LANGUAGE PROFICIENCY RATINGS

[CAA]

Hello Everyone

Attached, please find the draft document pertaining to language proficiency ratings. Please note that this is a DRAFT for comment; please do not start submitting your documentation yet.

Any constructive input on the draft will be appreciated.

Deadline for comment is Thursday, 12 July 2007.
All comments posted on this thread by the deadline, will be submitted for consideration

[RV]

Hi guys & gals, this one is important, please keep all debate clean & constructive. If avcom is to be taken seriously, please think before posting something that does not add value.

[dilligaf]

Disappointing is the word that comes to mind. That's after rejecting my first 10 choices as not fit for publication.

CAA has clearly decided to ignore the the fundamental issues and has spent a month window-dressing a half-baked temporary compromise aimed only at spreading out the testing period.

1. ICAO does not (as far as I can see) prescribe any requirement to CAA other than the need for pilots engaged in international flight to qualify their English language skills. My request for proof to the contrary has yet to find a response.
2. This is an "Interim" measure. After 3 or 6 years any PPL who passes the "interim" test by virtue of having Matric English or better will have to test anyway. Worse, CPL and ATPL holders have to test at renewal time.
3. It expires on December 15. Anyone who would have "qualified" will then have to do the test. Not that they would have lost their language skills by then, but.....

I was born to English parents, have spoken English as my home language all my life and graduated from a English medium high school and University. For this I get a level 5 rating. I have to undergo the test in 6 years as a PPL, but as a CPL I have to do the test at renewal time (October).

[Chris]

My thoughts exactly.

As far as I can see ICAO require at least level 4 for INTERNATIONAL flights. This document has been met with total rejection by GA in Europe where international flights are common. Why should we have it in SA where very few flight are international. ICAO has requested their member states to have language proficiency test in place by 2008. We all know that ICAO does allow member states to have differences.

The President if the FAI is meeting with the President of ICAO in Montreal on 12 July to discuss the matter, the same date the CAA document closes for comment. I think CAA should extend the date for comment until I can get feedback from that meeting. My understanding is that the FAI will be fighting for the language proficiency tests to apply to international IFR flights only not VFR.

[Dave]

Thanks for the opportunity to comment.

While I see the proposal as a move towards toning down the original onerous local requirements I still feel it does not go nearly far enough in dealing with the local situation where the majority of pilots are either ‘native’ English speakers or speak English reasonably fluently as a second language.

To quote from an ICAO document.

“In practice, language proficiency assessment for native and/or Expert speakers can consist of an interview with a representative from the Licensing Authority such as a flight examiner. If a problem is noticed (speech impediment or inappropriately strong regional accent) during such an interview, the applicant should be referred to a specialist for follow-through…………………….. This is because native speakers can easily identify other speakers with native and/or Expert language proficiency through fluent and natural use of the language. Similarly, completely inadequate proficiency is also relatively easy to identify.
"

From another source quoting ICAO

“, ICAO said that testing of an individual for whom English is his or her native language likely could consist of a brief interview by a representative of the state’s licensing authority, to determine that the individual does not have a speech impediment or inappropriately strong regional accent that affects communication.”


I believe that in the case of most local pilots a simple declaration by the Official Radio Examiner on the Radio Certificate or alternatively by the Grade II examiner on the PPL test form would conform with ICAO requirements. This is the case in the UK as mentioned in an earlier post by Irv Lee this year.

No fee should be necessary (I understand it would be R200), as it is not a “rating” in the sense originally intended in Part 187 but rather, in my view, a certification. This is of course assuming that the requirement would indeed apply to all pilots and not just those flying internationally.

The need for Linguistic Experts should come into play when English is clearly not the home language.

[buccaneer]

I concur with the comments by Chris and Dave.

I would further strongly advocate that both the closing dates for comments as well as the 15 December date be reconsidered. For us in other parts of the world, 15 December 2007 give us very little time to return to SA, as some might have only the opportunity to go back again after the end of the year! (They might have already utilised all their available opportunities!)

Without stirring the hornest nest, should we not have policy and procedures in place to address the language issue in totality? (ICAO and other parts of the world has some other recognised languages!) Or is it a question of too little too late?

I profess to be a staunch supporter of linguistic skills and competence in a variety of languages!

Better communication leads hopefully to better understanding!

[Ou Ballie]

What happens if you dont have a Matric certificate ?

[Harvard]

Does everyone have to go to JHB/ CPT/ DBN for this test? I haven’t had time to read through all of this.

Points that concern me:

1. Pilots from smaller areas such as Bloem, Kimberly, Eastlondon, Aliwal North (mostly PPL) have to travel a long distance to go "chat". Would it not be possible to get an examiner to go to central areas where pilots from around that town could come in one day and do these tests?

2. There are allot of pilots I know that have heard about this and let it brush over thinking that its not important for them to go through all of this.

3. There are pilots at our local flying club (Mainly the older guys, my dad included) that think this is all a bunch of bull and refuse to go up to JHB to do any testing and are against/ refusing to co-operate at all with the new system.

4. There's one pilot I know that put his foot down refusing to speak anything but Afrikaans, saying that they’ll have to take his license away, even then he wont speak English. Often I don’t understand what his saying on the radio and my Afrikaans is not bad!

5. Where and how long is the waiting period to do this? I'm at CAA early August for half a week, and then I’ll be full time busy with work. Besides costs to get to JHB, I don’t see where I'm going to find the time.

To end off, I'm not against the English requirement, just very concerned about some pilots that are refusing/ don’t know about this/ don’t have the time/ money to do this test. For some, it is not an option to even get out of town for a day.

Best solution for the problem (although not a brilliant one) is to have an examiner going to central areas for a full day, where pilots can quickly stop by the airport and do there test. Even if it is R100 or so more, still allot cheaper than traveling to JHB.

[Lardbeast]

Testing and certification fees are just another poorly disguised attempt to extort more money from what is considered the milch cow of aviation, the poor bloody user who needs to keep his licence for whatever reason. As for certifying native English speakers as anything less than level 6, it's ridiculous and once again an attempt to screw more fees out of the user by requiring wholly unnecessary recertification in a language used every day.

These measures are understandable where English is not a first or even a second language, but to pressure native speakers of the language in this manner is quite plainly a money grabbing excercise and has no bearing on the reality of the situation.

South African citizens should all be assumed to have the necessary language skills and a common sense approach to certification should be taken. Those quite clearly unable to communicate in English when they do a renewal should be referred to an examiner to be assessed and assisted to gain the level required. The use of English during a renewal followed by a tick in a box on the renewal form should be quite enough to certify and maintain that certification, with the proviso that it should not be used as part of the actual renewal test, merely as a confirmation that the person being tested is indeed able to converse in that language to a level acceptable for use by aviators.

[GaryM]

The use of English during a renewal followed by a tick in a box on the renewal form should be quite enough

Amen to that - can't ever see it happening unfortunately...!!

[dilligaf]

Mary - some commentary without the emotion of my initial response. I sincerely hope that whatever is posted here will find its way back to the proposers of the ruling.

1. It still appears (not just to me) that CAA has misinterpreted the fundamental intent of the ICAO ruling. I for one would like to see some open discussion based on the ICAO documents CAA is using as its foundation for the proposal as well as some proof that ICAO is pressurising CAA to adopt this specific approach. It would be useful if CAA could post these here for review, to ensure we're all talking the same language.

2. A fundamental problem in the proposal is that on the one hand it establishes a basis for obtaining a "rating" based on proof of qualification, yet on the other hand renders this invalid by mandating testing at a later date. This makes no sense whatsoever :

- The proposal readily accepts that someone with a C or better in English First Language is proficient enough to receive a level 5 rating. This means no testing for 6 years for a PPL. By definition CAA has therefore accepted that this person is proficient enough to fly anywhere, including outside SA. Yet after 6 years this same pilot has to undergo the test. This makes no sense - this pilot has been deemed safe to fly for 6 years, after which the rating is no longer any good. What could possibly have happened to reduce the pilot's language skills in the intervening 6 years ?

- The same logic applies to CPL and ATPL holders. Effective immediately, they may obtain a rating simply by sending proof of qualification. They can fly as long as they have this rating, which in some cases could be up to something like August 2008. After this they are assumed to not be proficient until they are tested. Yet we happily allow them to fly for up to a year on the assumption that matric results actually count for something. Again, what could have diminished the holder's language proficiency in the prior 12 months ?

3. CAA's assumption that no pilots are actually proficient in English until they have proven this, is equivalent to the presumption of guilt until proven innocent. It also makes a mockery of the education system inasmuch as it rejects the proof of competency issued by the authorities. This is nonsensical. Furthermore, to levy fees against pilots in forcing them to prove what has already been proven is extortionist.

4. Providing one week for discussion and input makes a mockery of CAA's own "consultation charter" and smacks of heavy-handedness to say the least. A suggestion has already been made that this very issue is on the table for discussion between ICAO and FAI. This should be more than adequate reason for providing more time for open discussion.

Nobody disputes the thesis that language proficiency is an integral part of aviation safety. It is simply SACAA's approach to addressing this that is being challenged.

1. ANY South African with a pass in Matric English (be this Higher or Standard Grade, First or Second Language) should be automatically rated at level 6. If it is good enough for the Dept of Education it should be good enough for CAA and ICAO.

2. Rational and client-centred approaches to assessing those who do not have Matric English should be developed; these should not automatically assume "Language Experts" are required to assess communication skills.

3. Going forward, proficiency should be assessed during Radio Telephony Licence testing as an integral part of the process, not as a separate langauge skills examination.

4. Consideration should be given to assessing flight examiners' (CFI's and DE's) capacity to assess the language skills of pilots as a matter of course during ab-initio and renewal testing.

[AirFalcon]

This is by far the the most ridiculous regulations that the CAA is trying to force on the South African aviation community.

It is simply a method to extort funds from all involved hitting those who can barely afford to get in to this expensive career hard. As well as those who are passionate about flying and scrape together money to be able to fly once in a while, and that is obviously not International flights.

The DRASTIC measures that the CAA is taking is totally uncalled for. You do not need a specialised to determine if somebody is proficient in English, a designated examiner or instructor would be able to do this. If he is unable to determine if the person is not proficient in English then he is definetly not capable of determining if a pilot has passed his flight test/renewal. After all, it is the job of the DE to determine if a person is capable to safely operate an aircraft. So therefor I strongly stand by the method that has been recommended.

The use of English during a renewal followed by a tick in a box on the renewal form should be quite enough

The time lines thrown at us are totally unrealistic and reflects the true nature of this whole project.

I get a feel from the community (not just avcom, but as a whole), judging from what people have been saying, that everyone is against this because of the method that has been chosen. I truly hope that what has been said on this forum is highlighted at the meetings where these regulations and decisions are being made. Safety is very important to us all, but please don`t use that as a tool to get rash and extort our time and money.

[Ou Ballie]

South African citizens should all be assumed to have the necessary language skills and a common sense approach to certification should be taken. Those quite clearly unable to communicate in English when they do a renewal should be referred to an examiner to be assessed and assisted to gain the level required. The use of English during a renewal followed by a tick in a box on the renewal form should be quite enough to certify and maintain that certification, with the proviso that it should not be used as part of the actual renewal test, merely as a confirmation that the person being tested is indeed able to converse in that language to a level acceptable for use by aviators.

I aggree. All South African PPL, COM, ATP pilots passed the ENGLISH CAA exams. How can they pass it if they cannot understand English. It should be for people with validated PPL, COM or CPL's I think

[dilligaf]

South African citizens should all be assumed to have the necessary language skills and a common sense approach to certification should be taken. Those quite clearly unable to communicate in English when they do a renewal should be referred to an examiner to be assessed and assisted to gain the level required. The use of English during a renewal followed by a tick in a box on the renewal form should be quite enough to certify and maintain that certification, with the proviso that it should not be used as part of the actual renewal test, merely as a confirmation that the person being tested is indeed able to converse in that language to a level acceptable for use by aviators.

Considering this some more, I think I was too "accommodating" in an attempt to get CAA to see sense. I concur with the above. This can be handled within the existing system painlessly. End of story.

[Can1]

South African citizens should all be assumed to have the necessary language skills and a common sense approach to certification should be taken. Those quite clearly unable to communicate in English when they do a renewal should be referred to an examiner to be assessed and assisted to gain the level required. The use of English during a renewal followed by a tick in a box on the renewal form should be quite enough to certify and maintain that certification, with the proviso that it should not be used as part of the actual renewal test, merely as a confirmation that the person being tested is indeed able to converse in that language to a level acceptable for use by aviators.

I concur.