictive of the selection of the optimal alternative’ (Wiggins & Bollwerk, 2006). This is an interesting finding in relation to the on-going perception within the aviation industry that total flight hours alone can accurately predict performance and mirrors an earlier study which also noted that task specific experience was more of a predictor of performance than total experience (Wiggins & O’Hare, 1995).

Airline pilots Interestingly, in a study of air transport pilot involvement in general aviation accidents, one study found that in general, air transport pilots (ATP) were safer than private pilots (Salvatore et al, 1986). The two groups had comparable exposure, that is, time in general aviation aircraft, but the ATP group were involved in fewer fatal accidents and fewer ‘pilot-induced’ accidents, indicating that the majority of ATP accidents were from factors not related to pilot skill (e.g. aircraft maintenance). One exception to this appears to be that ATP accidents more often involved aerobatic flight and for the ATP fatal accidents, nearly 50 per cent occurred during aerobatics. The authors note that ATPs tended to have less experience in the aircraft type for the fatal aerobatic accidents, pointing to a consistent finding in terms of experience (Salvatore et al, 1986). The authors also caution that with an increase in pilot experience ‘...comes the pilot’s willingness to encounter more challenging flight regimes and, perhaps consequently, to accept increased risk’ (Salvatore et al, 1986). This note is important to remember during any debate on flight experience and the performance of more experienced pilots. This concept is highlighted from a different perspective in another study examining the influence of flight experience on mid-air collision risk perception, which found that mid-air collisions typically involved highly experienced pilots and that high-hour pilots were less likely to scan properly for traffic and had become somewhat complacent given the low perception of risk their experience had provided, and the amount of successful flights they had completed (Shuch, 1992). There have been studies in the air transport or airline sector of aviation that examine accident rates and experience, including one which examined professional pilots’ risk of an accident as a function of age and flight experience. This study found that pilots with less than 5,000 hours were almost twice as likely to be involved in an accident as their more experience colleagues (Li et al, 2003). The authors found a stabilising effect once a total flight time of 10,000 hours had been accumulated. However, it should be noted that these pilots were all operating in the commuter or

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air taxi sectors of aviation (that is, not a major airline), which the authors note carries a 10 – 45 times higher fatal crash rate per pilot flight hour than major airlines. As part of a gender study examining accident risk for airline pilots, it was found that ‘airline pilots had less pilot-error accidents as experience (total flying hours) increases’. An effect of major airlines was also found, with pilots who flew for major airlines being less likely to have a pilot-error accident than those who flew for a non-major airline (McFadden, 1996). Of interest in relation to airline training, she also commented that ‘once pilots accumulate additional flying hours and training within the airline business, their pilot-error accident rates decrease markedly’ (McFadden, 1996). This statement appears to give some support to the idea that cadet training and development in a wholly airline environment will aid performance, with respect to a lower involvement in pilot-error accidents. This was also reflected in the findings of Salvatore et al (1986) above. A study of pilot performance as a function of flight hours in normal line operations found no statistically significant differences between low- and high-hour first officers or captains against a series of technical measures, although there were minor differences in non-technical measures as a function of crew composition (Todd & Thomas, 2012). There was a difference in the use of automation by low-hour first officers, who kept the autopilot engaged until a significantly lower altitude. For this study, low-hour first officers were classified as those with less than 1,500 hours, and high-hour first officers as those with more than 1,500 hours. For captains, low-hour was classified as less than 5,000 hours, and high-hour above 5,000 hours (Todd & Thomas, 2012). Despite the topic of pilot hours and performance attracting significant debate, there is little in the literature exploring this issue in relation to airline operations.

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Methodology

Data sources Data were collected from three airlines, one of which (Airline A) supplied data for one aircraft type, and two of which (Airline B and Airline C) supplied data for two aircraft types. All aircraft types are classified as large passenger carrying jet aircraft capable of conducting high-capacity regular public transport (RPT) operations. Performance measures were from simulator checks and line checks from each airline. De- identified demographic information, which included entry pathway and hours at entry, was also obtained. For Airline A, the performance of second officers was measured. For Airlines B and C, the performance of first officers was measured. All pilots held at least a commercial pilot licence and none were trained under the multi-crew pilot licence system.

Design and procedure Data sources Airline A Data were collected from proficiency check forms for all second officers who had entered the airline in the previous 13 years. The data were collected by the operator’s check and training captains during the pilot’s proficiency check in the simulator, which covered non-normal operations. A total of 473 records considered complete and suitable for analysis were received from the airline, covering simulator sessions (cadets n=78, direct entry n=395; low-hour n=69, high-hour n=404) and line checks (cadet n=22, direct entry n=175; low-hour n=23, high-hour n=174) conducted by the airline’s check and training captains. The airline’s flight training department oversees the calibration of check and training captains to ensure a consistent application of their rating system in both the simulator and line check environment. The check and training captains and pilots were blind to the specific hypothesis regarding entry pathway, flight hours and performance.

Airline B Data were collected from proficiency check forms for a selection of first officers on two aircraft types operated by the airline. The data were collected by the operator’s check and training captains during the pilot’s proficiency check in the simulator, which covered non-normal operations, and during the pilot’s line check, which covers normal operations. Inter-rater reliability and calibration was established by the airline and on-going calibration of the check and training captains by the flight training department occurs yearly. In addition, the check and training captains are provided with word pictures of performance at each of the five levels of rating (1=unsatisfactory, 5=excellent) for each measure being tested. When the data were grouped into entry pathway to test the effect of pathway on performance, a total of 116 records (cadet n=35, direct entry n=81) were completed and considered suitable for analysis for the simulator sessions (non-normal events) and 151 records (cadet n=45, direct entry n=106) were considered suitable for the line check data. When the data were grouped into hours below and above our thresholds to test the effect of hours on performance, a total of 169 records (low-hour n=19, high-hour n= 150) were complete and considered suitable for analysis for the simulator sessions (non-normal events). For the line check data, 168 records (low-hour n=10, high-hour n=158) were complete and suitable for analysis.

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The check and training captains and pilots were blind to the specific hypothesis regarding flight hours and performance.

Airline C Data were collected from proficiency check forms for a selection of first officers on one aircraft type operated by the airline. The data were collected by the operator’s check and training captains during the pilot’s proficiency check in the simulator, which covered non-normal operations, and during the pilot’s line check, which covers normal operations. Inter-rater reliability and calibration was established by the airline and on-going calibration of the check and training captains by the flight training department occurs yearly. In addition, the check and training captains are provided with word pictures of performance at each of the five levels of rating (1=unsatisfactory, 5=excellent) for each measure being tested. When the data were grouped into entry pathway to test the effect of pathway on performance, a total of 167 records (cadet n=33, direct entry =134) were completed and considered suitable for analysis for the simulator sessions (non-normal events) and 251 records (cadet n=56, direct entry n=195) were considered suitable for the line check data. When the data were grouped into hours below and above our thresholds to test the effect of hours on performance, a total of 167 records (low-hour n=26, high-hour n=141) were complete and considered suitable for analysis for the simulator sessions (non-normal events). For the line check data, 251 records (low-hour n=51; high-hour n=200) were complete and suitable for analysis. The check and training captains and pilots were blind to the specific hypothesis regarding flight hours and performance.

Independent variables Airline entry pathway For each airline, to test the effect of training pathway on performance, two groups were created, one for cadet pilots and one for direct entry. For Airline A, the measure used to test the effect of pathway on performance was a proficiency simulator session, which contained a number of metrics listed below under dependent variables, conducted at the time the pilot entered the airline, and the check to line flight test. Cadet second officers entered the airline with an average of 246 hours (S.D. 94 h), which they built up during training, while direct entry second officers had, on average, 3,826 hours (S.D. 1,344 h). Data about the type of previous flying experience for direct entry pilots into Airline A (airline, general aviation, military) was not provided, however, the airline reported that the majority of the direct entry second officers were from a general aviation (or similar) environment. At testing, direct entry SOs had, on average, 4,729 hours (S.D. 1,427 h) and cadets had, on average, 1,042 hours, (S.D. 431 h). For Airline B, the measure used to test the effect of pathway was a proficiency simulator session conducted 5 years after the first officers had joined the airline, and the most recent line check for these pilots. This time period was chosen to overcome any learning effect as a possible confound. Cadet first officers entered the airline with, on average 278 hours (S.D. 42 h) predominately built up during training, while direct entry first officers had, on average, 6734 hours (S.D. 2,853 h). Of the 81 direct entry first officers, 76 had previous airline experience, 3 were from general aviation and 2 were from the military. At testing, cadet first officers had, on average, 3,984 hours (S.D. 836 h), and direct entry first officers had, on average, 11,158 hours (S.D. 3,172 h). For Airline C, the measure used to test the effect of pathway on performance was a proficiency simulator session, which contained a number of metrics listed below under dependent variables, conducted during the first five years after entering the airline, and the check to line flight test. Cadet pilots typically entered the airline with, on average 561 hours (S.D. 457 h) predominately acquired during training, while direct entry pilots entered with, on average, 5,291 hours (S.D.

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3,110 h). Of the 134 direct entry pilots, 32 had previous airline experience, 99 were from general aviation and 3 were from the military. At testing, cadet pilots had, on average, 1,185 hours (S.D. 511 h) and direct entry pilots had, on average, 6,923 hours (S.D. 3,471 h).

Total flight hours The effect of flight hours on performance were examined against the same metrics used in the previous study (Todd & Thomas, 2012). Second officers from Airline A were grouped into those with below 1,500 hours and those above; and first officers from Airlines B and C into below 1,500 hours and those above. The divide of 1,500 hours was chosen based upon the current legislative changes in the United States, and the fact that 1,500 hours total time is necessary for pilots to hold an Air Transport Pilot Licence (ATPL). Due to the grouping, some high-hour pilots at the time of testing had entered the airline as cadets. For Airline A, 93 per cent of low-hour second officers had entered the airline as cadets and 3 per cent of high-hour second officers had entered as cadets. For Airline B, 100 per cent of low-hour first officers entered as cadets, and 29 per cent of high-hour first officers entered as cadets. For Airline C proficiency simulator check, 79 per cent low-hour first officers entered as cadets and 5 per cent of high-hour first officers entered as cadets. For the line check data, 91 per cent of low- hour first officers entered as cadets and 2 per cent of high-hour first officers entered as cadets.

Dependent variables Technical Performance For each airline, pilots were rated against technical measures during the simulator proficiency check designed to test technical knowledge and handling, with various normal and non-normal technical scenarios (Tables 1 to 3). They were assessed using a score range of 1 (unsatisfactory) to 5 (excellent). In addition, they were also required to demonstrate proficiency in various regulatory required manoeuvres. In addition to be above, for Airline B, proficiency was measured by a rating of pass (P), pass with repeat (1P) or fail (F) for each manoeuvre.

Non-Technical Performance For each airline, pilots were rated against various non-technical markers and again, pilots were rated on the 5 point ordinal scale (Tables 1 to 3). Checks included both normal events, which are routine, expected events that do not require additional training or specific targeted intervention by a pilot; and non-normal events, which involve a non-routine event or problem with the aircraft, its systems, other crew, or the environment, which is not routine and is outside of what is expected in a ‘normal’ flight (such as an engine failure).

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Table 1: Airline A - Technical (T), Non-technical (N) and required regulatory manoeuvres (M) Simulator proficiency check metrics Line check metrics Approach and Landing (T) Checklist usage (T) Pilot Flying duties (T) Automation use (T) Pilot Monitoring duties (T) Operational knowledge (T) Technical knowledge (T) Technical knowledge (T) Adherence to standard operating procedures (T) Adherence to standard operating procedures (T) Situation awareness (N) Error recovery (T) Communication (N) Communication (N) Assertion (N) Conflict resolution (N) Missed Approach (M) Environmental awareness (N) ILS approach (M) Weather assessment (N) Holding (M) Leadership (N) Departure (M) Handover (N) Normal Landing (M) Traffic awareness (N) Emergency descent (M) Teamwork (N) Stall (M) Engine failure during cruise (M) Normal takeoff (M)

Table 2: Airline B - Technical (T), Non-technical (N) and required regulatory manoeuvres (M) Simulator proficiency check metrics Line check metrics Non precision approach (M) Approach (M) ILS approach and missed approach (MAP) (M) Landing (M) Holding (M) Technical (T) En route NDB_VOR (M) Teamwork (N) Engine inoperative landing (M) Descent (T) Engine inoperative ILS and MAP (M) Configuration (T) V1 cut (engine failure during takeoff) (M) Takeoff (M) Preparation (T) Flight management (T) Automation (T) Automation (T) Handling (T) Handling (T) Procedure (T) Adherence to SOPs (T) Systems knowledge (T) Operational (T) Situation awareness (N) Conflict resolution (N) Crew Resource Management (CRM) (N) Communication (N) Command (N) Airmanship (N) Briefings (N) Aircraft (T) Traffic awareness (T) Weather assessment (T) Terrain awareness (T) Threat awareness (T)

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Table 3: Airline C - Technical (T), Non-technical (N) and required regulatory manoeuvres (M) Simulator proficiency check metrics Line check metrics Takeoff (M) Takeoff (M) Rejected takeoff (M) Initial climb (M) Instrument approach (M) Instrument approach (M) Engine failure (M) Cruise (T) Engine fire in cruise (M) Visual approach (M) Climb (Obstacle Clearance Procedure – OCP) (M) Abnormal emergency (M) Abnormal emergency (M) Descent planning (T) Approach and landing (T) Landing (T) Systems knowledge (T) Pre-flight planning (T) Procedures (T) Systems knowledge (T) Support duties (N) Procedures (T) Communication (N) Ground handling (T) Situation awareness (N) Communication (N) Leadership and management (N) Leadership and management (N) Decision making (N) Situation awareness (N) Decision making (N)

For technical and non-technical performance, the 1-5 ordinal scales were grouped into the following categories: below standard (1), meeting the standard (2-3), and exceeding the standard (4-5). These groups were formed on the basis of the rating scales and word pictures used by the airlines involved in the study.

Statistical analysis Chi square analyses were utilised for categorical variables and statistical tests were interpreted using the type 1 error rate of 0.01 for statistical significance. To control for small cell size, Fisher’s exact post hoc test was performed on the data. A limitation of using chi square for multiple comparisons is the increased propensity for type I error to occur, which was why the significance level of 0.01 was used (Wiggins & Stevens, 1999). However, the results that fall between 0.01 and 0.05 have also been included in the results to highlight overall trends in the data (Mendenhall et al., 1981).

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Results

Overall there were no significant differences between the groups for any dependent variable in relation to meeting the standard required in any of the three airlines. The results below show the differences in each group exceeding the standard. That is, they all passed, however, performance varied between the groups within the ‘pass’ standard. While the line check data from Airline C did contain some fail items for some pilots, these pilots successfully completed the subsequent check flight. Significant results are labelled with an asterisk (*) in the figures.

Airline A Simulator proficiency check Entry pathway study Of the seventeen metrics, the performance of cadets differed to the direct entry second officers with respect to seven of the 17 metrics. The difference was measured as a percentage of pilots exceeding the standard, with a higher number of direct entry second officers exceeding the standard compared to cadets (Figure 1). The metrics the groups differed on were engine failure in the cruise, normal landing, ILS approach, situation awareness, assertion, pilot flying and approach and landing (Table 4). Table 4: Differences in performance between cadets and direct entry second officers

Metric Cadet (%) Direct entry (%) χ2 (1, n=473) p (2-tailed) Engine failure in the cruise 74.4 87.8 9.63 0.004 Normal landing 73.1 88.4 12.50 0.001 ILS approach 69.2 90.6 26.56 <0.001 Situation awareness 75.6 88.4 8.88 0.006 Assertion 78.2 94.7 23.94 <0.001 Pilot flying 79.5 91.6 10.37 0.003 Approach and landing 73.1 91.4 21.26 <0.001

For the metric pilot monitoring, the difference was not significant at 0.01, but was within the range 2 of 0.01-0.05 (cadets = 82.1%, direct entry = 90.9%, χ (1, n = 473) = 5.38 p=0.027, 2-tailed).

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Figure 1: Performance in proficiency simulator check as a function of entry pathway

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Flight hour study The results for the comparison of hours versus performance mirror those for entry pathway for this cohort of pilots. Of the seventeen metrics, the performance of the low-hour pilots differed to the high-hour group with respect to seven metrics. The difference was measured as a percentage of pilots exceeding the standard, with a higher number of high-hour second officers exceeding the standard compared to low-hour second officers (Figure 2). The metrics the groups differed on were engine failure in the cruise, normal landing ILS approach, situation awareness, assertion, pilot monitoring, pilot flying and approach and landing (Table 5). Table 5: Differences in performance between low- and high-hour second officers

Metric Low-hour (%) High-hour (%) χ2 (1, n=473) p (2-tailed) Engine failure in the cruise 73.9 87.6 9.00 0.005 Normal landing 71 88.4 14.59 0.001 ILS approach 68.1 90.3 25.93 <0.001 Situation awareness 73.9 88.4 10.39 0.004 Assertion 78.3 94.3 20.54 <0.001 Pilot flying 78.3 91.6 11.27 0.002 Approach and landing 73.9 90.8 16.44 <0.001

As above, the metric Pilot monitoring was significant when tested at 0.05 significance (low-hour = 2 81.2%, high-hour = 90.8%, χ (1, n = 473) = 5.84 p=0.031, 2-tailed).

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Figure 2: Performance in simulator proficiency check as a function of flight hours

Line check Entry pathway study For the line check data, the only significant difference between cadets and direct entry second officers was with respect to the one non-technical metric of leadership (cadets = 72.7%, direct 2 entry = 95.4% , χ (1, n = 197) = 15.26 p=0.002, 2-tailed). The other thirteen metrics showed no significant difference (Figure 3).

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Figure 3: Performance in line check as a function of entry pathway

Flight hour study For the line check data, the only significant difference between low- and high-hour second officers, were with respect to the non-technical measure of leadership (low-hour = 78.3%, high-hour = 2 94.8%, χ (1, n = 197) = 8.45 p=0.014, 2-tailed) (Figure 4). Figure 4: Performance in line check as a function of flight hours

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Airline B The data collected and analysed for Airline B was for proficiency and line checks at the 5 year mark, in order to account for any learning effect that may have been present at airline entry.

Simulator proficiency check Entry pathway study The only significant difference between the cadets and the direct entry first officers was that the cadets scored lower on the measure of crew resource management (CRM) at the significance 2 level of 0.05 but not 0.01 (cadet = 62.9%, direct entry = 80.3%, χ (3, n = 116) = 10.39 p=0.018, 2- tailed). There was no significant difference between the two groups on any of the other technical or non-technical measures, or for the manoeuvres. While the other measures showed no significant difference, there was a trend towards a lower performance of cadets overall (Figure 5, Figure 6).

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Figure 5: Performance in simulator proficiency check manoeuvres as a function of entry pathway

P=pass F=fail 1P=pass with repeat

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Figure 6: Performance in simulator proficiency check as a function of entry pathway

Flight hour study For the four technical and three non-technical metrics, the pilots in the low-hour group had a significant difference with respect to all metrics (Figure 7, Figure 8 and Table 6). High-hour pilots scored significantly higher in these areas against their low-hour colleagues, with a greater number of these pilots exceeding the standard. The low-hour pilots, on the other hand, had a higher repeat rate for the required regulatory manoeuvres: engine inoperative landing (low-hour = 21.1%, high- 2 hour = 3.3%, χ (2, n = 169) = 10.59 p=0.016, 2-tailed) and non-precision approach (low-hour = 21.1%, 2 high-hour = 4.7%, χ (2, n = 169) = 7.53 p=0.032, 2-tailed). Table 6: Differences in performance between low- and high-hour first officers

2 Metric Low-hour (%) High-hour (%) χ df (n=169) p (2-tailed) Command 10.5 66 27.15 3 <0.001 CRM 36.8 73.4 12.28 3 0.003 Situation awareness 26.3 68 22.63 3 <0.001 System knowledge 63.2 85.3 6.98 2 0.042 Procedure 10.5 54.6 28.55 4 <0.001 Handling 15.8 69.3 28.64 3 <0.001 Automation 63.2 81.3 6.77 2 0.021

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Figure 7: Performance in simulator proficiency check manoeuvres as a function of flight hours

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Figure 8: Performance in simulator proficiency check as a function of flight hours

Line check Entry pathway study The only significant difference was with respect to the metric of communication, measured by a higher percentage of cadets exceeding the standard at the 0.05 level (cadets = 95.5%, direct entry 2 = 84.9%, χ (1, n = 151) = 7.48 p=0.036, 2-tailed) (Figure 9).

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Figure 9: Line check at 5 year mark as a function of entry pathway

Flight hour study For the line check data, the only significant differences between low- and high-hour first officers, were with respect to four technical metrics, measured by a higher percentage of high-hour pilots 2 exceeding the standard (terrain awareness, low-hour = 70% high-hour = 96.2%, χ (2, n = 168) = 2 13.45 p=0.010, 2-tailed; and traffic awareness, low-hour = 70% high-hour = 95.6%, χ (3, n = 168) = 23.16 p=0.002, 2-tailed). It should be noted that for terrain awareness, neither group scored lower than a 3 (Figure 10). Two metrics were significant at 0.05 level - SOP adherence, low-hour = 70%, 2 high-hour = 84.2, χ (3, n = 168) = 14.43 p=0.037, 2-tailed and approach, (low-hour = 70%, high-hour = 2 88%, χ (3, n = 168) = 17.15 p=0.044, 2-tailed).

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Figure 10: Line check at 5 year mark as a function of flight hours

Airline C Simulator proficiency check Entry pathway study The only significant differences between the cadets and the direct entry groups was that the cadets scored lower on the measure of leadership and management at the significance level of 2 0.01 (cadet = 44.8%, direct entry = 73.9%, χ (3, n = 159) = 10.06 p=0.007, 2-tailed). One metric was 2 significant at the 0.05 level only Situation awareness (cadet= 50%, direct entry= 73.9%, χ (3, n = 166) = 9.73 p=0.03, 2-tailed). There was no significant difference between the two groups on any of the other technical or non-technical measures, or for the manoeuvres (Figure 11).

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Figure 11: Performance in simulator proficiency check as a function of entry pathway

Flight hour study The only significant differences between the low- and high-hour groups was that the low-hour pilots scored lower on the measures of leadership and management at the significance level of 2 0.01 (low-hour= 39.1%, high-hour= 75.2%, χ (3, n = 159) = 11.50 p=0.004, 2-tailed) and situation 2 awareness at the significance level of 0.01 (low-hour= 36%, high-hour= 75.2%, χ (3, n = 166) = 18.07 p=0.001, 2-tailed). One metric was significant at the 0.05 level only – Abnormal emergency (low- 2 hour= 64%, high-hour= 84.6%, χ (2, n = 155) = 6.60 p=0.03, 2-tailed). There was no significant difference between the two groups on any of the other technical or non-technical measures, or for the manoeuvres (Figure 12).

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Figure 12: Performance in simulator proficiency check as a function of flight hours

Line check Entry pathway study The only significant differences between the cadets and the direct entry first officers was that the 2 cadets scored lower on the measures of landing (cadet=33.9%, direct entry = 58%, χ (4, n = 251) = 10.74 p=0.01, 2-tailed) and leadership and management at the significance level of 0.01 (cadet = 2 26.4%, direct entry = 52.6%, χ (3, n = 169) = 11.17 p=0.003, 2-tailed). There was no significant difference between the two groups on any of the other technical or non-technical measures, or for the manoeuvres (Figure 13).

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Figure 13: Line check as a function of entry pathway

Flight hour study The only significant differences between the low- and high-hour groups was that the low-hour first 2 officers scored lower on the measures of landing (low-hour = 31.4%, high-hour = 58%, χ (4, n = 251) = 12.5 p=0.005, 2-tailed) and leadership and management at the significance level of 0.01 (low-hour 2 = 25%, high-hour = 52%, χ (3, n = 169) = 11.55 p=0.003, 2-tailed). One metric was significant at the 2 0.05 level only – Visual approach (low-hour = 20.4%, high-hour= 38.3%, χ (4, n = 224) = 10.13 p=0.03, 2-tailed). There was no significant difference between the two groups on any of the other technical or non-technical measures, or for the manoeuvres (Figure 14).

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Figure 14: Line check as a function of flight hours

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Discussion

The subject of pilot performance is one that often draws heated debate and entrenched positions amongst the aviation industry. Often these positions have been formed and debates have occurred without scientific data to support or oppose the various stances. Despite this, the concept that the performance of low-hour and cadets pilots would be fundamentally different to their high-hour direct entry colleagues has not previously been explored to any great extent. While the results of this study indicated some significant differences between the pilot groups for each airline, it is worth noting that there are a significant number of similarities in their performance (Table 7 and Table 8). In the line check environment, all three airlines showed very few differences between the performance of cadets and direct entry pilots, and between low- and high-hour pilots. This finding is largely consistent with the authors’ previous study examining the effect of flight hours on performance in the line operational environment (Todd & Thomas, 2012). Table 7: Overview of significant differences in performance across all three airlines for simulator (S) and line (L) checks as a function of entry pathway (- indicates not tested) Metric Airline A Airline B Airline C Engine failure in the cruise (M) S - Normal landing (M) S L ILS approach (M) S Pilot flying (T) S - Approach and landing (T) S Leadership/ command (N) L S L Situation awareness (N) S Assertion (N) S - -

Table 8: Overview of significant differences in performance across all three airlines for simulator (S) and line (L) checks as a function of flight hours (- indicates not tested) Metric Airline A Airline B Airline C Engine failure in the cruise (M) S - Normal landing (M) S L ILS approach (M) S Non precision approach (M) - S Engine inoperative landing (M) - S - Pilot flying (T) S - Approach and landing (T) S System knowledge (T) S Procedure (T) S Handling (T) - S - Automation (T) S - Terrain awareness (T) L - Traffic awareness (T) L - Leadership/ command (N) L S S L CRM/ Communication (N) S Situation awareness (N) S S S Assertion (N) S - -

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Simulator proficiency check results In the simulator proficiency checks, there was a difference between the cadet and direct entry second officers and low- and high-hour second officers for Airline A. The differences in performance were fairly consistent between the entry pathway and flight hour groups. Since this data was collected at airline entry, data from Airline B was examined at the 5 year mark to account for any learning effect that may have been present at airline entry. Very few significant differences between the cadets and direct entry first officers in this simulator proficiency check were found. However when the data were analysed for flight hour experience, there were a few more differences between the low- and high-hour first officers. For Airline C, whose simulator proficiency checks were conducted within the first 5 years of joining the airline, a consistent difference on one metric only was found, between cadets and direct entry pilots and low- and high-hour first officers, with one other significant difference in the flight hour data. For Airline A, the differences in performance against the six technical and two non-technical metrics are worthy of further exploration. The technical metrics include the regulatory required manoeuvres, such as an ILS approach, and the main difference between the groups appears to occur during the approach and landing phase of flight. Given the role of the second officer is to act as a relief pilot in cruise flight it is not particularly surprising to see a difference in performance between cadet and direct entry second officers against this metric. While both groups are now limited to a non-control seat outside of the cruise phase of flight, it is conceivable that prior to their direct entry as a second officer, these pilots had flown either as first officers in other airlines, in the military, or in general aviation. They are therefore more likely to have had a higher exposure to the approach and landing phase of flight, and experience in a control seat during this phase. For the non-normal metric of engine failure, it is also possible that previous exposure to an airline environment, and therefore simulator sessions, has aided these second officers in their understanding of what the simulator session will involve, and the necessary actions on their part. However, irrespective of this, it is important for second officers, who will occupy a control seat during cruise, to be proficient at handling an engine failure in this phase of flight. While each pilot met the standard for this metric, the number of cadets and low-hour pilots were over-represented in this marking group, pointing to a potential need for future training to target this difference. The other technical metrics relate to flying role, which again, is something that a direct entry second officer with previous airline experience will have some familiarity with, compared to a cadet. The non-technical metrics covered areas such as situation awareness and assertion. It is possible that the prior exposure to, and familiarity with, airline operations has aided direct entry second officers in performance against this metric. It is also possible that the direct entry pilots have developed greater familiarity with the need for, and technique of, good situation awareness through the flying they conducted prior to entry into the airline. The metric of assertion may also be explained in the same way, especially if these pilots had operated in a team environment previously. The potential confounds of exposure and familiarity are also likely of pilots with more than 1,500 hours, which may well explain the similarity in the results between the entry pathway and flight hour groups for Airline A and Airline C. For the results from the simulator proficiency check for Airline B, the differences in performance against the metrics are quite interesting even in the bigger picture of the trend towards lower performance against all metrics for cadets. The significant difference against the CRM metric at the 0.05 level is not too surprising given it typically covers communication and workload management. Direct entry first officers are more likely to have had higher exposure to, and familiarity with, these concepts prior to entry to this airline and it is not surprising that their communication would be stronger, given the necessity of operating in a team environment for longer than the 5 years in this airline alone. This also applies to the results from Airline C, which showed that direct entry pilots were scoring higher in both situation awareness and leadership and management.

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The overall trend in performance of low-hour first officers may well be due to a similar effect. As many of the direct entry first officers had previous experience flying in an airline, it is likely they have had to fly the required manoeuvres a number of times before entry to this airline, as well as having to demonstrate technical and non-technical proficiency in the simulated environment. It is worth noting that the low-hour pilots were all cadets (n=19), and 96 of the high-hour pilots (n=150) had previous airline experience, although the high-hour group also included 43 cadets. It is therefore possible that the previous airline experience of the high-hour first officers has allowed these pilots to develop a more in-depth understanding of airline operations and the requirements of proficiency checks in an airline environment, the inexperience of which may be influencing the performance of the low-hour pilots. The difference in performance between the low- and high-hour pilots against all technical and non- technical metrics is surprising, given there was a lack of significant variation when the effect of entry pathway was considered on the same dataset. It seems from these results that the effect of low hours on performance is stronger than any effect of entry pathway, despite all of the low-hour pilots being cadets. The difference in performance against the two manoeuvres is quite interesting, given that the performance of the low-hour pilots was not significantly different against the non-normal manoeuvres that are generally perceived as being more challenging – such as the V1 cut (engine failure during takeoff) and the one engine inoperative Instrument Landing System Missed Approach (ILS MAP). This result is also not consistent with the results from the airline entry pathway study, despite all low-hour pilots being cadets. For Airline C the only differences in the simulator proficiency checks for technical metrics was at the 0.05 level of significance and were on the metrics of cruise engine fire (for entry pathway only) and abnormal emergency (for both groups). Given the number of comparisons and that this result was at the 0.05 level, it is possible the difference was due to chance only. However, it is also worth exploring these differences with a view to appropriate training intervention.

Line check results An interesting outcome from the line check data for entry pathway for Airline B was that the only metric showing a difference was communication at the 0.05 level. For our purposes, it is worth considering that there is a difference in communication in the line environment as a function of entry pathway and to treat the result as valid. That is, if a pilot entered the airline as a cadet, they appear not to communicate as effectively in the line check environment as their direct entry peers. As mentioned above, this may be a function of the previous exposure to an airline environment providing the direct entry pilots with a greater knowledge of what communication strategies are required in the line environment, and the skills to implement these effectively. The significant differences in the line check data for Airline B as a function of flight hours was also interesting. Given these metrics - SOP adherence and approach at 0.05; and terrain awareness and traffic awareness at 0.01 are high-level categories it is possible that the performance of the pilots differed on a subset of these metrics and not the overarching metric itself, per se. It may be that a low-hour pilot can fly an approach adequately, however, they may be receiving a lower rating because they did not fly a certain segment to a high standard, or did not follow a procedure exactly and as such this difference is being captured under the heading of ‘approach’. However for metrics such as terrain and traffic awareness, the finding is not exactly surprising. It is reasonable that a pilot will develop a greater ability to plan and operate adequately within their environment once they build up exposure to, and experience in, that environment. Issues such as terrain awareness in particular will require strong local knowledge and this may take time to adequately acquire. It should be noted that neither group scored lower than a 3 for terrain awareness, indicating they were both sitting at the high end of ‘meeting the standard’. The issue of exposure aiding performance may also be true of SOP adherence, which is another area where it is reasonable to anticipate that performance will improve with both exposure and practice. Low-

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hour pilots will be limited in the exposure they have to operating with, and following, SOPs in the line environment. For the line check data from Airline A, the difference in performance between the cadets and direct entry second officers for the metric of leadership could be a function of the role of a second officer not requiring leadership on the line. Therefore, cadets who have only ever flown as second officers will not be as familiar with the principles underpinning this metric as pilots who have had previous exposure to the concept and who have implemented it in previous roles, and/or airline operations prior to entry into this airline. That the same difference exists for low-hour pilots from Airline A, with the inclusion of communication, is not a particularly surprising finding. It is reasonable that low-hour pilots will not have had great exposure to the line operating environment, unlike many of their high-hour colleagues and it is probable that this lack of previous exposure is impacting their ability to communicate effectively. As is the case with leadership, it is possible the influence of role is a factor here also, specifically that second officers are typically not required to communicate to the same extent as first officers and captains. The line check data for Airline C was very similar, with cadets and low-hour pilots scoring lower on leadership and management and landing metrics. Once again, the prior exposure of direct entry pilots to the landing phase of flight and to the concept of leadership may be influencing the results. The only difference in technical metric for line check data was at the 0.05 significance level and indicated low-hour pilots were scored lower on the visual approach metric. However, given both groups had a low percentage exceeding the standard (20% low-hour v 38% high-hour), it is possible there is a difficulty within this metric that is influencing the performance of both groups. These results are close to those of Airlines A and B, indicating a consistent effect of prior experience being beneficial. Overall however, the results from Airline C showed very little difference in performance in both simulator proficiency checks and line checks for each of the entryway and flight hour groups, indicating that cadets and low-hour pilots were performing to an acceptable level.

Limitations It is important that the various figures throughout the results section are interpreted correctly. They show the percentage of each pilot group for each airline that exceeded the standard. As outlined previously, the ratings were divided into: below standard (unsatisfactory), meeting the standard and exceeding the standard. As such, the figures show the percentage of pilots who exceeded the standard, however, it should be noted that all pilots passed the simulator proficiency or line check (and therefore at least met the standard) and were suitable to continue flying. It should also be noted that the idea of a simulator proficiency check is to ensure that a pilot is proficient in a number of manoeuvres, as well as technical and non-technical skills and knowledge. It is reasonable to assume there will be an individual variation in performance within this environment that may well occur due to issues unrelated to individual skill, such as stress or the physical fitness/wellbeing of the pilot, both of which are beyond the scope of this study to consider. The other potential influencing factor is that the metrics pilots are rated against are the overarching areas of proficiency and as such, any sub-element of that metric may influence performance. For example, if a procedure has recently changed or is not often used, it may be the execution of the procedure rather than the approach which is causing the pilot to repeat the manoeuvre, or receive a lower rating. It is therefore possible that the variation in performance that is being seen is not a function of pilot proficiency or ability, but rather the subtleties of an underlying procedure and/or other training issues. Another factor that must be acknowledged is the possibility that one or more of the differences might be to chance alone, due to the limitation that multiple comparisons were required. However,

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this was addressed by using the lower significance level of 0.01 with exploration of results that were significant at 0.05 to ensure overall trends in performance were identified. The other possible influence on the data, which should be considered, is that of marking bias. Marking bias by check captains is reported to be an inherent problem in the recurrent measure of flight crew proficiency checks and generally involves the pilots under check receiving a mark consistent with their performance for their rank and/or experience. That is, a cadet or low-hour pilot performing well may only receive a 3, whereas the same performance from a more experienced first officer or captain may attract a 4. Interestingly the data for Airline B showed a potential bias of a low-hour ‘stop’ at 3, with high-hour pilots receiving marks clustered around 3-4. Therefore the reader should be mindful of the possibility that what the data is showing is a difference in marking and not in performance.

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Conclusion

This study has provided an overview of pilot performance as a function of both airline entry pathway, and flight hours within three high-capacity regular public transport airlines. There is a level of unease within the wider aviation industry regarding the concept of low-hour pilots in general, and cadets and MPL pilots in particular. Despite the prevalent existence of cadet training schemes for a number of airlines around the world for a number of years, there remains a level of opposition within Australia to such a concept. With the development of training innovations such as the MPL, this opposition has certainly not abated. The results indicate that while there are differences in performance between the various groups, the performance of the cadets and low-hour pilots against their direct entry and more experienced brethren is remarkably similar. All pilots within the cadet entry and low-hours groups passed the simulator and line checks required of them, meaning they are proficient to be operating as second and first officers within the respective airlines, as rated by the airlines’ check and training staff. The differences in performance were between ‘meeting the standard’ and exceeding it, and are subject to the caveats listed in the discussion. However given that the cadets met the standard and are therefore proficient, the evidence is demonstrating that the cadet pathway for low-hour pilots is a valid option for airlines. Contrary to the expressed concerns of some sectors of the industry, there was no evidence indicating that cadets or low-hour pilots within these airlines were any less competent or proficient than their direct entry and high-hour peers. The inclusion of simulator proficiency data and airline entry pathway in this study was to address some of the limitations from a previous study, which occurred within the line operating environment only, and without the data to study entry pathway. By studying simulator proficiency checks, this study was able to examine the performance of cadet and low-hour pilots in non- normal scenarios, which is not possible during line operations. Aircraft accidents such as AF447 and the DHC-8 accident at Buffalo, New York, highlight the importance of appropriate training for non-normal events and the need for competent, proficient performance of all flight crew to successfully handle non-normal events that occur in the operational environment. The differences in the performance of pilots against all metrics were variable within airlines and inconsistent across all three airlines. This suggests that the differences between the groups were not of a systemic nature that would highlight an area of concern for industry. While the metric normal landing showed a difference across two of the three airlines, none of the rest of the required regulatory manoeuvres or technical metrics were significantly different in more than one airline. For non-technical metrics, both leadership and situation awareness were significantly different in all three airlines. Although this is understandable given the low experience of cadet and low-hour pilots, focused exposure to those metrics during initial airline training may reduce this difference as was seen with cadets at the 5-year mark in Airline B. While differences in performance were discovered as a function of flight hours in some non- normal scenarios, the fact remains that these differences did not result in the low-hour pilots being marked as unsatisfactory. Nevertheless, the data from these comparisons may well further inform future training within high-capacity RPT airline operations to ensure that low-hour pilots are receiving suitable training interventions for the areas they are not performing as well on. While the subject of low-hour and cadet pilots have received significant international attention recently (e.g. the Australian senate inquiry and American legislative changes), it is important to ensure that any on-going debate is informed by relevant studies and science. With the advancement of aircraft technology and a growing shortage of pilots; regulators, airlines and industry bodies need to ensure that the underpinning training aids pilots by providing targeted training to prepare them for any non-normal events during flight.

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References

Air Line Pilots Association. (2009) ALPA White Paper: Producing a Professional Airline Pilot. Washington DC, US: Air line Pilots Association, International. Bazargan, M., & Guzhva, V.S. (2011). Impact of gender, age and experience of pilots on general aviation accidents. Accident Analysis and Prevention, 43:962-970. BEA (2012). Final Report on accident on 1st June 2009 to the Airbus A330-203 registered F- GZCP operated by Air France flight AF447 Rio de Janeiro – Paris. Bureau d’Enquêtes et d’Analyses pour la sécurité de l’aviation civile. Paris, France. Causse, M., Dehais, F. & Pastor, J. (2010). Flight experience and executive functions predict flight simulator performance in general aviation pilots. In: 4th International Conference on Research in Air Transportation – ICRAT 2010, 04 June 2010, Budapest, Hungary. Clarke, D.D., Ward, P., Bartle, C. & Truman, W. (2006). Young driver accidents in the UK: The influence of age, experience, and time of day. Accident Analysis and Prevention; 38:871-8. Dinges, T.A., Hulse, M.C., Mollenhauer, M.A., Fleishman, R.N., McGehee, D.V. & Manakkal, N. (1997). Effects of Age, System Experience, and Navigation Technique on Driving with an Advanced Traveler Information System. Human Factors 39(2):177-99. Dismukes, R.K., Berman, B.J. & Loukopoulos, L.D. (2007). The Limits of Expertise: Rethinking pilot error and the causes of airline accidents. Ashgate, Aldershot, UK. Fisher, D.L., Laurie, N.E., Glaser, R., Connerney, K., Pollatsek, A., Duffy, S.A. & Brock, J. (2002). Use of a Fixed-Based Driving Simulator to Evaluate the Effects of Experience and PC-Based Risk Awareness Training on Drivers’ Decisions. Human Factors, 44(2): 287-302. Goh, J. & Wiegmann, D. (2002). Human Factors Analysis of Accidents Involving Visual Flight Rules Flight into Adverse Weather. Aviation, Space, and Environmental Medicine, 73:817-22. Groff, L.S. & Price, J.M. (2006). General Aviation Accidents in Degraded Visibility: A Case Control Study of 72 Accidents. Aviation, Space, Environmental Medicine, 77:1062-7. Hunter, D.R. (2001). Retrospective and Prospective Validity of Aircraft Accident Risk Indicators. Human Factors, 43(4), 509-518. ICAO (2006). Annex 1 – Personnel Licensing (10th edition). International Civil Aviation Organization, Montreal, Canada Kennedy, Q., Taylor, J.L, Reade, G. & Yesavage, J.A. (2010). Age and Expertise Effects in Aviation Decision Making and Flight Control in a Flight Simulator. Aviation, Space, and Environmental Medicine, 81(5), 489-497. Li, G., Baker, S.P., Grabowski, J.G., Qiang, Y., McCarthy, M.L. & Rebok, G.W. (2003). Age, Flight Experience, and Risk of Crash Involvement in a Cohort of Professional Pilots. American Journal of Epidemiology, 157:874-880. McFadden, K.L. (1996). Comparing Pilot-error Accident Rates of Male and Female Airline Pilots. Omega, International Journal of Management Science, 24(4), 443-450. Mendenhall, W., Scheaffer, R.L. & Wackerly, D.D (1981). Mathematical Statistics with Applications (second edition). PWS Publishers, Boston, United States. NTSB (2012). Loss of Control on Approach Colgan Air, Inc. Operating as Continental Connection Flight 3407, Bombardier DHC-8-400, N200WQ, Clarence Center, New York, February 12, 2009. National Transportation Safety Board, Washington, United States of America.

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O’Hare, D. & Chalmers, D. (1999). The Incidence of Incidents: A Nationwide Study of Flight Experience and Exposure to Accidents and Incidents. International Journal of Aviation Psychology, 9:1-18 Parliament of Australia Senate. (2010). Pilot training and airline safety. Retrieved 20 October 2010 from http://www.aph.gov.au/senate/committee/rat_ctte/pilots_2010/info.htm Salvatore, S., Stearns, M.D., Huntley Jr, M.S. & Mengert, P. (1986). Air transport pilot involvement in general aviation accidents. Ergonomics, 29(11), 1455-1467. Shuch, H.P. (1992). The Influence of Flight Experience on Midair Collision Risk Perception. Accident Analysis and Prevention, 24(6), 655-660. Sutton O. (2005). Shortcut or Fast Track? Air Transport World, 2005. Retrieved 24 April 2008 from http://www.atwonline.com/channels/safetySecurity/article.html?articleID=1428 Todd, M.A. & Thomas, M.J.W. (2012). Flight Hours and Flight Crew Performance in Commercial Aviation. Aviation, Space, and Environmental Medicine, 83(8), 776-782. United States of America Congress. (2010). Airline Safety and Federal Aviation Administration Extension Act of 2010. Washington, DC: United States Government Printing Office. Wiegmann, D.A., Goh, J. & O’Hare, D. (2002). The Role of Situation Assessment and Flight Experience in Pilots’ Decisions to Continue Visual Flight Rules Flight into Adverse Weather. Human Factors, 44(2), 189-97. Wiggins, M.W. & Bollwerk, S. (2006). Heuristic-Based Information Acquisition and Decision Making Among Pilots. Human Factors, 48(4), 734-46. Wiggins, M.W. & O’Hare, D. (2003). Expert and Novice Pilot Perceptions of Static In-Flight Images of Weather. International Journal of Aviation Psychology, 13:173-87. Wiggins, M.W. & Stevens, C. (1999). Aviation Social Science: Research Methods in Practice. Ashgate, Aldershot, England.

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Sources and submissions

Submissions Under Part 4, Division 2 (Investigation Reports), Section 26 of the Transport Safety Investigation Act 2003, the ATSB may provide a draft report, on a confidential basis, to any person whom the ATSB considers appropriate. Section 26 (1) (a) of the Act allows a person receiving a draft report to make submissions to the ATSB about the draft report. A draft of this report was provided to the airlines involved in the study, the Civil Aviation Safety Authority (CASA) and the International Civil Aviation Organization. Submissions were received from CASA and two of the airlines involved in the study, and where considered appropriate, the text of the draft report was amended accordingly.

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Australian Transport Safety Bureau

The Australian Transport Safety Bureau (ATSB) is an independent Commonwealth Government statutory agency. The ATSB is governed by a Commission and is entirely separate from transport regulators, policy makers and service providers. The ATSB’s function is to improve safety and public confidence in the aviation, marine and rail modes of transport through excellence in: independent investigation of transport accidents and other safety occurrences; safety data recording, analysis and research; fostering safety awareness, knowledge and action. The ATSB is responsible for investigating accidents and other transport safety matters involving civil aviation, marine and rail operations in Australia that fall within Commonwealth jurisdiction, as well as participating in overseas investigations involving Australian registered aircraft and ships. A primary concern is the safety of commercial transport, with particular regard to fare-paying passenger operations. The ATSB performs its functions in accordance with the provisions of the Transport Safety Investigation Act 2003 and Regulations and, where applicable, relevant international agreements.

Purpose of safety investigations The object of a safety investigation is to identify and reduce safety-related risk. ATSB investigations determine and communicate the factors related to the transport safety matter being investigated. It is not a function of the ATSB to apportion blame or determine liability. At the same time, an investigation report must include factual material of sufficient weight to support the analysis and findings. At all times the ATSB endeavours to balance the use of material that could imply adverse comment with the need to properly explain what happened, and why, in a fair and unbiased manner.

Developing safety action Central to the ATSB’s investigation of transport safety matters is the early identification of safety issues in the transport environment. The ATSB prefers to encourage the relevant organisation(s) to initiate proactive safety action that addresses safety issues. Nevertheless, the ATSB may use its power to make a formal safety recommendation either during or at the end of an investigation, depending on the level of risk associated with a safety issue and the extent of corrective action undertaken by the relevant organisation. When safety recommendations are issued, they focus on clearly describing the safety issue of concern, rather than providing instructions or opinions on a preferred method of corrective action. As with equivalent overseas organisations, the ATSB has no power to enforce the implementation of its recommendations. It is a matter for the body to which an ATSB recommendation is directed to assess the costs and benefits of any particular means of addressing a safety issue. When the ATSB issues a safety recommendation to a person, organisation or agency, they must provide a written response within 90 days. That response must indicate whether they accept the recommendation, any reasons for not accepting part or all of the recommendation, and details of any proposed safety action to give effect to the recommendation. The ATSB can also issue safety advisory notices suggesting that an organisation or an industry sector consider a safety issue and take action where it believes it appropriate. There is no requirement for a formal response to an advisory notice, although the ATSB will publish any response it receives.

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Glossary

AF447 Air France Flight 447 ATP Air Transport Pilot ATPL Air Transport Pilot Licence CRM Crew Resource Management GA General Aviation ICAO International Civil Aviation Organization ILS Instrument Landing System ILS MAP Instrument Landing System Missed Approach IMC Instrument Meteorological Conditions MPL Multi-Crew Pilot Licence RPT Regular Public Transport S.D. Standard Deviation SOP Standard Operating Procedure TEM Threat and Error Management VFR Visual Flight Rules

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ATSB Transport Safety Report Research Aviation Research Investigation Pilot experience and performance in an airline environment AR-2012-023 Final – 17 July 2013 ATSBinfo 1800 020 616 616 020 1800 [email protected] www.atsb.gov.au Australian Transport SafetyAustralian Bureau Transport 24 Hours Web @ Twitter Email Acknowledgements

We are grateful to everyone who contributed to this submission, at extremely short notice.

Research into the applicants' Supporting Information was by Andrew Tomlinson.

The document was edited, and published on August 9 2013, by Brian Mackie.

GAA is based at 1199 Tram Road, Swannanoa, RD6, Rangiora 7476 and Upwood, 1395 Puketitiri Road, RD4, Napier 4184

Des Lines can be contacted on: 03 312 6732 or by email at [email protected]

Brian Mackie can be contacted on: 06 844 0540 or 021 613 914 or by email at [email protected]

GAA is an independent, not-for-profit social network of aviators. It is an open forum for pilots, aircraft owners, aero clubs, aviation organisations and related businesses. It has no affiliations.

www.caa.gen.nz

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