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Issued as part of the process of public consultation by CASA’s Regulatory Development Management Branch

Document NPRM 0714FS – November 2007

Notice of Proposed Rule Making

Flight Crew English Language

Proficiency for Radiotelephony Communication

Proposed amendment to Civil Aviation Order (CAO) 40.0

Who this NPRM applies to It is expected that this proposal will affect the following persons in the aviation community:

Pilots conducting international operations, Approved Testing Officers, and applicants for new flight crew licences including student pilots, with effect from 05 March 2008.


Flight Crew English Language Proficiency for Radiotelephony

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Document NPRM 0714FS Page 1 of 22

Foreword

Context of this NPRM The Civil Aviation Safety Authority (CASA) invites members of the aviation community, and members of the public in general, to comment on this proposal to introduce an amendment to Civil Aviation Order (CAO) 40.0. This Notice of Proposed Rule Making (NPRM) introduces, and invites consultation on the implementation of the International Civil Aviation Organization (ICAO) Standards on language proficiency which enhances the current English requirement of Civil Aviation Regulation (CAR) (1988) 5.09(1)(a). It is proposed that the ICAO Standards be fully implemented on 05 March 2008.

Background In Australia the language used in flight and ground operations is English. The required of standard English language proficiency, conditional to the issue of a flight crew licence to an applicant, is expressed in CAR (1988) 5.09(1)(a). In accordance with CAR (1988) 5.09(1)(a), CASA may only issue a flight crew licence to an applicant if the applicant possesses a knowledge of the English language that is sufficient to enable him or her to exercise safely the authority given by the licence. In addition to the above requirements, with effect 5 March 2008, CASA will implement the standards of the ICAO Standards and Recommended Practice (SARPS) on language proficiency. This standard pertains only to oral communication. The detailed specifications of the ICAO SARPS on language proficiency are contained in the Manual on the Implementation of ICAO Language Proficiency Requirements (Doc 9835 – AN/453). Australia’s compliance to the ICAO SARPS is expressed in this Order.

Proposed Changes In A Page The time-conscious reader can obtain a quick appreciation of the proposed changes in Section 2 of this NPRM.

A more detailed explanation of the regulation changes is provided in Section 3 of this NPRM.

How you can help us CASA is responsible under the Civil Aviation Act 1988, amongst other functions, for developing and promulgating appropriate, clear and concise aviation safety standards. In the performance of this function and the exercise of its powers, CASA must, where appropriate, consult with government, commercial, industrial, consumer and other relevant bodies and organisations.

Civil Aviation Act 1988 Subsection 9(1)(c) and Section 16



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“CASA is committed to working cooperatively with the aviation industry to maintain and enhance aviation safety. This is especially important as far as the development of standards and regulatory material is concerned.”

CASA Standards Development and Rule Making Manual, 2.6.1

To ensure clear and relevant safety standards we need the benefit of your knowledge, as an aviator, aviation consumer and/or provider of related products and services, by completing the Response Form (in this NPRM) and returning it to CASA by 11 January 2008. I thank you for expressing interest in this proposal and emphasise that no rule changes will be undertaken until all NPRM responses and submissions received by the closing date of 11 January 2008 have been considered.

Greg Hood Group General Manager Personnel Licensing, Education & Training Group

16 November 2007



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Contents

Abbreviations and Definitions .................................................................... 51. The Consultation Process ..................................................................... 7What CASA does with your comments .................................................................... 7

2. Proposed Changes in a Page ................................................................ 83. Synopsis of Change Proposals ............................................................ 9

3.1 Purpose of this NPRM ............................................................................... 9

3.2 Background ............................................................................................... 9

3.3 Reasons for change .................................................................................. 17

3.4 Key change proposals ............................................................................... 17

3.5 Benefits and impact of changes ................................................................ 18

3.6 Persons and organisations affected .......................................................... 18

3.7 Implementation and review ........................................................................ 19

NPRM Response Form................................................................................. YOU CAN RESPOND ONLINE OR BY FAX, POST OR EMAIL

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A web-based online response form is offered as an alternative to the printed form in this NPRM. Online submission is the preferred method of sending your comments to CASA. If you are connected to the Internet, type casa.gov.au/newrules/ors into your web browser and follow the links for this NPRM.

Annex A – Proposed amendment to Civil Aviation Order (CAO) 40.0 – Flight Crew English Language Proficiency for Radiotelephony Communication ........................................................................................... A1



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Abbreviations

ATC Air Traffic Control ATO Approved Testing Officer ATPL Air Transport Pilot Licence CAO Civil Aviation Order CAR Civil Aviation Regulations 1988 CASA Civil Aviation Safety Authority CASR Civil Aviation Safety Regulations 1998 CFI Chief Flying Instructor CP Chief Pilot CPL Commercial Pilot Licence ICAO International Civil Aviation Organization IELTS International English Language Testing System NFRM Notice of Final Rule Making PPL Private Pilot Licence RPPL Restricted Private Pilot Licence SARPSs Standards and Recommended Practice SPL Student Pilot Licence TOEFL Test of English as a Foreign Language TOEIC Test of English for International Communication TTMRA Trans-Tasman Mutual Recognition Agreement

Definitions

Definition of ‘Flight Crew’ in this Order Where this Order refers to the term ‘flight crew’ it includes all pilots holding aeroplane and helicopter Air Transport Pilot Licence (ATPL), Commercial Pilot Licence (CPL), unrestricted Private Pilot Licence (PPL), and flight engineers, but only if the flight engineer is required by flight crew duties to conduct radiotelephony communications with Air Traffic Control (ATC) and other aircraft.



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1. The Consultation Process 1.1 A legislative change proposal was raised within CASA in 2006 to introduce an amendment to CAO 40.0 to implement the ICAO SARPS on language proficiency for flight crew. This proposal was considered and a rule change project initiated in mid-2007. 1.2 Through consultation with CASA subject matter experts, industry participants, and aviation English language specialist providers, CASA has developed the proposed amendment contained in Annex A to this NPRM. 1.3 Members of the aviation industry community are invited to consider and comment on the proposed rule.

What CASA does with your comments? 1.4 At the end of the response period for public comments, all submissions will be analysed, evaluated and considered. Subsequent to the closing date for comments a Notice of Final Rule Making (NFRM) will be prepared, and made publicly available in conjunction with the making of the Final Rule. 1.5 CASA is required to register each comment and submission received, but will not individually acknowledge a response unless specifically requested. However, the names of respondents will be published in the subsequent NFRM, except where CASA is specifically requested not to do so.



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2. Proposed Changes in a Page

INTERNATIONAL STANDARDS

EXISTING AUSTRALIAN STANDARDS

Proposed Amendment to CAO 40.0

ICAO Language Proficiency

Requirements (Doc 9835 – AN/453)

Objectives • To introduce the ICAO SARPS on language proficiency for flight crew. • Amend CAO 40.0 to require pilots on international flight operations to have an English

language endorsement in their flight crew licence. • Set renewal requirements for the Levels of English language proficiency. • Preserve existing standards for flight crew licences issued before 05 March 2008. • Specify English language proficiency requirements for issue of new flight crew licences with

effect from 05 March 2008.

Key Proposed Changes • Levels Four and Five English language proficiency require renewals at periodic intervals. • No change to domestic operations for holders of licences issued before 05 March 2008. • Licences issued from 05 March 2008 shall only be issued if applicant has a Level Four English

language proficiency. • Student Pilot Licence shall only be issued if the CFI is satisfied with the student pilot’s English

speaking proficiency necessary for the student to exercise the authority of the SPL safely. For students from non-English speaking background the applicant has to demonstrate a minimum standard of General English like IELTS, TOEFL, etc.

• Flight crew on international operations must have at least a Level Four English Language proficiency endorsed licence.

Civil Aviation

Regs 1988

Civil Aviation

Order 40.0

CAO 40.0

CAR

Part 5



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3. Synopsis of Change Proposals

3.1 Purpose of this NPRM 3.1.1 The purpose of this NPRM is to seek formal comment on a proposed amendment to CAO 40.0 – an Order relating to English language proficiency for safe flight operations in accordance with ICAO SARPS. 3.1.2 A number of key change proposals have been developed, and as such, CASA is seeking input as to whether these requirements are appropriate. 3.1.3 Comments elicited from the consultation process will allow CASA to ‘fine tune’ the amendment to ensure a positive safety outcome results, whilst also being confident it meets the needs of industry within the legislative safety framework.

3.2 Background 3.2.1 In 2006, CASA announced its intention to comply with the ICAO SARPS on English language proficiency for pilots (and Air Traffic Control), with the requirements published in a new CAO 40.0 – an Order supplementing and enhancing the existing English standards as defined in CAR (1988) 5.09(1)(a). 3.2.2 The new standards will not affect holders of licences issued before 05 March 2008 and who only conduct domestic operations.

Australian Licences issued before 05 March 2008 3.2.3 CAR (1988) 5.09(1)(a) and its legislative predecessors have stipulated a regulatory requirement to assess the holder of a flight crew licence as having a satisfactory standard in English language proficiency before a flight crew licence could be issued. Therefore a holder of an Australian flight crew licence issued before 05 March 2008, and conducting domestic operations only, need not hold an ICAO prescribed proficiency level in English. A holder of an Australian flight crew licence issued before 05 March 2008, and conducting international operations on or from 05 March 2008, provided specific conditions are met, is deemed as possessing a standard in English language that is at least equal to the minimum standard for operational flying required by the ICAO Standards and Recommended Practice (SARPS) and will be issued a Level 4 English language proficiency statement. 3.2.4 The specific conditions deeming a holder of an Australian flight crew licence issued before 05 March 2008, intending to conduct international operations on or from 05 March 2008, as possessing a standard in English language proficiency required by the ICAO SARPS for operational flying, and therefore not requiring a re-assessment of English language proficiency, shall be that the holder has been resident in Australia (or an English speaking country or region) for the major part of the last two successive years.



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3.2.5 CASA has determined the English speaking countries are Australia, New Zealand, UK, Republic of Ireland, USA and English speaking regions of Canada. 3.2.6 Notwithstanding the above, a holder of an Australian flight crew licence issued before 05 March 2008 requires an assessment in English language proficiency on or after 05 March 2008, if the licence holder:

• upgrades the licence; • obtains a licence for a new aircraft category; • renews an existing English language proficiency endorsement at the expiry of its

validity period; or • is required by CASA as necessary in the interest of safety.

Levels of language proficiency from 05 March 2008 3.2.7 The language proficiency standard grades speakers into six levels of language proficiency, starting from (Pre-elementary) Level 1 to (Expert) Level 6 – see Appendix 1 of this NPRM for details. 3.2.8 The Proficiency Rating Scale in the ICAO SARPS is extracted from Annex 1 to the Convention on International Civil Aviation. The language proficiency of a flight crew is determined by the degree to which the flight crew’s demonstrated performance complies with the descriptor for the appropriate proficiency level in each language category. The overall proficiency rating is determined by the lowest rating level assigned in any particular category. 3.2.9 The Level Four (Operational) language proficiency descriptors are the minimum proficiency skill level determined necessary for safe aeronautical radiotelephony communications. 3.2.10 For the assessment in English language proficiency, CASA re-emphasises two requirements for safe effective radiotelephony communication. These are that the flight crew adheres strictly to standard ICAO phraseologies, and has the English language proficiency to resolve unexpected or non-routine situations, which may not be covered by standard phraseologies but which need the use of plain English.

Minimum level of proficiency acceptable for operational flying from 05 March 2008 3.2.11 With effect from 05 March 2008, holders of Australian flight crew licences shall be certified with a minimum of Level Four (Operational) English language proficiency in accordance with the ICAO Scales of language proficiency. 3.2.12 Notwithstanding the above, holders of Australian flight crew licences issued before 05 March 2008 who are only conducting domestic operations in Australia are not required to hold, nor would be issued, an English language proficiency statement.



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Issue of English language proficiency endorsement 3.2.13 Only CASA may issue an English language proficiency statement to a holder of an Australian flight crew licence. The certification with a validity period shall be notated in Part XIII of the flight crew licence. 3.2.14 An Australian flight crew licence in this respect shall be limited to an aeroplane or helicopter ATPL, CPL or unrestricted PPL, as well as a flight engineer licence but only if the flight engineer is required to conduct radiotelephony communication with ATC or other aircraft as part of his flight crew duties. 3.2.15 CASA may only issue the proficiency level to the holder of an Australian flight crew licence who has been assessed as having attained at least a Level Four (Operational) proficiency by a CASA approved English language assessor. 3.2.16 Notwithstanding the above paragraph, CASA may issue a Level Four (Operational) proficiency statement in English language oral skills on application by a holder of an Australian aeroplane or helicopter flight crew licence issued before 05 March 2008, who can provide evidence of intention to conduct an international flight, and provided the holder has been resident in Australia for the major part of the two years before the application, and that the application is made before 05 March 2010. 3.2.17 Notwithstanding the above condition, if the applicant has not been resident in Australia for the major part of the two years before the application, the applicant may provide evidence in lieu that he has been resident in one of the determined English speaking country. CASA has the right to direct the applicant to be assessed by a CASA approved assessor in English language proficiency. 3.2.18 CASA shall not issue an English language proficiency statement to a student pilot licence, special pilot licence or certificate of validation. 3.2.19 A holder of an Australian licence with a valid English language proficiency statement issued by CASA, when applying for a higher licence or licence of a different aircraft category, may have the same proficiency included in the new licence to the extent of its validity period, without a re-assessment.

Renewals of endorsement in English language proficiency 3.2.20 A Level Four (Operational) English language proficiency statement is valid only for three calendar years from the date of assessment. 3.2.21 A Level Five (Extended) English language proficiency statement is valid only for six calendar years from the date of assessment. 3.2.22 A Level Six (Expert) English language proficiency statement is valid perpetually. 3.2.23 Renewals of Levels Four and Five endorsements in English language proficiency may only be conducted by a CASA approved specialist English language assessor.



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Conducting international flights 3.2.24 A holder of an Australian flight crew licence who conducts international operations shall have evidence of the minimum required level of English language proficiency recorded in the pilot licence by CASA. 3.2.25 Once a holder of a flight crew licence has been issued a statement in English language proficiency, the holder is required to renew its validity in order to use the licence to conduct either domestic or international operations. A holder of a flight crew licence, which has an expired English language proficiency certification, may not conduct domestic or international operations.

Conducting domestic flights 3.2.26 A holder of an Australian aeroplane or helicopter flight crew licence issued before 05 March 2008, and who conducts only domestic flights in Australia, does not require nor will be issued with an English language proficiency statement. 3.2.27 Pilots of aircraft other than aeroplane or helicopter who may be required to conduct radiotelephony communications with Air Traffic and other aircraft, such as glider or free balloon pilots, shall have the ability to speak and understand the English language in accordance with the requirements of CAR (1988) 5.09(1)(a).

Issue of PPL, CPL or ATPL from 05 March 2008 3.2.28 With effect from 05 March 2008, applicants for the issue of a flight crew licence, but excluding ratings, shall only be issued the licence if they can demonstrate they have at least a Level Four (Operational) proficiency in the English language.

Student Pilot Licence 3.2.29 The Student Pilot Licence (SPL) continues to be issued under the provisions of CAR (1988) 5.09 and 5.65. Before processing the SPL for the student, the Chief Flying Instructor (CFI) shall be responsible for ascertaining a student has the minimum English language proficiency to exercise the authority of the SPL safely. 3.2.30 The CFI shall also shall sight that the student has one of the following documents listed in Para 7 of the CAO testifying to the undertaking or completion of secondary education in the English language in an (determined) English-speaking country, or having worked at least three in the past five years of employment in an (determined) English speaking country, or meeting or exceeding the General English Test criteria specified in the Appendix. 3.2.31 The CFI shall be responsible for ascertaining that a student, before being authorised as solo pilot or pilot–in-command on cross-country training flights, has the minimum standard of English language proficiency that is required by the relevant flying syllabus for the safe conduct of that phase of flight training.



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When CASA does not issue a certification in English language proficiency 3.2.32 CASA shall not issue an English language proficiency statement for the holder of a Student Pilot Licence, restricted Private Pilot Licence (RPPL), Certificate of Validation (C of V) or Special Pilot Licence. 3.2.33 CASA shall not issue an English language proficiency statement to the holder of a foreign flight crew licence for the purpose of issuing an Australian Certificate of Validation or a Special Pilot Licence. 3.2.34 CASA shall only issue a Certificate of Validation or Special Pilot Licence to a holder of a foreign pilot licence provided the licence is:

• issued by the authority of an ICAO contracting State; and • certified with at least a Level Four (Operational) English language proficiency by

the same foreign authority.

CASA’s right to re-assess flight crew licence holder in English language proficiency 3.2.35 If CASA believes on reasonable grounds that the holder of a flight crew licence, with an English language proficiency, does not possess an English language proficiency certification that is adequate to safely exercise the authority of that licence, or does not meet at least Level 4 (Operational) of the ICAO SARPS on language proficiency it may, by notice in writing, require the holder to undertake an assessment of English language proficiency with an approved linguistic specialist organisation. 3.2.36 If the holder of a pilot licence, after having been required by CASA to undertake an assessment of English language proficiency, fails to achieve a minimum of Level Four (Operational) proficiency, CASA may suspend the licence until the holder is able to demonstrate at least a minimum Level Four (Operational) proficiency in English language.

CASA approved assessors for English language proficiency 3.2.37 Only CASA may approve a person or an organisation to be an assessor for the purposes of assessing the proficiency level of a flight crew applicant in the English language in accordance with the rated levels of language proficiency of the ICAO Standards. 3.2.38 CASA shall only accept an assessment of a flight crew made by a CASA approved English language assessor as evidence for the issue or renewal of an English language proficiency statement. 3.2.39 There are two types of assessors, namely the ‘Level Six (Expert)’ assessor and the specialist English language assessor.



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3.2.40 Unless the person has linguistic specialist qualifications in English, the approval is limited to assessing candidates at ‘Level Six (Expert)’ proficiency. 3.2.41 A ‘Level Six (Expert)’ assessor is a CASA approved person who is restricted to assessing candidates directly related to his/her role which has merited the approval, eg. an Approved Testing Officer (ATO) may only assess an applicant on a flight test for a flight crew licence, while a CAR 217 ‘check and training’ captain may only assess an applicant who is a flight crew member of the same CAR 217 organisation. 3.2.42 A specialist English language assessor may be a CASA approved person or organisation which possesses specialist linguistic qualifications and may assess an applicant for all levels of language proficiency including assessing and recommending another assessor for CASA to approve. 3.2.43 CASA has approved linguistic specialist persons and organisations to assess English language proficiency of flight crew holding Australian flight crew licences for the issue of a Certificate of English Language Proficiency. The approved persons and organisations and location of their venues are published on the CASA website.

CASA’s right to withdraw its approval for an assessor 3.2.44 If CASA believes on reasonable grounds that an approved assessor (person or organisation) no longer possesses the attributes to exercise the CASA approval, that would ensure applicants for assessment of English language proficiency safely meet the minimum of Level 4 (Operational) of the language proficiency, it may, by notice in writing, inform the assessor that the approval has been withdrawn. 3.2.45 Depending on CASA determination, the person or organisation may be allowed to apply for a re-issue of the CASA approval to conduct assessment of English language proficiency, subject to satisfactory re-training and re-assessment by an approved linguistic specialist organisation or specialist nominated by CASA. 3.2.46 The person or organisation so required by CASA to undertake the English language re-training and re-assessment shall bear the cost of the re-training and re-assessment. 3.2.47 CASA may also determine that a person or organisation, whose approval to conduct assessment of English language proficiency has been withdrawn, is not suitable for re-approval.

Undertaking an assessment in English language proficiency 3.2.48 Only a holder of an Australian issued flight crew licence, except those that CASA has explicitly stated it will not issue an English language proficiency statement to (see earlier paragraphs 3.2.34 and 3.2.35), may apply for an assessment in English language proficiency in order to receive a CASA endorsement.



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3.2.49 In order to maintain the integrity of the assessment process, the CASA approved assessors shall ensure applicants provide photographic proof of identity and official documented evidence of one of the stated pre-requisites (see paragraph 3.2.58 below). The acceptable forms of photographic proof of identity are published on the CASA website. 3.2.50 Approved assessors shall maintain a record of the assessment in accordance with the Australian Archival Act (1983) for audit.

Pre-requisite for assessment leading to an endorsement in English language proficiency 3.2.51 The language proficiency assessments are to determine an applicant’s command of both standard ICAO phraseologies and plain English language used in effective aviation radiotelephony communication. 3.2.52 The assessments must be set in a broad aviation-related context and the language must cover that needed for aviation-related situations or tasks, including unusual and/or abnormal flight or ground situations, and be generally applicable to all licence levels. 3.2.53 While the language proficiency assessments are not tests of aeronautical theoretical knowledge, all language proficiency applicants are expected to have basic aviation awareness in order to demonstrate an ability to communicate in an aviation context. This awareness would only be achieved through training that covers the aeronautical subject matter and adequate aeronautical flight experience. 3.2.54 Therefore, the pre-requisite to undertake a language proficiency assessment is:

• an Australian aeroplane or helicopter pilot licence which shall be an ATPL, CPL or an unrestricted PPL; or

• if the applicant only holds an Australian PPL or CPL examination pass credit, just prior to taking the relevant flight test for the licence.

Conversion of Overseas Flight Crew Licence 3.2.55 A candidate for a flight test leading to the issue of an Australian flight crew licence includes a holder of a foreign flight crew (unrestricted) licence, issued by the authority of an ICAO contracting State, who is applying for conversion of the foreign licence to an Australian flight crew licence, and who has passed all the required flight crew examinations for the conversion.

Conversion of New Zealand Professional Flight Crew Licence under the provisions of the Trans-Tasman Mutual Recognition Agreement 3.2.56 Under the provisions of TTMRA, the holder of a New Zealand unrestricted professional flight crew licence may apply for the issue of an equivalent Australian licence.



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3.2.57 On English language proficiency, the application shall be processed as if the New Zealand licence, with regard to its date of issue, has been issued in Australia, and the type of operations the applicant intends to conduct with the Australian licence.

3.3 Reasons for change 3.3.1 Adoption of the ICAO SARPS on language proficiency for flight crew. 3.3.2 Preserve existing English standard as defined by CAR (1988)(1)(a) for licences issued before 05 March 2008 if conducting only domestic operations.

3.4 Key change proposals 3.4.1 Key proposed changes in relation to the proposed new CAO 40.0 include:

• flight crew on international operations must have at least a Level Four English language proficiency certification;

• levels Four and Five English language proficiency require renewals at periodic intervals;

• no change to domestic operations for holders of licences issued before 05 March 2008;

• licences issued from 05 March 2008 shall only be issued if applicants have a Level Four English language proficiency; and

• the student Pilot Licence shall only be issued if the CFI is satisfied with the student pilot’s language proficiency for the student to exercise the authority of the SPL safely. For students from non-English speaking background the applicant has to demonstrate a minimum standard of General English like IELTS, TOEFL, etc.

3.5 Benefits and impact of changes 3.5.1 There are clear safety benefits in enhanced English standards. The differentiation of various levels of English Language proficiency and their associated levels in Appendix 4 of the CAO are realistic management of the vital language proficiency necessary for safe flight operations 3.5.2 The amendment to CAO 40.0 enhances the existing English requirement as defined by CAR (1988) 5.09(1)(a). 3.5.3 There is no impact for licence holders operating domestically. Most licence holders, whether pre or post 05 March 2008 are expected to be either English native or expert speakers, therefore are likely to achieve a Level Six proficiency with no renewal required.



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3.5.4 It is not anticipated that any negative safety or financial impact on the aviation industry will be experienced as the principal assessors will be the existing core of ATOs, Chief Pilots and CAR 217 check & training captains, who will conduct the majority of the language proficiency assessments during the respective flight test or cyclic training. Therefore, in real terms, the activity remains the same. Foreign students from non-English speaking countries are currently provided with English language training and the emphasis on the English language skills requirement for them in the proposed CAO merely restates what should be done currently.

3.6 Persons and organisations affected 3.6.1 The persons and organisations affected by the proposed amendment will include:

• Australian flight crew licence holders; • Approved Testing Officers (ATOs); • CAR 217 training & checking organisations conducting international operations; • Charter or corporate flight conducting international operations; • Flying Training Schools; • Specialist English language providers (universities); and • CASA staff.

3.6.2 It is specifically requested that these persons and types of organisations consider and respond to this NPRM.

3.7 Implementation and review 3.7.1 The ICAO SARPS on language proficiency enhances the existing CAR (1988) 5.09(1)(a) requirements by adding specifications for different levels of language proficiency and their associated renewal requirements. 3.7.2 The Order also preserves in specific circumstances the pre-ICAO SARPS English language standard, assessed under the requirements of CAR (1988) 5.09(1)(a) as part of the transitional process. 3.7.3 The Order describes the role and limitation of CASA approved assessors of English language proficiency.



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NPRM Response Form FLIGHT CREW ENGLISH LANGUAGE PROFICIENCY FOR

RADIOTELEPHONY COMMUNICATION Please complete your response by 11 January 2008

and return it by one of the following means: Online (preferred method*) casa.gov.au/newrules/ors

Fax 1800 653 897 (free call in Australia)

Post (no stamp required in Australia) CASA’s Regulatory Development Management Branch

Reply Paid 2005, Canberra ACT 2601, Australia

E-mail (use the response format in this NPRM) [email protected]

* A web-based online response form is offered as an alternative to the printed form in this NPRM. Online submission is the preferred method of sending your comments to CASA. If you are connected to the Internet, type casa.gov.au/newrules/ors into your web browser and follow the links for this NPRM.

Your Details Please provide relevant information below and indicate your acceptance or otherwise of the proposal presented in this Notice of Proposed Rule Making by ticking [ ] the appropriate boxes.

Your name: ______________________________________ ARN* (if known):

Organisation: ____________________________________ ARN* (if known):

Address: _____________________________________________________________________

_____________________________________________________________________________

*Aviation Reference Number, usually your CASA-issued licence or certificate number

Your telephone number (optional): ___________________ (to enable the Project Leader to contact you as necessary)

Do you consent to have your name published as a respondent to this NPRM? YES [ ] NO [ ]

Signed: ………………………..………………………………….. Date: ……………….….…

How are you responding to this questionnaire/proposal, i.e. whose views are represented in your response?

Private individual

Aviation industry body/association

Staff association/ union

Government agency/authority/ department/council

Aviation business owner/ service provider

Other

Please advise your main involvement in aviation: Passenger/

public consumer of aviation services

Air crew for passenger-carrying activities

Air crew for non-passenger-carrying activities

Ground support for passenger-carrying activities

Ground support for non-passenger carrying activities

Other (specify below*, e.g. regulator)

* Details: ____________________________________________________________________

Are you satisfied with CASA’s consultation on this issue?

Very satisfied Satisfied No opinion Dissatisfied Very dissatisfied



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Key Change Proposals (refer to NPRM Section 3) CASA invites you to advise your comments on the subject matter proposed in this NPRM by indicating your preference by ticking [ ] the appropriate box and commenting below:

Flight crew on international operations must have at least a Level Four English language proficiency endorsement in licence [ ] acceptable without any changes [ ] acceptable but would be improved if changes were made [ ] not acceptable but would be acceptable if changes were made [ ] not acceptable under any circumstances [ ] no opinion

Additional explanation (and, if appropriate, an estimate of any consequential impacts including costs): __________________________________________________________________________ ________________________________________________________________________________ ________________________________________________________________________________ ________________________________________________________________________________

No change to domestic operations for holders of licence issued before 05 March 2008 [ ] acceptable without any changes [ ] acceptable but would be improved if changes were made [ ] not acceptable but would be acceptable if changes were made [ ] not acceptable under any circumstances [ ] no opinion


Licences issued from 05 March 2008 shall only be issued if applicant has a Level Four English language proficiency [ ] acceptable without any changes [ ] acceptable but would be improved if changes were made [ ] not acceptable but would be acceptable if changes were made [ ] not acceptable under any circumstances [ ] no opinion




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Student Pilot Licence shall only be issued if the CFI is satisfied with the student pilot’s English speaking proficiency necessary for the student to exercise the authority of the SPL safely. For students from non-English speaking background the applicant has to demonstrate a minimum standard of General English like IELTS, TOEFL, etc [ ] acceptable without any changes [ ] acceptable but would be improved if changes were made [ ] not acceptable but would be acceptable if changes were made [ ] not acceptable under any circumstances [ ] no opinion


General and Specific Comments

Your response to the draft proposed amendment to CAO 40.0: Having read the draft amendment to CAO 40.0 (NPRM Annex A) are there specific issues that you wish to see addressed? Please indicate by specifying the relevant section or paragraph number, any change that you believe will add value to the proposal, and a short explanation of your reason for proposing the change.

Section/Para No.

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(please suggest change) Explanation

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Thank you

Your responses ensure balanced consideration by CASA of the interests of the aviation community and consumers.

Please forward your response to CASA by 11 January 2008

by one of the following means:

Online (preferred method) casa.gov.au/newrules/ors

Fax To: Regulatory Documentation Coordinator

1800 653 897 (free call) or international +612 6217 1691

Post (no stamp required in Australia) Reply Paid 2005

Regulatory Documentation Coordinator CASA’s Regulatory Development Management Branch

Canberra ACT 2601, Australia

E-mail (use the response format in this NPRM) [email protected]

Additional information is available from:

Teoh Cheang Hoe, Project Leader Post (no stamp required) Reply Paid 2005

Civil Aviation Safety Authority Canberra ACT 2601, Australia

E-mail [email protected]

Telephone: 02 6217 1643 or 131 757 (for the cost of a local call) International +61 2 6217 1643

Fax: 02 6217 1664 International +61 2 6217 1664

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