PRB reports for the European Commission - Eurocontrol 1 - PRB advice to the Commission in the setting of Union-wide performance targets for RP2 Appendix B: Summary of responses to

- 1 -

PRB advice to the Commission in the

setting of Union-wide performance

targets for RP2

Appendix B: Summary of responses to the consultation

Edition date: 27/09/2013

COPYRIGHT

NOTICE AND

DISCLAIMER

© European Union, 2013

This report has been prepared for the European Commission by the Performance Review

Body of the Single European Sky, in its capacity as an advisory body to the European

Commission.

Reproduction is authorised provided the source is acknowledged. However, neither the

European Commission, nor any person acting on its behalf, may be held responsible for the

use which may be made of the information contained in this publication, or for any errors

which may appear, despite careful preparation and checking.

- 1 -

Stakeholder consultation on Union-wide

performance targets for RP2

Comprehensive summary of responses to the

consultation

Edition 00.06

Edition date: 09/08/2013

COPYRIGHT

NOTICE AND

DISCLAIMER

© European Union, 2013

This report has been prepared for the European Commission by the Performance Review

Body of the Single European Sky, in its capacity as an advisory body to the European

Commission.

Reproduction is authorised provided the source is acknowledged. However, neither the

European Commission, nor any person acting on its behalf, may be held responsible for the

use which may be made of the information contained in this publication, or for any errors

which may appear, despite careful preparation and checking.

Stakeholder consultation on Union-wide performance targets for RP2. Part A: Summary of responses

- i -

Table of Contents

1 INTRODUCTION AND CONTEXT ........................................................................................................... 4

1.1 THIS DOCUMENT.................................................................................................................................... 4

1.2 SCOPE OF CONSULTATION .................................................................................................................... 4

1.3 COMMENTS RECEIVED .......................................................................................................................... 4 1.4 STATISTICAL ANALYSIS ......................................................................................................................... 6 1.5 ORGANISATION OF THE REPORT ........................................................................................................... 6

2 SAFETY ........................................................................................................................................................ 7

2.1 PRB INITIAL PROPOSAL ........................................................................................................................ 7

2.2 STAKEHOLDERS ANSWERS TO CONSULTATION QUESTIONS ................................................................. 8

2.3 STAKEHOLDERS’ COMMENTS ON APPROACH...................................................................................... 11 2.4 STAKEHOLDERS’ COMMENTS ON EOSM TARGET............................................................................... 11

2.5 STAKEHOLDERS’ COMMENTS ON RAT TARGET .................................................................................. 12 2.6 ADDITIONAL COMMENTS NOT DIRECTLY RELATED TO RP2 TARGET SETTING.................................... 14

3 ENVIRONMENT ........................................................................................................................................ 15

3.1 PRB INITIAL PROPOSAL ...................................................................................................................... 15 3.2 STAKEHOLDERS ANSWERS TO CONSULTATION QUESTIONS ............................................................... 15

3.3 STAKEHOLDERS’ COMMENTS ON METHODOLOGY .............................................................................. 18

3.4 REQUESTS FOR DATA ......................................................................................................................... 18

3.5 STAKEHOLDER COMMENTS ON KEP TARGET .................................................................................... 19 3.6 STAKEHOLDER COMMENTS ON KEA TARGET .................................................................................... 20

3.7 ADDITIONAL COMMENTS NOT DIRECTLY RELATED TO RP2 TARGET SETTING ................................... 20

4 CAPACITY ................................................................................................................................................. 22

4.1 PRB INITIAL PROPOSAL ...................................................................................................................... 22 4.2 STAKEHOLDERS ANSWERS TO CONSULTATION QUESTIONS ............................................................... 22

4.3 STAKEHOLDERS’ COMMENTS ON APPROACH...................................................................................... 24

4.4 REQUESTS FOR DATA.......................................................................................................................... 25 4.5 STAKEHOLDERS’ COMMENTS ON TARGET RANGE .............................................................................. 25

4.6 ADDITIONAL COMMENTS NOT DIRECTLY RELATED TO RP2 TARGET SETTING.................................... 26

5 COST EFFICIENCY.................................................................................................................................. 27

5.2 STAKEHOLDERS ANSWERS TO CONSULTATION QUESTIONS ............................................................... 27

5.3 STAKEHOLDERS’ COMMENTS ON TECHNICAL EVIDENCE .................................................................... 40

5.4 STAKEHOLDERS’ COMMENTS ON HISTORICAL TRENDS ...................................................................... 40 5.5 STAKEHOLDERS’ COMMENTS ON COOPERATION BETWEEN ANSPS.................................................. 41 5.6 STAKEHOLDERS’ COMMENTS ON COST STRUCTURE OF ANS PROVISION ......................................... 42

5.7 STAKEHOLDERS’ COMMENTS ON CAPEX ENVELOPE FOR RP2 ........................................................ 43 5.8 STAKEHOLDERS’ COMMENTS ON FOCUS ON TOTAL COSTS INCURRED .............................................. 43

5.9 STAKEHOLDERS’ COMMENTS ON PROPOSED RANGE ......................................................................... 44 5.10 STAKEHOLDERS’ COMMENTS ON TERMINAL ANS COST-EFFICIENCY ................................................ 45

6 GENERAL COMMENTS .......................................................................................................................... 47

6.1 AIRSPACE USERS ............................................................................................................................... 47 6.2 ANSPS ................................................................................................................................................ 47

6.3 NATIONAL SUPERVISORY AUTHORITIES AND MEMBER STATES ........................................................ 47

6.4 PROFESSIONAL STAFF ........................................................................................................................ 47


Tables

TABLE 1 - SUMMARY OF RESPONDENTS BY STAKEHOLDER TYPE ........................................................................ 5 TABLE 2 - PRB CONSULTATION PROPOSAL – SAFETY......................................................................................... 7

TABLE 3 - SUMMARY OF RESPONSES FOR Q2.1 PER STAKEHOLDER TYPE ......................................................... 8

TABLE 4 - SUMMARY OF RESPONSES FOR Q2.4 PER STAKEHOLDER TYPE ......................................................... 9 TABLE 5 - SUMMARY OF RESPONSES FOR Q2.7 PER STAKEHOLDER TYPE ....................................................... 10 TABLE 6 - PRB CONSULTATION PROPOSAL – ENVIRONMENT ............................................................................ 15

TABLE 7 - SUMMARY OF RESPONSES FOR Q3.1 PER STAKEHOLDER TYPE ....................................................... 15 TABLE 8 - SUMMARY OF RESPONSES FOR Q3.4 PER STAKEHOLDER TYPE ....................................................... 16

TABLE 9 - SUMMARY OF RESPONSES FOR Q3.7 PER STAKEHOLDER TYPE ....................................................... 17 TABLE 10 - PRB CONSULTATION PROPOSAL – CAPACITY ................................................................................. 22

TABLE 11 - SUMMARY OF RESPONSES FOR Q4.1 PER STAKEHOLDER TYPE ..................................................... 22

TABLE 12 - SUMMARY OF RESPONSES FOR Q4.4 PER STAKEHOLDER TYPE ..................................................... 23 TABLE 13 - PRB CONSULTATION PROPOSAL – COST EFFICIENCY .................................................................... 27

TABLE 14 - SUMMARY OF RESPONSES FOR Q5.1A PER STAKEHOLDER TYPE ................................................... 28

TABLE 15 - SUMMARY OF RESPONSES FOR Q5.1B PER STAKEHOLDER TYPE ................................................... 29 TABLE 16 - SUMMARY OF RESPONSES FOR Q5.1C PER STAKEHOLDER TYPE ................................................... 30

TABLE 17 - SUMMARY OF RESPONSES FOR Q5.1D PER STAKEHOLDER TYPE ................................................... 31

TABLE 18 - SUMMARY OF RESPONSES FOR Q5.1E PER STAKEHOLDER TYPE ................................................... 32

TABLE 19 - SUMMARY OF RESPONSES FOR Q5.3 PER STAKEHOLDER TYPE ..................................................... 33 TABLE 20 - SUMMARY OF RESPONSES FOR Q5.5 PER STAKEHOLDER TYPE ..................................................... 34

TABLE 21 - SUMMARY OF RESPONSES FOR Q5.7 PER STAKEHOLDER TYPE ..................................................... 35

TABLE 22 - SUMMARY OF RESPONSES FOR Q5.10 PER STAKEHOLDER TYPE ................................................... 36

TABLE 23 - SUMMARY OF RESPONSES FOR Q5.12 PER STAKEHOLDER TYPE ................................................... 37 TABLE 24 - SUMMARY OF RESPONSES FOR Q5.14 PER STAKEHOLDER TYPE ................................................... 38

TABLE 25 - SUMMARY OF RESPONSES FOR Q5.17 PER STAKEHOLDER TYPE ................................................... 39


Figures

FIGURE 1: DISTRIBUTION OF RESPONDENTS ......................................................................................................... 4 FIGURE 2 – STAKEHOLDERS ANSWERS TO Q2.1 .................................................................................................. 8

FIGURE 3 – STAKEHOLDERS ANSWERS TO Q2.4 .................................................................................................. 9

FIGURE 4 – STAKEHOLDERS ANSWERS TO Q2.7 ................................................................................................ 10 FIGURE 5 – STAKEHOLDERS ANSWERS TO Q3.1 ................................................................................................ 15 FIGURE 6 – STAKEHOLDERS ANSWERS TO Q3.4 ................................................................................................ 16

FIGURE 7 – STAKEHOLDERS ANSWERS TO Q3.7 ................................................................................................ 17 FIGURE 8 – STAKEHOLDERS ANSWERS TO Q4.1 ................................................................................................ 22

FIGURE 9 – STAKEHOLDERS ANSWERS TO Q4.4 ................................................................................................ 23 FIGURE 10 – STAKEHOLDERS ANSWERS TO Q5.1A ........................................................................................... 27

FIGURE 11 – STAKEHOLDERS ANSWERS TO Q5.1B ........................................................................................... 29

FIGURE 12 – STAKEHOLDERS ANSWERS TO Q5.1C ........................................................................................... 30 FIGURE 13 – STAKEHOLDERS ANSWERS TO Q5.1D ........................................................................................... 31

FIGURE 14 – STAKEHOLDERS ANSWERS TO Q5.1E ........................................................................................... 32

FIGURE 15 – STAKEHOLDERS ANSWERS TO Q5.3 ............................................................................................. 33 FIGURE 16 – STAKEHOLDERS ANSWERS TO Q5.5 ............................................................................................. 34

FIGURE 17 – STAKEHOLDERS ANSWERS TO Q5.7 ............................................................................................. 35

FIGURE 18 – STAKEHOLDERS ANSWERS TO Q5.10 ........................................................................................... 36

FIGURE 19 – STAKEHOLDERS ANSWERS TO Q5.12 ........................................................................................... 37 FIGURE 20 – STAKEHOLDERS ANSWERS TO Q5.14 ........................................................................................... 38

FIGURE 21 – STAKEHOLDERS ANSWERS TO Q5.17 ........................................................................................... 39


4

1 Introduction and context

1.1 This document

1.1.1 By the end of 2013, the European Commission is required to adopt Union-wide Performance

targets for European Air Navigation Services (ANS) for the second reference period (RP2

2015-2019) in accordance with the Single European Sky (SES) legislation, i.e. the revised

performance [Ref. i] and charging [Ref. ii] Regulations, which were adopted by the

Commission on 3 May 2013.

1.1.2 The first reference period (RP1: 2012-2014) is currently underway.

1.1.3 The objective of the report is to summarise responses received during the public consultation

on the Union-wide targets for the second reference period which lasted from 17 May to 3 July

2013.

1.2 Scope of consultation

1.2.1 To support provision of stakeholder comments the public consultation document [Ref. iii] contained 16 questions covering safety, environment, capacity, cost efficiency and EU-wide

targets and alert thresholds. The consultation was undertaken through the European

Commission’s ‘Your Voice’ web based questionnaire. This document provides an analysis of

the comments received and the PRB responses to the comments. This analysis has informed

the development of the PRB’s final recommendations to the Commission.

1.3 Comments received

1.3.1 By 3 July 2013, the closing date, comments were received from 63 organisations and

individuals representing all aspects of the air transport industry. A full list of responders is

provided in Table 1. The responses cover 24 states and 11 European or multinational

organisations. In terms of the States covered by the performance scheme, at least one response

was received from each State except: Malta, Cyprus, Lithuania, Slovakia, Croatia and Iceland.

The magnitude and quality of responses received by all stakeholders provides a clear

indication of the importance of the Union-wide targets.

1.3.2 In order to consider the comments received, respondents have been characterised by their

industry sector. Figure 1 provides a breakdown of responses by stakeholder type.

Figure 1: Distribution of respondents

4

5 1

16

16

4

11

11

1

3

Airport operator

Airline

Military

ANSP

NSA

Ministry

FAB - ANSP side

FAB - NSA side

Professional StaffAssociationsInternational organisation


5

Stakeholder type Total Names of respondents

Airport operator 4 ADP, Dusseldorf Airport, Heathrow Airport,

Swedavia

Airline 5 IATA and AEA, International Air Carrier

Association, LOT, Ryanair, ERA

Military 1 Spanish Air Force

Air Navigation Service

Provider (ANSP)

16 AENA, ANS CR, Austro Control, BULATSA,

CANSO, EANS, ENAV, EUMETNET,

HungaroControl, IAA (ANSP), LFV, LGS,

NATS, Nav Portugal, Polish ANSA, ROMATSA

National Supervisory

Authority (NSA)

16 AESA, Belgian CAA + Belgian NSA,

Bundesaufsichtsamt für Flugsicherung, CAA

Czech Republic, CAA-Norway, Civil Aviation

Authority of Italy, DGCAA Bulgaria, Estonian

CAA, Finnish NSA, Hellenic ANSA, IAA (NSA),

Polish CAA, Portuguese CAA, Romanian CAA,

The Danish Transport Authority, UK national

authorities

Ministry 4 Federal Office of Civil Aviation Switzerland,

French State,

Ministry of Infrastructure and Environment

(Netherlands),

Ministry of Transport (Czech Republic)

FAB - ANSP side 1 FABEC ANSPs

FAB - NSA side 1 FABEC Financial & Performance Committee

Professional Staff

Associations

11 ACV TRANSCOM, European workers Transport

Federation (ETF), Finnish Air Traffic Controllers

association, GATCO, IFATCA, IFATSEA,

Prospect Trade Union and PCS Trade Union,

SINCTA, SwissATCA – Swiss Air Traffic

Controllers’ Association, USCA - Air Traffic

Control Officers Spanish Trade Union, ZZKRL

(Polish ATC Union)

International organisation 1 EUROCONTROL

Other 3 Citizens

Table 1 - Summary of respondents by stakeholder type


6

1.3.3 The following responses represented multiple organisations:

Airlines: IATA and AEA, IACA and ERA.

ANSPs: CANSO, EUMETNET and FABEC ANSPs (no individual responses).

National Authorities: Belgian CAA and NSA (under NSA), UK Authorities (CAA, DfT

and MoD) (under NSA), FABEC NSAs (additional individual responses included).

1.4 Statistical analysis

1.4.1 Most of the questions asked had a range of predefined answers (for example Yes, No, Other)

and a free form comment. In order to analyse the comments, statistics are presented on the

level of each fixed response for each stakeholder group.

1.4.2 The PRB has considered the range of responses from each stakeholder group in order to

determine the nature of the feedback received. In particular the PRB note that the written

comments often indicate that stakeholders would have preferred an additional option. The

statistics are only presented to help readers understand the range of responses.

1.5 Organisation of the report

1.5.1 The remainder of this report contains a reminder of PRB’s initial proposals in each area, a

summary of the comments received and the PRB responses using the same structure as the

consultation document. The remainder of this report is organised in 5 chapters:

Chapter 2 Safety, covering questions 2.1 to 2.9

Chapter 3 Environment, covering questions 3.1 to 3.9

Chapter 4 Capacity, covering questions 4.1 to 4.6

Chapter 5 Cost Efficiency, covering questions 5.1 to 5.19

Chapter 6 General Comments, covering questions 6.1 and 6.2

1.5.2 Similar comments received by the stakeholders on proposed targets or methodology which the

PRB consider necessary to highlight because either are of a particular importance or because

PRB is considering replying with detailed argumentation in the final report, are categorised in

homogeneous areas/themes and handled together. They are identified by a reference number

with some explanatory text according to the model:

Identifier (e.g. ENV 01) Description

1.5.3 This report should be read in conjunction with:

PRB consultation document titled “Union-wide targets for the second reference period

of the Single European Sky Performance Scheme” [Ref. iii], published on 9 May 2013;

PRB final report to the Commission titled “PRB advice to the Commission in the setting

of Union-wide performance targets for RP2” to be published in September 2013.

1.5.4 This report has been prepared by the Performance Review Body (PRB) of the SES.

EUROCONTROL, acting through its Performance Review Commission (PRC) supported by

the Performance Review Unit (PRU) which has been designated [Ref. iv] as the PRB to assist

the Commission in the implementation of the performance Scheme until mid-2015.


7

2 Safety

2.1 PRB initial proposal

2.1.1 The PRB proposed range for the Safety KPI target as contained in the Consultation Document

are summarised in Table 2.

EoSM: Effectiveness of safety management on States/NSAs

Projected value (2014) Target (2019)

Most but not all NSAs will have achieved at least

EoSM Level 3 (C) in all MOs.

All NSAs have achieved at least EoSM

Level 3 (C) in all MOs.

EoSM: Effectiveness of safety management on Service Providers

Projected value (2014) Target (2019)

All ANSPs will have achieved EoSM Level 3 (C) in all

MOs.

All ANSPs have achieved EoSM Level 4 (D)

in all MOs.

RAT: Application of severity classification scheme

Value (2009)

Projected value (2014)

Target (2019)

Not applicable

RP1 Performance Plans included commitments on the

use of RAT methodology. It is therefore expected, that

by the end of RP1, all ANSPs should be using the RAT

methodology.

It is not expected that all other investigation entities

(e.g. CAAs/NSAs) should be using the RAT

methodology by 2015. Their degree of experience is

generally lower than ANSPs.

By the end of RP2, all ANSPs should be

reporting ATM Ground using the RAT

methodology for severity classification for

all reported occurrences (i.e. 100%).

By the end of RP2 all NSAs/States should be

reporting ATM Overall using the RAT

methodology for severity classification for

almost all reported occurrences (i.e. 99%).

Table 2 - PRB consultation proposal – Safety


8

2.2 Stakeholders answers to consultation questions

Q2.1 Approach and methodology

To what extent do you agree that the methodology and evidence provided in the PRB

consultation document supports the proposed performance targets in the key performance

area of safety?

A. Fully agree

B. Mostly agree

C. Agree to some extent

D. Not at all

E. No opinion

Figure 2 – Stakeholders answers to Q2.1

2.2.1 Table 3 below indicates the answers to the question 2.1 broken down as provided by the

different types of stakeholders

Type / answer A B C D E Total

Airport operator 2 1 1 4

Airline 1 2 2 5

Military 1 1

ANSP 1 10 2 1 2 16

NSA 2 8 4 2 16

Ministry 2 1 1 4

FAB – ANSP side 1 1

FAB – NSA side 1 1

Professional Staff Association 2 6 2 1 11

International Organisation 1 1

Other 1 1 1 3

Total 6 27 18 4 8 63

Table 3 - Summary of responses for Q2.1 per stakeholder type

9%

43%29%

6%

13%A

B

C

D

E


9

Q2.4: Effectiveness of Safety Management (EoSM)

The PRB proposes the following Union-wide target for RP2:

all NSAs achieve at least EoSM Level 3 in all Management Objectives (MOs) and

all ANSPs achieve EoSM Level 4 in all Management Objectives (MOs).

Do you agree that the proposed target for Effectiveness of Safety Management is both

sufficiently challenging and achievable by the end of 2019?

A. Not acceptable because too

ambitious

B. Acceptable but very challenging

C. Acceptable and fully supported

D. Acceptable but could be more

challenging

E. Not acceptable because not

ambitious enough

F. No opinion




Type / answer A B C D E F Total


Airline 1 2 2 5

Military 1 1

ANSP 1 13 1 1 16

NSA 1 10 4 1 16

Ministry 1 2 1 4





Other 1 1 1 3

Total 5 30 13 3 4 8 63


8%

47%21%

5%6%

13% A

B

C

D

E

F


10

Q2.7: Application of Risk Analysis Tool (RAT) methodology for Risk Severity Classification

The PRB proposes the following Union-wide target for RP2:

all ANSPs report ATM Ground score using the RAT methodology for severity

classification for all reported occurrences (i.e. 100%) and

all NSAs/States report ATM Overall score using the RAT methodology for severity

classification for almost all reported occurrences (i.e. 99%).

Do you agree that the proposed target for the application of the RAT methodology for risk

severity classification is both sufficiently challenging and achievable by the end of 2019?


ambitious




challenging


ambitious enough

F. No opinion






Airline 1 2 2 5

Military 1 1

ANSP 3 7 3 1 1 1 16

NSA 8 6 1 1 16

Ministry 3 1 4



Professional Staff Association 6 1 4 11


Other 1 1 1 3

Total 15 16 15 4 5 8 63


24%

25%24%

6%

8%

13% A

B

C

D

E

F


11

2.3 Stakeholders’ comments on approach

2.3.1 Stakeholders recognize the inclusion of EU-wide safety targets in the performance scheme for

RP2 as major step forward.

2.3.2 A few stakeholders expressed a need for safety and risk assessment when setting EU-wide

targets.

Evidence in the PRB Document not supported by safety/risk impact assessment.

[ROMATSA];

This includes identification of interdependency between safety and the other targets

notably cost-efficiency [IFATSEA, Finish ATC Association, Prospect, USCA,

HungaroControl]. Stakeholders referred to the output of the 3rd

EASp summit

[Romanian CAA];

IFATSEA feel EASA should have a role in monitoring operational safety performance

at the European Level;

The approach needs to consider link to traffic growth [IACA].

2.3.3 Stakeholders felt that further guidance material is required to ensure harmonised approach

across Europe [French State, FABEC NSA, EANS] and EASA should develop the guidance

material [French State] using the CANSO & EUROCONTROL explanatory document.

2.3.4 Four stakeholders are concerned about the formulation of the target and how it relates to the

organisation and FAB level:

PRB should avoid setting targets at individual ANSP and NSA level [AENA, AESA];

Aggregation at FAB level may skew level achieved [UK Authorities, Irish NSA].

2.3.5 Only four (4) replies indicated no agreement; this included Nav Portugal, who indicated that

the lack of historical data means the evidence is not sufficiently robust to set targets, and

professional staff associations (IFATCA and GATCO) who are concerned about the lack State

commitment.

2.4 Stakeholders’ comments on EoSM target

2.4.1 Most stakeholders consider proposed EoSM target ambitious but achievable. ANSPs suggest

that a more granular approach to target setting for EoSM might be required. Some are

concerned with potential costs of requiring all ANSPs to move to EoSM Level 4 (D).

Proposed EoSM target is acceptable and fully supported

2.4.2 Thirteen (13) stakeholders consider proposed target acceptable and fully supported

[EUROCONTROL, Finish Transport Safety Agency, IATA and AEA, ADP: Aéroports de

Paris, Estonian Civil Aviation Administration, Prospect Trade Union, SwissATCA, ENAC,

ETF, Swedavia, CAA Norway, LOT, LGS).

2.4.3 Three (3) of these stakeholders raised concerns over self-assessment [Finish NSA, CAA

Norway, and Estonia NSA].

2.4.4 EUROCONTROL raised concerns on how the extra investment would be achieved.

Proposed EoSM target is acceptable but could be more challenging

2.4.5 Three (3) staff associations state that proposed EoSM target is acceptable but could be more

challenging for the following reasons:

They believe that NSA should also be requested to comply with the same target (Level

4), considering their role in the safety chain and regulation. It doesn't make sense to be

less demanding with NSA than with ANSP [SINCTA];

EoSM indicator may be too general to address real-life processes behind constructing

safe operations on day-to-day basis [Polish Air Traffic Controller’s Union].


12

Proposed EoSM target is acceptable but very challenging

2.4.6 Thirteen (13) responses indicated that the EoSM target is acceptable but very challenging this

included the majority of NSAs and ANSPs.

EoSM 01 Stakeholders are concerned that the target formulation for the EoSM target is

insufficiently granular [AESA, PANSA, AENA, French State, ENAV, FABEC ANSPs,

UK Authorities, LFV, CANSO, Nav Portugal, IAA].

2.4.7 Specific proposals are:

Establish a minimum EoSM score and “together with a modulation scheme that clearly

reflects the efforts made by the agents and measures the progress achieved” [AESA];

Require organisation to improve by a percentage rather than achieve a particular level

[PANSA];

CANSO proposes that both the level and percentage score should be applied. Two

options were suggested:

A compromise could be Level 3/C in EoSM with an overall achievement score of

75 % (80% proposed by the FABEC ANSPs);

Another alternative compromise could be that the target be on only those

objectives which have a close relation to IR 1035/2011, level 4 (D) (“managing

and measuring”). Concentrating on those objectives would ensure focusing on

areas where a higher maturity level is really desired to ensure an effective

management of safety (= managing and measuring level) and going beyond pure

compliance (= implementing level).

2.4.8 The CANSO approach is supported by AENA, ENAV, FABEC ANSPs, LFV, Nav Portugal,

and IAA.

Proposed EoSM target is not acceptable because too ambitious

EoSM 02 Four (4) stakeholders are concerned that the proposed EoSM target is too challenging,

and that the PRB may have underestimated the significant cost and amount of work

required to move from Level C (or below) to Level D [CANSO, AENA, MoT Czech

Republic, NATS].

2.4.9 The following reasons were provided:

The PRB may have underestimated the significant cost and amount of work required to

move from Level 3 (C or below) to Level 4 (D), not only in the production of more

formal processes, but in embedding these processes within the organisation [CANSO,

AENA, MoT Czech Republic];

Level 4 (D) goes beyond the current regulatory requirements [NATS]. NATS provides

evidence that moving to level 4 would cost them €1million by the end of RP2 and that

there current level (high end of Level 3) is supported by customer feedback.

Proposed EoSM target is not acceptable because not ambitious enough

2.4.10 Four (4) replies, all from professional staff associations, indicated that the proposed target is

not ambitious enough. The staff associations feel that strong safety targets are an important

counter balance to cost efficiency targets.

2.5 Stakeholders’ comments on RAT target

2.5.1 Stakeholders see the proposed RAT target as challenging for NSAs, however acceptable for

ANSPs. NSAs do not feel that they can achieve a high level of RAT application in RP2. This

is due to lack of data and resources. Most stakeholders however support the ANSP target

albeit with reservations on the approach to ATM specific events.


13

Proposed RAT target is acceptable and fully supported

2.5.2 Fifteen (15) stakeholders consider proposed target acceptable and fully supported [ZZKRL

(Polish ATC Union), SINCTA, ADP: Aéroports de Paris, EUROCONTROL, NATS, Finnish

Air Traffic Controllers association, Prospect Trade Union and Public and Commercial

Services (PCS) Trade Union, UK, SwissATCA, ETF, LFV, Swedavia, Polish Civil Aviation

Authority, LOT, LGS].

2.5.3 LFV supports the target even though some organisations will find the target very challenging

if (1) they do not have a strong reporting culture and (2) they do not have the embedded

automated systems to enable easy reporting and analysis of data.

2.5.4 NATS supports the transition to the RAT methodology across Europe.

2.5.5 Whilst supporting the propose target, three (3) Staff associations expressed concern that the

current low use of RAT suggests that safety is not a sufficient priority [ETF, SINCTA,

GATCO].

Proposed RAT target is acceptable but could be more challenging

2.5.6 Four (4) stakeholders state that proposed RAT target is acceptable but could be more

challenging [NAV Portugal, IATA and AEA, ERA, ACV TRANSCOM / CSC TRANSCOM].

Proposed RAT target is acceptable but very challenging

2.5.7 Sixteen (16) responses indicated that the RAT target is acceptable but very challenging

[Dusseldorf Airport, Estonian CAA, PANSA, AENA, Hellenic ANSA, ENAV, FABEC

ANSPs, CAA-Norway, CANSO, Finnish NSA, ANS CR, HungaroControl, IAA (NSA) , IAA

(ANSP) and Portuguese CAA].

2.5.8 Many stakeholders feel that it is a challenge to ensure harmonised classification of ATM

Special Events [ENAV, FABEC ANSPs, LFV, CAA Norway, CANSO, Finish NSA,

EUROCONTROL]. IFATSEA recommend additional guidance material.

2.5.9 States do not have the systems in place to measure Overall ATM Score [LFV, CANSO] and

ANSPS should only report Ground ATM Score [ROAMTSA, BULATSA].

2.5.10 RAT does and should not apply to all events [ANC CS, IAA].

Proposed RAT Target is not acceptable because too ambitious

RAT 01 Fifteen (15) stakeholders felt that the RAT target was too ambitious for the NSAs [CAA

Czech Republic, AESA, Austro Control, ROMATSA, Romanian CAA, Belgian CAA +

Belgian NSA, French State, DGCAA Bulgaria, BULATSA, Ministry of Transport, Czech

Republic, Civil Aviation Authority of Italy, UK national authorities, The Danish Transport

Authority, Ministry of Infrastructure and Environment (Netherlands) and FABEC Financial

& Performance Committee].

2.5.11 The main reasons provided were:

Target would require substantial effort without reconcilable benefit [MoT Czech

Republic. CAA Czech Republic, AESA, Italian NSA, UK Authorities, Irish CAA];

The NSA does not receive all information required to compute the Overall ATM score

[French NSA, FABEC NSAs, NAV Portugal].

RAT 02 Most stakeholders felt that RAT target is however acceptable for ANSPs (if limited to the

Ground ATM Score) albeit with reservations on the approach to ATM specific events.

2.5.12 Some stakeholders felt the RAT target was too ambitious for both ANSP and NSAs. The

reasons included:

Use of RAT does not provide benefits for all types of incidents [AustroControl];


14

Lack of agreement on which types of incidents RAT should apply to [Danish NSA].

Proposed RAT Target is not acceptable because not ambitious enough

2.5.13 Four (4) professional staff associations and one (1) ANSP, felt that the target was not

ambitious enough and that RAT should be applied to all incidents [Estonian Air Navigation

Services, GATCO, USCA, IFATCA, IFATSEA].

2.6 Additional comments not directly related to RP2 target setting

2.6.1 In responding to the consultation stakeholders commented on the need for additional safety

KPIs:

Need for a Just Culture Target and in particular the need to ensure open occurrence

reporting as the underpinning for all other safety targets. [NATS, PANSA, Prospect,

ENAV, ETF. LFV, CANSO, ZZKRL, GATCO, IAA]

Need for targets for lagging indicators (for example runway incursions, separation

minima infringements and airspace infringements) [IATA and AEA, IFATSEA, ETF,

SINCTA, GATCO]. IFATSEA identify the need to study use of automated tools in this

area.

Need for monitoring of lagging indicators but not setting of targets lest it reduces the

reporting rate. [NATS, PANSA, ENAV, FABEC ANSPs, LFV, CANSO, NAV

Portugal]

2.6.2 Stakeholders also expressed concern about the use of the EoSM as performance indicator and

how it is measured [EANS, ROMATSA, Estonia CAA, French State, ENAV, CAA of Italy,

USCA, FABEC ANSPs, UK National Authorities, LFV, CAA Norway, CANSO, GATCO,

Finish NSA, Nav Portugal, IAA (NSA).

2.6.3 Main reasons provided were:

SFMS (which was used as a basis for development of EoSM for ANSP level) was

developed as internal tool to improvement safety management and culture and was not

intended for target setting.

Independent assessment would provide the consistent approach that is currently lacking

in independent verification carried out by NSAs.


15

3 Environment

3.1 PRB Initial Proposal

3.1.1 Table 6 contains the PRB initial proposed range for the Environment KPI target as contained

in the Consultation Document.

KEP: The average horizontal en route flight efficiency of the last filed flight plan

Value (2009) RP1 target (2014) Range (2019)

RP1 Baseline 4.67% 4.1%-4.4%

KEA: The average horizontal en route flight efficiency of the actual trajectory


N/A N/A 2.50%-2.75%

Table 6 - PRB consultation proposal – Environment


Q3.1: Approach and methodology



area of environment?

A. Fully agree

B. Mostly agree


D. Not at all

E. No opinion






Airline 1 3 1 5

Military 1 1

ANSP 2 11 3 16

NSA 4 4 6 2 16

Ministry 3 1 4





Other 1 1 1 3

Total 5 13 29 4 12 63


8%

21%

46%

6%

19% A

B

C

D

E


16

Q3.4: Horizontal flight efficiency of last filed flight plan (KEP)

The PRB proposes that the Union-wide KEP target range for RP2 should be between 4.1%

and 4.4%.

Do you agree that the proposed range for the KEP target for RP2 is sufficiently challenging

and achievable?


ambitious




challenging


ambitious enough

F. No opinion





Airport operator 4 4

Airline 1 2 1 1 5

Military 1 1

ANSP 1 11 4 16

NSA 9 2 1 4 16

Ministry 1 2 1 4





Other 3 3

Total 6 28 4 3 1 21 63


10%

44%

6%5%

2%

33%

A

B

C

D

E

F


17

Q3.7: Horizontal flight efficiency of actual trajectory (KEA)

The PRB proposes that the Union-wide KEA target range for RP2 should be between 2.50%

and 2.75%.

Do you agree that the proposed range for the KEA target for RP2 is sufficiently challenging

and achievable?


ambitious




challenging


ambitious enough

F. No opinion





Airport operator 4 4

Airline 1 1 1 2 5

Military 1 1

ANSP 4 5 7 16

NSA 3 3 3 1 6 16

Ministry 1 2 1 4





Other 1 2 3

Total 13 12 9 2 2 25 63


21%

19%

14%

3%3%

40%

A

B

C

D

E

F


18

3.3 Stakeholders’ comments on methodology

ENV 01 Many stakeholders indicated that the HFE metrics failed to measure ANSP behaviour as

they are directly affected by other factors

3.3.1 Some specific comments related to ENV 01 can be found below:

Airspace User choice during flight planning phase [MoT Czech Republic, CAA Czech

Republic, DGCAA Bulgaria, Prospect, IFATCA, CANSO, SINCTA, HungaroControl,

EUROCONTROL, ENAV].

ENV 02 Many stakeholders indicated that the ENV metrics are not yet sufficiently mature

Many stakeholders felt that there is insufficient data to comment on the KEA and

KEP target proposals.

3.3.2 Stakeholders who are concerned by the insufficient data are AESA, LGS, NATS, ROMATSA,

Romanian CAA, Polish ANSA, AENA, French State, Spanish Air Force, BULATSA, ENAV,

USCA - Air Traffic Control Officers Spanish Trade Union, LFV, Polish CAA, CAA-Norway,

CANSO, SINCTA, Finnish NSA, FABEC Financial & Performance Committee, ANS CR,

Nav Portugal.

ENV 03 Some stakeholders point out that those who have already achieved FRA will not have room

for further improvement

3.3.3 The stakeholders concerned with ENV 03 were CANSO, NAV Portugal, Irish NSA and Irish

ANSP.

3.3.4 Introduction of FRA [AustroControl, CANSO, ANS CR, HungaroControl, PANSA]

3.3.5 Some stakeholders point out the implementation of FRA is indeed a key enabler of horizontal

flight efficiency. [CAA Norway, Finish NSA, Swedavia, Estonia CAA, EUROCONTROL]

3.3.6 Others point out that FRA is not “low cost” as it involves potentially expensive FDP upgrades.

[CANSO, NAV Portugal, ENAV]

3.4 Requests for Data

3.4.1 In response to Q3.2 (“Please specify what additional evidence you would need”) stakeholders

requested the following data:

FAB-level reference values.

Description of the calculation of the two KPIs and process for monitoring and reporting.

Step-by-step illustrations of how the “achieved distance” parameter is derived.

Definition of the start and end points of the tracks under study (when exiting/entering

SES airspace).

The optimum values for KEA and KEP per FAB, the expected improvements per FAB

for a given operational environment and the areas where no further improvements can

be expected.

Expected evolution of KEA and KEP with traffic growth.

Justification of the NM contribution of 0.65 percentage point between 2012 and 2019

Justification of the NM proposal that a 1% point improvement from 2012 to 2019 would

be possible through a wide spread application of FRA.


19

A study to determine if optimised route planning would reduce the gap between KEA

and KEP including reasons for inefficiencies and rationale for AOs not using the

shortest available route.

Values generated for the annual FIR Horizontal flight efficiency calculation (2012 and

going back as far as you are able) in terms of both GCD vs. Actual and Last filed Flight

Plan vs. Actual (based on the 40NM radius) and the data that underpins these

calculations – a full year’s worth if possible, but at least a good sample (month).

More explanatory material and confirmation of how all the data is derived including

calculations / interpretations / interpolations that are applied to plans and surveillance

data, etc. This last set of information is specifically to enable stakeholders to

understand how the metric is computed, performs and how reasonable the target ranges

are.

The link between flight efficiency, traffic and capacity.

Further details on the PRB analysis of differences between the environmental

improvements gained through KEP and those got through KEA at local and European

level.

3.5 Stakeholder Comments on KEP Target

KEP too challenging

3.5.1 Reasons stakeholders provided for stating that the KEA targets is too challenging were:

RP1 target is not being met [AESA, Prospect, Spanish Air Force, USCA, SINCTA]

Airspace users are not correctly incentivised [Austro Control, MoT Czech Republic]

3.5.2 For this group the EU-wide target should be less demanding than the proposed upper range,

for example: A target range between 4.6 and 4.8%.

KEP not challenging enough

3.5.3 Whist the majority of respondents stated that the propose range was challenging, a number

(mostly airlines) did feel it was not challenging enough:

Based on the extrapolations for KEP, a range of 3.9%-4.4% is preferable to the

proposed and the preference should be for a stretching target (i.e. closer to 3.9% than

4.4%) [UK National Authorities].

No clear reason why the original RP1 horizontal (KEP) flight efficiency target could not

be reached / set for RP2. KEP does not strictly depend on the level of traffic. If the RP1

goal is not going to be met during RP1 period, then the RP2 KEP should be set on

higher level than the original KEP for RP1. [LOT]

IACA’s overall view is that both the upper and lower bound are too conservative in the

perspective that technological, institutional and procedural changes can and should be

delivered in the 2020 timeframe thereby driving better horizontal flight efficiency

performance. As mentioned in the PRB report, achieving the current RP1 target and

maintaining the "status quo" for RP2 would lead to a target of plus 3.92% in 2019. This

should constitute the upper bound and plus 3.17% should constitute an acceptable lower

bound. [IACA]

The difference between the 2012 horizontal profile data for the last filed flight plan

(KEP) and actual trajectory (KEA) demonstrates the inefficiencies present in today's

ATC route network. The KEP target should be set to reach the current KEA (-2.25%) by

2020. [RyanAir].


20

3.6 Stakeholder Comments on KEA Target

KEA value supported

3.6.1 Nine responses support the target range. [Finnish Air Traffic Controllers association, Hellenic

ANSA, CAA-Norway, IFATCA, ZZKRL (Polish ATC Union), GATCO, Finnish NSA,

EUROCONTROL, Ryanair]

3.6.2 EUROCONTROL rationale was: “The proposed range for the Horizontal flight efficiency of

actual trajectory (KEA) target is acceptable and fully supported. As already mentioned in the

PRB document, it has to be recognised that as we motivate the users to optimise their flight

planning, the ability to provide tactical improvement may diminish. Although this would be a

very positive development, it could mean that a too ambitious target on KEA cannot be met.

KEA too challenging

3.6.3 Acceptable but too challenging [CAA Czech Republic, French State, Prospect Trade Union

and PCS Trade Union, Ministry of Transport, Czech Republic, LFV, Polish CAA, ANS CR,

HungaroControl, Nav Portugal, IAA (NSA), IAA (ANSP) and ERA] and [Austro Control,

ROMATSA, Romanian CAA, Belgian CAA + Belgian NSA, AENA, DGCAA Bulgaria,

Spanish Air Force, BULATSA, USCA - Air Traffic Control Officers Spanish Trade Union,

FABEC ANSPs, Ministry of Infrastructure and Environment (Netherlands), FABEC Financial

& Performance Committee] made up 40% of respondents.

3.6.4 These respondents claim that the KEA target proposal is too challenging due to the lack of

data.

3.6.5 A further 40% of respondent had no opinion; the rationale included insufficient data to

comment.

3.6.6 AustroControl stated that airline behaviour would not support a high target.

3.6.7 HungaroControl feel that as FRA will be implemented in core-Europe in RP1 there will be

little room for improvement in RP2. HungaroControl also state that local targets should take

account of: “Traffic volumes and the number of frequency changes /ATC sectors involved

should also be taken account of, as well as other factors such as savings in PBN, CDA and

AMAN, and clearly defined applicable aerodromes in terms of size/number of operations”.

3.6.8 The theoretical optima for KEA and KEP are not yet known [FABEC NSAs] and the rate of

convergence is not established [Polish CAA].

KEA not challenging enough

3.6.9 Again Airlines and the UK National Authorities would welcome a tough target for KEA for

the same reasons as stated for KEP.

UK National Authorities suggest a range of 2.0%-2.5% is preferable to the proposed

2.5%-2.75%, and the preference should be for a stretching target (i.e. closer to 2.0%

than 2.5%).

IACA suggest KEA should also be reduced to mirror the same performance as KEP

LOT suggest KEA should be rather 2,75% than 2,5%. FRA implementation should be

faster.

3.7 Additional Comments not directly related to RP2 target setting

3.7.1 A number of stakeholders indicated the need for additional environmental KPIs, including:

Vertical Flight Efficiency [IACA, IATA and AEA, Heathrow Airport, Italian NSA,

HungaroControl]

Other measures such as a harmonised TA are required [GATCO]


21

Additional ASMA Time [IATA and AEA]

Comparison to wind optimum route [IACA] and comparison to “greenest route”

[USCA]

ANSP could train controllers to affect the metric rather than optimise the system [ACV

TRANSCOM]

The PRB should consider adopting the MUAC indicators REDES and RESTR which

provide more accurate measurements of horizontal flight efficiency over a specific

airspace segment. [RyanAir].

Lack of information on how the ANSPs could affect the metrics [ROMATSA,

BULATSA]

The impact of excluding the non-SES portion of the flight needs to be studied [IAA

(NSA), UK Authorities]NATS and CANSO point out that States using a vertical flight

efficiency indicator will need to set targets with an appropriate balance between vertical

and horizontal efficiency.


22

4 Capacity

4.1 PRB Initial Proposal

4.1.1 Table 10 contains the PRB proposed range for the Capacity KPI target as contained in the

Consultation Document.

Minutes of en route ATFM delay per flight

Value (2012) RP1 target (2014) Range (2015-2019)

0.63 0.5 0.3-0.6

Table 10 - PRB consultation proposal – Capacity


Q4.1: Approach and methodology

The methodology for capacity target setting considers the various aspects of determining,

designing and delivering sufficient capacity to meet traffic demand. It also recognizes the

influence of external factors on the ability of individual ANSPs to deliver capacity

performance, whilst seeking to drive improvements for airspace users.



area of capacity?

A. Fully agree

B. Mostly agree


D. Not at all

E. No opinion





Airport operator 3 1 4

Airline 1 3 1 5

Military 1 1

ANSP 7 7 2 16

NSA 5 7 2 2 16

Ministry 2 1 1 4





Other 1 1 1 3

Total 6 25 21 3 8 63


9%

40%33%

5% 13%A

B

C

D

E


23

Q4.4: Minutes of en route ATFM delay per flight

The PRB proposes that the Union-wide capacity target range for RP2 should be between 0.3

and 0.6 minutes of en-route ATFM delay per flight.

Do you agree that the proposed capacity target range for RP2 is sufficiently challenging and

achievable?


ambitious




challenging


ambitious enough

F. No opinion






Airline 1 2 2 5

Military 1 1

ANSP 4 9 2 1 16

NSA 1 6 7 2 16

Ministry 1 2 1 4





Other 1 2 3

Total 12 23 14 2 2 10 63


19%

37%22%

3%

3%16% A

B

C

D

E

F


24

4.3 Stakeholders’ comments on approach

4.3.1 The following comments were made on PRB proposed approach:

CAP 01 Stakeholders’ comments revealed differences in interpretation of the legislation regarding

the indicator, the target setting and ‘exceptional events’

For example NATS requests information on how the NM would deal with disruption.

AENA queried how the new definition of the KPI would influence the target setting

process. BULATSA queried the rules that would apply for exceptional events.

CAP 02 Stakeholders had many comments about the existing ATFM delay causes (including ANS

controllable / attributable delay); about how delays are classified into the various

categories, and about the lack of transparency into the process for attributing delays.

The stakeholders concerned by CAP 02 were IAA, BULATSA and Ryanair.

CAP 03 Stakeholders queried the likely benefits to be gained through SESAR deployment in RP2.

The stakeholders concerned by CAP 03 were IFATSEA, LFV, CANSO and FABEC

ANSPs.

Stakeholders also feel that 8-10% is an R&D target not yet validated for deployment.

CAP 04 Stakeholders queried the link between EU wide capacity targets and local capacity targets

especially regarding traffic levels, traffic complexity, and local management of capacity.

For example PANSA feels that breakdown to FAB/local level should involve

consultation with the States. SINCTA requests “full disclosure of information regarding

“reference values”… the methodology and input variables must be completely

transparent and reviewable by concerned stakeholders”.

CAP 05 Stakeholders queried the specific relationship between the cost of additional capacity and

the cost of delay.

In the specific, several stakeholders queried the linear relationship presented in the

consultation documentation, and the capacity planning documentation from

EUROCONTROL.

CAP 06 Stakeholders queried the relationship between capacity performance and cost effectiveness.

In the specific, a number of stakeholders suggested that providing additional capacity

would have an influence on attempts to improve cost efficiency.

CAP 07 Stakeholders queried the possibility of setting capacity targets according to traffic levels, or

using bands of capacity performance.

For example NATS suggested that Capacity targets “should be modulated according to

actual traffic growth in the reference period”. The importance of stable and accurate

forecasts from STATFOR [Hellenic NSA] was highlighted. LFV suggest that EU

targets could have been set using traffic bands, similarly to traffic risk sharing.

CAP 08 Stakeholders queried the ability to implement capacity enhancements within the timeframe

of RP2.

Whilst supporting the PRB views on potential measures to increase capacity, the French

State noted “One main issue is the pace at which such change will be possible and at


25

what cost. In this respect PRB assumptions for RP2 may look optimistic and

uncertainties remain as 7 years only allow a limited set of investments and operational

changes.

4.4 Requests for data

4.4.1 In response to Q4.2 (Please specify what additional evidence you would need) stakeholders

requested the following data:

Breakdown of targets at FAB/National Level.

Modelling of the System Wide Cost Optimum including the error margin and cost of

capacity.

Historical data for delay across FABs.

Explanation of why RP1 target is not forecast to be met despite traffic fall.

Methodology for NM attribution in the event of exceptional events.

Link between traffic development and delay (given the high uncertainty of traffic

forecast, delay forecast is highly volatile).

Link between delay and complexity.

New methods for forecasting delay for new working methods like Short Term ATFCM

measures, occupancy monitoring, etc.

More robust evidence with regards the achievability of any theoretical optimum point

would be welcome.

Weather allowance and sharing mechanism.

4.5 Stakeholders’ comments on target range

Proposed capacity target is not ambitious enough

4.5.1 Airspace users felt that the proposed capacity target is either not ambitious enough or

acceptable but could be more challenging. The provided rationale are [IATA and AEA,

IACA]:

The proposed ranges for network and weather disruption are considered unacceptably

high. The RP1 allowance for weather was 0.1 (based on historic data since 2003); there

is a lack of evidence to support the increase for RP2.

The main proposal for variation is the allowance for network disruptions (0.05 to 0.25).

The RP1 allowance for disruptions was 0.05; there is a lack of evidence to support the

increase for RP2. The rules governing the application of this allowance are unclear.

A gate-to-gate approach is not proposed for RP2 – the transfer of additional time to

Environment exacerbates this.

High risk of delay transfer activities in order to meet the ATFM delay targets - it is

proposed that airport related capacity KPI is established as part of Airport CDM

projects.

Support for the current target

4.5.2 Three-quarters of responses (including most ANSPs and NSAs) feel that the lower bound is

too ambitious and about 50% of stakeholders expressed support for the current target (0.5

min/flight) to be used for RP2. The rational included:

The RP2 target should not be less ambitious that the RP1 target [LOT, PANSA, ENAV,

Italian NSA, NL State]

Maintaining this level of en route delays whilst accommodating the traffic growth

expected during RP2 (a realistic average forecast could be +2% per year) is already a


26

capacity performance enhancement. [French State, AENA, AESA HungaroControl.

LFV, CANSO, FABEC NSAs, NAV Portugal]

A capacity improvement of 8-10% added through SESAR first priorities (IDP included);

combined with a traffic growth of ca. 2% yearly as an average, this would suggest that

keeping capacity targets of RP1 would require in addition a number of other

improvements from airspace and staff management. [French State, AENA, AESA

HungaroControl. LFV, CANSO, NL State, FABEC NSAs]

During RP2, the ATCO will have to accommodate a large amount of technical and

operational changes, in preparation of and/or indirect link with the SESAR deployment

program and they will have to face training obligations; [French State, NL State,

FABEC NSAs]

Introducing new systems will require expert teams of ATCOs for validation and testing

phases before commissioning new systems or amending concepts of operation; [French

State, NL State, FABEC NSAs]

The obligation to set incentives on the capacity targets implies the target must be

realistic. Over ambitious target setting leading to structural and systematic issues for

ANSPs would lead to a degradation of their investments in capacity and we should

avoid to taking risks that induce delays in the SESAR deployments needed to introduce

further capacity gains. [French State, NL State, FABEC NSAs]

NATS feel that the current level enables them to offer best value to airspace users when

considering the total economic cost.

Generally, capacity problems can only be solved with investments and/or more staff. An

ambitious cost efficiency target could hamper the achievement of the capacity target.

There is some doubt whether the interdependency between capacity and CE is taken into

account. [NL State]

The timing of the implementation of SESAR investments with an effect on the capacity

and the possible effects of these investments is unknown. [NL State]

4.5.3 In addition, the Network Manager supported maintaining the current target with the “caveat

that greater focus needs to be given to flights that have considerable delays. The working

processes between the Network Manager and PRB need to be clarified in relation to

apportioning targets and providing reference values”.

Proposed capacity target is too ambitious

4.5.4 Most stakeholders (8 of 12) who indicated that the target was not acceptable because it was

too ambitious went on to explain that the current target would be acceptable. The exceptions

were staff associations [ETF, ZZKRL, USCA, SINCTA]. These stakeholders feel a value of

0.6 would be more appropriate.

4.6 Additional comments not directly related to RP2 target setting

4.6.1 Some stakeholders indicated the need for additional capacity KPIs, including:

Use of number of fights delayed more than 15 minutes [EUROCONTROL]

Additional metrics taking account of peak demand (for RP3) [IATA and AEA]


27

5 Cost Efficiency

5.1.1 Table 13 contains the PRB proposed range for the Cost-efficiency KPI target as contained in

the Consultation Document.

Determined Unit Cost for en route air navigation services (€2009)


€63.7 €53.92 €53.0 - €43.3

(-2.5% to -5.8% p.a.)

Table 13 - PRB consultation proposal – Cost Efficiency

5.1.2 The PRB proposal considered setting a starting point for 2014 based on the determined costs

(DCs) underlying the EU-wide target adopted by the EC (€6,179M). The PRB considered that

this amount allowed reflecting the impact of potential cost reduction measures on States costs

in 2014 and also to maintain the EC original level of ambition for RP1. Based on the technical

evidences and considering that the Performance Scheme in RP2 should bring significant

improvements in cost-efficiency performance, the PRB proposed reductions in total en-route

determined costs ranging from -1.0% p.a. to -3.0% p.a. between 2014 and 2019. Considering

STATFOR February 2013 SUs forecasts, this would lead to reducing the en-route Determined

Unit Costs (DUC) by -2.5% p.a. to -5.8% p.a. between 2014 and 2019.


Q5.1a: Technical evidence to set the level of cost-efficiency ambition for RP2 - relevance

Analysis of cost-efficiency performance at European system level including historic analysis

of the European system performance, forward looking projections until 2014, and analysis of

ANSPs’ cost structures.

A. High relevance

B. Medium relevance

C. Low relevance

D. No opinion

Figure 10 – Stakeholders answers to Q5.1a

62%

24%

6%8%

A

B

C

D


28

5.2.1 Table 14 below indicates the answers to the question 5.1a broken down as provided by the


Type / answer A B C D Total


Airline 1 2 2 5

Military 1 1

ANSP 10 5 1 16

NSA 13 3 16

Ministry 4 4





Other 2 1 3

Total 39 15 4 5 63

Table 14 - Summary of responses for Q5.1a per stakeholder type


29

Q5.1b: Technical evidence to set the level of cost-efficiency ambition for RP2 - relevance

High level cost-efficiency continental benchmarking with the US FAA Air Traffic

Organisation (ATO).

A. High relevance

B. Medium relevance

C. Low relevance

D. No opinion

Figure 11 – Stakeholders answers to Q5.1b

5.2.2 Table 15 below indicates the answers to the question 5.1b broken down as provided by the




Airline 5 5

Military 1 1

ANSP 2 14 16

NSA 4 12 16

Ministry 1 3 4



Professional Staff Association 1 10 11


Other 1 1 1 3

Total 5 13 41 4 63

Table 15 - Summary of responses for Q5.1b per stakeholder type

8%

21%

65%

6%

A

B

C

D


30

Q5.1c: Technical evidence to set the level of cost-efficiency ambition for RP2 - relevance

Intra-ANSP benchmarking analysis.

A. High relevance

B. Medium relevance

C. Low relevance

D. No opinion

Figure 12 – Stakeholders answers to Q5.1c

5.2.3 Table 16 below indicates the answers to the question 5.1c broken down as provided by the




Airline 2 2 1 5

Military 1 1

ANSP 3 11 2 16

NSA 5 9 2 16

Ministry 1 3 4





Other 2 1 3

Total 12 39 7 5 63

Table 16 - Summary of responses for Q5.1c per stakeholder type

19%

62%

11%

8%

A

B

C

D


31

Q5.1d: Technical evidence to set the level of cost-efficiency ambition for RP2 - relevance

Exploratory econometric modelling to infer the potential level of industry-wide cost-

inefficiency.

A. High relevance

B. Medium relevance

C. Low relevance

D. No opinion

Figure 13 – Stakeholders answers to Q5.1d

5.2.4 Table 17 below indicates the answers to the question 5.1d broken down as provided by the




Airline 3 2 5

Military 1 1

ANSP 1 2 13 16

NSA 1 3 12 16

Ministry 4 4





Other 1 1 1 3

Total 3 15 39 6 63

Table 17 - Summary of responses for Q5.1d per stakeholder type

5%

24%

62%

9%

A

B

C

D


32

Q5.1e: Technical evidence to set the level of cost-efficiency ambition for RP2 - relevance

Cross-industry comparisons of productivity improvements.

A. High relevance

B. Medium relevance

C. Low relevance

D. No opinion

Figure 14 – Stakeholders answers to Q5.1e

5.2.5 Table 18 below indicates the answers to the question 5.1e broken down as provided by the




Airline 5 5

Military 1 1

ANSP 1 6 9 16

NSA 1 7 8 16

Ministry 1 3 4





Other 1 1 1 3

Total 6 20 33 4 63

Table 18 - Summary of responses for Q5.1e per stakeholder type

10%

32%

52%

6%

A

B

C

D


33

Q5.3: Historical trends and Union-wide targets for RP2

Do you agree with the PRB that it is appropriate to consider historic trends in en-route unit

costs in developing the Union-wide cost-efficiency target for RP2?

A. Fully agree

B. Mostly agree


D. Not at all

E. No opinion






Airline 3 2 5

Military 1 1

ANSP 3 7 6 16

NSA 11 2 3 16

Ministry 3 1 4





Other 1 1 1 3

Total 18 19 19 3 4 63


29%

30%

30%

5%6%

A

B

C

D

E


34

Q5.5: Effect of cooperation between ANSPs

Please indicate to what extent you think cooperative initiatives amongst ANSPs will

influence en-route unit costs leading to cost reductions during RP2?

A. A large impact

B. A little impact

C. Not at all

D. No opinion






Airline 2 2 1 5

Military 1 1

ANSP 2 14 16

NSA 3 12 1 16

Ministry 4 4





Other 1 1 1 3

Total 16 37 2 8 63


25%

59%

3% 13%

A

B

C

D


35

Q5.7: High level analysis of the cost structure for ANS provision

Do you agree with the PRB assumption that for RP2 the greatest scope for en-route cost

reductions at Union-wide level lies within support costs?

A. Fully agree

B. Mostly agree


D. Not at all

E. No opinion






Airline 1 2 1 1 5

Military 1 1

ANSP 3 9 4 16

NSA 2 5 7 1 1 16

Ministry 3 1 4





Other 1 1 1 3

Total 2 12 29 13 7 63


3%

19%

46%

21%

11%A

B

C

D

E


36

Q5.10: Capex envelope for RP2

Do you agree with PRB’s assumption that rationalisation and prioritization of capex projects

during RP2 should allow the level of capex to be kept in the same order of magnitude as

spent during RP1 (circa EUR 1 billion per year) while deploying "best in class" technology

and possibly new technology arising from SESAR deployment?

A. Fully agree

B. Mostly agree


D. Not at all

E. No opinion






Airline 1 2 1 1 5

Military 1 1

ANSP 2 10 3 1 16

NSA 2 3 5 5 1 16

Ministry 4 4



Professional Staff Association 2 2 1 2 4 11


Other 1 1 1 3

Total 5 10 22 16 10 63


8%

16%

35%

25%

16%A

B

C

D

E


37

Q5.12: Focus on total cost incurred

Do you agree with the PRB approach to derive cost-efficiency targets by applying control to

the cost base, i.e. the total cost incurred, then adjusting the Determined Unit Cost (DUC) to

meet the traffic forecasts?

A. Fully agree

B. Mostly agree


D. Not at all

E. No opinion






Airline 3 1 1 5

Military 1 1

ANSP 1 6 7 2 16

NSA 7 2 5 1 15

Ministry 4 4





Other 1 1 1 3

Total 9 15 24 6 8 62


14%

24%

39%

10%

13%A

B

C

D

E


38

Q5.14: Setting the assumptions for the level of en-route cost-efficiency ambition over RP2

The PRB proposes to consider en-route cost-efficiency Determined Unit Cost (DUC)

reduction for RP2 ranging between -2.5% p.a. and -5.8% p.a.

Do you agree that the proposed cost-efficiency target range for RP2 is sufficiently

challenging and achievable?


ambitious




challenging


ambitious enough

F. No opinion






Airline 1 3 1 5

Military 1 1

ANSP 11 4 1 16

NSA 6 8 1 15

Ministry 4 4



Professional Staff Association 11 11


Other 1 1 1 3

Total 34 16 2 1 4 5 62


55%26%

3%

2%6%

8% A

B

C

D

E

F


39

Q5.17: Terminal ANS cost-efficiency

The PRB has given an indication of the type of target that might be developed for Union-

wide terminal ANS cost-efficiency. The PRB considers that the analysis and target range

being developed for en-route cost efficiency should be applicable to terminal ANS cost-

efficiency, or at least a continuation of constant total terminal ANS costs over the period.

Do you agree that this approach to terminal targets is appropriate?

A. Fully agree

B. Mostly agree


D. Not at all

E. No opinion






Airline 1 1 1 1 1 5

Military 1 1

ANSP 7 9 16

NSA 1 10 4 15

Ministry 1 2 1 4





Other 1 1 1 3

Total 2 5 25 24 6 62


3%

8%

40%39%

10%A

B

C

D

E


40

5.3 Stakeholders’ comments on technical evidence

ECO 01 Stakeholders showed greatest support for use of historic data and intra-ANSP

benchmarking; the least support was for econometric and productivity analysis.

Stakeholders expressed mixed views on US-Europe comparison.

5.3.1 A number of stakeholders considered:

PRB have included too optimistic traffic forecasts [EANS].

US-Europe needs to be interpreted carefully, and would benefit from comparison with

other States including Airways NZ [Dusseldorf Airport, Heathrow Airport, Swedavia],

if you look at relative performance Europe has performed better than US over the 2004-

2012 period [Austrocontrol German NSA, FOCA, LFV, CANSO, ANS CR,

Hungarocontrol], needs to take account important differences between the regions (fuel

prices, number of centres, ATCO licences) [IFATSEA, GATCO, Heathrow airport],

regulatory, social, cultural and legal differences [Belgian CAA, PANSA, AENA,

Prospect, Ministry of Transport Czech Republic, USCA, EUROCONTROL], funding

model [Prospect, ETF, SINCTA].

Econometric and productivity analysis do not take into consideration industry specific

issues so are less valuable than historic and intra-ANSP benchmarking [AESA].

Relative efficiency important, using EU-US comparison even though not at the

efficiency frontier. Historic and intra-ANSP evidence most relevant, Econometric and

cross industry productivity suffers from data availability [IATA and AEA], Econometric

should not be used [Italian NSA, ETF, Ministry of Infrastructure and Environment,

Netherlands].

Past and projected performance most relevant [ROMATSA, NATS, German NSA,

SINCTA, ANS CR, Hungarocontrol], intra-ANSP, including US-Europe and cross-

industry, need to be interpreted with caution due to different circumstances [NATS],

will be impacted by FAB development [Ministry of Infrastructure and Environment,

Netherlands] and have low relevance [ROMATSA]. However, US-Europe comparison

received strong support from all 5 airlines responses. IATA and AEA consider it to be

the best available basis for setting targets noting that the FAA should not be considered

to have reached the efficiency frontier [IATA and AEA]

Intra-ANSP benchmarking suffers from too many groups [NAV Portugal].

In general evidence not robust enough to set targets [AENA].

Cost efficiency targets should focus on the largest 5, as they are the ones with the largest

impact on costs [Ryanair].

5.4 Stakeholders’ comments on historical trends

ECO 02 Stakeholders showed majority support for analysing historical trends, however many noted

that one-off events and/or local circumstances should be taken into account, as well as

performance in RP1.


Useful but one off events need to be considered [AESA,], local circumstances

considered [Austrocontrol, German NSA, FOCA, BULATSA, ANS CR,

Hungarocontrol, NAV Portugal], and changes that have already taken place [NATS,

IFATSEA], these may not be repeatable [AENA], local investment decisions important

[German NSA, FOCA].

Support use but data needs to be handled with care – local cost efficiency studies need

to be undertaken [CANSO].


41

Of some importance, but less so in volatile traffic conditions with little predictability

[ACV Transcom].

Need to consider step changes from FABs and SESAR [EANS, EUMETNET], and

investment programmes [Belgian CAA], and changes in trends in future [Ministry of

Infrastructure and Environment, Netherlands].

As history reflects a period with lack of political it will not useful for predicting the

future [LOT], also reflects a period of cost recovery mechanism so less relevant [IATA

and AEA, EUROCONTROL] and period of inefficiency [Ryanair]

Only appropriate for mature markets [EANS].

Needs to be reflected that a number of states did not make enough effort in RP1

[PANSA].

Important in context of traffic evolution [UK National Authorities, IAA (NSA and

ANSP)].

Not relevant as SES High level goals are the only relevant targets [IACA].


Starting point needs to be clear and that forward looking state data needs to be

considered [French State].

Other studies (SESAR, Return on equity, pension contributions, IFRS,

interdependencies of KPAs) need to be considered [German NSA, FOCA].

NSA costs are likely to increase with regulatory burdens increasing [Italian CAA].

Interpret trend different, we are at the limits of what can be done [USCA].

5.5 Stakeholders’ comments on cooperation between ANSPs

ECO 03 Stakeholders had mixed views on the potential for co-operation initiatives, with FAB

performance to date and lack of political will cited as constraints.

Most stakeholders believe that co-operation improvements will not materialise until the end

of RP2.

Influence of co-operation initiatives - Evidence


Lack of evidence from PRB means not persuasive[ACV Transcom].

Likely to have only a limited impact in the absence of a free market for ANS [LOT].

Impact will link to the scale of restructuring taking place [AENA].

Concern impact will be small due to lack of political will [LGS].

Based on FAB experience, sceptical whether there will be real savings [IATA and

AEA], FABs in early stage of development [ROMATSA, Romanian CAA].

Further centre consolidation in UK would lead to significant restructuring costs and

impact performance quality. It does believe the alliances can provided benefits

particularly in sharing technological solutions [NATS]. Little benefit to date from UK-

Ireland FAB [UK Authorities] benefits from COOPANS [IAA].

Experience shown that national, governance and legislative differences will need to be

addressed before FAB benefits materialise [Belgian CAA].

Synergies can be provided [Dusseldorf Airport].


42

Likely to lead to impacts on fuel savings (shorter routes) and other flight planning

benefits rather than cost efficiency [Prospect].

Different national unit rates cause an obstacle to more co-operation [Swedavia],

FRA through NEFAB example of benefit [CAA Norway].

NM should be involved with providing solution [IFACTA, Swedavia, Heathrow

Airport].

Benefits will require major restructuring [ANS CR].

FABs have not worked and the PRB should consider imposing sanctions for States who

did not meet the December 2012 deadline [Ryanair].

Influence of co-operation initiatives - Timing


Leads to improvements in the long run [PANSA, BULATSA, ENAV, LFV, CANSO,

Ministry of Infrastructure and Environment Netherlands], end of RP2 [Hellenic CAA]–

through common procurement and training [Czech CAA, Czech Ministry of Transport],

potentially big impact in long run [EANS].

Structural changes are needed so this will mean that only benefits are provided in long-

run [AESA], likely to have integration costs associated with the change [Austrocontrol].

SESAR means benefits only available the in the longer run [IFATSEA].

Long lead time to set up centralised functions [French State, German NSA, FOCA].

5.6 Stakeholders’ comments on cost structure of ANS provision

ECO 04 Stakeholders suggested a spectrum of sources for cost improvement opportunities, with the

most common support being for support cost, ATCO (and training) cost areas.

A number of stakeholders stated that the source of cost reduction opportunities is a decision

that should be left to the State/FAB.

Greatest scope for en-route is support costs


Support costs are the area with the greatest scope [EUROCONTROL], but State

relativities need to be considered [AESA], support CNS and MET all areas with

potential [LGS], and back-office which can be outsourced [ZZKRL].

ATCO and support costs [IATA and AEA, PANSA, Spanish Air Force, LFV].

Support costs might increase linked to reorganisation and SESAR [EANS], limited

further opportunities for improvement [IAA].

Not relevant as choices should be left to States [Austrocontrol, ROMATSA, Romanian

CAA, BULATSA, FOCA, Ministry of Transport Czech Republic, Hellenic NSA, ANS

CR, Hungarocontrol], local circumstances should drive decisions [Belgian NSA,

German NSA].

Needs to be placed in context of what already done in State [NATS, AENA, LFV] and

potential for further improvements available in the FAB [NATS].

Not available for reduction as affect other services [Prospect].

Other potential sources of cost reduction

5.6.2 A number of stakeholders considered other candidates for cost reductions:

Reconsidering projects in ATM Master plan [CAA Czech Republic, ANS CR].


43

General reduction in staff costs [CAA Czech Republic, Dusseldorf Airport, Swedavia,

Polish CAA, IACA, Heathrow Airport], ATCO costs and their training [EANS, IATA

and AEA].

Investment [IACA].

Cost of capital [IATA and AEA, IACA].

Broad spectrum of sources [UK National Authorities, IFATSEA, CANSO].

Centralised services area [EUROCONTROL].

Separation of services (MET, AIS Comms) [Ryanair].

5.7 Stakeholders’ comments on CAPEX envelope for RP2

ECO 05 Stakeholders agreed on the need for capex rationalisation and the importance of linkage to

the SESAR timetable.

Some stakeholders noted that the delay of capex in RP1 may have implications in RP2.

Approaches to efficient capex


Common procurement of ATM systems [ACV Transcom].

System rationalisation rather than like-for-like replacement is needed [IATA and AEA].

Expectation of need for less capital investment [IACA], resulting from new low cost

solutions [Ryanair].

Depends on level of integration and synergies, might not happened in RP2 [Belgian

NSA].

Need for rationalisation and prioritisation but also best in class investment [CANSO].

Centralised strategy needed for investment [EUROCONTROL]

Other issues


Some postponement of capex in RP1 may have a logjam affect [ACV Transcom, AESA,

German NSA, FOCA, ANS CR, Hungarocontrol].

Local investment cycles need to be considered [Czech NSA, Czech Ministry of

Transport, ZZKRL], need to be based on case by case basis [LGS].

Depends on SESAR outcome [EANS, BULATSA, Ministry of Infrastructure and

Environment Netherlands, ANS CR and Hungarocontrol], SESAR will lead to higher

capex (Austrocontrol, IFATSEA), SESAR and final implementing rules will determine

level of capex needed. Not yet clear if SESAR is the right technology [ROMATSA].

Not enough evidence to support PRB proposals [AENA].

Believe RP2 will require less capex than RP1 (UK Authorities), more in Norway

(Norway NSA), Netherlands (Ministry of Infrastructure and Environment, Netherlands),

linked to investment cycles.

5.8 Stakeholders’ comments on focus on total costs incurred

ECO 06 Stakeholders generally accept that splitting total costs from the traffic-determined unit

costs is sensible, although there is disagreement about the level of ambition proposed.

The importance and potential unpredictability of traffic forecasts was widely noted.


44

Control of total costs - Approach


Generally accepted split between total costs and traffic determining unit costs [IATA

and AEA, UK National Authorities, LFV, Polish CAA, CANSO. EUROCONTROL].

Mainly agree but traffic important [EANS], particularly as outside ANSP control

(NATS).

Agree to approach but level of ambition in total cost reduction too ambitious [Belgian

CAA, Netherlands Ministry of Infrastructure and Environment], a dynamic approach to

determining the optimum cost structure needs to be considered [German NSA, FOCA].

Possible only to achieve in mature markets [LGS].

Approach too simplistic and needs to take account potential to incur further costs

[AENA].

Ambition needs to be linked to traffic evolution and not in isolation [French State.

BULATSA, IAA], some costs are variable with traffic [Spanish Air Force, Italian

NSA].

2012 costs need to be taken into consideration [Hellenic CAA].

A better approach than RP1, but some costs are traffic related moreover the approach

calls into question the traffic risk sharing arrangements in the performance scheme

[HungaroControl].

Control of total costs - Traffic forecasts


Traffic forecasts are uncertain and appear unpredictable [PANSA, German NSA,

IFACTA] and could lead to a higher risk premium [Czech CAA, Czech Ministry of

Transport, ANS CR], must be fully taken into account [IFATSEA].

Concern traffic forecasts may be underestimated [IATA and AEA].

5.9 Stakeholders’ comments on proposed range

ECO 07 Stakeholder comments on the proposed range were aligned within stakeholder groups, with

ANSPs and NSAs generally preferring the lower end of the range and Airlines the higher

end.

Proposed range


Target range generally not acceptable [ROMATSA, Spanish Air Force, LFV].

Proposing a freeze in the current DUC [ACV Transcom, ZZKRL].

Freezing the current cost base [Austrocontrol, ETF], ability to reduce costs further

indefinitely not possible and eventually some cost increases will be needed [CANSO,

NAV Portugal].

Cost increases of 2% to 5% should be applied [NSA Italy].

A DUC reduction toward the lower end of the range of -2.5% is appropriate [CAA

Czech Republic, AESA, Belgian NSA, Estonia CAA, Ministry of Transport Czech

Republic, Hellenic CAA, CAA Norway, Danish Transport Authority, Ministry of

Infrastructure and Environment Netherlands, Finish NSA], even lower end will be

difficult to achieve [IAA], -1.0% to -2.0% [AENA], -1.0% to -3.0% [Czech ANS,

Hungarocontrol], upper end out of reach [French State].


45

Support the upper end of the range -4.5 to -5.8% [LOT]

Support the range subject to final traffic projections [UK Authorities,

EUROCONTROL]

Suggest continuing the target from consolidated NPPs from RP1 to RP2 adjusting for

latest traffic forecasts [German NSA, FOCA].

Should be set to be consistent with SES high level goals [IATA and AEA], proposal for

-9.3% pa [IACA].

Is not ambitious enough even at the high end [Ryanair].

Proposed Range – Starting point


PRB proposing wrong starting point should be adjusted to reflect cost efficiencies

achieved in 2012 (€53.9 set for 2014 in RP1) [IATA and AEA, IACA].

Cost targets should be linked to the number of service units so that the effect of traffic

levels is accounted for [CANSO].

A breakdown of the Union-wide target starting point needs to be provided to State level

[PANSA].

Proposed Range – Other issues


Interdependencies to be taken into account [NATS, Prospect].

Concerned that lack of predictability of traffic a problem with setting targets

[IFATSEA].

Targets can only be achieved if SESAR deployment costs are excluded [EUMETNET],

SESAR needs to be fully considered [CAA Poland].

Targets will lead to staff reductions and social unrest [Prospect].

Concern targets could lead to ANSP bankruptcy [ETF].

5.10 Stakeholders’ comments on Terminal ANS cost-efficiency

ECO 08 Stakeholders generally supported setting TANS targets at local level, although there was

some dissent (suggesting no targets or monitoring only).

A number of NSAs and ANSPs considered the data required to set terminal targets is not

mature enough.

EU vs. Local targets


It was only appropriate to set targets at a local level [ACV Transcom, IFATSEA,

AENA, Prospect, German NSA, FOCA, ETF, IAA], not yet ready for Union-wide

targets [French State], no targets at all [SINCTA], only monitoring [NAV Portugal].

Local only until 2015 consultation [NATS], local till 2017 [ENAV, CANSO].

Releasing ‘ghost target’ undermines local process and goes against the principles of

better regulation [NATS].

Local considerations and variety of size in airports needs to be considered [ROMATSA,

CAA Norway].


46

Not possible to set targets on individual airports, different services requirements by

airport make comparison difficult [LFV].

TNS has closer links to the evolution of airports charges than en-route [Swedavia].

Lack of maturity of data


That the data was not mature enough or missing [NSA Czech, Ministry of Transport

Czech Republic, AENA, German NSA, FOCA, Hellenic NSA, ANS CR,

Hungarocontrol], traffic forecasts not reliable [Belgian CAA, PANSA] and terminal

area definition not mature [Belgian CAA].

Therefore better to rely on gate-to-gate data [NSA Czech, Ministry of Transport Czech

Republic].

Not rely on gate-to-gate needs bottom-up TNS specific analysis [Austrocontrol,

Prospect, Hungarocontrol]

Lack of available data. mean it is not mature enough to set targets [AESA,

Austrocontrol] or only high level targets should be applied [UK Authorities].

Compare to TMA at New York and Los Angeles [an Individual].

Same targets as for en-route business?

No exemptions should be allowed, [LOT].

Use en-route target for efficiency [French State, LOT, EUROCONTROL].

Support PRB approach to using the same target as En-route as avoids incentives for

changing allocation of costs [IATA and AEA].

Do not support approach [AENA, Swiss ACTA].

Support constant TNS costs [Ministry of Transport Czech ANS, Ministry of

Infrastructure and Environment Netherlands].

Targets to achieve the SES goals need to be implemented [IACA].


47

6 General Comments

6.1 Airspace Users

6.1.1 Airspace Users largely support the PRBs approach. They consider that the inefficiency of the

current system is such that improvement can be made in all areas without trade-off. Airspace

Users consider that the EC is committed to delivering the SES High Level Goals by 2020.

6.2 ANSPs

6.2.1 ANSPs feel that a more balanced approach is require to target setting that takes full account of

the dependencies between KPAs. CANSO supports a description of the scenarios for a longer

period of time than for one reference period, and extracting the relevant effects for RP2.

6.2.2 Most ANPS noted that there is need for robust local traffic forecasts and information on the

proposed evolution of targets under different traffic scenarios.

6.2.3 LFV notes that new systems will drive cost for all involved in the ATM system. LFV

considers that the baseline of some evidence is still not robust enough.

6.2.4 NATS believes that ANSPs need to be more involved with the inter-dependency and

accountancy studies in order for their results to be realistic, credible and accepted.

6.2.5 For ANS CR, the performance scheme does not take into account operational efficiency

improvements in the terminal area sufficiently.

6.2.6 EUMETNET states that whilst METSP are in principle only influenced by the cost efficiency

KPA, better integration and use of the existing and near future MET information services

(currently under development in SESAR WP11.2) would indirectly contribute in a positive

manner to a number of other KPAs such as safety, capacity and environment.

6.3 National Supervisory Authorities and Member States

6.3.1 Most NSAs noted that reference values for Capacity and Flight Efficiency are required to

assess the impact of proposed Union-wide targets at local level.

6.3.2 The Italian NSA would like to see more evidence relating to NSA costs which have their own

drivers and likely increase “if the level of oversight required by EASA during standardisation

inspections will be adopted Europe wide, the safety targets on RAT reached and all the

regulations being issued properly overseen”.

6.3.3 The Italian NSA would also like to see an ANSP cost model based on variable and fixed costs,

in order to understand what the fixed infrastructure required deliver a determined level of

Capacity for a given traffic forecast.

6.3.4 For the Swiss and French States, he experience of RP1, where the local cost-efficiency targets

were assessed against the average trends, is not desirable for RP2 – “more flexibility should be

considered according to the local circumstances and plans” including the need for investment

line with the SESAR and warranting a rise in depreciation costs beyond the 1 b€ level. The

EU-targets should be chosen taking into account as far as possible the concrete technical and

operational changes expected by 2019 and their impact on performance.

6.4 Professional Staff

6.4.1 Prospect indicated that they would welcome additional information, including workshops, to

help ensure that professional staff understand the complexities of the performance scheme.

6.4.2 ETF warn that RP2 targets “could create a lot of social tensions everywhere in Europe”. ETF

believes that the EC approach on RP2 is based on unrealistic targets. This is mainly due to the

so called high level goal for SES which were never accepted by the ATM stakeholders and

which create unrealistic expectations for the users.


48

6.4.3 IFATCA remains committed to the objective of a "true single sky"; “our members are not

against change, but in our domain, change must be managed and organized on a reasonable

and sustainable way”. IFATCA works pro-actively with other professional staff organizations

in solution-oriented proposals.

6.4.4 For Swiss ATCA, “targets are required” but they must be “the right targets at the right time

to enhance the overall system” and ensure that the current level of safety is maintained or

even increased, regardless of economic interests of some stakeholders.

6.4.5 USCA notes that there is some challenge in meeting the RP1 targets and that caution is

required in setting RP2 targets to ensure that a failure to meet targets is not seen as

demotivating. The also press on the need to ensure that the data used in target setting is fully

audited.


49

References

i Commission Implementing Regulation (EU) No 390/2013 of 3 May 2013 laying down a

performance scheme for air navigation services and network functions

http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2013:128:0001:0030:EN:PDF.

ii Commission Implementing Regulation (EU) No 391/2013 of 3 May 2013 laying down a

common charging scheme for air navigation services

http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2013:128:0031:0058:EN:PDF.

iii PRB consultation report “Union-wide Targets for the 2nd Reference Period of the Single

European Sky Performance Scheme” published on 17 May 2013.

iv Commission Decision of 29 July 2010 on the designation of the Performance Review Body of

the Single European Sky.

http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2013:128:0001:0030:EN:PDF

http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2013:128:0031:0058:EN:PDF

Documents

PRB reports for the European Commission - Eurocontrol 1 - PRB advice to the Commission in the setting of Union-wide performance targets for RP2 Appendix B: Summary of responses to