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Recommendation issued to: Civil Aviation Safety Authority

Recommendation details
Output No: R20000096
Date issued: 08 September 2000
Safety action status:
Background: Why this Recommendation was developed

Output text

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.

Initial response
Date issued: 04 January 2001
Response from: Civil Aviation Safety Authority
Action status: Open
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.

Further correspondence
Date issued: 21 September 2001
Response from: Civil Aviation Safety Authority
Response status: Closed - Not Accepted
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.

 
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Last update 05 April 2012