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Foreign Language Proficiency Endorsements on UK-CAA-issued EASA PPL

Hello,

This topic is not new. Specifically, it has been discussed at length here: http://www.euroga.org/forums/flying/2111-flying-into-french-languange-only-airfields

For those speaking German, it’s also been discussed here: https://www.pilotundflugzeug.de/artikel/2012-07-18/EASA_FCL055

After reading this, I still find the interpretation of FCL.055 ambiguous (though some contributors have very distinguished opinions about this). For the sake of completeness, let me quote it once again:

FCL.055 Language proficiency
(a) General. Aeroplane, helicopter, powered-lift and airship pilots required to use the radio telephone shall not exercise the privileges of their licences and ratings unless they have a language proficiency endorsement on their licence in either English or the language used for radio communications involved in the flight. The endorsement shall indicate the language, the proficiency level and the validity date.

This can be interpreted in two ways:

  1. You always need to have a language proficiency endorsement on your license for the language used for radio communications involved in the flight. English is only mentioned above as it is considered the standard language for radio communication in aviation.
  2. You need to EITHER have a language proficiency endorsement on your license for the language used for radio communications involved in the flight, OR generally a language proficiency endorsement in English. In other words, having a LP endorsement in English would exempt you from having a LP endorsement in the local language.

Personally, I’m in favour of option 2 – not only because it is convenient for me, but also because that’s the way I read the sentence (and the way I understand “either… or…”) and it makes some sense to me. I’m generally willing to keep it that way until some authority tells me otherwise (Context: I’m holding a UK-CAA-issued EASA PPL but I live and fly in Germany and I’m fluent in German (mother tongue) and fluent in English. My license has English LP level 6).

Now I was recently confronted with this by the owner of a charter company that I’m booking a check flight with to charter their airplanes in the future. He is also an aviation lawyer. Upon seeing my license, he first claimed I’m not allowed to fly in Germany. Obviously, that’s not true – at least not if the entire flight is conducted with coms in English (e.g. both departure and arrival aerodrome with EN in the AIP and FIS contact in English, too). However, how about flights to and from airfields that do not offer English radio (like the one his charter company is based at).

Slightly annoyed by this, I emailed the CAA to see how I could get a German LP endorsement. Their (quick! ) answer implies that it is not possible to add another LP endorsement on the UK license:

“As the main concern of ICAO is the proficiency in English, for air navigation the UK licence complies, we do not have a legal requirements to show any other language, so regret that German cannot be added to a UK licence.”

Now:
1) Doesn’t this support the interpretation number 2 of FCL.055 as explained above?
2) Does anyone on this forum have (or know someone who has) a UK-CAA issued EASA PPL license with a language proficiency endorsement other than English?

I’d like to get the opinion of the LBA on this, too – but I don’t bother. They have a habit of not even answering my emails.

Thanks!

Hungriger Wolf (EDHF), Germany

Welcome to the idiocy called EASA (or EU…). Imagine you could only fly on an FAA ticket in Texas if you could prove you had a proper southern drawl…. ok, a bit OTT, but the principle stands.

My license has English LP level 6).

How that? Is that one of the recently issued EASA ones? The older CAA/JAR ones don’t have the level indicated on them.

shall not exercise the privileges of their licences and ratings unless they have a language proficiency endorsement on their licence in either English or the language used for radio communications involved in the flight.

There is nothing ambiguous about this statement at all. Its very clear “EITHER, OR” You either have ELP which is valid for international flight, or you have another language which is confined to the State(s) where that language is spoken.

The whole purpose of ELP is to ensure that the standard of English used on the radio for International Flights meets a minimum “operational standard” The UK does that and issues an ELP endorsement, there is no requirement for any other endorsement to fly in any other country if you have English.

The UK does not, and cannot issue an endorsement in any other language than English.

The problem is largely due to the non English speaking countries who are attempting to make up their own local rules which are not in accordance with ICAO Annex 1 or Part FCL

How that? Is that one of the recently issued EASA ones?

Yes.

There is nothing ambiguous about this statement at all. Its very clear “EITHER, OR”

I agree, but the web is full with people arguing the other way.

In any case, I found this – which in my view makes it pretty clear that the LBA in Germany follows this logic:

http://www.lba.de/cln_008/DE/Luftfahrtpersonal/Sprachanforderungen/Sprachanforderung_Uebersichtsseite.html?nn=23104

Schon mit einem gültigen Sprachvermerk Englisch sind die Forderungen sowohl nach §125 LuftPersV (1) als auch nach Teil FCL.055 (a) in vollem Umfang erfüllt.
Ein weiterer Sprachvermerk Deutsch ist nicht erforderlich, selbst dann nicht, wenn der Sprechfunkverkehr in der deutschen Sprache geführt wird.

Hungriger Wolf (EDHF), Germany

Microsoft translates that section (and the bit after it) as

What Airmen need a proof of German language skills in their license?

With a valid language note, the claims are English both according to § 125 LuftPersV (1) as well as part of FCL. 055 (a) fully met.
A further note of language German is not required, even if the two-way traffic in the German language. A flight radio certificate that is entitled to the exercise of the two-way traffic in the German language, however, is prerequisite.
Therefore require air driver, the does not have an English language note, a voice note German.
Airmen, whose native language is not German, have a language examination pursuant to § 125 for this to complete travel in the German language. A self declaration is sufficient for Airmen of German mother tongue (see news for Airmen I 16/13), to obtain a German language statement.

What does it mean by the bit:

A flight radio certificate that is entitled to the exercise of the two-way traffic in the German language, however, is prerequisite.
Last Edited by dublinpilot at 25 Jun 20:56
EIWT Weston, Ireland

A flight radio certificate that is entitled to the exercise of the two-way traffic in the German language, however, is prerequisite.

Translation (not Google): However, a (flight) radio license that entitles the holder to r/t in German, is a prerequisite. My bold.

Sounds like they are contradicting themselves there. Weird…..

Sorry for pasting the German original only and having you run it through Google.

To clarify the apparent contradiction:

There is a distinction between the language proficiency endorsement on the flight crew license and the independent radio telephony license. According to FCL.055 and also the LBA interpretation above, it is sufficient to have the English language proficiency on the flight crew license – regardless of the language used in flight. In contrast, you absolutely do need a valid radio telephony license for the language you use on the radio.

Hungriger Wolf (EDHF), Germany

Are you sure? I certainly don’t need Google to translate from German , and to me the German text as referenced is contradictory. Could simply be a badly drafted rule (not unheard of….), but I’d get that in writing from the LBA.

The critical passage is this one (my bold): Ein Flugfunkzeugnis, das zur Ausübung des Sprechfunkverkehrs in der deutschen Sprache berechtigt, ist jedoch Voraussetzung.

I’d still say it’s pretty clear.

We agree that we’re cool on the flight crew license, correct? No need for local language endorsements here. English is good enough.

However, now my bold: Ein Flug funk zeugnis, das zur Ausübung des Sprechfunkverkehrs in der deutschen Sprache berechtigt, ist jedoch Voraussetzung.

You’re required to carry a radiotelephony certificate (aeronautical) that permits you to perform radio telephony in German – if you want to perform radio telephony in German (i.e. fly to aerodromes that only offer German).

Last Edited by Patrick at 26 Jun 09:36
Hungriger Wolf (EDHF), Germany

OK, understood. This, however, brings us back o the starting point. If you hold a non-German issued flight crew license, BUT speak perfect German (native or otherwise) and do not hold a German r/t license you cannot legally fly to airfields that offer German only. Is that correct?

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