This document summarises the submissions received from stakeholders on the International Air Transport Policy discussion document.

The engagement process

On 24 May 2012 the Ministry of Transport released a discussion document for the International Air Transport Policy Review.

Twelve submissions were received in total. Three of these represented individual airports, two were from airlines, five were from industry associations, one was from a crown entity, and one was from the general public.

Despite the variation in the views of stakeholders, the following key themes emerged:

  • broad support for the policy’s primary objective to “help grow the economy and deliver greater prosperity, security and opportunities for all New Zealanders”
  • support for continuing to adopt a liberal approach to air services including the pursuit of reciprocal open skies agreements where it is in New Zealand’s overall best interests
  • support for the policy proposals relating to airline investment and ownership, provided that measures are in place to prevent anti-competitive behaviour
  • support for the proposal to focus on relationships with emerging markets in East Asia and South America, as well as India and ASEAN states
  • support for systematic engagement with a range of stakeholders in determining priorities and approaches in future years


Submissions were generally supportive of the proposed objective. Most agreed that air transport connectivity is vital to the economic wellbeing of New Zealand and, to that end, should continue to be supported by the International Air Transport Policy. However, several suggested that the objective should begin with the overriding priority of this policy, to “help grow the economy and deliver greater prosperity, security and opportunities for all New Zealanders”, and then follow with a statement about how the policy would achieve this.

While there was no opposition to the primary policy objective, several submissions did recommend changes to the wording around how the policy would achieve this.

Some submissions proposed that the objective should explicitly mention that the policy would support aviation, trade, and tourism. Auckland Airport suggested that the objective could go further by positioning New Zealand as the preferred global ‘hub’ for movement of people and goods between Asia, Australasia and the Americas. Christchurch Airport felt that the objective would better reflect the dynamic nature of markets by referring to “current and potential” customers and key passenger and goods markets.

Approach to air services liberalisation

There was general agreement around the direction of the policy proposal with respect to air services liberalisation. All submissions on this issue supported the pursuit of reciprocal open skies agreements where it is in the national interest and, where the other party does not agree to this, the most open arrangements possible. Views on unilateral liberalisation and granting extra-bilateral rights were mixed.

Airports strongly endorsed the granting of extra-bilateral services and access for cargo-only services. However, they felt that the policy could go even further by providing for qualified unilateral (unreciprocated) liberalisation in cases where it may be in New Zealand’s best interests. Two airports also proffered support for a policy that removed barriers for regions within New Zealand. In particular, Christchurch Airport recommended a regional air access package for the South Island or extra-bilateral services for the South Island. This would support the Canterbury region’s earthquake recovery by removing barriers for any airline wishing to fly to the South Island.

Two submissions explicitly cautioned against unilateral liberalisation and the granting of extra-bilateral rights. They argued that liberalisation may not necessarily deliver growth for New Zealand, particularly if it is not reciprocated. Similarly, while in support of liberalisation, Auckland Airport noted that requirements for reciprocity under bilateral air services agreements and open skies as the preferred goal would not remove all potential regulatory impediments to air service growth.

Four submissions expressed the importance of a strong national carrier and suggested that the International Air Transport Policy should take this into account. Some felt that unilateral liberalisation or extra-bilateral rights may limit the competitiveness of New Zealand airlines compared to those of other countries.

Airline investment

Submissions were generally supportive of the proposals relating to airline investment and ownership. However, three submissions emphasised that the most important factor in ownership and control criteria for foreign airlines and the designation of New Zealand airlines was competitiveness.

Three of the submissions representing airports felt that the policy could further relax foreign ownership regulations in some way. The New Zealand Airport Association recommended a consideration of equity structures (such as differentiated economic and voting share ownership) which may allow greater off-shore capital support without jeopardizing air service agreements.

Elements of agreements

Again, submissions generally viewed the policy proposal favourably. Three specifically mentioned support for the inclusion of seventh, eighth and ninth freedoms in negotiations, although Air New Zealand emphasised the importance of reciprocity.

The Aviation Industry Association recommended that agreements should look at all aviation products and services, rather than air services alone.

Stakeholder engagement

Four submissions touched on the idea of having a greater degree of cooperation between relevant government agencies in air service negotiations. Such agencies may include those involved in the development and implementation of immigration, border control, trade, and tourism policies.

Almost all submissions supported the proposal to develop mechanisms to allow more systematic engagement with a range of stakeholders, including airlines, airports, and tourism and freight interests. Two submissions thought that the policy could also include mention of stakeholders from the wider aviation sector.

The forward negotiation programme

Air New Zealand suggested that negotiations should be undertaken with states where there is a demonstrated commercial demand. However, two submissions emphasised that air service agreements should be in place ahead of demand and therefore negotiations need to be based on the projected importance of a market to New Zealand tourism and trade.

Of the submissions that mentioned specific regions or countries that New Zealand should be negotiating air service agreements with in the short- to medium-term, all agreed that Asia and South America should be prioritised. In particular, two submissions recommended negotiating open access to ASEAN states, including by leveraging off the development of the ASEAN Single Aviation Market.

The Tourism Industry Association felt that priority should be given to markets where the prospect of non-stop flights is high as these are likely to be of the greatest benefit to New Zealand. Air New Zealand objected to the policy proposal to maintain a flexible and positive attitude in the negotiation and implementation of air services arrangements with Forum Island Countries. It was argued that there is no need for special considerations for South Pacific states.

Other comments

The submission from a member of the public suggested that the International Air Services Policy should explicitly restrict international air services to Christchurch and Auckland Airports on the grounds that this would help ensure New Zealand’s biosecurity.

List of submissions received

Air New Zealand Aviation Industry Association of New Zealand
Virgin Australia New Zealand Air Line Pilots' Association
Auckland International Airport Limited Tourism Industry Association New Zealand
Christchurch International Airport Limited Tourism New Zealand
Wellington International Airport Limited International Air Transport Association
New Zealand Airports Association From a member of the public

View the submissions received