English Language Proficiency Nonsense
 

I am wading through the mire that is EASA FCL trying to figure out how to extract an English language proficiency EPL certificate without needlessly spending too much time/money. I have a UK JAR license expiring very soon which was issued with language proficiency: English. From what I can gather this was recorded in the CAA annals as level 4 unless otherwise proven. Level 4 certificates expire after 4 years and my license was issued for 5 years and thus my level 4 certificate has expired.
In CAP804 Part 1, section 5.1 (transitional arrangements), quote:
UK licence holders who need to revalidate/renew a language proficiency endorsement
previously granted by the UK CAA may do so by:
a) i) Assessment by any of the methods set out in Paragraph 4.1. (i.e. Level 6
assessment by an examiner during a radio test, skill test, proficiency check, or
assessment of competence; assessment to Level 4, 5 or 6 at a language school
or at an ATO approved by the CAA for the purpose); or
ii) Assessment at Level 6 only with the holder of UK CAA-issued Examiner Certificate
in accordance with Appendix 2 to Part-FCL and the guidance published in the
Guidance to Examiners conducting Language Assessments (i.e. a face-to-face
aviation discussion not associated with a Skill test or proficiency check).

A UK Examiner Certificate is any holder of a valid RTF Examiner, FE, TRE, CRE, IRE, SFE
or FIE certificate issued by the UK CAA.

Examiners conducting an assessment of Language Proficiency not in association with
a Skill Test, Proficiency Check, Assessment of Competence or Flight Radio Practical
Test, in accordance with 5.1 a) ii) above, will complete Form SRG 1199, to confirm that
the candidate has demonstrated proficiency at Level 6. unquote

HOWEVER the guidance notes on the last page of SRG 1199 state:
General Guidance
Section 3 of this form should only be used when the assessment of ICAO Language Proficiency in English is undertaken during a flying or radio licence test with a CAA Flight Examiner or a CAA Authorised Flight Examiner. The examiner may only assess an individual native speaker as being at level 6. If the examiner is in any doubt as to the proficiency of the
individual in the use of the English language, no assessment result may be given.
Section 4 of this form is to be completed by an accredited English language school, and permits the assessment of the individual at level 4, 5 and 6.

So there appears to be no section of SRG 1199 that can be used by a A UK Examiner Certificate to comply with CAP 804.

Either CAP804 is incompatible with SRG 1199, or my English Language Proficiency is not quite as high as I thought.

Please help me understand!

PS I currently fly on a non-european license which is why I have not sorted this out sooner

To make life easier, if your an English native then ELP is 6 and valid for life. If its not then you require a test.

Your original ELP is Level 4 until you change it.

Ignore the Guidance Notes. Fill in an 1199 form, print it off, then get any UK CAA Examiner to asses you, and sign it, at part 3, to get Level 6.

If only all Civil Aviation Authorities were as practical.

I'm a native English speaker living and an English speaking country yet I need to do an exam in order to get any level of ELP on my licence. How stupid is that?

How? Any English native speaker automatically gets ELP without an exam.
When you get your license the examiner will be issue you it.

When I did my PPL skill test in Spain I got the ICAO Spanish level 6 as I am Spanish!

Not under the New Zealand CAA you don't. They think they're better than the rest of the world.

It is hard to measure the stupidness of all such language nonsense.