Should ICAO level 6 be removed? Should life mean life? The problem with level 6 is not so much that it exists, it is more accurately about the circumstances and inferences that stem from it.
Life is a long time. Even in the criminal justice system, a life sentence rarely means the whole of an individual’s lifetime. Minimum terms are usually set to allow for changes of circumstances, possible reform, further review. Yet, our current English Language Proficiency (ELP) policy promotes the recognition of a certain level of language acquisition that is set in stone, or at least the forty years or so that might span the career of a pilot or an Air Traffic Controller (ATC). Do we then accept that over potentially four decades an individual’s ELP will remain constant or be immune from external factors? Attrition studies suggest otherwise. Languages learnt, with the exception usually of our native-tongue, will almost certainly be forgotten through factors such as lack of use, changes to our state of health and reduced exposure. Speaking is the predominant skill used in radio communications and, of the 4 language skills, we know from research that it is the most vulnerable to language attrition.
The lifers in our context of aviation language testing however, belong to a more precise group and therein emerges one of the principal issues with ICAO level 6. Once awarded, a level 6 gives rise to some inexplicable and inequitable retesting periods. Taking the example of Europe in particular, pilots and ATCs are treated differently, potentially in a discriminatory fashion.1 An ATC assessed as worthy of level 6 is reassessed every 9 years whereas his peer in the pilot world will have his language endorsement for life.2 This is a bewildering policy in the light of the factors involved in successfully maintaining second language proficiency for these two groups. An ATC might typically speak in English to a multitude of aircrew and other ATCs on every shift with differing scenarios, whereas a pilot will usually make a finite number of transmissions to a handful of controllers relative to his own flight. How this disparate situation has come about is unclear. Why should one section of the aviation community be considered tacitly susceptible to language attrition and another unaffected? Whether this decision is grounded in empirical evidence or is rather the result of lobbying or other policy considerations is open to debate but the ramifications are clearly discernible when contemplating the current situation surrounding language testing for pilots.
Firstly, it could be argued that a “golden ticket” to lifelong impunity from more aviation English tests has increased the search for the easy-to-pass test or even the easy-to-persuade rater. On a human level this behaviour is understandable but coupled with the substandard quality of many of the aviation language tests for pilots, there is a real danger that level 6 is being undeservedly bestowed on pilots worldwide.
A certain grade in a language test is only worth the inferences that are made from it. The problem with unwarranted awards of ICAO level 6 is that sooner or later comparisons are made. If your “expert level” Captain is incapable of explaining the reason for his late pushback to ATC, his fellow pilots will begin to question his actual language capabilities regardless of the ELP endorsement on his licence. News travels quickly in small communities such as the commercial airline world, and before you know it, resentment grows and people question the value of the ICAO Language Proficiency Requirements (LPRs), becoming suspicious that there is a hidden agenda such as financial gain. A sense of injustice amongst stakeholders breeds a dangerous and damaging perception of any policy. ICAO English language training and testing is perhaps even more susceptible to any negative press as the stakes are so high, not just in terms of safety but also because of the implications for a pilot’s career and future employment opportunities.
Amongst many non-native English speaking pilots, the journey towards attainment of level 6 appears to be underestimated. Whilst working in both language testing and teaching, I have heard comments to the tune that one or two months of training would suffice to move from a middle ground ICAO level 4 to an ICAO level 6. Others have told me confidently that they speak English every day with their job so they should be able to achieve “expert level” at their next assessment. In contrast, ICAO warns that there are “simply no magic, quick-and-easy language learning techniques or programmes to substitute for a serious and mature commitment of time and effort”.3 The advice continues that around 100 to 200 hours of training would be necessary before any “measurable improvement in ability”.4
The ICAO Rating Scale denotes the category, level 6, as expert level. It would appear to exist primarily to provide a classification for L1 users of English. ICAO Document 9835 also makes the point that because of this, the ICAO Rating Scale goes beyond the needs of aeronautical radiotelephony communication. Given that native speakers of English are hardly ever actually tested under the ICAO LPRs, it raises the question: Why have it at all? Furthermore, the added comment in 9835, that level 6 is “beyond the realistic expectations of most second- or foreign-language learners”, could be seen to elevate the native speaker onto a linguistic podium from which he can look down on his non-native speaking peers.
Level 6 in its current form promotes a “them and us” culture in aviation English. Native speakers and non-native speakers. ATCs and aircrew. So should it be removed? My own point of view is in fact, no. There are grounds to suggest that changes could be made to make the retesting policy surrounding ICAO’s expert level more equitable and justifiable. Whilst there remains a paucity of language attrition research in the aviation English testing sphere, we do know that both language acquisition and attrition are variable. Accordingly, the exemption from retesting aircrew for level 6 would seem to be indefensible and in the spirit of the ICAO LPRs should, at least, be aligned with the air traffic fraternity time frame of every nine years. Cooperation and communication are key factors in maintaining a safe, expeditious flow of air traffic in our increasingly busy skies. More proficient speakers of English, whether they be native speakers or not, have a role to play. They can help this process by using their language skills to support those with lower levels. It is encouraging to see that Eurocontrol5 has introduced a specific test for obtaining level 6 and that communication accommodation theory has been incorporated into the required tasks. Nevertheless, a review of the function of the expert level by ICAO is arguably overdue. The future significance of ICAO level 6 could be modified so that it is not a symbol of a ‘master’ in English but rather one of a ‘mentor’. Adjusting the six descriptors on the ICAO Rating Scale for the uppermost classification could introduce extra required skills. It would be necessary to demonstrate the capability to adapt speech and delivery to meet the communication needs of others, placing an onus on holders of this highest level of endorsement to cooperate with and assist the wider aviation community.
Should level 6 be removed from the ICAO rating scale? Criterion-referenced testing typically has predetermined standards. Candidates will be classed according to the criteria set out in the descriptors. Equally, these descriptors are often arranged by ascending levels so that there will usually be an ultimate class or category. If we remove level 6, would level 5 simply become the new crowning point? Its actual existence is not the dilemma; it is the inferences that we draw from its award that need rethinking. If, in addition to granting the grade, we confer on a level 6 holder a responsibility to actively contribute to safe and effective communication over the radio, over and above that of other holders of lower ELP levels, we can hopefully change both the status and the role of the highest category on the ICAO Rating Scale. Notwithstanding, whatever its standing may be in the future, there appears to be no reasonable justification for level 6 to be awarded in perpetuity. Consequently, life should not mean life. I rest my case.
1 As FCL.055 c) of Commission Regulation (EU) No 1178/2011 has not been changed; the validity of level 6 for pilots still remains unlimited.
2 ATCO.B.035 of Commission Regulation (EU) 2015/340 the validity of an English language endorsement for a controller shall be nine years from the date of assessment.
3 ICAO (2010) Document 9835: Manual on the Implementation of Language Proficiency Requirements section 4.5.2.
4 ibid. section 4.5.5.
5 EUROCONTROL’s English Language Proficiency for Aeronautical Communication.