The regulatory and commercial backdrop
One reason language testing for the LPRs is in such a poor state is the regulatory and commercial backdrop.
Designing, maintaining, validating and administering a quality language test requires field-specific expertise and is costly and time-consuming. To recover costs, test service providers need either substantial volume or subsidies.
Compared to testing in other contexts, for example, in academic English where a small number of professional testing organisations assess millions of test takers each year, the total worldwide population of pilots and controllers is very small. Remove those with level 6 completely. Remove those with level 5 for 6 years. Remove those with level 4 for 3 years. What you are left with is a tiny annual candidature. Given the plethora of inadequately regulated commercial test service providers competing for this very small population, it is no wonder we see such poor quality.
To be clear: It is possible to provide quality aviation language testing. And it is possible to make money from aviation language testing. But in the current regulatory landscape, you can't do both. The numbers don't add up.
Non-commercial aviation language testing services require generous subsidies. Some are well funded and provide good services, but more often than not, non-commercial test service providers are run on a shoestring by passionate people who are obliged to operate without adequate training and support. To quote a phrase: "We, the willing, led by the unknowing, are doing the impossible for the ungrateful".
Until:
Regulators implement approval procedures which create the conditions for quality commercial test service providers to thrive; and
Non-commercial aviation language testing is supported with adequate training and funding;
Pilots and controllers will continue to take poorly-constructed language tests that fail to address aeronautical radiotelephony communication.
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