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Gökhan Demirdöken

Pilot English Proficiency A Global Challenge for the ICAO and the Aviation Industry

Issue 3 - 2020
Pilot English Proficiency A Global Challenge for the ICAO and the Aviation Industry
by Gökhan Demirdöken, Researcher & English Language Instructor

2003 was one of the milestones in the history of civil aviation and air travel. That year was the 100th anniversary of the Wright Brothers` first flight and the whole aviation industry was getting ready for a remarkable countdown for the celebration of the 60th anniversary of the ICAO. Meanwhile, the theme of the 2003 edition of the International Civil Aviation Day, celebrated on 7 December annually, was set “For 60 Years... Setting the Standards for International Civil Aviation”. In his message on December 3, 2003 marking the anniversary, Dr. Assad Kotaite, then President of the ICAO Council, pointed out the great achievement of the Wright Brothers. However, Dr. Taieb Cherif, then Secretary General of the ICAO, shed light on a more remarkable event in the history of aviation, safety, and he continued “In 1947, the first year that the ICAO kept records, of 21 million passengers carried, 590 lost their lives in 34 aircraft accidents. In 2002, with over 1.6 billion passengers carried, there were 791 fatalities in 14 accidents. The ICAO is indispensable to the safe and orderly growth of international civil aviation". What Dr. Taieb Cherif pointed out for the first time was the beginning of a series of events to take place in aviation in the upcoming decades with regards to setting standards and improving safety both on the ground and in the air.

The rise in air traffic incidents had already paved the way for taking strict safety measures. In March 2003, the ICAO Council adopted amendments to Annex 1 — Personnel Licensing, Annex 6 — Operation of Aircraft, Annex 11 — Air Traffic Services, to ensure that flight crew, air traffic controllers and aeronautical station operators comply with the language proficiency rating scale (at Level 4 or above) by 5 March 2008. On September 2004, the ICAO’s Secretary General approved the first edition of the ICAO Doc 9835 – Manual on the Implementation of ICAO Language Proficiency Requirements, which was a comprehensive document on various aspects related to language proficiency training and testing. The purpose was to support member states’ efforts to comply with the strengthened provisions for language proficiency. At first, such a crucial regulation by the ICAO to improve safety standards sounded good. However, the concerns over the effective implementation of the newly announced program and over the resources available soon started to be mentioned on various occasions. The causes for such concerns were mostly related to the complexity of assessing the proficiency in any language. No matter how comprehensive and detailed the items in the rating scale can be written, the reliability of raters and the differences in the implementation of language proficiency tests are always quite difficult to ensure. While an average speaker of English could be rated at Level 4, the same person could easily be rated at Level 5 or 6. In such an occasion, this variance would make a great difference in terms of flight operations because while the first speaker would need to certify his/her proficiency in the future, the other speaker would not need to comply with the same requirement again. Such concerns have already proven to be true as pilots displayed a preference to countries where the language proficiency test taker could be rated at Level 5 or 6 more easily when compared to other member states. Another serious problem that the ICAO faced throughout this process of implementing the new regulation was the lack of resources. Although the deadline was extended, the member states were in need of both the test materials to be developed and the appropriate locations to serve the great number of pilots and air traffic controllers who would take the tests. Testing and evaluation have always been crucial components of any language assessment process. Yet, it is even more crucial when it comes to the assessment of proficiency in a professional context. Due to the role of English as a means of communication globally, there are so many variances in the areas where English is spoken. This seemed to be one of the biggest obstacles against effective communication between pilots and air traffic controllers because pilots whose native language is other than English were reported to have more difficulty in comprehending air traffic instructions in air spaces where English is either the official language or the second language when compared to pilots whose native language is English.

On one occasion, just less than a year before the implementation took effect, the International Council of Aircraft Owner and Pilot Associations (IAOPA) published a report referring to the differences in member states in terms of the progress made towards meeting the requirements since March 2003. The IAOPA, then representing more than 470,000 aircraft operators and pilots, clearly stated the conflict between what the aviation industry needs to develop and how it contrasts with the new regulation. Besides, it highlighted the already existing difficulty of completing all of the procedures required to qualify for a private license, but the most difficult part was yet to come, the language proficiency test. Apart from, completing all other requirements, one of the biggest challenges the IAOPA faced was the availability of language testing facilities. Although more and more qualified pilots were needed to meet the demands of the aviation industry, there were not enough facilities at which to test the language proficiency of the pilots at that time. What’s more, the report mentioned another significant difference between ICAO member states. The IAOPA had requested its affiliates to determine their readiness so that necessary actions could be taken before March 2008. However, of all 14 affiliates of the IAOPA, only three states responded that they had some basic plans for testing of language proficiency. More interestingly, the majority of its affiliates stated that they might not be able to get ready to meet the standard implementation before March 2008. Finally, the report mentioned the most crucial issues: cost and location. There was no availability of locations for such tests and the cost of building a facility for that purpose was also a problem.

In 2007, what seemed to be one of the milestones in the aviation industry had almost turned into a total failure. Taking all of these concerns into consideration, the IAOPA provided some solutions to the ICAO in the same report. The options covered several issues such as using threat and error measurement (TEM) techniques to determine the most crucial components of the aviation industry so that the language proficiency requirements could be implemented for aviation personnel based on an order of priority from the most critical component to the least: air traffic controllers, airline pilots, charter pilots, aeronautical station operators, general aviation pilots operating IFR, and general aviation pilots operating VFR. Another solution was to qualify examiners to test the language proficiency of pilots. These examiners would be authorized to test the pilot in terms of language proficiency during the flight test. Last and the most important solutions offered by the IAOPA was to delay the implementation of the language proficiency requirement until the majority of member states report their readiness to efficiently test aviation personnel.

Eventually, in September 2007, in the 36th session of the ICAO Assembly, the decision to give member states additional time to implement the language provisions was taken and the Resolution A36-11 was adopted. The latest changes in the timeline stated that if the member states were unable to comply with the standards by March 5, 2008, they would be allowed to do so until 2011 with this extension of the deadline. Later on, in 2010, the ICAO issued the second edition of the Doc 9835. This second edition included additional guidance for civil aviation authorities and test service providers on processes for testing candidates. However, the biggest step taken by the ICAO was in October 2011 when the Aviation English Language Test Service (AELTS) website was put into use. By measuring test performance against the Language Proficiency Requirements, the ICAO made it possible to provide important information on test quality so that its member states, pilots and controllers can make the most informed selection possible when choosing a test provider.

While the headquarters of the ICAO was trying to do their best to provide solutions for this issue, the member states were expected to take necessary steps before the extended deadline. Initially, the member states were asked to report their current status and readiness for the implementation of new regulations. As of January 3, 2013, one hundred sixty-seven member states had provided information concerning their status of implementation. Eighty-one of them indicated compliance with the requirements whereas twenty-three states did not provide any implementation plan or any statement of compliance.

Meanwhile, more and more reports started to be published in order to better understand the feasibility of the language proficiency rating scale. The most significant report was published by the Federal Aviation Administration of the USA in May 2009. It was rather a final report of a series of reports. The previous reports provided a detailed description of 51 hours of routine ATC transmissions and how the complexity and length of ATC messages affected pilots’ readback performance, prevalence of ATC readback errors, breakdowns in communication, and requests for repetition made by commercial U.S. and foreign airline pilots. The last and the final report provided insights into a better understanding between the operational levels of the language proficiency scales and communication problems. The report concluded that pilots flying for countries whose primary or official language was other than English showed varied performance in terms of language proficiency and that foreign pilots made more of the communication problems. Consequently, the inevitable need for a more secure environment for flight operations was once again put forward in the aviation industry.

Turkey, one of the council member states of the ICAO, has taken important steps towards implementing the new regulation and several opportunities are offered for aviation personnel who are required to certify proficiency in the English language. The Turkish Directorate General of Civil Aviation (DGCA) published an order with regards to the regulations identified by the ICAO. The order disclosed the conditions under which language proficiency test centers can be authorized to test aviation personnel within the borders of Turkey, and to specify the language proficiency of pilots and air traffic controllers. The execution of the orders in Turkey towards implementing new regulations in member states authorized several institutions under the supervision of the Turkish DGCA. As of 2020, there exists six institutions which are authorized by the Turkish DGCA to test the English language proficiency of pilots in accordance with ICAO requirements. Also, there are 6 approved institutions for evaluating the same proficiency of aircraft maintenance personnel in Turkey.

The rapid increase in the demand for more and more pilots, air traffic controllers, and aircraft maintenance personnel has so far made it quite difficult to quickly implement the decisions made in 2003. Seemingly, the biggest challenge, as always, has been the time restriction for ICAO member states. Both the headquarters of the ICAO and member states put forth a great amount of effort to meet the latest schedule by 2011. More than eight conferences were held to discuss the implementation process in the smoothest way possible, several workshops have been organized, and many reports have been published over the past seventeen years. Although it has been a rather painful and radical change for everybody who is involved in aviation, the ICAO seemed to have reached what Dr. Taieb Cherif, Secretary General of the ICAO, stressed in 2003, at the annual celebration of International Civil Aviation Day, “The ICAO is indispensable to the safe and orderly growth of international civil aviation” as the responsibility of the ICAO. By and large, the overall progress so far and the full implementation plan promise safer flight operations in the future all around the world


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