After submitting a DoT complaint in mid April I heard nothing back from DoT or Air NZ. (Non-refundable sale PE flights NZ to USA return in June, with Air NZ stating that I would only be eligible for refund under DoT rules if I were a US citizen or purchased tickets in the US)

Air NZ have subsequently changed their tune re: DoT rules in their COVID-19 flexibility policy - https://www.airnzagent.co.nz/covid-1...ibility-policy

I contacted the Air NZ support team who I had previously corresponded with. They have now told me their interpretation was incorrect and I am eligible for a refund.