When it comes to aviation safety, effective communication plays a crucial role, particularly when ensuring clear and accurate exchanges between pilots, air traffic controllers, and other stakeholders. Central to this communication framework are the Language Proficiency Requirements (LPRs) established by ICAO, which set standards for linguistic competence among aviation personnel. Within the European area, the ICAO European Aviation System Planning Group (EASPG) serves as a key forum for regional collaboration and implementation of ICAO Standards. At the forefront of this endeavor is the Language Proficiency Requirements Implementation Task Force (LPRI TF), which is tasked with enhancing awareness and facilitating the implementation of LPRs.
In 2020, the LPRI TF was given the task of working on five key actions and their respective outputs for a period of three years. As part of this endeavor, two subgroups were formed. The primary objective of the first subgroup was to create a regional document that would ensure the harmonization and consistent implementation of LPRs, while also promoting effective oversight among participating States.
This article delves into the collaborative efforts of the LPRI TF and stakeholders in developing and implementing EUR Doc. 046, Guidance on the Harmonized Implementation of Language Proficiency Requirements and its Oversight. This guidance is invaluable when it comes to promoting standardized language proficiency practices for aviation safety within the EUR NAT region.
The role of the European Aviation System Planning Group (EASPG)
By Levan-Karanadze
The EASPG provides a platform for regional cooperation in implementing international aviation standards. It provides high-level planning and implementation support to the 56 States accredited to the ICAO EUR NAT Office. Within the EASPG framework, the LPRI TF plays a crucial role in raising awareness and enhancing regional implementation of language proficiency requirements. The LPRI TF, composed of various stakeholders, including civil aviation authorities, training organizations, and international organizations, has been instrumental in shaping regional guidance and facilitating collaboration.
LPRI TF is responsible for the harmonized implementation of the LPRs within the EUR/NAT area and is comprised of linguistic experts coming from the EUR Region. The Task Force, which has been in existence for more than 25 years, is unique within ICAO regional structure. They often contributes to the LPR activities organized in other ICAO regions (e.g SAM, APAC, MID), supporting interregional conferences and workshops. It maintains excellent working relations with EASA, Eurocontrol, IATA, ICAEA, industry and academia, receiving valuable contributions from them to its work programme.
The role of the Language Proficiency Requirements Implementation (LPRI TF)
By Inna Abdullayeva
The LPRI TF works within the terms of reference of the EASPG to raise awareness and enhance regional implementation on safety-related language issues. It is one of the oldest task forces within the EASPG structure, working for ICAO Language LPR policy from the conception phase.
The LPRI TF is encompassed of all concerned stakeholders: CAA/regulators, national ELP (English Language Proficiency) focal points, training organizations, airspace users, ANSPs and test service providers along with the relevant international and regional Organizations (EASA, IATA, Eurocontrol, ICAEA, IAOPA etc).
The TF members are organized in two distinctive sub groups to facilitate this work:
- Sub Group 1 (SG#1): regulatory issues and development of new tools and guidance material
- Sub Group 2 (SG#2): development and organization of implementation activities
During their bi-annual plenary meetings and of the virtual SG meetings, LPRI TF members discuss concerns and best practices, regarding the implementation status and maintenance of the ICAO LPRs. Among such concerns, are the lack of harmonizing rules for oversight, and that LP testing varies markedly in the level of quality.
The LPRI TF was tasked with addressing the harmonization and establishment of the relevant processes/procedures through the development of the new EUR Document 46. Not only does the document support Member States in aiming to ensure a high-quality aviation language assessment, but it also assists them with effectively using limited resources to implement best practices and to identify harmonization issues. Additionally, the document guides and supports LPR implementation, raises awareness and facilitates harmonized oversight among States. Finally, it serves to support the work of ICAO and EASA in the field of personnel licensing and language proficiency by using available expertise and resources.
The development process
Before drafting this regional document, the LPRI TF made numerous proposals and suggested the best practices for enhancing the LPRs implementation process. There was agreement that the guidance material would have to be accessible by all 56 EASPG Member States within the ICAO EUR NAT Area to support their efforts to implement LPRs. The new EUR Doc 046 would serve as a record of important outcomes of the EASPG LPRI TF, this outlines the work that was undertaken to draft it:
- Discussions first began during the LPRI TF/38 meeting in March 2021. Experts would be volunteering their time, plans had to be established.
- By the LPRI TF/39 meeting, held in November 2021, two SGs were formally established, with SG#1 specifically tasked with developing implementation guidelines and consolidating them into a new regional document.
- Following endorsement from the European Aviation Safety Planning Group (EASPG) in December 2021, the document’s structure and name were finalized as “Guidance on the harmonized implementation of Language Proficiency Requirements and its oversight”.
- The drafting process for this document, later designated as EUR Doc 046, commenced on 16 January 2022, under the leadership of SG#1.
- By 4 May 2022, the SG#1 had compiled the initial draft, labeled as “DRAFT #1”, and submitted it to the LPRI TF Secretariat for further review.
- During the LPRI TF/40 meeting in May 2022, all TF members were tasked with reviewing and providing feedback on the first draft by 15 August 2022.
- SG#1 received 129 comments from TF members, which were carefully considered, leading to modifications in DRAFT #1, including a significant redrafting of Chapter 5 with support from the International Civil Aviation English Association (ICAEA).
- In September 2022, SG#1 sent the modified DRAFT#1 to the ICAEA representative/EFL speaker for linguistic proofreading. In addition, the TF Chairperson provided comments/input to the content, which initiated further discussions on the content between the Chair and SG#1 and the ICAEA representative.
- Following these modifications, the revised draft, named “DRAFT #2”, was sent to the ICAO EUR NAT/LPRI TF Secretariat for further action.
- SG#1’s role in drafting the document was deemed successfully concluded, and subsequent steps were discussed among TF subject matter experts and SG leaders during a coordination teleconference in late October 2022.
- During the LPRI TF/41 meeting in November 2022, detailed discussions led to a decision to request input from all SG leaders and individual subject matter experts to revise DRAFT #2, with the aim of integrating valuable contributions from SG#2 and the ICAEA representative.
- The collaborative effort between SG#1 and SG#2 involved discussions regarding the adaptation of respective contents, with proposed changes forwarded to SG#1 leader for consolidation into the FINAL DRAFT.
- On 6 February 2023, the SG#1 leader circulated the final draft to all SG#1 members for a final check and, upon approval, submitted it to the EUR NAT Office for further proceedings on 10 February 2023.
- Following endorsement from the EASPG Planning Coordination Group (PCG) meeting in May 2023, EUR Doc 046 was approved for publication during the EASPG meeting in December 2023.
- The document was officially published on the ICAO website on December 18, 2023.
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The key benefits of EUR Doc 046 for regulators
The content in the new EUR Doc 046, which is not found in any other ICAO document to date, includes:
- Guidance on how to achieve harmonized approval of language testing organizations on the basis of a structured handbook referencing relevant contents of ICAO Doc 9835 (chapter 3.1 where the example of a generic handbook is given);
- Guidance on how to deal with remote language testing (chapter 3.2);
- Descriptions of tasks and competencies of authority inspectors during approval and oversight (chapter 4.1) and guidance on the training of authority inspectors (chapter 4.2);
- Guidance on how to oversee approved language testing organizations on the basis of before-mentioned handbook (chapter 4.3);
- Uniform LP certificate for better mutual recognition amongst MS (chapter 6.2); and
- basic guidance for developing LP material for remote pilots (chapter 7.2).
- Though not entirely new, chapter 5 contains quality criteria of ICAO language testing, being part of what ICAEA had already introduced in 2019 in a series of workshops on “LPR Test Design Guidelines”.
- Chapter 7 touches on possible modifications of LPRs for GA pilots (chapter 7.1) or LPRs for aerodrome vehicle drivers (chapters 7.3).
- The appendix contains relevant opinions, deliberations, discussions or suggestions of TF members in the field of language proficiency requirements, that are beyond current ICAO SARPS.
- Appendices A and B revolve around language training and assessment by describing standard tasks and competencies of aviation English teachers/ trainers and language raters, to provide the basis for developing respective competency-based training.
- Appendix C illustrates the lack of uniform rules on oversight in Europe, which is also true internationally on the global level, implying additional rulemaking.
- Appendices E and F describe respective TF discussions on current status and safety cases that should be taken into account when considering any changes to LPR provisions.
- Appendix G raises a genuine safety issue in having English level 6 license endorsements for non-native speakers with lifelong validity, received in a non-harmonized testing environment lacking harmonized approval and oversight, while having differing test standards and not being supported by scientific facts.
Both the main content and the appendix of EUR Doc 046 pave the way forward to further discussions and rulemaking activities, not only within the EUR NAT region, but worldwide, where stakeholders are seeking to improve flight safety.
EUR Doc. 046 encompasses comprehensive guidance aimed at harmonizing the implementation of language proficiency requirements across the EUR NAT region, including regulatory guidance, oversight procedures, and recommendations for addressing emerging challenges such as remote testing.
Planned Activities for Implementation
by Sarantis Poulimenakos
During the ICAO EASP LPRI TF/43, the Chair presented the new action plan for the upcoming 2024-2027 period. This comprehensive plan was carefully considered with the invaluable input of LPRI TF members and participants. A key component of this plan will be to monitor and address activities related to EUR Doc. 046. This involves making any necessary future amendments or updates, as well as developing additional resources for the tools used, with a specific emphasis on online testing. Various aspects will be thoroughly examined, including the conditions for the interlocutors/raters, potential modifications to the methods employed, backup solutions, and the essential prerequisites for testing.
To ensure widespread awareness and understanding of the EUR Doc. 046 among Member States, a dedicated Workshop syllabus is developed by the LPRI TF . A number of workshops will be then organized/scheduled that delve deep into the content of the document. This workshop, titled “Guidance on the Harmonized Implementation of Language Proficiency Requirements and its Oversight,” will primarily cater to ATOS, airlines, ANSPs, CAMOs, and other pertinent stakeholders.
The development and implementation of EUR Doc. 046 represent a significant milestone in advancing aviation language proficiency standards within the European region. Through collaborative endeavors and steadfast dedication, stakeholders have come together to foster a culture of excellence in linguistic competence, thereby contributing to enhanced safety and efficiency in air transportation.
If you are interested in the current work of the LPRI TF and/or you would like to join this dynamic group of professionals, please contact Mr. Sarantis Poulimenakos and Mrs. Natalia Savvina in the ICAO EUR/NAT Regional Office.
So many contributed their time and expertise to drafting this guidance. The following list includes the names of the core drafting team which included 19 LPRI TF subject matter experts (in alphabetic order) who are members of civil aviation authorities, air navigation service providers, those who have supervisory authority in air navigation services, state aviation training Center, as well as representatives from EASA, IAOPA or ICAEA:
ABDULLAYEVA Inna (SG#2 leader, 2021-2023)
BRUGATA Bogdan (SG#2)
BULLOCK Neil (SG#3 leader, 2021-2023)
CORTAC Natalia (SG#1)
DEGISCHER Joana (SG #1)
HAUSER Philippe (SG#1)
HERCOG Andjelka (SG#2)
KANEVCHEV Ilche (SG#2)
KOTIANOVA Natalia (SG#1)
KULJANISHVILI Lado (TF Chair 2020-2022)
LATU Alexei (SG#1)
LOMADZE Davit (SG#1)
MARIANIC Martin (SG#1)
MAXIM Cristina (SG#1)
NURITDINOVA Aelita (SG#2)
RUBENBAUER Franz (SG#1 leader, 2021-2023)
STARK Sarah (SG#2)
VASKOVA Maja (SG#2)
WULFF Tobias (SG#
For future revisions (there will be a passing of the torch):
ABDULLAYEVA Inna (TF Chair, 2024-)
DEGISCHER Joana (SG #1 leader, 2024-)
VASKOVA Maja (SG#2 leader, 2024-)
