Guy Leitch
Sometimes it seems that the CAA really loses the plot and sets out to destroy general aviation. (And thus living up to its moniker the Commission Against Aviation). We are in the middle of one of those moments, and for many this is a life or death struggle.
I have been sitting quietly on my hands watching the noise on social media interspersed with announcements from bodies such as the Commercial Aviation Association (CAASA) and the CAA. In the end the noise-to-signal ratio become hard to unscramble and so I have done something new: I asked Chatgpt’s ‘In depth’ research button and was amazed at what it produced.
Here is a shortened version that I have taken the liberty of applying a very few of my own changes to, denoted by [square brackets]:
Background: What is AIC 18.19?
Aeronautical Information Circular 18.19 was a notice issued by the South African Civil Aviation Authority (SACAA) related to aircraft engine overhaul requirements. Originally issued in 2001 (re-issued in 2006), AIC 18.19 effectively provided an exemption from a strict time-based engine overhaul rule: it allowed aircraft owners to maintain airworthiness through periodic inspections, rather than mandating an engine overhaul after 12 years in service, [regardless of how many hours it had accumulated before the manufacturer’s recommended overhaul time in hours.]
In practice, this meant that under AIC 18.19, if an aircraft’s engine was older than 12 years since its last overhaul, a detailed inspection regimen could be used to confirm the engine was still airworthy, instead of automatically requiring an expensive overhaul.
This alternate compliance method was intended to ensure safety while relieving operators of the cost and downtime of a calendar-time overhaul. The circular mainly benefited the general aviation sector – including private owners, flight schools, and charter operators – by keeping older aircraft flying as long as they passed inspections. For over 15 years, AIC 18.19 was part of the SACAA’s published guidance, and many in the industry operated under its provisions.
CAA’s Official Reasoning for Upholding (and Withdrawing) AIC 18.19
Why did SACAA maintain AIC 18.19 for so long, and why withdraw it now? The SACAA has provided several official justifications:
- Regulatory Misalignment: In a recent review of legacy AICs, the regulator found that AIC 18.19 was out of alignment with current aviation regulations. Notably, the circular referenced the 1997 Civil Aviation Regulations (CARs), which had been repealed and replaced by 2011 regulations. In other words, AIC 18.19 was legally outdated – it pointed to rules that no longer existed. This inconsistency created a legal void: the AIC was being used to justify practices not supported by the current law, prompting the CAA to act. The Director of Civil Aviation explained that given these irregularities, it was “necessary for the Regulator to withdraw the AIC.”
- Improper Use of an AIC: SACAA emphasised that an Aeronautical Information Circular is meant to disseminate information, not to grant ongoing exemptions from regulations. In the case of AIC 18.19, the circular had been effectively used as a long-term loophole to bypass the manufacturer’s 12-year engine overhaul recommendation [Note: this is a recommendation by the manufacturers, it is not mandatory] that was embedded in earlier regulations. The CAA characterised this as an incorrect use of an AIC – since binding requirements or exemptions should be handled through formal regulations or notices, not just an informational circular. This procedural critique was part of the justification for ending the circular’s effect.
- Safety and Liability Concerns: The regulator identified AIC 18.19 as a potential safety risk and legal liability. By allowing engines to run beyond the recommended [my emphasis] overhaul interval (based on calendar time), the circular could increase the chance of engine failure due to age-related factors – a risk that SACAA found unacceptable. SACAA officials noted that the circular was “exempting aircraft owners and operators” from complying with manufacturer-prescribed overhaul intervals, which raised red flags for both safety oversight and the CAA’s legal responsibility. If an accident were traced to an overdue engine, the existence of an SACAA-issued exemption could implicate the regulator. Thus, continuing to uphold AIC 18.19 was seen as creating liability and undermining the safety mandate of the CAA.
- Alignment with Manufacturer Guidance and Global Standards: SACAA argues that its duty as regulator is to enforce compliance with manufacturer maintenance manuals and standards, including engine overhaul schedules. Most engine manufacturers (such as Textron Lycoming and Continental) recommend overhauls every 12 years or a certain number of flight hours, whichever comes first. [Note though that at time of writing, the AIC withdrawal only affects Lycoming and Continental piston engines, and there are no moves to include Rotax or Pratt & Whitney or Franklin engines.] The SACAA’s stance is that adhering to these guidelines is essential to catch problems like internal corrosion, metal fatigue, or seal degradation that may not be visible during routine inspections. A spokesperson noted that “aging components – particularly in critical engine assemblies – can experience metal fatigue, corrosion, and rubber degradation that are invisible during external inspections. Overhaul intervals are designed to identify these failures before they become safety risks.” In enforcing the time-based overhaul, SACAA also cites international norms. They point out that authorities like the European Union Aviation Safety Agency (EASA) and even the U.S. Federal Aviation Administration require such overhauls for commercial operations and expect regulators to ensure aircraft are maintained per manufacturer specifications. SACAA has indicated it is essentially aligning South Africa’s rules with global best practices on engine maintenance, especially to avoid any issues when South African-registered aircraft fly abroad. There’s an underlying concern that failure to enforce fundamental safety standards could lead to international scrutiny or downgrading of South Africa’s aviation safety rating, should an incident occur. An SACAA official warned that waiting for a major accident involving an ageing engine could be derelict: “If we wait for a major incident to act, we will have failed in our duty of care.” This sense of pre-emptive safety enforcement is a key reason the CAA has held firm.
- Inconsistencies in Alternate Compliance: According to SACAA, the inspection programmeme allowed under AIC 18.19 introduced too much subjectivity and variability. Not all maintenance inspectors might catch latent problems in an ageing engine – skill levels vary, and some deterioration can be subtle. SACAA insiders noted that this “blanket inspection exemption created a loophole”, relying on subjective judgments of engine health. The regulator concluded that safety cannot depend on discretionary inspections alone. In their view, a rigid overhaul requirement is a more uniformly enforceable and fail-safe standard. Essentially, SACAA lost confidence that the industry’s on-condition inspections were sufficient to guarantee safety in every case, especially as aircraft age. They even cited an example from the region: a 2019 private aircraft accident in Botswana where an old engine failed after long storage, which was attributed to internal corrosion and missed warning signs – an incident that “raised red flags across the SADC region” about allowing engines to go indefinitely without overhaul. This kind of data, albeit limited, reinforced SACAA’s belief that time limits serve as an important safety backstop.
In summary, the SACAA’s official justification for upholding the overhaul rule (and thus ending AIC 18.19’s exemption) centres on regulatory conformity and safety assurance. The Authority maintains that its stance is “safety-first”, even if that means imposing economic costs. As SACAA’s Director Poppy Khoza stated, decisions taken for safety can override commercial interests, and finding a balance isn’t always possible when lives are at stake. The CAA has indicated it will continue engaging with stakeholders and even engine manufacturers to “find a middle ground” or clarify technical requirements, but it has “dug its heels in” on the principle that engines beyond the recommended life must be overhauled for the sake of safety.
Enforcement of the 12-Year Overhaul Rule
After withdrawing AIC 18.19 in late 2023, the SACAA implemented a transition period to give operators time to comply. A general exemption (with conditions) was issued on 1 December 2023 for an initial 180 days, and later extended by another 180 days, ultimately expiring on 26 November 2024.
This exemption essentially temporarily preserved the status quo of AIC 18.19 – allowing affected aircraft to keep flying under inspection programmes – while the industry prepared for the enforcement of the overhaul rule. SACAA made it clear that after November 2024, no further extensions would be granted; aircraft owners would be required to fully comply with the Civil Aviation Regulations (CAR) 43.02.5 and associated technical standards, which mandate adherence to manufacturers’ maintenance instructions (including any 12-year overhaul recommendations).
Going into 2025, SACAA followed through with this plan. The grace period lapsed, and the CAA began denying Airworthiness Certificates to aircraft that had engines older than 12 years without overhaul. Effectively, those aircraft have been “constructively grounded” until their engines are rebuilt or replaced. SACAA’s June 2025 media statement emphasises that this policy mainly impacts general aviation aircraft (especially those with Textron Lycoming or Teledyne Continental piston engines) and not large commercial airliners. The regulator also disputes the scale of impact estimated by critics, saying claims of 1,400 aircraft grounded and 300,000 jobs affected are “untested” and believed to be exaggerated. Nonetheless, by mid-2025 there is no doubt that a significant portion of the private and flight-training fleet in South Africa has been forced to stop flying pending costly overhauls. SACAA has acknowledged the industry’s outcry but insists that the ultimate goal is to “ensure aviation safety and security is not compromised”, and it has stood by the enforcement as a necessary tough step.
Industry and Community Responses to AIC 18.19’s Withdrawal
Industry stakeholders warn that enforcing the 12-year engine overhaul rule has effectively sidelined hundreds of light aircraft, with dire consequences for flight schools, charter operators, and maintenance businesses.
The reaction from South Africa’s aviation community to the withdrawal of AIC 18.19 has been overwhelmingly negative. Aviation industry groups, political figures, and individual operators have voiced serious concerns, arguing that the SACAA’s hardline stance is inflicting economic damage without clear safety benefits. Key responses and opposition points include:
Scale of Impact: Various stakeholders claim that around 1,400 aircraft have been grounded due to the new enforcement, representing a large portion of South Africa’s general aviation fleet. These are primarily light planes and helicopters used for pilot training, charter flights, aerial work (like game counting or surveying), and private/business transport. The knock-on effects of suddenly immobilizing this many aircraft are enormous.
Flight schools cannot operate their trainers; charter and safari operators lose business; aircraft maintenance shops and parts suppliers see demand evaporate; and pilots and support staff face layoffs. Industry estimates suggest up to 70% of the country’s aging general aviation fleet could ultimately be affected, given how many aircraft engines are over 12 years old. A consortium of aviation bodies warned that an “entire sector of the aviation industry could grind to a halt,” with ripple effects on related sectors like tourism, agriculture (which uses planes for surveying and anti-poaching patrols), and even emergency services.
CAASA described the situation as a “serious threat to South African aviation”, noting that many owners may simply quit flying because they cannot afford the required overhaul, potentially crippling general aviation for years to come.
Financial Burden: A central complaint is the extraordinary cost of compliance. Overhauling an aircraft engine (especially twin-engine aircraft, common in training and charter) is very expensive in South Africa – often on the order of R1 million to R2.5 million per engine (approximately $50k–$130k). For older light aircraft, this may exceed the aircraft’s monetary value, effectively rendering them write-offs. Industry representatives argue that forcing “premature” overhauls – when an engine might have low running hours and be in good working order – makes no economic sense, especially as the country’s aviation sector is still recovering from the COVID-19 downturn. The time out of service is also a factor: each overhaul can take months (if not a year) due to scheduling backlogs and potential parts shortages. Kevin Storie, CEO of CAASA, highlighted that spare parts are scarce and subject to import tariffs, compounding the difficulty of compliance. The outcome, opponents say, is that many small aviation businesses face bankruptcy or liquidation because they either cannot use their aircraft or must sink unaffordable sums into them.
Lack of Consultation and Transparency: Both industry stakeholders and the DA have criticised the manner in which AIC 18.19 was withdrawn, saying it was done with no warning, no stakeholder consultation, and poor communication. The withdrawal came “without consultation” in late 2023, surprising many operators who suddenly found themselves in non-compliance. Stakeholders argue that SACAA should have engaged the community to develop a phased approach or alternative solutions (such as a tailored inspection programme or a risk-based extension process) instead of an overnight rule change. The Aviation Watch Action Committee and other groups decried the lack of a “clear path forward” when the AIC was pulled, leaving owners scrambling. This perceived heavy-handedness has fuelled resentment and calls for oversight on the regulator’s decision-making process.
Safety Record and Data: A core argument from opponents is that AIC 18.19 worked effectively for nearly two decades without compromising safety. They point out that over the 17 years that the 12-year overhaul rule was not enforced (thanks to AIC 18.19), South Africa did not experience any spike in engine-failure accidents attributable to “old” engines. In fact, the general aviation safety record during that period remained strong, suggesting that the combination of regular inspections, adherence to hourly maintenance, and sensible preventative care was sufficient to ensure safety. Industry experts have noted the lack of empirical data or accident statistics to justify the new overhaul mandate. “No empirical evidence exists to indicate that safety is being compromised.” They also challenge SACAA’s claim of “high risk to safety” as unsubstantiated, citing independent studies and manufacturer Service Bulletins that do not show a significant increase in engine failure risk solely due to calendar age, provided proper maintenance and periodic internal inspections are done. In short, the aviation community is asking: Where is the proof that a well-maintained 13-year-old engine is unsafe? Many see the enforcement as overreach without science, potentially solving a problem that isn’t evidenced to exist in South Africa’s context.
[Surprisingly what has not been mentioned is the widely help belief (which may be empirically proven) that recently overhauled engines are in fact more dangerous than 12-year old engines with a long record of serviceability.]
Operational Contradictions: Some critics highlight inconsistencies in how the rule is applied. For example, under current regulations, an aircraft operated privately (non-commercially) might still be flown with an engine beyond 12 years (at the owner’s risk), whereas the same aircraft cannot be flown commercially (for hire) once it hits the 12-year mark. This creates a paradox where an aircraft is deemed “unsafe” for paying passengers but “safe enough” for an owner’s personal use or family, which opponents argue “constitutes a mockery of safety”. (It should be noted that as of 2025, even private Part 91 operators in general aviation are effectively pressured to comply with the overhaul rule for insurance and airworthiness; however, ultralight and recreational aviation under Part 94/96 has been exempt from the start.) Sections of the aviation community feel that SACAA’s decision was driven more by bureaucratic or commercial motives than by actual safety data.
Public and Political Outcry: The backlash has extended beyond just pilots and plane owners. News of the grounding of [a claimed] 1,400 aircraft made national headlines in mid-2025, portraying it as a “sudden policy shift” that threatens an entire industry. The story has been covered in mainstream media and aviation publications, often emphasising the potential loss of 300,000 jobs in the aviation value chain (a figure the CAA disputes). Politically, members of Parliament and provincial authorities have been lobbied to intervene. The opposition Democratic Alliance has been especially vocal – not only demanding AIC 18.19 be reinstated or replaced with an equivalent measure da.org.za, but also using this case to criticise SACAA and the Ministry of Transport for what they call heavy-handed and ill-informed regulation. In short, AIC 18.19’s removal has become a flashpoint in the country’s aviation community, rallying a normally fragmented sector into a unified front against the regulator’s policy.
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