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Output Number
R20000096
Approval Date
Published Date Time
Recommendation type
Recommendation
Mode
Aviation
Date released

The Australian Transport Safety Bureau recommends that Civil
Aviation Safety Authority review the assessment process for the
issue of a radiotelephone operator certificate of proficiency or
equivalent, as specified by Civil Aviation Regulations
subregulation 83A(2) and subregulation 83E(1)(a) and establish
competency standards for those applicants for whom English is a
second language, especially in respect of a candidate's ability to
effectively communicate and comprehend traffic information.

Organisation Response
Date Received
Organisation
Civil Aviation Safety Authority
Response Text

The Australian National Competency Standards for Private and
Commercial Pilots, which became effective on 1 July 1999
incorporate a standard which defines the English language
requirements for private and commercial pilots operating
radiotelephony equipment.



The text used in this response is taken directly from the published
standards, and Unit 2, 'Operate Radio' is attached to this
response, for your reference..



The description of the task to be performed states that the
equipment must be operated in normal and emergency
conditions:

Description:



Knowledge and skills to operate and manage radiotelephone and
intercom equipment under normal and emergency flight
conditions.



The Performance Criteria, which represents the standard that must
be achieved, clearly states that English language must be used and
"all messages are rected to appropriately."



" Transmission and receipt of R/T messages is carried out using
English language in accordance with procedures and phraseology
detailed in the FROL syllabus and Aeronautical Information
Publications (AIP), and emergency and urgency transmissions and
procedures are made in accordance with Enroute Supplement Australia
(ERS(A) current edition) and AIP and all messages are reacted to
appropriately."



In the Range of Variables, in Consistency of Performance, is the
statement:

'"Lack of proficiency in spoken English is never a cause of
misunderstanding."



At Critical Aspects of Evidence, proficiency in English is again
stressed:

"Assessment must confirm a level of oral and written English
language communication skills sufficient to support safe flight
operations."



In the Underpinning Knowledge, further guidance is given:

"English language to a standard which enables requests and
instructions to be understood by ATS and other stations and ensures
compliance with received instructions."



Finally, in the Context of Assessment, guidance on assessment of a
persons English competency is supplied:

"Assessment must confirm, by simulation or actual conditions, the
consistent ability to convey and receive information by R/T, using
standard English radiotelephone phraseology during normal and
emergency flight, and to respond appropriately."



I acknowledge that the accident referred to, occurred before the
standards became effective, but now, flying schools have a standard
which can be applied to ensure the English competency of all
pilots.

ATSB Response

The Bureau replied on 25 January 2001 as follows:



Thank you for your response to Air Safety Recommendation R20000096
dated 4 January 2001 that outlined the Australian National
Competency Standards for radiocommunication proficiency of Private
and Commercial Pilots.



The Bureau has classified the response as OPEN.



The Bureau accepts that the assessment for the issue of
radiotelephone operator certificate of proficiency for private and
commercial pilots is adequate but in the context of the report,
Recommendation R20000096 was directed at the competency of
radiocommunication by glider pilots.



Gliding Federation of Australia (GFA) rules require glider pilots
using other than GFA allocated frequencies to posses either a
Radiotelephone Operator's licence or a GFA Radiotelephone Operator
Authorisation. Applicants are assessed by GFA approved instructors
who themselves must hold either a GFA authorisation or a
Radiotelephone Operator's licence. Authorisation is notified by
logbook endorsement.



Although GFA publication "Basic Gliding Knowledge" makes reference
to the Radiotelephone Operator Authorisation being an equivalent
standard to the Radiotelephone Operator's licence, CAO Part 95.4
"Exemption from provisions of the Civil Aviation Regulations 1988 -
Gliders, Powered Sailplanes and Power-assisted Sailplanes",
subsection 3A "Licence not required" paragraph 3A.2 states, in
part, "a person must hold a flight radiotelephone operator licence
if he or she makes airborne radio transmissions.



There appears to be a disparity between the requirements of Civil
Aviation Orders and the GFA published requirements for a
radiocommunication authorisation of glider pilots. Could you please
advise:



i) that the competency and standards for radiocommunication
required of glider pilots, for use on other than glider allocated
frequencies, are the same as that for private and commercially
licensed pilots, and



ii) if this is the case, the process by which the regulator ensures
that the standards are met and complied with.

Date Received
Organisation
Civil Aviation Safety Authority
Response Text

I refer to your letter of 25 January 2001 in regard to
Recommendation R2000096, relating to the competency of
communication by glider pilots, and your observation of an apparent
disparity between the Gliding Federation of Australia (GFA)
Operations Regulations and CAO 95.4.



The source of the apparent disparity is that the pre-existing
requirement for glider pilots to hold a Flight Radiotelephone
Operator Licence (FROL) when making transmissions on HF frequencies
was incorrectly transcribed when the CAO was amended in 1992.
Subsequent intentions to correct the error have not come to
fruition. A recent omnibus amendment also compounded the situation
by overlooking the fact that this had been erroneously inserted
into the Order.



The Radiocommunication Act only requires that a person be
authorised to make transmissions on a particular frequency band,
not that they hold a licence as such. The only difference is that
the FROL requires the holder to have an aviation medical
certificate whilst the gliding certificate is exempted from
this.



The standards employed by the GFA are those which applied under CAO
42.0 to applicants for a FROL. In practice they are identical to
those called up by CASA's Day VFR Syllabus, but are now expressed
there in competency based terms. Standards Division has no
objection to allowing the GFA to republish the standards as they
appear in the Day VFR Syllabus - Aeroplane.



CASA has for many years contracted out to the GFA the
responsibility for monitoring the standards of glider pilots and
gliding clubs, by means of a contract requiring at least annual
reporting of activity. Auditing of the GFA and other sport aviation
organisations is carried out by the Airways & Self
Administration Branch of CASA's Compliance Division.



There have been no adverse findings to date in respect of use of
radio by glider pilots. Concerns about English language standards
are more widespread in relation to aeroplane licence
applicants.



It is worth noting that, in the case of the accident at Waikerie on
2 March 1999, the Japanese glider pilot held a Japanese FROL, which
Australia is obligated to recognise under its international
convention signatory responsibilities. He was also considered to be
more proficient than average in the English language, and easily
met the requirement in the GFA Operational Regulations for English
language competency. The pilot of the glider which was being towed
by VH-EVZ has held a PPL for a long time and regularly exercises
the privileges of his licence.