Why does Regulation (EU) No 139/2014 refer to the ICAO operational level 4 for English language proficiency, which has not been developed for aerodrome vehicle drivers, but flight crew and air traffic controllers (ATCOs)?
Answer
Flight crews, air traffic controllers (ATCOs), and aerodrome vehicle drivers are operating in the same environment; therefore, it is appropriate to require the same minimum level of language proficiency, which is level 4.
International Civil Aviation Organization (ICAO) Document 9835 on language proficiency states in Section 2.3.4 that the recognition of possible (language) errors “contributed to the construction of ICAO Operational Level 4 which is considered to be the minimum level acceptable to ensure safe operations”. Since the role of the personnel in question (flight crew, ATCO, or aerodrome vehicle driver) is irrelevant to the possibility of making an error, it should be considered appropriate that ICAO’s Operational Level 4 is equally applicable to the aerodrome vehicle drivers as the minimum acceptable level. Indeed, even Level 3 of proficiency as described in AMC1 ADR.OPS.B.029(b) is insufficient to prevent impaired communication caused by errors in comprehending the meaning, which may result in failure to understand a situational complication or an unexpected turn of events.