With changes afoot to the regulatory environment in aviation English, we feel it important to understand properly the existing situation, some aspects of which are unclear to us.

Here we propose some questions to ask regulators. Do others wish to add more questions? 

If you are yourself a regulator, would you be willing to answer?

The reasons for the questions are explained below.

Questions for Regulators

1) Do State regulations demand an oral test of standard phraseology in English? 

2) Pilot Examiners in many European airlines are permitted, during simulator checks, to simply sign off their pilots at either Level 4 or Level 6 without having conducted a formal ELP test. Is this a valid methodology?

3) Could every State consider collecting the number (or percentage) of Level 6 ELP certificates awarded by its approved entities,

Explanation / Commentary

1) Do State regulations demand an oral test of standard phraseology in English? (By 'oral', we mean a test of speaking and listening, not a written test)

It’s our understanding that regulations in the UK, Malta and Germany demand an oral test (as well as a written test). It would be useful to know if that holds true for all EASA Member States. If States do not demand an oral English test of standard phraseology, then this would appear a weakness in the testing of English communications since ELP testing is not meant to account for RT proficiency testing at all. ICAO 9835, 6.2.8.6., states:

“The use of ICAO standardized phraseology is an operational skill that is taught by qualified aviation operational specialists and is acquired to the required level of proficiency by trainee pilots and controllers during operational training. Teaching and testing standardized phraseology are operational issues, not a language proficiency issue. It follows that a test designed to evaluate knowledge or use of standardized phraseology cannot be used to assess plain language proficiency.”

In States in which there is no mandatory oral English phraseology/radiotelephony test in place, it would appear that many regulators view an ELP test as a catch-all solution for both phraseology and plain English testing. A change to the guidance on oral English testing  of standardised phraseology might really assist the ELP testing industry to progress, whilst improving aviation safety.

2) Pilot Examiners in many European airlines are permitted, during simulator checks, to simply sign off their pilots at either Level 4 or Level 6 without having conducted a formal ELP test. Is this a valid methodology?

We have anecdotal evidence that suggests that the roles of Sim Instructor and ELP Assessor are being conflated as a matter of convenience, since having both certifications enables assessors to “sign off” pilot ELP levels at the end of a sim session.

If ELP test outcomes are to be fully trusted, formal tests which include a thorough challenge to all candidates and an assessment by 2 certified Raters (as per ICAO 9835 guidelines), are required.  Meanwhile, however, if the accepted practice of ‘sim check ELP sign offs’ continues, it may well have the result that: 

  • The ELP levels of thousands of licensed pilots are unregulated;
  • Aviation professionals may consider the ELP testing industry is performing poorly and perhaps even failing in its responsibilities;
  • Non-airline pilots (e.g., PPLs) who are not afforded this luxury are therefore being unfairly penalised.

3) Could every State consider collecting the number (or percentage) of Level 6 ELP certificates awarded by its approved entities?

We have anecdotal evidence that pilots who receive Level 3 at one ELP testing source receive Level 6 certificates soon after from another (EASA MS-approved) LAB.

If this is a verifiable phenomenon then there is likely to be evidence of “test shopping” which might become visible from such data, potentially warranting further investigation into the outcome disparity.

Until issues such as these are tackled at regulatory level, there seems little value in trying to standardise formal ELP testing as there will always be the ‘good and the bad’, that is, those providers who take the task seriously and professionally and those who do not.

As before we can be contacted via our LinkedIn page, or privately through this email.

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