March 2023 – Who Guards the Guards?
The development of general aviation in South Africa faces three large hurdles:
1) The high price of fuel.
2) The weak Rand and associated high price of new planes and parts.
3) The CAA – which, despite its mandate to develop aviation, has all too often become the ‘Commission Against Aviation’ with its endless ‘tea time’ rulemaking that slowly strangles the industry.
THERE IS NOT MUCH GA can do about the first two hurdles, but having the SACAA strangle the industry is hard to swallow. As the regulator, or ‘traffic cop,’ of civil aviation, the SACAA comes in for more than its fair share of flak. However, at times it falls down properly – and at the moment it has at least three big stumbling blocks, (plus many smaller ones) which quietly fester:
The Designated Flight Examiners (DFEs) are at war with the SACAA’s testing officers (TOs) who oversee them. In one of its sporadic eruptions of idiocy the SACAA is shooting itself in the foot by demanding to be paid for what should be a free service – and in the process completely screwing up the entire type ratings and differences system which has worked okay for the past twenty years.
In an equally incomprehensible move, the SACAA seems determined to make life impossible for what few restricted radio licence examiners are left – which will make it stupidly difficult and expensive for new pilots to get a radio licence.
‘victimisation and authoritarianism’
I don’t have the space in this column to review all these issues, so this month I will focus on the DFE vs TO conflict.
DFEs vs TOs
Contrary to what many seem to want to believe, the stumbling blocks to SACAA competence and quality service delivery are not inexperienced affirmative appointees, but the writhing snake pit of race relations and internal politics which makes it difficult for the regulator to attract and retain quality people – particularly experienced inspectors.
South Africa is increasingly beset by toxic race relations. Non-whites are frustrated by the entrenched prejudice that comes from the endless concessions made to compensate for substandardeducation. And white males are threatened by those who consider themselves entitled to their jobs.
This inherent racial tension aggravates the empire building and back-stabbing that characterises any bureaucratic organisation. The net result is that, like the American presidency, all too often the best people for the job simply don’t make themselves available.
In aviation, the function where the SACAA, as the regulator, particularly needs to have the best people available is the Testing Officers (TOs) who conduct Designated Flight Examiner (DFE) oversights. The SACAA may be the custodian of aviation standards in South Africa, but it is the designated flight test examiners who really set and keep the standards of flying. They represent the SACAA and are the uberinstructors – the best of the best. Although the DFEs are the highest of all instructor levels, they are still subject to oversight inspections by the Testing Officer; the ‘examiners of the examiners’. Thus are the guards of flying guarded.
‘DFEs report feel humiliated’
As the ‘examiners of the examiners’, the TOs must be drawn from the ranks of senior pilots with tens of thousands of hours of experience, usually as Training Captains on the airlines. They should have in-depth experience from having seen and done it all.
Usually enough retired airline Training Captains can be persuaded to continue contributing their lifetime’s worth of accumulated knowledge by taking these TO posts so that they may mentor others. But many claim the politics and toxic working environment at the SACAA just does not make it attractive enough.
ICAO is well aware of this problem. ICAO Doc 8335 specifies that, “Ideally an inspector should be at least as qualified as the personnel to be inspected or supervised. …… Persons seeking a position as a flight inspector should have held previous appointments, either in operational management, as an airline pilot and designated examiner, or training instructor, or as a military pilot, where equivalent experience in air transport operations would have been acquired.”
The problem that threatens to tear apart the top levels of testing standards is that the DFEs say, “As far as the DFE’s can ascertain, the SACAA AOs neither hold valid flying licences, Instrument Ratings, nor Instructors ratings.”
And so we have the situation where a lapsed Grade 2 instructor is supposed to be able to test a DFE.
Describing how the lack of TO experience has become toxic, the DFEs say, “The oversights conducted by the SACAA AOs are perceived, by a number of the DFEs as a punitive process brought on by the perceived victimisation and authoritarianism by the AOs.
Some DFEs report feeling humiliated by the AOs. We feel that the current manner of conducting oversights does not foster sound interaction and communication between DFEs and AOs, which will have a long term detrimental effect on flight safety in South Africa.”
Simply put – if the DFEs get gatvol of the ‘victimisation, authoritarianism and punitive testing’ they will take their clipboards and headsets and leave the industry, creating a chronic skills shortage that will have a large impact on the standards and thus safety of the South African aviation industry.
‘SA aircraft could be black-listed’
So what can be done?
The DFEs write; “It is easy to find fault, but far more difficult to find solutions. DFEs are dedicated members of the aviation industry and as such have a number of suggestions to overcome the problems:
Considering that DFEs are appointed by the SACAA, treat DFEs as part of the team and solution, and not as the opposition.
In the interest of transparency, the SACAA should publish the credentials of AOs so that, within the flying industry, their credibility will be accepted.
Check AO oversight pass/fail statistics to ensure standardisation and as such, establish if AOs are possibly undermining the oversight process and generating a problem in this regard.
Don’t work in isolation. Look at world best practices and appoint a group of DFEs to assist in developing workable and implementable solutions. Refer to the helicopter DFE standardisation group that has been formed.
Treat these issues as urgent within the aviation industry as the safety implications cannot be ignored. To these I can add three more suggestions that have been proposed at various times.
This problem of DFEs vs TOs is not unique to South Africa. It has happened elsewhere in the world, so there are lessons to be learned.
In Europe there was also excessive emphasis on the ground evaluation during the TO oversight process of DFE. This was mainly due to the fact the TOs were inexperienced and focused mostly on what they were good at, that is, the regulatory side. This process created enough frustration for the examiners to conduct an anonymous, independent survey amongst the examiners to determine the extent and nature of the problem. Based on the outcome of this survey, they then contracted an independent aviation consultant to act on behalf of the examiners, negotiating with EASA for a workable solution.
The agreed solution was to move the assessment/examiners process back into the industry. To do this, EASA appointed suitably experienced and talented Senior Examiners (SE) from within the industry. As a safety check, EASA still maintained a small group of Flight Inspectors that had the right to, from time to time, monitor tests being conducted by a senior examiner.
While knowledge of rules and regulations is essential, what is most important is the SE creating a healthy environment in which a pilot can prove his skills. The emphasis therefore when selecting SEs rests heavily on human factors, interpersonal relationship and communications skills to eliminate any possibility of perceived victimisation and authoritarianism leading to the humiliation of candidates. SEs must not be appointed if they are not able to demonstrate these human factor skills.
Since there are no checks and balances for the TOs, to defuse the adversarial relationship between DFEs and TOs, all complaints should be heard by an oversight committee comprising SACAA senior officers and two outside nonexecutive people of sufficient standing in the aviation community. This should not just be for DFEs but, if it was available across the industry, it would save the SACAA much time and money.
As recently introduced in the USA, South Africa needs a ‘Pilot’s Bill of Rights’. We need an Ombudsman for Aviation to counterbalance the unchecked and too often destructive behaviour by the SACAA.
‘The SACAA has a regular ICAO finding about the quality of its Testing Officers.‘
The DFEs write, “High training standards, the suitable climate and good training facilities have made South Africa a ‘go to’ destination for flying training. Additionally, the South African aviation industry plays a vital role in underpinning the tourist industry.
“If the safety situation deteriorates, it is conceivable that South African aircraft could be black-listed from flying into other countries’ airspaces or regulators prohibiting their aircraft from landing in South Africa. South Africa cannot afford to let this happen and we owe it to future generations to uphold the standards.”