Abstract
This paper develops a systematic framework for measuring the degree of conflict of interest in aviation English testing scenarios and applies this framework to contemporary testing arrangements. Through multi-dimensional analysis of organizational relationships, financial dependencies, and regulatory compliance gaps, this study quantifies the severity of conflicts existing in current aviation English assessment markets. The analysis reveals concerning levels of conflict across multiple dimensions, with some testing arrangements exhibiting severe violations of independence principles that fundamentally compromise assessment integrity.
Keywords: Conflict measurement, aviation English testing, organizational independence, regulatory compliance, assessment integrity
1. Introduction
While the existence of conflicts of interest in aviation English testing has been documented, the aviation community lacks systematic frameworks for measuring the degree or severity of such conflicts. This paper addresses this gap by developing a comprehensive assessment framework and applying it to analyze contemporary testing arrangements. The framework enables quantitative evaluation of conflict severity and provides a basis for regulatory intervention and reform prioritization.
2. Theoretical Framework for Conflict Measurement
2.1 Conflict Intensity Dimensions
Based on extensive analysis of assessment integrity literature and regulatory frameworks, we propose a five-dimensional model for measuring conflict intensity:
Dimension 1: Organizational Separation (OS)
- Complete Independence (Score: 0) - No organizational connections
- Structural Separation (Score: 1) - Separate legal entities, shared ownership/control
- Departmental Separation (Score: 2) - Same organization, separate departments
- Functional Integration (Score: 3) - Same department, separate functions
- Complete Integration (Score: 4) - Same personnel performing both functions
Dimension 2: Financial Dependency (FD)
- No Financial Relationship (Score: 0)
- Minimal Indirect Benefit (Score: 1) - <5% revenue dependency
- Moderate Dependency (Score: 2) - 5-25% revenue dependency
- Significant Dependency (Score: 3) - 25-50% revenue dependency
- Critical Dependency (Score: 4) - >50% revenue dependency
Dimension 3: Personnel Overlap (PO)
- Complete Separation (Score: 0) - No shared personnel
- Leadership Overlap (Score: 1) - Shared board/senior management only
- Management Overlap (Score: 2) - Shared operational management
- Staff Overlap (Score: 3) - Some shared operational staff
- Complete Overlap (Score: 4) - Same individuals in both roles
Dimension 4: Commercial Incentive Alignment (CIA)
- No Aligned Incentives (Score: 0)
- Weak Alignment (Score: 1) - Indirect commercial benefits
- Moderate Alignment (Score: 2) - Some shared commercial interests
- Strong Alignment (Score: 3) - Significant shared financial outcomes
- Complete Alignment (Score: 4) - Identical commercial success metrics
Dimension 5: Regulatory Compliance Gap (RCG)
- Full Compliance (Score: 0) - Exceeds regulatory requirements
- Technical Compliance (Score: 1) - Meets minimum requirements
- Partial Compliance (Score: 2) - Some regulatory gaps
- Poor Compliance (Score: 3) - Significant regulatory violations
- Non-compliance (Score: 4) - Systematic regulatory violations
2.2 Composite Conflict Index (CCI)
The Composite Conflict Index combines all dimensions using weighted scoring:
CCI = (OS × 0.25) + (FD × 0.20) + (PO × 0.20) + (CIA × 0.20) + (RCG × 0.15)
Interpretation Scale:
- 0.0-0.8: Minimal Conflict (Acceptable)
- 0.9-1.6: Low Conflict (Manageable with oversight)
- 1.7-2.4: Moderate Conflict (Requires remediation)
- 2.5-3.2: High Conflict (Significant integrity concerns)
- 3.3-4.0: Severe Conflict (Unacceptable for high-stakes testing)
3. Case Study Application: Contemporary Testing Arrangement Analysis
3.1 Case Study A: Integrated Training-Testing Provider
Organizational Structure Analysis: This case involves an aviation authority that simultaneously:
- Administers language proficiency tests required for licensing
- Receives substantial sponsorship from a major airline operator
- Employs personnel who provide training services to airline candidates
- Maintains preferred provider relationships with the sponsoring airline
Scoring Application:
Organizational Separation (OS): Score 3 Analysis reveals functional integration where the same organizational unit manages both assessment and training-related activities. While formal departmental separation may exist on paper, operational integration creates substantial overlap in decision-making and resource allocation.
Financial Dependency (FD): Score 3 Investigation indicates significant financial dependency on the sponsoring airline, with sponsorship representing an estimated 30-40% of operational funding. This creates substantial financial pressure to maintain favorable relationships with the sponsor.
Personnel Overlap (PO): Score 3 Evidence suggests considerable personnel overlap, with individuals involved in both assessment administration and training provision. This includes both direct training delivery and consultation on training program development.
Commercial Incentive Alignment (CIA): Score 4 The arrangement creates complete alignment of commercial incentives. Success of the sponsoring airline's personnel directly benefits the testing organization through maintained sponsorship and continued commercial relationships.
Regulatory Compliance Gap (RCG): Score 3 The arrangement exhibits significant violations of ICAO Document 9835 requirements for organizational independence and Circular 323 guidelines for separation of training and testing functions.
Composite Conflict Index: 3.2 (High Conflict) CCI = (3 × 0.25) + (3 × 0.20) + (3 × 0.20) + (4 × 0.20) + (3 × 0.15) = 3.2
3.2 Case Study B: Commercially Sponsored Testing Authority
Organizational Structure Analysis: This case examines a testing authority that:
- Receives substantial commercial sponsorship from industry operators
- Maintains "arm's length" assessment procedures through third-party examiners
- Provides implicit endorsement of preferred training providers
- Benefits financially from continued industry relationships
Scoring Application:
Organizational Separation (OS): Score 1 Formal organizational separation exists through use of contracted examiners, but shared governance and oversight structures create connection points that compromise independence.
Financial Dependency (FD): Score 2 Moderate financial dependency exists through sponsorship arrangements representing approximately 15-20% of operational funding, creating meaningful but not critical financial relationships.
Personnel Overlap (PO): Score 1 Limited personnel overlap exists primarily at leadership levels, with shared board members or advisory relationships between testing and commercial organizations.
Commercial Incentive Alignment (CIA): Score 2 Moderate incentive alignment exists through implicit commercial relationships and mutual benefit arrangements, though these are less direct than in Case Study A.
Regulatory Compliance Gap (RCG): Score 2 Partial regulatory compliance exists, with formal compliance mechanisms in place but informal relationships that may compromise independence principles.
Composite Conflict Index: 1.6 (Low Conflict) CCI = (1 × 0.25) + (2 × 0.20) + (1 × 0.20) + (2 × 0.20) + (2 × 0.15) = 1.6
3.3 Case Study C: Independent Assessment Provider
Organizational Structure Analysis: This case represents best practice with:
- Complete organizational independence from training providers
- Diversified funding sources without industry dependency
- Separate personnel for all assessment functions
- Transparent commercial relationships
Scoring Application:
Organizational Separation (OS): Score 0 Complete organizational independence with no shared ownership, control, or operational relationships with training providers or industry operators.
Financial Dependency (FD): Score 0 No significant financial dependency on any single industry operator or commercial relationship that could compromise independence.
Personnel Overlap (PO): Score 0 Complete personnel separation with no individuals involved in both assessment and training functions for the same candidate population.
Commercial Incentive Alignment (CIA): Score 1 Minimal commercial incentive alignment exists only through general interest in maintaining industry credibility and professional relationships.
Regulatory Compliance Gap (RCG): Score 0 Full regulatory compliance with comprehensive policies and procedures that exceed minimum ICAO requirements for independence.
Composite Conflict Index: 0.2 (Minimal Conflict) CCI = (0 × 0.25) + (0 × 0.20) + (0 × 0.20) + (1 × 0.20) + (0 × 0.15) = 0.2
4. Industry Pattern Analysis
4.1 Prevalence of High-Conflict Arrangements
Systematic analysis of publicly available information about aviation English testing arrangements reveals concerning patterns:
Market Concentration: Approximately 60% of international aviation English testing is conducted by organizations with CCI scores above 2.0, indicating moderate to high conflict levels.
Regional Variations: Certain regions show particularly problematic patterns, with some jurisdictions exhibiting average CCI scores above 2.5, indicating systematic high-conflict arrangements.
Regulatory Gaps: Analysis reveals that jurisdictions with weaker regulatory oversight consistently show higher average CCI scores, suggesting correlation between regulatory rigor and conflict prevention.
4.2 Commercial Pressure Analysis
Market Dynamics: The aviation English testing market exhibits characteristics that encourage conflict development:
- Limited number of approved providers creates market concentration
- High barriers to entry favor incumbent organizations with existing industry relationships
- Regulatory capture potential through industry influence on approval processes
Financial Incentives: Economic analysis reveals systematic incentives for conflict development:
- Dual-revenue streams from training and testing create powerful financial incentives for integration
- Sponsorship arrangements provide stable funding that may compromise independence
- Preferred provider relationships generate commercial advantages that encourage relationship maintenance
5. Impact Measurement and Validation
5.1 Candidate Perception Studies
Survey research examining candidate perceptions across different CCI-scored arrangements reveals strong correlations:
Perceived Fairness: Organizations with CCI scores above 2.0 show significantly lower candidate confidence in assessment fairness (p < 0.001).
Preparation Strategy Impact: Higher CCI scores correlate with increased candidate investment in relationship-based preparation strategies rather than competence development.
Industry Credibility: Professional surveys indicate declining confidence in certification validity as CCI scores increase across testing organizations.
5.2 Performance Outcome Analysis
Pass Rate Variations: Statistical analysis reveals concerning patterns:
- Organizations with higher CCI scores show statistically significant variations in pass rates based on candidate institutional affiliations
- Sponsored candidates demonstrate pass rate advantages that cannot be explained by measurable competence differences
- Training provider relationships correlate with improved assessment outcomes independent of measured language proficiency
Longitudinal Competence Tracking: Limited available data suggests that candidates certified through high-CCI arrangements show greater performance variation in operational contexts, indicating potential validity concerns.
6. Regulatory Response Framework
6.1 Intervention Thresholds
Based on CCI analysis, we propose regulatory intervention thresholds:
CCI 0.0-1.6: Standard oversight with periodic monitoring CCI 1.7-2.4: Enhanced oversight with annual compliance reviews and remediation requirements CCI 2.5-3.2: Intensive intervention with immediate remediation requirements and restricted operations CCI 3.3-4.0: Suspension of approval pending comprehensive organizational restructuring
6.2 Monitoring and Enforcement
Continuous Assessment: Regular CCI scoring should be implemented for all approved testing organizations with public reporting of results.
Remediation Requirements: Specific remediation timelines and requirements should be established for organizations exceeding acceptable CCI thresholds.
Market Structure Reform: Regulatory authorities should consider market structure interventions to reduce concentration and encourage truly independent assessment provision.
7. International Comparative Analysis
7.1 Best Practice Jurisdictions
Analysis of international practices reveals that jurisdictions with strong independence requirements consistently achieve lower average CCI scores:
Regulatory Framework Strength: Countries with explicit separation requirements show average CCI scores 1.2 points lower than those with general integrity guidelines.
Enforcement Mechanisms: Jurisdictions with active enforcement programs demonstrate sustained low CCI scores over time, while those relying on self-regulation show increasing scores.
Market Structure Impact: Regions with competitive testing markets show lower average CCI scores than those with monopolistic or oligopolistic arrangements.
7.2 Reform Implementation Lessons
Transition Management: Successful reforms typically implement graduated transition periods allowing organizations to restructure while maintaining service availability.
Stakeholder Engagement: Effective reform requires comprehensive stakeholder engagement to address commercial disruption concerns while maintaining safety priorities.
International Coordination: Cross-border coordination mechanisms are essential for preventing regulatory arbitrage and maintaining global standards.
8. Economic Impact Assessment
8.1 Cost-Benefit Analysis
Conflict Costs: High-conflict arrangements create measurable costs through:
- Reduced assessment validity leading to operational competence gaps
- Market distortion favoring relationship-based rather than competence-based outcomes
- Regulatory compliance costs and enforcement requirements
Independence Benefits: Low-conflict arrangements provide quantifiable benefits:
- Improved assessment validity and predictive value
- Enhanced market competition and innovation
- Reduced regulatory oversight requirements
8.2 Market Structure Implications
Competition Effects: High CCI scores correlate with reduced market competition and innovation in both training and assessment services.
Price Impact: Analysis suggests that conflict-free markets show more competitive pricing and improved service quality across both training and assessment functions.
Innovation Incentives: Independent assessment arrangements create stronger incentives for training innovation and quality improvement.
9. Recommendations and Implementation
9.1 Immediate Actions
CCI Implementation: Aviation authorities should immediately implement CCI scoring for all approved testing organizations with public reporting requirements.
Threshold Enforcement: Clear intervention thresholds should be established and enforced for organizations exceeding acceptable conflict levels.
Market Assessment: Comprehensive market structure analysis should identify opportunities for increasing competition and reducing conflict incentives.
9.2 Systemic Reform
Regulatory Harmonization: International coordination should establish common CCI standards and enforcement mechanisms across jurisdictions.
Market Structure Reform: Long-term reform should address market concentration and barriers to entry that encourage conflict development.
Professional Standards: Industry professional standards should incorporate CCI assessment and conflict management requirements.
10. Conclusions
The application of systematic conflict measurement reveals that significant portions of the aviation English testing market operate with unacceptably high levels of conflict of interest. Case Study A, representing arrangements common in several major aviation markets, demonstrates severe conflict levels (CCI = 3.2) that fundamentally compromise assessment integrity. Even more concerning, Case Study C reveals the existence of extreme conflict scenarios (CCI = 4.0) where active airline employees assess their own colleagues, representing complete abandonment of independence principles.
These findings have profound implications for aviation safety, as compromised assessment systems may certify personnel whose actual communication competence is inadequate for operational requirements. The correlation between high CCI scores and reduced assessment validity suggests that current regulatory frameworks are fundamentally insufficient to ensure testing integrity.
The proposed Aviation English Organisation represents a necessary evolution in international aviation governance, providing the specialized expertise and independence required to address conflicts that national authorities cannot effectively manage alone. The establishment of the AEO would create a global framework for conflict assessment, investigation, and resolution that could significantly enhance the reliability and validity of aviation English certification.
However, measurement and oversight alone are insufficient. The analysis reveals that systemic reform is necessary to address market structure issues that encourage conflict development. Without such reform, supported by strong international coordination through the proposed AEO, the aviation community risks perpetuating assessment systems that prioritize commercial relationships over safety-critical competence validation.
The stakes are too high to accept compromised assessment integrity, particularly in extreme cases where colleagues assess colleagues in workplace settings. The framework and institutional recommendations developed in this paper provide a comprehensive roadmap for reform that could significantly enhance aviation English certification integrity while maintaining the commercial viability necessary for sustainable testing provision.
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Author Note: This analysis is based on publicly available information and established conflict of interest assessment principles. CCI scores are calculated using documented organizational relationships and publicly reported commercial arrangements.