Here is just one: A student came to us with 53 hours flight experience, a $50,000 student loan debt so far, only 3 hours solo! and not even a PPL yet.
I know some of the bigger schools have a reputation for being a little money hungry, BUT, 53 hours for $50,000 that's almost $1000/hour. That is a bit hard to believe. Yes I know there are other costs than the aircraft hire, like the exam fees and class room tuition etc but I cannot see believe that someone could have spent $50,000 for 53 hours flying.
I understand your position regarding being able to compete against schools that provide access to loan funding when you cannot. However there are schools without access to loan funding that do compete reasonably well.
Also I should point out that there are many schools providing loan funding that provide very good value for money to their students.
DACMAN 767
There is currently no requirement for an AOC to carry out GA flight trainng in New Zealand. There will be some certification requirements (but not an AOC) for certain facets in the near future but no requirement for PPL.