LANGUAGE PROFICIENCY RATINGS

Questions for the South African Civil Aviation Authority.

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Chris
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Unread post by Chris » Mon Jul 09, 2007 12:16 pm

AirFalcon wrote:This is by far the the most ridiculous regulations that the CAA is trying to force on the South African aviation community.
Just to get some balance here - it is ICAO that promulgated these regulations. CAA as a signatory has to do something.

There is little commentary around on this topic except ICAO identified the lack of proficiency in English as a contributory cause of accidents. The gradings etc are of ICAO's making.

The guys in Europe have a far greater problem and the FAI has a meeting with ICAO on 12 July. It will be interesting to see what comes out of this.

What we have asked for repeatedly is the ICAO regulation and some justification for the SACAA's interpretation and response. We are still waiting.
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Unread post by Chris » Mon Jul 09, 2007 12:24 pm

Aha - found some interesting documents
http://www.icao.int/icao/en/trivia/peltrgFAQ.htm
ICAO wrote:Do native speakers need to be evaluated and how?

Native speakers need to be evaluated. However, in this case, it is possible to use a process similar to that which is routinely used today to ensure that applicants do not have a speech impediment that would affect their capacity to operate safely. This assessment can also be extended to non-native language assessment at the highest or Expert level. 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.

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.
The question to CAA is why not allow the instructor to give the rating as part of the renewal. This is obviously acceptable to ICAO as above. Why do SACAA have to make a huge issue about it?
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Unread post by Sideslip » Mon Jul 09, 2007 12:44 pm

Chris wrote:
The question to CAA is why not allow the instructor to give the rating as part of the renewal. This is obviously acceptable to ICAO as above. Why do SACAA have to make a huge issue about it?
That sums it up for me.

Something obviously has to be done to meet ICAO but the CAA seem to be making a mountain out of a mole hill here.

It just seems practical that instructors should be given the authority to judge an acceptable level of proficiency or to refer the applicant to a "specialist" should he or she feel that said applicant does not meet the minimum requirements.
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Unread post by AirFalcon » Mon Jul 09, 2007 12:57 pm

Chris wrote:
AirFalcon wrote:This is by far the the most ridiculous regulations that the CAA is trying to force on the South African aviation community.
Just to get some balance here - it is ICAO that promulgated these regulations. CAA as a signatory has to do something.
Just my point there Chris, its not the regulations but rather the method that is ridiculous.
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Agree with all above

Unread post by BasieB » Mon Jul 09, 2007 6:20 pm

I agree with all above - matric certificate (especially before 199...) should put one at minimum level 6. For our country ouks this is really a hassle and ... (I don't know the english word for what I want to say - this means I fail?)

Please CAA - get some balance in all our current legislation.
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Re: LANGUAGE PROFICIENCY RATINGS

Unread post by Dave » Wed Jul 11, 2007 12:21 pm

Bump!
CAA wrote:Deadline for comment is Thursday, 12 July 2007.
All comments posted on this thread by the deadline, will be submitted for consideration
Human beings, who are almost unique in having the ability to learn from the experience of others, are also remarkable for their apparent disinclination to do so. Douglas Adams
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Language Proficiency Ratings

Unread post by Rick Bull » Wed Jul 11, 2007 4:55 pm

I have tried on a number occasions to voice my objection to this latest proposal by CAA.
Hopefully this time I will be successful because I believe it is very important that CAA recognise that, particularly to English speaking people this requirement is insulting to say the least.
I have been flying for 8 years and I can honestly say that I have never had problems communicating with any ATC's nor other pilots in the air and making myself understood.
I therefore object in having to waste a great deal of time to attend some nominated Test Centre to establish that I can speak my mother tongue and to add further insults I have to pay for the privilege.
A further issue is that I took GCE at school in Rhodesia does this not have any standing with CAA?
I am afraid all these Quasi Government organisations such as CAA, ATNS and ACSA are just "skinning the cat" and they feel they can run rough shod over any objections with impunity[/list]
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Unread post by kosie » Wed Jul 11, 2007 6:36 pm

I got a distinction for English at school, teach at an English university and have published a textbook and almost a hundred scientific and popular scientific articles all in English. Who is going to test me and why? I understand ICAO's hand in this but we live in an English speaking society. Tell me, will all British pilots in the UK also have to undergo this testing? If not then we should also not be subjected to this waste of time and money.
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Unread post by pilotC » Wed Jul 11, 2007 8:07 pm

I disagree with this as it is just a way to make more money.
Dont have time also.
A tick in the box during renewal/test time is appropriate.
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Unread post by birdlady » Wed Jul 11, 2007 10:48 pm

I think what CAA is forgetting is that not all ICAO signotories are english speaking countries hence the reason for this testing. South Africa is a country where english is widely spoken and hence,as lardbeast so succintly put it, a tick in a box during inital licencing/renewel should be sufficent.
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Unread post by TITAN » Thu Jul 12, 2007 3:35 pm

For the past 63 years I have only spoken English. I was born in England and received my education in that country( in English).
I enjoy the privileges of a South African PPL. I own and fly my own new aircraft here in RSA. I a South African permanent resident.
Why now do I have to be subjected to this apparent control which indicates that I am not an expert in the spoken Queen's English ?
In addition the draft indicates that I would have to be retested after a number of years presumably because I my have forgotten some of my mother tongue.
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Unread post by MikeG » Thu Jul 12, 2007 3:37 pm

In my situation I am an english speaking native of the UK and hold an SA Licence, I have UK GCE's and higher qualifications which at first pass is not catered for in this document.

I also know many UK Natives that have UK english qualifications, having regional accents that can be quite hard to understand, would they qualify for exemption?

Landbeast's suggestion of a tick box on renewal, would apppear to be sufficent.


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Unread post by Chris » Thu Jul 12, 2007 4:11 pm

I would have liked to have more time on this one as I would like to see what the result of the meeting between the presidents of the FAI and ICAO was. The deadline set by ICAO is March 2008. Is there any reason that there cannot be a delay for a few weeks.

I understand that the inability to communicate can increase the safety risk so in the case of international flights flying into countries with different languages there can be a safety issue. It is with this background that ICAO promulgated the regulations that require evaluation in terms of the 6 levels.

The interim relief as set out in your document is really no relief at all. ICAO only requires that language proficiency is introduced by March 2008. The SACAA want to introduce the requirements earlier and then give us relief until 31 December 2007. Explain where an extension till 31/12/07 is relief for a requirement is only applicable in March 2008. There was an outcry by general aviation pilots about the regulations contained in AIC30.20. Pilots are not happy with the the contents of that AIC. The response posted above only puts in interim measures until a date prior to the required implementation date. This is therefore an inadequate response.

This impression most general aviation pilots have of the SACAA is that the SACAA interprets any ICAO or other requirement in the most restrictive way possible to try to discourage general aviation. The impression is also that the SACAA will invent a fee for every new requirement making aviation more and more expensive. The introduction of the LPR as contained in AIC 30.20 seems to confirm this impression.

It is almost impossible for a man in the street to obtain a copy of the Annexes to the ICAO memorandum so it has been impossible to see if the regulations published by the SACAA are what is envisaged by ICAO or if CAA has once again gone overboard. It is therefore difficult to comment on the suggestions.

AIC 30.16 and the few bits ICAO information I can find make it clear that the ICAO requirements are for international flight only NOT for domestic flights. The proposal by the SACAA makes no differentiation between the two. In fact the SACAA proposal makes no differentiation between an ATP flying an airliner into a European city and a VFR pilot flying in South Africa only. ICAO make it very clear that while native (English) speakers need to be evaluated but on a far less formal basis refer the link I have posted above.

The idea that the language proficiency test must result in a "Rating" is ludicrous. Surely that is similar to asking a pilot that has passed all his theoretical exams to send in his results with a completed form and of course a fee to get a Theoretical Knowledge Rating. (If you start this I want commission on the fees the SACAA charges).

My proposal is therefore that:
1) You forget about calling it a rating with a form and a fee and rather require that the necessary documents get attached to the license application/renewal form as is normal with other test forms. The license itself can be amended to show when the next LP test is due. Process it like you process the radio license.
2) Forget about a new fee for this. The is no need for a fee and there is no fee promulgated in Part 187
3) You allow instructors doing initial tests or renewals to confirm language proficiency up to level 4 for native English language speakers as suggested by ICAO. Just a checkbox on the form will be fine. All thta is needed is to ensure that there is no speech impediments (if I read the ICAO FAQ properly). Non English speaking persons would have to do a test at an ATO
4) For level 5 and 6 (why would anyone want a level 5 grade?) require a test to be done by an a credited ATO and the form is merely attached to the application form or renewal form as is done for any other documentation.

A similar situation is a PPL obtaining a IF rating. As a PPL there was a restricted radio license which is merely a document submitted with his initial license application. When obtaining an IF rating you send in the test form, the exam results and the general radio license and you get your rating. Surely the LP should be handled on the same basis.

In summary - the interim measures in now way address the objections the flying community have. The objections are against stringent requirements in AIC30.20 which we do not believe are necessary. The whole issue should be looked at with a view to re-issuing AIC30.20

PS - is it legal to make new requirements without going through CARCom.
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Unread post by contrails » Fri Aug 10, 2007 11:50 am

homer simson once said: 'who needs english, i'm never going to england'
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Unread post by raptor » Fri Aug 10, 2007 12:45 pm

Something I don't understand. If you are proficient in English at level 4 and higher or whatever it is, why should you need to be tested. As the others have said. I was born in England, have spoken it all my life, educated in it, my daily routine requires writing technical documents in english. So now I need someone to tell me I am proficient. Sorry not on. As LArdy say, tick in the box.

To add to this. If you get nervous during interviews and stutter and stammer, would this make you not proficient in the English language.

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