where the pilot holds a National licence, if the FRTOL has an expiry date then because the FRTOL is a seperate licence it has to be renewed.
The CAA changed the UK National Licence into the same format as the EASA license: e.g..
Section XII Flight Radiotelephony Operators privileges. 'The holder of this licence has demonstrated competence to operate R/T equipment on board aircraft in English.'
XIII Remarks 'Language Proficiency English Level 6. Valid for life'. The wording in my National licence is identical to that in my EASA licence and does not require an additional RT licence to be held.
I remember well the CAA reissuing licenses, without application, to include section XIII but providing only 'Level 4'. The CAA under a lot of pressure defended by saying that Level 4 was all that was required internationally for any purpose although limited to the three years. They also claimed this was satisfactory in the first instance because all ratings were issued for periods for one or two years and therefore all licence holders would need to see an examiner within the three years. The examiners were authorized to assess level 6 if appropriate during the course of revalidating/renewing ratings, without formality, and the relevant form included a section to do so. They also commented that it had never before been a requirement to demonstrate English proficiency for the issue of a UK pilots licence. It was likely therefore that many who would not be at level 6. Another hiccup was that the CAA never informed examiners of this and so pilots when revalidating/renewing were not always informally assessed and upgraded to level 6.
To add to the confusion many at the CAA were not properly briefed either. One fuming PPL having been sent to me in hope stormed into my office saying that the CAA had told him that he was required to attend a CAA approved language school to be assessed for level 6. "I spent 22 years in her Majesties Royal Air Force, retired as a Sqn. Ldr, and some bloody bureaucrat says i can't speak the Queens English". The incorrect advice given to this man was widely repeated by CAA staff at the time.
A Level 4 candidate should be able to pass a R/T licence test in my view.