Gate One views on the EU Airspace Architecture Study (AAS)

Gate One members acknowledge the need to deliver the performance required for an efficient and sustainable Single European Sky and solve the capacity crises forecasted in some areas of the European airspace. Gate One ANSPs are already in the process of introducing new cross-border arrangements envisioned by the AAS (Study) such as SECSI FRA and SEEN FRA. Gate One members welcome the idea of elaborating an Airspace Architecture Study to serve as a firm basis for further policy-making and regulation. We appreciate the efforts of the SJU and the Commission to ensure stakeholders’ involvement and to bring greater clarity to the new EU Airspace Architecture vision. We support a continued focus on interoperability, new technologies and safety. We consider that it is important to realise the vision along the broadest possible consensus of Member States and stakeholders. Having said that, we would like to express our views in a more detailed manner in respect of the aspects of the Study we consider most relevant at this point in time on the basis of the information we obtained at the workshop held in Brussels at the beginning of July.

I. Need for a Clear and Improved Vision

It is of fundamental importance that the vision is sufficiently comprehensive, clear and realistic, avoiding any short term and unsustainable solutions, bringing no future benefits.

In our view, the vision outlined at the EU AAS workshop this July provides an incomplete view of the ATM sector. Therefore, we suggest that the Study should take into consideration the important developments that have taken place within and in the operating environment of the sector since the adoption of SES2. Furthermore, the role of the Study as a policy document needs to be clarified. The outcome of the study could have a potential to influence the policymaking process. We suggest that the Study strives for a holistic and long term view and focuses on creating a sustainable and future-proof aviation sector in a rapidly changing, complex environment.

We consider that a clear AAS vision can only be achieved taking into consideration the changes of and pressures coming from the wider operating environment including climate change or market forces emerging infrastructures. To this end clear links need to be established to other EU policies such as environmental and competition policies.

We are convinced that solutions proposed in the Study must be coupled with clear links to changes these would introduce to the institutional setup. I. e,. institutional framework of the vision also needs to be clarified, including the role of the Network Manager and addressing potential conflicts of interest.

While we understand that the intention of the authors of the Study is to create a vision first and to deal with technicalities such as the legal environment at a later stage, we consider that some circumstances need to be taken into consideration when developing the vision in order to propose a legally feasible solution and to enhance legal clarity. It is of utmost importance that legal clarity is achieved.

We consider that this may be ensured through the clarification of the most important aspects of the proposed transition: the scope of EU competences, clear distinction between State functions and market activities, the public interest aspect of ATM service provision, data ownership and control, and how we can avoid the creation of new global and multi-national, monopolistic service providers.

The expected benefits of the proposed changes need to be clearly defined. We suggest that structural costs are identified, quantified and taken into consideration. The Study should identify the most important risks involved in the process including business continuity, security and safety aspect of centralisation and the social aspect of automation. Risk assessment should include risks posed by digitalisation.

One major obstacle of creating flexible cross-border arrangements has been the lack of a harmonised liability system in Europe. The Study should in our view also consider the possibility of establishing such an EU wide liability regime. It is equally important that the liability aspect of digitalisation is considered, since the liability implications of digitalisation and the emergence of new infrastructures and service providers lacks sufficient clarity today.

We consider that new incentive schemes may be introduced to achieve cross-border sectorization and more environmentally efficient service provision.

II. Capacity

While Gate One members support solving the predicted European airspace capacity crisis, we consider that capacity increase requires the contribution of all involved stakeholders. Not only ANSPs are challenged in procedure and system adaptations, it requires AUs system capabilities as well to achieve this goal. Capacity cannot be the sole purpose and ultimate goal of a comprehensive Study.

Gate One members suggest that a target capacity needs to be defined and it should be clarified how the proposed solutions help to achieve that target capacity. When defining the optimal level of capacity, the trade-offs between capacity and environmental considerations as well as capacity and cost-efficiency need to be properly justified.

Gate One members agree with the statement that network predictability needs to be enhanced through strengthening traffic forecasting and ensuring better co-ordination between stakeholders and a straightforward flight-planning process. Along with the coordinated ATC with increased automation and prediction across the system, peaks overloads shall be avoided. Therefore short-term reactions or rather avoidance of peaks shall stay in the hands of ANSPs, leaving the Network Manager the role of pre-tactical and strategic ATFCM. The problem of non-European traffic flows inbound to and/or overflying Europe should be tackled. Overloads during peak periods should be avoided by flying according to the flight plans, using latest planning methods and with appropriate incentive schemes for airspace users.

Again, it should be acknowledged that ANSPs are not the only cause of capacity shortages and they alone cannot solve the capacity crisis: the contribution of all stakeholders is needed to optimize network performance.

III. EUIR

Gate One members consider that the EUIR concept should be clarified to not generate any ambiguities and should be based on the broadest possible consensus of Member States and stakeholders prior to any decision or recommendation on that subject. We would like to point out that while the concept may be politically problematic, it does not create much added value in solving the capacity crisis. Furthermore, the capacity problem will not be resolved focusing on the upper airspace only, but shall consider a holistic and seamless use of the upper and lower airspace instead.

IV. Technology: a tool rather than an objective

Gate One Members see the need to further develop and promote operational concepts and solutions to be derived from the ATM Master Plan. In Gate One’s view, the Study should define what problem each proposed technological solution is intending to address. Interoperability, automation and other new technologies should be considered tools for realizing the vision rather than objectives in an approach characterized by technological determinism.

V. The Human Factor

Gate One members suggest that the Study should define a clear vision in respect of the role of humans in ATM service provision, including the evolution of the ATCO’s role, from executing to monitoring and flow management and the new roles for humans due to increased automation. It would also be essential to address the need for change management, the social aspect, and the evolution of the human-machine relationship.

Gate One CEOs met in Budapest

GO CEO BudapestPress release

The Gate One CEOs met on May 11th in Budapest to discuss high level ATM issues relevant for the Gate One region. The conference was dedicated to share views and formulate common positions on significant topics such as the new Network Functions Implementing Rule and RP3 preparation, and developments of the Digital Single European Sky concept. Gate One CEOs also expressed their view of the future ATM environment and fundamentals of the new CANSO Strategy. For the next one year term, Gate One chairmanship will be undertaken by Mr Kornél Szepessy, CEO of HungaroControl.

Gate One Views on the new legal text proposal for the NF IR

At their meeting in Budapest on the 11th of May 2018, the CEOs of the Gate One partners agreed on a joint position on the draft proposal of the new Network Functions Implementing Rule that the European Commission recently tabled for discussion.  
The draft proposal, which came after almost a two-year revision process that included several evaluations of the network functions, consultations during the Single Sky Committee meetings as well as a dedicated workshop, introduces a number of changes that are of a shared concern among the Gate One partners.
The Gate One partners´ reservations, detailed in the common position, are related to the revised governance arrangements (role of the Single Sky Committee and composition of the Network Management Board), ambiguity concerning a new Network Function – the ATFCM and the separation of the Network Functions from the Network Manager, proposed consultation of the Member States and the process of adopting remedial measures, as well as the process of the Network Manager appointment withdrawal.   
Given the significance of the network functions for the air traffic management in Europe, the Gate One partners share their view that the proposed draft Network Functions Implementing Rule should be further revised in order to address the identified concerns and ambiguities.  

Gate One partners share common guiding principles for legislative changes foreseen for Reference Period 3 (RP3)

Press release

Realizing the great importance of the ongoing process of amending the Single European Sky performance and charging regulatory framework for the third reference period, Gate One partners decided to support the process by agreeing on a common position and sharing it with all the stakeholders involved.  

The position involves a set of principles Gate One partners would strongly encourage to be reflected during the process of amending the Performance and Charging Schemes.

The principles refer mainly to simplification of both regulations in terms of setting clear and universal rules for all pertained stakeholders, focus on local level, more balanced approach to respective categories of targets, or introduction of simpler, more automatic mechanism of revision of performance targets during the reference period.

Gate One partners support the more comprehensive position of CANSO and are open to discussion throughout the preparation of aforementioned pieces of legislation.

M-NAV and SMATSA joined Gate One

The members of the GATE One (GO) initiative, which is one of the largest regional ANSP platforms in Europe, agreed to play a more active role to explore potential for future inter-FAB cooperation. 
 

The CEOs of the GO Initiative which includes designated ANSPs covering 3 existing FABs (Baltic FAB, Danube FAB and FAB CE) and 2 non-EU FIRs (Belgrade and Skopje) - at their meeting in Sofia on 3rd December agreed to strengthen their operational and technical cooperation. As a pilot common project the CEOs proposed to launch a study to synchronize cross-border Free Route (FRA) implementation in the region for the airspace serviced by GO members. The participating CEOs went along with the opinion to keep GO as a cooperation platform.
„The ANSP members supported the proposed vision, which will allow us to work more closely together among others for airspace optimization, thus to be able to offer the best possible longer term ATM solutions for our airspace users” – said Miroslav Bartoš, Chairman of the GO CEO Committee meeting.
GO members will continue with their ongoing FAB development and national ATM improvement projects. GO FRA shall be developed on top of the existing ATM efforts being a kind of regional FRA umbrella project. It will be built step by step, making best use of the lessons learnt from similar regional initiatives and to get common benefits from SES/SESAR deployment.    
Another significant outcome of the meeting was the accession of SMATSA (the Serbian-Montenegro ANSP) and M-NAV (Macedonian ANSP) to the GO initiative. „We are very pleased to join the GO initiative, thus we can act as a bridge between our region and other initiatives. We look forward to working on airspace defragmentation together with all GO members. Our airspace is an important transit corridor and we need to develop a synchronized FRA Concept of Operation in close cooperation with our neighbouring ANSPs.  For us, GATE One is also a „door” which can bring us to a future pan-European Single Sky” – stated the SMATSA and the M-NAV delegation.
Sofia, 3rd December 2015