FAA’s English Language Standards Leave Gaps for Learners

Newly graduated flight students enter a global industry with varying levels of English proficiency.

Language and comprehension skills are necessary for successful communication in nearly every field, but in the safety-critical field of aviation, miscommunication and/or misunderstanding can lead to a runway incident or accident, or worse, a midair collision. 

Studies indicate that more than 2,000 people have died in aircraft accidents as a result, at least in part, from language-related/communication issues—mostly between air traffic controllers and pilots—since 1973. And, researchers suspect that many more aviation incidents and accidents—including in general aviation and pilot training environments—are the result of miscommunication and/or lack of English language proficiency. 

Recognizing the importance of communication to aviation safety, the International Civil Aviation Organization (ICAO), a United Nations agency formed in 1944 to support the global air transportation industry, adopted English as the industry’s universal language in 1951, and has since created English-language Standards and Recommended Practices. Formalized in 2003, ICAO’s language proficiency requirements have been adopted and implemented widely by civil aviation authorities (CAAs) around the world, including the FAA and the European Union Aviation Safety Agency (EASA). 

But Jennifer Roberts, a linguist and curriculum chair for the department of aviation English at Embry-Riddle Aeronautical University’s Worldwide campus, says more needs to be done, particularly in the area of English language proficiency for flight training. 

“The ICAO language proficiency requirements, they are for professional pilots, professional [air traffic] controllers,” she says. “ICAO doesn’t actually have regulations for flight students.”

However, the FAA and other civil aviation authorities do. The FAA’s Aviation English Language Standards (AELS), see Advisory Circular 60-28B, applies to flight students as well as professionals working in aviation. The AELS are modeled after ICAO standards and require a minimum of level 4, or operational English proficiency. 

The AC states: “AELS will be evaluated before acceptance of a student pilot application or issuance of a student solo endorsement, recommendation or examination of an applicant for an FAA pilot certificate or additional aircraft rating, and whenever any individual is tested or checked as required by the Administrator under Title 14 of the Code of Federal Regulations (14 CFR).”

The Wild West of the Skies

But Roberts says the way proficiency is evaluated is not standardized, even across the U.S., and this is a problem. There’s also very little policy enforcement. “It’s just really unregulated. It’s kind of wild out there. What’s going on in flight school A and flight school B could be vastly different. It’s a mess,” Roberts says.

What’s worse, she says, is that upon completion of flight school training and receipt of their pilot’s certificate, newly graduated flight students enter a global industry with varying levels of English proficiency. 

“The way the FAA does it, they just put a stamp or an endorsement on [certificates] that says ‘English language proficient,’” Roberts says. “A student can actually go back to Saudi Arabia, for example, let’s say they’re now going to work for Saudi Airlines. That airline may test the student and come to see that they’re not even level 4, which is the minimum.” The student is left with a pilot certificate and ratings that they paid tens of thousands of dollars for and spent years to achieve that is essentially useless, because of their lack of English language proficiency. 

On the other hand, Roberts says, “Some countries, when they receive a student back from the U.S., they automatically assume that they must be at least level 4 because they managed to get through training in the U.S. But that’s so far from true. That’s very far from true, to be honest.”

Need for a Universal Assessment Tool

Henry Emery, cofounder and managing director of Latitude Aviation English Services in the U.K., which prepares students for flight training in an English-speaking environment and works with airlines and air navigation service providers, says a universal [aviation English language proficiency] assessment tool is needed. 

“One of the greatest problems is that no instrument was set down, no instrument was professionally developed in accordance with the ICAO standards and then adopted by member states so that the assessment was uniform at the same level worldwide,” Emery says.

Ideally, role-specific language assessment tools would be developed for each area of aviation, Emery says, with a different test for pilots (further broken down by commercial pilots, student pilots, general aviation/private pilots, and rotary wing pilots); for air traffic controllers; for aviation maintenance professionals, etc. 

Given the associated costs of creating and maintaining a universal aviation English language test instrument, Emery says it will take a collaborative effort to achieve. “And that has to come through civil aviation authorities, through airlines, through air navigation service providers working together, making a financial contribution to an instrument which is universally owned and operated, making sure that it’s done to at least minimum standards.” 

Who Determines Aviation English Proficiency? 

Another challenge in the implementation of ICAO’s standards, is that the people assigned to make judgments regarding aviation English language proficiency aren’t necessarily qualified to do so. And, there’s a lot that hangs in the balance: the candidate’s career and livelihood, for one, and for aviation safety, Emery says. “The decisions you make around language, whether it’s a student, or a pilot keeping his or her license have an impact on safety and on the individual as well. You would like to think that the candidate being subject to taking language assessment would have the highest standards that the field can offer…and sadly, that’s very often not the case.” 

According to studies, more than 2,000 people have died since 1973 in aircraft accidents as a result, at least in part, from language-related/communication issues—mostly between air traffic controllers and pilots. [File Photo]

The FAA, per AC 60-28B, assigns language proficiency assessment and decision-making to any/all of the following: “FAA personnel, DEs, flight and ground instructors, Training Center Evaluators (TCE), check FEs/check pilots, training facilities, and flight schools.” 

“Flight examiners can interact with a student pilot and say they’re level 6,” which means they essentially communicate at the level of a native-English speaker, Emery says. This then nullifies the requirement for any additional language courses or assessments. “That’s problematic in itself as very often aviation professionals are not language professionals,” Emery explains. “Very often what we find in the U.S. and the U.K., and other places in the world, are those without the education in language assessment performing language assessments with varying degrees of quality and success.” 

He adds, “We are 18 years into the language proficiency requirements—and to be honest, at the moment, it’s a dog’s breakfast. I would imagine it’s going to be another generation before we’re anywhere close to having meaningful workable standards worldwide.”

Pilot Shortage Intensifies Aviation English Issues

According to Roberts, complicating the situation is the aviation industry’s increased demand for pilots. 

“Ab initio flight training organizations are experiencing a push to get students through quicker and more cost-effectively than before, due to the pressure facing the airline industry to hire new pilots and keep the National Air Space System operating efficiently and safely,” Roberts states in a paper she coauthored in 2020. The result, she says, is that more students are coming to flight schools in English speaking countries, like the U.S. And, while ground and flight instructors are well-versed in teaching flight operations, they are not usually experienced in teaching English-as-a-second-language learners. 

Andrew “Andy” Schneider, aviation English coordinator for the flight training department at Embry-Riddle’s Daytona Beach campus, says oftentimes—especially in today’s pilot hiring environment—flight instructors are young. “They’re in their 20s…they’re kids teaching kids.”

Teaching CFIs How To Teach Second-Language Learners

Schneider helped establish several programs at Embry-Riddle to help non-native English speakers achieve greater success. This includes language training for the Part 141 school’s certified flight instructors. 

“I do a hefty amount of training with our instructors on how to teach using language and how to work with second-language speakers both from a psycho-linguistics perspective, like a cognitive perspective, and a cultural perspective,” he says. One thing Schneider emphasizes is, when it comes to English language proficiency, “It’s not something to be swept under the rug.” 

He says, “All of the flight instructors are language teachers, whether they know it or not.” In addition to non-native English speakers, CFIs teach all of the pilots they train how to talk on the radio. “Part of the training [we give at Embry-Riddle to instructors] is informing them, making them aware of what the English language standards are, because that is not part of the CFI materials from the FAA now. It’s part of the circulars, but it’s not part of the fundamentals of instruction, their FOI.”

Aviation English Entry Exams Are One Solution

Addressing the need for evaluation at the very start of flight training, Embry-Riddle has established its own aviation English language standards. All non-native English-speaking students entering flight training are required to take the university’s Aviation English for Flight Training course (FA 135) as a prerequisite, Schneider says. However, those who pass a specialized placement exam created by Embry-Riddle, called the English for Flight Training Assessment or EFTA, can “place out” of taking the course.

The exam is designed around ICAO’s rating scale for pronunciation, structure (grammar), vocabulary, fluency, comprehension, and interactions to determine a student’s “plain language proficiency,” he says. The exam does not assess aviation phraseology or a student’s knowledge of technical or operational language.

English for Radiotelephony

For Schneider, radio communication is a key element of English-language instruction for student pilots, and it’s at the heart of why ICAO established its English language standards in the first place. 

“Most of the famous accidents have to do with standard phraseology,” Schneider says. But learning this “second/technical artificial language,” which is unique to air traffic controllers and pilots, is only part of the issue. Non-standard phraseology and “local code” often creeps into radio communications, he says; for example, when air traffic controllers use the term “no delay” in place of the standard term, “expedite.” This can cause confusion for pilots—especially for those who are non-native English speakers. 

“We are 18 years into the language proficiency requirements—and to be honest, at the moment, it’s a dog’s breakfast. I would imagine it’s going to be another generation before we’re anywhere close to having meaningful workable standards worldwide.”

Henry Emery, cofounder and managing director of Latitude Aviation English Services

“I think standard phraseology solves 90 percent of our problems,” Schneider says.

To this end, Schneider created Embry-Riddle’s PILOT (Preflight Immersion Laboratory for Observation Training) program, which gives non-native and native-English speaking students 35 hours of virtual reality training, including radio communication and standard phraseology.

Emery says it should come as no surprise that non-native English speakers have difficulty communicating on the radio. “I cannot conceive of learning to fly an aircraft in a second language….It would be really hard in my own language,” he says. “So the fact that these kids do it at all, is a thing of wonder.”

However, at the starting point of learning to fly, plain English skills are actually more important.

“The work we do to prepare students for flight training is very different from the work we would do with an experienced airline pilot who needs to brush up on language in order to maintain his or her license at level 4,” Emery says. “You need to give them [students] the skills they need to listen to instructors, to cope with a preflight briefing, to be able to read training manuals on a variety of subjects, such as powerplants, rules of the air, meteorology…Those sorts of learning contexts are very different to aeronautical communication.” 

This is why aviation English language assessments for flight training applicants and aviation English preparatory courses are so important to student success, he says.

Safety Should Come Before Business

Another challenge related to ensuring student pilots are English-language proficient when they take to the skies is the business model of flight training. In the U.S., some for-profit flight schools shy away from a robust front-end screening procedure, Emery says. “Because what they want to see is people who have 60,000 U.S. [dollars] in their pocket…the last thing a flight school wants to do is to turn that business away because somebody isn’t language proficient, which is probably a reason why there are still so many language issues in the States. Flight schools are frightened of the negative impact that good language screening will have on their business.” 

Despite the challenges surrounding aviation English proficiency, Emery says progress has been made, and thankfully, flying is still “phenomenally safe…compared to other forms of transport.”

He adds, “Language should not be a point of discrimination. Language is an enabler; it’s the thing that lets us do things. Language should be opening doors to this fantastic industry, to a brilliant career as a pilot, or a controller, or a maintenance engineer, or whatever the next generation are going to be. But if we don’t treat it as an enabler and we don’t assign a level of importance to it, then there’s really no point in doing it at all.”


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