After I've submitted the paperwork for my MPL revalidation, RAASA refused on the basis that my flight test was not of one hour duration.
Despite me pointing out to Mr Laubscher that they had no problem revalidating my license on two previous occasions with less than one hour flight test, RAASA persisted with their arbitrary and new interpretation of regulations.
I then took up the matter with CAA, saying the following:
I received a response from CAA today:I am the holder of a Microlight Pilot Licence (MPL), Number 30271052664. It was issued on 19/05/2005.
I am required to do a proficiency check every two years to have this revalidated.
This is governed by Part 62 of the Civil Aviation Regulations.
Accordingly my previous proficiency checks were done on 25/05/2011 and on 10/07/2013. These checks included a 0.6 and 0.8 hour (respectively) flight test. On these occasions, the appropriate paperwork, which included documentation of the flight test duration was submitted to RAASA, and the MPL was revalidated.
RAASA (a company) was established to discharge specific functions designated to it, by the South African Civil Aviation Authority.
On 20/06/2015 I underwent a proficiency check (see Part 62, Subpart 1, par 62.01.9 (2) (a) ) , including a flight test of 0.7 hours. This was conducted by the same flight instructor as before (see Part 62, Subpart 1, par 62.01.9 (4)). Accordingly (see Part 62, Subpart 1, par 62.01.9 (5)) the proficiency check shall consist a skills test as defined in Document SA-CATS 62 (see SA-CATS 62 - page 997). Note that the duration of the flight test is not defined.
As in the case with previous proficiency test, all documentation was submitted to RAASA with the full and reasonable expectation that the MPL will be revalidated.
I was then contacted by the instructor on 20/07/2015 telling me that he was contacted by RAASA and that I will have to redo the flight test on the basis of the flight not been one hour.
I subsequently questioned RAASA regarding this arbitrary and inconsistent requirement. My emails were ignored until Mr Laubscher (RAASA) supplied me with a copy of Part 62, which I already had. He seemed to interpret the regulations now (in contrast to previous years) differently, and wrongly wanted to apply a requirement mentioned in SUBPART 5 (62.02.5) which deals with requirements for the issue of a MPL to SUBPART 1, which deals with the requirements of revalidating a MPL.
Since RAASA is a private company doing administrative work on behalf of the South African Civil Aviation Authority (SACAA), and since RAASA seems to interpret said regulations arbitrarily and inconsistently, I contacted SACAA on 21/07/2015 asking that SACAA look into the matter, that is, that RAASA changes requirements without any notice and probably without any legal basis, and is refusing my application on an arbitrary basis and has not informed me of the fact or basis of this refusal.
Ms Stephens of SACAA undertook to come back to me.
In the mean time, not because I agree with the arbitrary and inconsistent manner in which RAASA dealt with me, but because I could see that it will take time to get these bureaucrats to admit that they are wrong, I did another proficiency test, at cost to the instructor.
As a result, and despite my request that Ms Stephens of SACAA reply to my initial complaint regarding this inconsistent and arbitrary application of regulations, I have had no response from SACAA regarding my complaint. Ms Stephens does not reply to emails, and a Mr Blake Vorster, who was cc’ed in some emails now would not tell me which official at SACAA should be dealing with this matter, neither would he tell me which official at the Department of Transport had oversight over the SACAA. 
The principle which needs to be addressed is whether a private company (RAASA, whose only reason for existence, and whose employees’ salaries depends on the creation and promulgation of paperwork) doing the bidding for a public department (SACAA, Department of Transport) should be allowed to arbitrarily and inconsistently apply regulations. What should be done is that the Public Department (SACAA, Department of Transport) should instruct RAASA to revalidate licences, as it has in the past, without the requirement of a hour flight test, as this is not stipulated in the relevant section of the regulations. Alternatively, the overseeing public department (SACAA, Department of Transport) should revisit the regulations so that there is no uncertainty regarding any requirement, shutting the door to these private bureaucrats to hold the public at ransom.
As SACAA does not seem intent on addressing the issue, my next step will be to ask the Department of Transport to address this.
I can provide a copy of all emails referred to above.
Please confirm receipt of this email.
So, do NOT allow this company, whose only reason for existence is to make and promulgate paperwork, bully you into accepting their illogical and self-serving intepretation of the regulations.Dear Dr Coetzee,
The Legal Division of the South African Civil Aviation Authority agrees with you interpretation of the relevant regulations pertaining to Part 62.
The SACAA will consider amending Part 62 in regard to the duration of skills tests in order to make the regulations clear and unambiguous on this particular aspect.
The SACAA will bring this the handling of your application for renewal by RAASA to their attention and request them to follow the applicable provisions with reference to the renewal or re-issuing of a MPL.
Principal Legal Advisor
South African Civil Aviation Authority
If you have any problems with Mr Laubscher and Co. I suggest you contact Mr Herman Wildenboer, or Ms Mamabolo :