SACAA Fees: Because Flying Was Getting Far Too Affordable

By Garth Calitz

New SACAA charges came into effect on 1 October, proving once again that in South African aviation, the aircraft may be grounded, but the invoices never are.

South African pilots, aircraft owners, operators and aviation organisations were greeted on 1 October with another round of increased fees from the South African Civil Aviation Authority. The new charges affect a range of regulatory services, including pilot licensing, examinations, aircraft operations, maintenance personnel and other aviation-related functions. According to the SACAA, this is simply the cost of providing the regulatory machinery required to keep South African aviation safe and compliant. For those actually paying the bills, however, it is another line item added to an already impressive list of expenses associated with the privilege of keeping an aircraft legally airborne. Because, apparently, aviation in South Africa wasn't expensive enough. The aircraft may have wings, but the cost of operating one increasingly requires something closer to financial flight planning.

Nobody in the aviation industry seriously argues that regulation should be free. Aviation safety depends on properly trained inspectors, licensing systems, technical oversight, investigations, standards, audits and a regulator with sufficient resources to do its job properly. A poorly funded aviation authority would be a far greater concern than a fee increase. The problem is therefore not that SACAA charges money for its services. The problem is the increasingly familiar perception within general aviation that every interaction with the regulator comes with a price tag, while the corresponding question of whether the service being provided is efficient, proportionate and delivered within a reasonable timeframe is sometimes treated as an entirely separate matter. The industry is expected to pay promptly. It would be refreshing if the regulatory system were expected to perform with the same urgency, not only when undergoing a massive rebranding exercise or moving into brand-spanking-new offices.

There is an old aviation adage that the easiest way to make a small fortune in aviation is to start with a large one. South African aviation appears to have discovered a variation on the theme: start with a large fortune, hand a portion of it to the fuel company, another portion to the insurer, another to the maintenance organisation, another to the airport, another to the engineer, another to the training organisation and then wait patiently for SACAA to explain where the rest went. I was planning on publishing the increases here but decided against it; if you are brave enough, follow this link, but be warned some items and services have increased by up to 400%.

The modern South African pilot has become remarkably familiar with the concept of paying for the privilege of paying. You want to fly? There is a cost. You want to obtain or renew a licence? There is a cost. You want a rating? There is a cost. You want to write an examination? There is a cost. You want an approval or inspection? There is a cost. You need the regulator to process the paperwork associated with the thing you have already paid for? Naturally, there is another cost. At this point, SACAA could almost introduce a loyalty programme. Ten regulatory transactions and you receive a complimentary application form. Twenty transactions and perhaps the CAA will actually answer your email before you have forgotten what the original question was.

Of course, none of this means that the CAA should simply stop charging fees. The point is that a regulator does not operate in isolation from the industry it regulates. Every additional cost has an effect, particularly on general aviation, where there isn't a multinational airline carrying millions of passengers over which to spread the bill. The private aircraft owner pays personally. The small charter operator has a comparatively narrow revenue base. The flight school has to recover its expenses from students who are already paying substantial amounts to become pilots. The maintenance organisation passes its regulatory and compliance costs down the chain. Eventually, the cumulative effect becomes significant.

There is something almost impressive about the consistency with which the cost of aviation continues to rise while the industry is repeatedly reminded that these expenses are necessary. Fuel becomes more expensive, insurance premiums rise, aircraft parts cost more, maintenance becomes more expensive, hangarage increases and airport charges creep upwards. Then, when everybody is already looking at the balance sheet with the expression of someone who has just discovered an unexpected engine overhaul, another regulatory increase arrives.

The SACAA appears to approach the situation with the reassuring confidence of an organisation that knows its customers have absolutely nowhere else to go. There is no competing regulator across the road offering SACAA Basic at a discounted rate. There is no budget regulatory airline where pilots can obtain their licences for half price provided they bring their own paperwork. There is no "SACAA Lite" for recreational aviation. If you want to operate legally within South African aviation, you deal with the regulator, you comply with its requirements and you pay the associated fees. That makes accountability even more important, because this isn't a normal commercial transaction in which an unhappy customer can simply take their business elsewhere.

The aviation industry is effectively a captive customer. That does not make the CAA the villain, but it does make the relationship one that deserves considerably more scrutiny whenever costs rise.

South African aviation has developed another regulatory tradition alongside paying fees: WAITING. Waiting for licences, waiting for approvals, waiting for certificates, waiting for responses, waiting for paperwork and sometimes waiting for an answer to a question that was asked because the applicant was trying to determine which paperwork was required in the first place. To be fair, not every applicant experiences delays and SACAA has made efforts to modernise its systems and improve processes. But anyone who has spent enough time dealing with aviation administration will recognise the frustration when regulatory processing becomes a significant part of the operational timeline. The GA world is still trying to understand how an analogue system that took 2 hours became a digital system that initially took about 3 months.

This creates an awkward question when fees increase. If the cost of regulatory services goes up, should the industry not reasonably expect the service to improve as well? If a licensing process becomes more expensive, should it not become faster, more transparent and easier to track? If operators are paying more for approvals and oversight, should measurable service standards not accompany those increases? These are not unreasonable demands. In fact, they are the sort of basic accountability questions that any organisation charging customers for a service should expect to face.

Perhaps SACAA could publish something revolutionary: a service-level agreement that tells applicants exactly how long ordinary processes should take, what happens when those deadlines are missed and what performance the regulator is achieving against its own targets. That would be an interesting document. Particularly if it were accompanied by the same level of transparency expected from operators when they are being audited.

One of the problems with treating aviation regulation as though the entire industry has the same financial capacity is that it doesn't. South African aviation is an extraordinarily diverse ecosystem. At one end are major airlines operating sophisticated fleets and carrying hundreds of passengers at a time. At the other are private owners operating a single aircraft, predominantly flying for recreation. Between those extremes are flight schools, aerial work operators, helicopter companies, charter operators, maintenance organisations, agricultural operators and a host of small businesses supporting the aviation sector.

The financial impact of a regulatory increase is therefore not remotely uniform. A large airline can distribute certain regulatory costs across thousands or millions of passengers and a substantial operating base. A private pilot cannot. If the owner of a small aircraft receives a new regulatory bill, there are no 300 passengers in the back of the aircraft to share it. There is simply the owner, the bank account and the increasingly uncomfortable realisation that the cost of flying another hour has nothing to do with the price of the fuel alone.

This matters because general aviation is not an irrelevant corner of the aviation industry as the regulator is perceived to believe. It is part of the pipeline that produces professional pilots, engineers, instructors and aviation businesses. The recreational pilot of today can become the commercial pilot of tomorrow. The student who starts flying a Cessna may eventually sit in the left-hand seat of an airliner. The maintenance organisation servicing a handful of privately owned aircraft may eventually employ engineers who work on commercial fleets. When the entry-level end of aviation becomes too expensive, the consequences eventually work their way upwards.

The fundamental purpose of aviation regulation is safety. That cannot be compromised, and Flightline Weekly certainly isn't suggesting that it should be. Nobody wants an aviation environment in which aircraft operate without proper maintenance, pilots fly without appropriate qualifications or operators ignore established safety standards simply because compliance costs money.

But regulation can become counterproductive if the cost and administrative burden become disproportionate to the risk being managed. There is a significant difference between managing aviation risk and managing paperwork. More forms do not automatically mean more safety. More fees do not automatically mean better oversight. More administrative requirements do not automatically produce better pilots or safer aircraft.

The regulator therefore has a responsibility beyond simply creating requirements and collecting fees. It has to consider the economic health of the industry it regulates. A healthy aviation sector is easier to regulate than a shrinking one. A growing pool of pilots provides more future professionals. Active maintenance organisations retain skills. Flying schools produce new licence holders. Airfields support businesses and communities. Aircraft that fly contribute to the aviation economy. Aircraft that sit in hangars because their owners can no longer justify the cost contribute very little beyond dust.

South African general aviation has already experienced the consequences that regulatory decisions can have on aircraft owners. The debate surrounding engine-life requirements is a particularly good example of how a technical regulatory decision can have a significant financial impact on individuals and operators.

Whatever one's position on the technical arguments, the economic reality is difficult to ignore. An engine replacement can represent a substantial financial burden for a private aircraft owner. For a major airline, replacing an engine is an unpleasant but budgeted maintenance event. For a private owner, it can represent a substantial percentage of the aircraft's value. Add regulatory fees, insurance, fuel, hangarage, maintenance, inspections, mandatory avionics upgrades and training to the equation and the cost of participation begins to look less like a hobby and more like a long-term financial commitment with wings attached.

At some point, the question becomes whether the regulatory environment is encouraging people to remain safely active in aviation or simply making it progressively harder for them to participate. That is a question SACAA should take seriously.

There is an uncomfortable irony in an aviation regulator overseeing an industry where the cost of participation continues to rise. SACAA quite rightly wants aircraft to be safe, pilots properly trained and operators compliant. But if the cumulative regulatory and operating burden becomes excessive, the unintended consequence can be fewer pilots, fewer aircraft flying, fewer students training and fewer small operators surviving. Reducing aviation does not enhance safety; it merely diminishes it. Smaller aviation is not necessarily more beneficial, especially to the DCA, who is reported to be paid more than the country's president.

The regulator should not only evaluate whether each regulation is technically sound, but also consider the overall impact of regulations, fees, administrative requirements and compliance costs on the industry as a whole. While an aircraft that remains safely on the ground is very unlikely to have an accident, it does not contribute positively to South African aviation. Perhaps the CAA needs to reassess its approach.

There is nothing wrong with SACAA defending its fees. There is nothing wrong with explaining why they are necessary. There is nothing wrong with ensuring that the authority has the resources required to perform its safety responsibilities. What would be welcome is a more visible recognition that the aviation industry also has limits.

Every rand extracted from a small operator eventually has to come from somewhere. Every additional cost imposed on a flight school ultimately finds its way into the student's training bill. Each new expense for an aircraft owner makes the decision to keep that aircraft operational slightly more challenging. Every additional administrative task consumes time that could otherwise be dedicated to maintaining aircraft, training pilots, or running businesses.

The regulator cannot simply look at each fee in isolation and conclude that it is affordable because the individual amount doesn't appear enormous. The aviation industry experiences the combined bill. And that bill is becoming rather substantial.

It’s important to state clearly: the South African Civil Aviation Authority (SACAA) plays a crucial role. Aviation regulation is essential, as is safety oversight, proper licensing, and maintaining aircraft standards. No one wants to go back to the days when aviation regulation was viewed as optional. However, SACAA is not immune to criticism simply because it serves as the regulator. In fact, its role increases the need for scrutiny and accountability.

The CAA should be able to explain its fees, demonstrate the value being delivered for those fees, publish meaningful service standards and demonstrate that its regulatory processes are becoming more efficient rather than simply more expensive. Because from the industry's perspective, the current arrangement can sometimes look remarkably one-sided.

• The CAA gets its fees.

• The CAA gets its applications.

• The CAA gets its inspections.

• The CAA gets its compliance reports.

• The CAA gets its regulatory authority.

The aviation industry gets the bill.

And then, occasionally, it gets to wait for the privilege of having somebody process the bill. Perhaps the question needs to change.

Instead of asking "How much can we charge the aviation industry?", perhaps the CAA should periodically ask "How much more can the aviation industry afford?" Because there is a point at which regulation stops protecting an industry and starts suffocating it.

If SACAA manages to make general aviation prohibitively expensive, they will achieve the ultimate goal of aviation safety: zero accidents. This isn’t due to South African aviation becoming the safest in the world, or because every aircraft is technically flawless, or because every pilot is exemplary. Instead, it will simply be because no one can afford to fly.

At that point, SACAA will finally have the perfect aviation system.

Every application can be processed on time. Every licence can be renewed immediately. Every inspector can be available. Every aircraft can be perfectly compliant. There will be one small problem.

There won't be anybody left flying.