Mooney_Driver wrote:
That is the big rub: The DGAC has to my knowledge never actually said anything
Because FCL.055 is very clear about this, no clarification is required. Have you entertained the idea that if the DGAC do not clarify, it might be because they do not feel they need to because 1) they feel that FCL.055 is clear and are satisfied with it, and 2) because they do not consider a few foreign pilots landing at sleepy FR-only airfields with less than perfect French as a problem?
The very idea that a non-native speaker should be examiner on any of these exams is a travesty.
I do not agree with that. The DGAC language examiners that I have met on two occasions spoke English exceptionnally well. I did not really get what their backgrounds were, but it was hard to hear that they were not native speakers. On could argue that they should better be language scholars rather than pilots or controllers so they would be better trained in assessing language proficiency based on objective linguistic criterias, but maybe they have received such training.
The real travesty as far as the DGAC tests is the way that the ELP exams are conducted – particularly the parts of the exam where you listen to recordings and have to render what was said. For the IFR exam, the sound quality of some recordings is extremely poor. Those are recordings of actual, crackling HF transmissions from pilots with an Indian accent. If those were to be transcribed in an AAIB accident report, it would say “[inaudible]”. So in France level 6 is really hard to get, even for native English speakers. Not because they have such high standards. But just because they spill oil in the curve for you to skid off the road.
The DGAC answer would be that one needs to be FLP level 4.
On what legal basis? Certainly not based on FCL.055. In once supported the contrary until bookworm and a couple others set me straight convinced me of the contrary during a previous discussion on the same subject.
IIRC according to a conversation, reported (probably by bookworm) here at some point, that took place in Cologne with a DGAC representative that was asked about it some years ago, the DGAC do not require FLP for speaking French. FCL.055 does not require you have an FLP to speak French. There are no credible reports of anyone having been fined in France for speaking French w/o a FLP. I do not myself have a FLP and have been ramp-checked after landing FR-only airfields twice, speaking French. I have done skill tests in French and noone even mentioned the absence of FLP. There is no way of adding FLP to a German, Italian, Swedish, Norwegian or UK license (just as examples) because the NAAs AFAIK won’t do it.
FCL.055 says:
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
So the LP is only valid if it is on the license. Even if you get a paper from DGAC attesting you passed French LP, it cannot be added to your license, and if it is not on your license, it is not valid according to FCL.055.
And there is one other thing: LP is intended for communications with ATC
I once dug up the ICAO documents laying out the language proficiency requirements, and IIRC LP is not the same as phraseology. It is supposed to assess your abilities in the following dimensions:
It is not a phraseology exam. @Bordeaux_Jim would know more since he is a LP examiner.
The Americans have a very pragmatic approach to that which really surprised me the first time I went to a FSDO to get my first 61.75 certificate. No exam required. The conversation I had with the examiner was sufficient. The second time, during my certificate validation by NAA, after 2008, my NAA wrote that I did not have the ELP. So initially the examiner told me that I would need to take an English exam before they could deliver the certificate. When I showed up at the FSDO expecting to have to sit an exam, and she just delivered the certificate without further process, I was surprised and asked about it. She just said that in the meantime she had checked the rules, and since she obviously had no problems having a conversation with me in English, that was good enough for her. So I got “English Proficient” on my FAA certificate.
Mooney_Driver wrote:
tells me that if you want to use an ICAO language other than English for radio coms, you need the corresponding LP
Well, read it again. What can I say. I struggled a little bit with that one too once upon a time, but it was because I was prejudiced and could not fathom why one would allow people to use a language in which they had not been tested. Once I managed to do away with that prejudice, it dawned on me.
Mooney_Driver wrote:
ICAO language other than English for radio coms, you need the corresponding LP. That is the only thing that IS logical actually
See? That’s what I am saying; you are prejudiced. 
(just like I was)
Noe wrote:
I feel we’re debating again a non problem:
Yes!! Isn’t that fun? Real problems are so tedious.
Aviathor, I don’t recall writing that French Air Traffic Controllers are the best in the world only that they are highly trained.That’s not to suggest that other ATC’s in other parts of the world are not also not highly trained. I was simply trying to say that the English language proficiency exam for ATC’s in France is very difficult.
As for 123, 5, I can only say that I have been using this frequency since 1993 and have only on a very few occasions heard someone transmitting in English. When they have they have usually been told by other pilots that they will not be understood and should speak in French. Whether or not this is written in law I do not know and have never felt the need to research it.
Mooney Driver, yes the Brit member I wrote of has a first class honours degree in the English language from Oxford University. He also has a letter from the DGAC reminding him that he needs a level 4 French language proficiency to fly in France.The letter is dated not long after the introduction of the ELP and did not affect him because his licence carried an endorsement saying that he was able to use radiotelephony in the French language.
In my case I took the ELP (Fcl 055d) in England and received a level 6.When this was transferred into my French licence the DGAC would only give me a level 5. The only place, at the time, that one could get a level 6 was at the DGAC Centre for examinations at Orly. I took the exam, found it much more difficult than the one I had taken in England and got a level 5.
Whether pilots from other countries fly to small French airfields is up to them. If you do you might find it enjoyable and that the people you might meet are usually friendly, however bad your French. Airfields in this area are hardly going to make a fortune out of you, especially as often there are no landing or parking fees, no PPR, yellow jackets are usually optional, and you can leave or arrive at any time from 30 minutes before sunrise to 30 minutes after sunset with no formalities. The only limiting factor is that most small airfields do not have lighting for night flying and of course if there is a Notam.
Regarding fines for not having FR ELP, I have just done a search using the terms
fine* AND french
and it digs out enough reading material. Notably this post.
It does seem to be real, and it would only be expected that few of the people will want to talk about it.
On a slight tangent, many people have observed that the quality of English grammar here on EuroGA is generally vastly better from the non-English contributors And I well know a number of people who have excellent conversational English but who could not get a Level 6, which I find bizzare. Perhaps 90% of native Brits could not get a 6 on that basis.
gallois wrote:
because his licence carried an endorsement saying that he was able to use radiotelephony in the French language.
Which would indicate that he has a French license, in which case he does need a FLP. He could get a Norwegian license, in which case he would not need an NLP since Norwegian R/T no longer exists. And a Norwegian language examiner would probably give him a ELP 6 so until they change the regulations, he would have it for life.
When this was transferred into my French licence the DGAC would only give me a level 5.
That is unfortunately standard procedure, not only in France I am afraid, but also in other countries. Actually the Norwegian CAA refused to accept my ELP 6 delivered by DGAC. They would not even give me level 5. I had to use a Norwegian language examiner.
As for 123, 5, I can only say that I have been using this frequency since 1993 and have only on a very few occasions heard someone transmitting in English.
That does not mean anything. It just means that there are extremely few foreign pilots using that frequency or landing at A/A/ airfields in France which goes to the point that the whole FR-only problem is not a problem.
When they have they have usually been told by other pilots that they will not be understood and should speak in French.
That is just ignorant by those French pilots. The fact that you heard that, does not mean it is not allowed to use English on the A/A frequency so you should not state that as a fact just because of what you heard on that very frequency. Incidentally AFAIK A/A means Aircraft-to-Aircraft. I do not think its use is restricted to communication around airfields. I’ve tried to find something about from some authoritative source, but have so far not been successful. In Sweden it is also used for communication amongst gliders. I wonder what flights in formation use?
no PPR, yellow jackets are usually optional,
Usually… Unfortunately not always. At Quiberon there is a big sign warning you that the yellow jacket is mandatory.
It just means that there are extremely few foreign pilots using that frequency or landing at A/A/ airfields in France which goes to the point that the whole FR-only problem is not a problem.
You would not get that past a student in philosophy, never mind one with a PhD like the one I have in the house here
It’s like Fraport arguing that GA doesn’t come to Greece anyway so why not charge them €400?
April 2013, LFAT Le Touquet, ramp check 80€ fine for missing LP French and doing R/T in French (no fine had he spoken English) – Police was monitoring R/T of arriving aircraft with handheld
May 2013 LFOM Lessay, ramp check, field PPR – 140€ fine
May 2013 LFRF Granville Mont St.Michel, ramp check, 50€ fine
Are you kidding me? Is that even credible?
Most pilots fly for years without ever being ramp-checked, and this dude gets checked 3 times in two months? And on top of that gets fined?
The problem is that even if those above fines are real, we have no idea about the context or if the reason invoked is real.
April 2013, LFAT Le Touquet, ramp check 80€ fine for missing LP French and doing R/T in French (no fine had he spoken English) – Police was monitoring R/T of arriving aircraft with handheld
He claims he got fined for not having an LP. But there is no legal basis for that. The fine is really small, though.
May 2013 LFOM Lessay, ramp check, field PPR – 140€ fine
This has nothing to do with LP.
May 2013 LFRF Granville Mont St.Michel, ramp check, 50€ fine
For what? LP? Well, Granville is FR-only. If his French is not good enough to be understood, and he does not understand French well enough… I guess he had it coming. That still does not mean that FLP is required.
Peter wrote:
It just means that there are extremely few foreign pilots using that frequency or landing at A/A/ airfields in France which goes to the point that the whole FR-only problem is not a problem.You would not get that past a student in philosophy, never mind one with a PhD like the one I have in the house here
It’s like Fraport arguing that GA doesn’t come to Greece anyway so why not charge them €400?
Objection your Honor; this does meet your standards for “personal attacks” which is against forum rules, and I have had several posts deleted for similar offenses in the past. So please delete it! Forum rules apply t all, including the moderator.
I disagree.
Here I am pointing out the illogical reasoning that a lack of FR speaking traffic means that there would not be any if FR was not required.
Loads of your posts were deleted because they were simply pointlessly rude. And I know your ELP is perfectly good enough to know that, so why write it?
Regarding post 148, it does seem unlikely but “law enforcement” is often done in batches – hence the Inspector Clouseau “arrest the usual suspects” trademark phrase is how most police work is done, and for a good reason. Another thing is that if you do something to provoke them, they will give you a hard time. These people are not usually particularly bright, so that is an easy avenue.
Aviathor,
FYI, that guy on the German forum reporting those “fines” a few a years ago was a total troll. Nothing was true about it.
