DIESER TEXT DIENT DER NAVIGATION ICAO Language Proficiency Implementation – Sometimes a great challenge for NAA`s An example how National Aviation Authorities can adopt and implement ICAO Standards ICAO St Petersburg Joachim Wirths – NAA Austria © WIJ / LSA

How we did it… Implementation of  LPT requirements  Training and assessment procedures

Legal Requirements ? ICAO Annex 1 (Personnel Licensing) ICAO Annex 6 (Operation of Aircraft) ICAO Annex 11 ( Air Traffic Services) ICAO Doc 9835 EC Directive 2006/23 – English Language Requirements for ATCO JAR-FCL 1 – / App 1 + AMC / IR And in Addition… ICAO Resulution A / 36 ICAO Assembly 2007 urged those states that could not comply with language requirements by 05th March 2008 deadline to publish „language proficiency implementation plans“  Transition period should not exceed 05th March 2011  ICAO Circular 318 – Language Testing Criteria for Global Harmonization 2009  ICAO Circular 323 – Guidelines for English Training Programme (EN-L4)  EU FCL 055 / AMC 055

Observed facts: a) About 9377 Pilot licenses.... b) About 315 ATCO licenses c) About 712 Examiner (FE, TRE, CRE..) Challenge: All pilots minimum L 4 certified… and we have to re- evaluate them until

Further Facts Only limited resources available No language proficiency experts employed Observation made 2008: Observed harmonization problems between NAA`s Observed harmonization problems between NAA`s Observed problems of implementation and Interpretation Observed problems of implementation and Interpretation Observation made 2009: ICAO launched Circ 318 /323 Observed adjustment problems because of national law Increase of harmonization problems Increase of harmonization problems Due Date Due Date

Initial Solution 2008 PracticalApproach

Review Philosophy A basic command of plain language is necessary to meet the needs of communication beyond standard phraseology: –in emergencies or unusual situations –to clarify or elaborate on instructions –for normal and non-urgent, yet non- standard situations

Iplementation phases Phase 1: Release of published information 2008/2009 and establishment of implementing procedures including FAQ list via a dynamic approach Phase 2: Commitment to use a semi-direct and a direct testing system (interview) with interactive components included ( ICAO Doc 9835 Ch 6 / Cric ) Phase 3: Examiner (LPE) selection, training, testing, authorization (Circ 318/323) Phase 4: Soft implementation regulation with credits and practicable timeframe settings 2009 / 2010 Phase 5: Establishment of LAB`s for training and testing 2011 (Circ 318 / 323)

PILOTS 2008 Initial compliance via radio certificate 2009 Developing and investigation for LP – test implementing scenarios. Challenge: „Find a way to implement ICAO requirements with limited resources!“ (Doc 9835 / Circ 318 / Circ 323) 2009 Establishment of initial procedures and regulations 2009 Selection and training for Language Proficiency Examiner 2010 Language Proficiency Testing is in force 2011 Language Assessment Bodies established (JAR-FCL App 1)

ATCO LP Training via Austro Control Academy ( Circ 323 ) LP – Test ( Circ 318 ) a)ELPAC (ac. 2006/23/EG) b)RELTA (ac. 2006/23/EG) Initial Approach: Different kind of test for ATCO and Pilots Different procedures established to excecute LP – test Transition procedure established between ATCO and pilot LP-Test via an special interview

Established requirements for our acceptance of ANY digital LP – test program on the market: Concept: No commitment for any test provider – performance based acceptance.. Must be compliant with established legal framework (Circ 318 Ch 4) Must have realistic contents and scenarios – Must be easy to use, focus on web based CBT program Program must include data protection and test result storage system Program must have an access option for quality control reasons Examiner must be able to use program and rate matrix to establish a documented test result by himself Fast and easy to evaluate the test results in a serious, documented way Must contain aeroplane and helicopter topics Must contain an advanced module / EN L Must have access posibility for second examiner (Q- Reasons) Must be listed on our NAA / or ICAO acceptance list ( starting 2011 )

12 Examiner Assessment - LPE Examiner Examiner must receive an initial assessment with a SEN. This shall be done via the recurrent examiner assessment, followed by a special LPE training course, Involving a LP examination via digital, interactive test to confirm the personal LPE Skill and at least requested additional LPE authorization! Qualify pre assessed examiners…

LPE Selection,Training, Authorization Active and experienced Flight Examiner Pre-selection passed LP Examiner training LP test passed Initial LPE authorization Rater Training passed [ Reference Cricular 318]

14 LPT Pilots The authorized LPE will perform the LP Test with the candidate -digital test and interview- [semi – direct and direct testing Circ )

15 Failed L4 Should perform a LPT with the same examiner / LPE OR has to approach a language assessment body / AMC No 2 FCL 1.010!

AMC No 2 JAR FCL (4) LAB CRITERIA FOR THE ACCEPTABILITY OF LANGUAGE ASSESSMENT BODIES A language assessment body offering services on behalf of the Authority (see Appendix 1 to JARFCL paragraph 5) should meet the specifications at paragraphs 14 to 18. In order to ensure an impartial assessment process, the language assessment should be independent of the language training. In order to be accepted, the language assessment bodies should demonstrate: a ) appropriate management and staffing, and b ) quality system established and maintained to ensure compliance with, and adequacy of assessment requirements, standards and procedures. In addition: Must employ minimum one linguistic expert and one operative expert / Examiner Level 6 [ Circular. 318 / 323]

Language Assessment Body FTO`s TRTO`s Aviation companies and Other organizations… Audit criteria: ICAO Circ 323 and 318 ACG will audit and observe!

18 Just NO I don’t want.. Must perform an interview test with an examiner / LPE GERMAN Level 4,5,6 will be endorsed in JAR-FCL license.. [ICAO Annex 1 ]

Action taken by EU Commission

SAFA

SAFA - CAT Findings – Related to ICAO Member States noted on F-SIX Web Site CAT 2 no compliance but Action Plan CAT 3 no compliance and no Action Plan established CAT G proper endorsement in license and observed no proficiency to speak and understand English in accordance with the ICAO Scale / LEVEL 4 This may lead us to a training for SAFA Inspectors in the future…

Consequence AIP 05/11

SAFA inspector`s duty Checking FSIX Web Site Checking country status of aircraft and crew inspected Checking compliance with entry and SAFA requirements Raise findings Take action accordingly….

24 INTOLERABLE Aircraft will leave with a CREW probably not able to speak or understand Aviation English at the proficiency level required by state (AIP- ICAO EN L 4) Consequence  high risk of a serious on GND or in FLT incident or accident.  Further high cost and reclaim by operator, if blocking the aircraft for longer period of time.  Probably legal action by the operator Probability of incident / accident % Probability of legal action by operator 100 % Accept the Risk Hazard Identification Risk Assessment  Severity / Criticality Risk Assessment  Probability Risk Assessment  Acceptability Take Action  Risk Mitigation not acceptableacceptable Process of SAFA LP / G- Finding Risk Management Clarify situation with an accepted LP Competence check to keep delay at a minimum or have proven evidence in case of legal action later on.

SAFA EN L 4 Competence Check SAFA EN L 4 Competence Check (RMK: This is not an LPT!) Trigger:  SAFA Inspector is unable to communicate with the pilot / crew during inspection or an  ATC incident was evident during arrival of aircraftFinding: SAFA „G“ finding is considerd as initially „NOT ACCEPTABLE RISK“ in regard to SSP and AIP!Consequence: Crew must be changed, or must demonstrate EN L 4 competence prior release of aircraft

SAFA „G“ Finding - RISK MANAGEMENT Objective:  Changing risk to the tolerable / acceptable level  Documented decision process - Adressing the finding to the crew - Offering solution to clarify the situation by using a digital SAFA - LP L 4 Competence Check Procedure to avoid any further delay in excess of 1 hour - If pilot / crew agrees, SAFA Inspector will launch a digital test as trained interlocutor, and will select one authorized LPE from the official LPE list - Inspector will release the LPC access code to the LPE - LPE will rate the competence of pilot / crew as an expertResult:  Clear basis for GO / NOGO decision

Related Links on Austro Control Web Site ICAO FSIX Web Site List of LPEs in Austria of LPEs in Austria Examination form form Official Announcement / Austro Control Announcement / Austro Control – available in German Language only FAQ`s Flight Examiners Handbook – containing national information in addition to those provided by the FEM (v.18, JAA) including LPE Examiners Handbook List of accepted Language Proficiency Test – Testproviders

Outlook We will continue to develop the system together! (..with test providers / LPE`s, PILOTS, ATCO´s, ATO´s, AOC holder ect...) We would like to harmonize and to develop our system with other NAA`s (sharing exp)

What should we discuss? A mutual recognition for LPT results between all member states compliant noted on the ICAO FSIX web site…… ICAO Doc 9835 and Circular 318 / 323 should be free of charge LPT test provider - Quality Good List established on ICAO homepage Test standards (p.e. no LPT during LPC/OPC Sim Session) Test for maintenance personnel (reading, writing?) Test for dispatch, meterological –AIS- personnel Test for cabin crews – (EASA License req. 2012) Test recomondation for national licenses (ML/UL ect)

30 LSA Jour Fix, 4 März 2011, Ing. Franz Graser Thank you for your attention Joachim Wirths - Manager PEL