Recommendation

SUBJECT - ENGLISH LANGUAGE COMPETENCY OF NON-ENGLISH SPEAKING
BACKGROUND

STUDENT PILOTS IN AUSTRALIA





SAFETY DEFICIENCY



There are currently no standards by which to assess the English
language competency of pilot licence applicants. As a result, some
licence applicants with inadequate English skills are being issued
with licences.





FACTUAL INFORMATION



Occurrence summary



The De Havilland Dash 8 was tracking inbound to Tamworth via the
040 radial of the Tamworth VOR (a radio navigation aid) at 3,500 ft
in accordance with air traffic control instructions. Meanwhile, a
TB10 Tobago was about to depart Tamworth via the 018 VOR radial, a
track that would require the Tobago to turn across the inbound
track of the Dash 8. Air traffic control had decided to limit the
initial climb of the Tobago to 2,500 ft in order to ensure vertical
separation with the Dash 8.



The aerodrome control task was being performed by a trainee
controller under the supervision of a rated controller. The pilot
of the Tobago was instructed to "line-up" and given an altitude
restriction of 2,500 ft, which was read back by the pilot. However,
the readback was not clear and the aircraft subsequently took-off
with both the trainee controller and the rated controller uncertain
as to the actual altitude read back by the pilot, who was from a
non-english speaking background and had an accent that was, on
occasions, difficult to understand. It was subsequently determined
that the pilot of the Tobago had understood the controller to say
3,500 ft, and that was the altitude he had read back to air traffic
control. The crew of the Dash 8 were given traffic information on
the position of the Tobago by air traffic control and commenced a
look-out for that aircraft.



Because both controllers were unsure that the 2,500 ft restriction
had been correctly acknowledged, it was agreed that the trainee
controller would request the pilot of the Tobago to confirm that he
was maintaining that altitude. Before that could take place, the
pilot of the Tobago asked the controller to confirm his assigned
altitude. Again the transmission was not easy to understand. The
trainee controller confirmed 2,500 ft and passed traffic
information on the Dash 8 at the same time. The only reply from the
pilot of the Tobago was the word "affirm" and his callsign.



In fact, the Tobago had been maintaining 3,500 ft, and it was that
later transmission from air traffic control that made the pilot
realise he should have been maintaining 2,500 ft. He commenced an
immediate descent from 3,500 ft, but did not make any radio
transmission to that effect.



The crew of the Dash 8 heard the exchange between air traffic
control and the pilot of the Tobago. At almost the same time they
saw the Tobago about 400 metres ahead, at the same level. They
commenced an immediate descent then realised the Tobago was moving
to their right. The aircraft passed with a horizontal separation of
approximately 200 metres, and no discernible vertical separation.
The required standard was 1,000 ft vertical separation until the
aircraft had passed.





Related occurrences



A search of the Bureau's occurrence database identified 45
incidents involving Australian-registered aircraft since 1993 in
which English language difficulties had contributed to the
occurrence. Most of these incidents involved instructional or
private flights and several occurred in proximity to aircraft
engaged in fare-paying passenger operations.





Results of surveys, studies and research



In 1993, BASI reviewed the problem of pilots with limited English
who were flying or learning to fly in Australia. That review
identified that the regulator allowed delegates, usually chief
flying instructors (CFIs), to issue student pilot licences, but did
not provide CFIs with adequate information on the required
knowledge of English, or the methods that could be used to test a
candidate's English language competency. Operators who were
approached on this matter in 1993 acknowledged that a problem
existed, that the issue of a pilot's licence to an applicant who
had a limited understanding of English was a dangerous practice,
and that there was no uniform way of testing an applicant's
competence in the largely technical English words and phrases which
are used in aviation. At the conclusion of this review, BASI
released Safety Advisory Notice (SAN) 930115, suggesting that the
regulator, in conjunction with the industry and appropriate
language experts, undertake a review of the requirements for
English language competency. In response to that SAN, the then
Civil Aviation Authority (CAA) replied that it was looking at
implementing a standard of English language competency.



In 1995, the CAA released a discussion paper dealing with the issue
of English language competency. That paper recommended that pilots
and pilot trainees whose first language was not English, be
required to pass a structured test for English competence prior to
the issue of a pilot licence or certificate. The majority of those
who responded to the discussion paper supported the move towards a
formal standard of English competency. Flight instructors in
particular, expressed the concern that under the current
arrangements, they were being required to make determinations which
they did not feel qualified to make.



As part of the regulatory review which commenced in 1996, the Civil
Aviation Safety Authority (CASA) set up eight technical committees
to review the legislation in various areas. Technical Committee
Five considered the issues of personnel licensing.



A project team was formed as part of Technical Committee Five to
consider the issues of English language competency for pilots. In a
position paper dated 16 September 1997, this project team noted
that overseas practice was similar to that currently employed in
Australia. The committee did not learn of any countries which had a
system in place to check the English language competency of
pilots.



In May 1998, Technical Committee Five released a progress report
which contained the recommendation that definitive standards for
English language competency of pilots be introduced.



Since that date, all technical committees have been disbanded
because of other priorities within CASA, and no further progress
has been made.





Current standards and practices



Civil Aviation Regulation 5.09 paragraph 1 (a) specifies that
applicants for a flight crew licence must possess "a knowledge of
the English language sufficient to enable him or her to exercise
safely the authority given by the licence".



At present, flying school personnel must make an assessment of the
adequacy of each student's English language skills. However, CASA
does not specify how English language competency should be
determined.



At least one flying school (the Australian Aviation College at
Parafield) has developed its own syllabus of technical English,
which includes specific terms and expressions which must be
understood by pilots. This syllabus covers 10 areas, including the
language used in the automatic terminal information service (ATIS),
circuit terminology, the description of positions and the use of
key phrases.





ANALYSIS



English is the international language of aviation and a command of
the language is an important flying-related skill which all pilots
must possess.



The lack of English language skills of some pilots appears to be
contributing to air safety incidents in Australia. The training of
foreign student pilots in Australia has increased in recent years
and is likely to increase further in the future. Unless action is
taken to ensure that student pilots have attained a minimum
standard of English language competency, it is likely that
language-related incidents will become more frequent.



There has been general acknowledgment since the early 1990s that
current practices with regard to English language competency of
student pilots are not adequate. Despite this, no progress has been
made towards the development of English language standards.



The key problem appears to be that although CASA requires licence
applicants to possess English language skills, it does not provide
objective guidelines or a test to enable CFIs to determine whether
an applicant possesses sufficient language skills. Few flying
instructors or CFIs would possess the skills to make an expert
judgement of a student's language competency in the absence of such
guidance.



It should be noted that although an applicant's language skills may
appear to be adequate in normal circumstances, when faced with a
stressful in-flight situation involving the use of technical terms,
language skills may deteriorate.



Any assessment of pilot language skills would need to take into
account the fact that those required of pilots largely consist of
verbal comprehension and expression skills in technical English,
rather than standard English conversation or writing. For example,
an effective test of language skills would need to evaluate an
applicant's ability to comprehend ATC instructions, ATIS broadcasts
and the transmissions of other pilots, even when the clarity of
radio reception is poor. To work effectively, such a test would
need to be capable of being administered by CFIs, without creating
a major administrative burden.