I spoke this week to a newly minted CFIG at my home club's board
meeting. He is about as steeped as you can get on analyzing the tea
leaves for the latest and greatest FAA "leanings".

We agreed that there are several stops along the path of who can spot
and resolve issues with non-English proficient students.

1) FSDO - When the candidate applies for a student certificate. If
accepted by the FSDO, this implies a "English proficiency" blessing
from the FAA. At least in some limited way. Right? Hmmmmm.
2) CFIG - During initial training towards solo.
3) FAA Exam Site - During written exam. This would be a clear
stopping point if they fail due to lack of English (written)
proficiency. Of course reading a foreign language is easier than
either speaking, verbally understanding or writing a foreign language.
4) DPE - During a check ride (oral and practical).

The point here is that when my club accepts a student, we are not
incurring direct responsibility to determine proficiency or to "turn
in" someone who is not. We do have some "moral" responsibility to not
lead someone down a path that they will clearly fail.

That being said, to cover our bases, we have decided to update our
application process to ask potential new members if they are "English
Proficient", and if they are US citizens, along with the words, "As
required by the Federal Aviation Administration."

- John