Gate One Position Paper on The ATM Data Services Provision Concept

This position paper on the ATM Data Services Provision (ADSP) concept contains Gate One ANSPs´ expert insight and recommendations, which the Gate One Members believe should be taken into consideration in the interim and final reports of the study on the “Legal, economic and regulatory aspects of ATM data services provision and capacity on demand as part of the future European airspace architecture,” commissioned by the European Commission.  

Gate One Members support the overarching objective of the European Airspace Architecture Study (EAAS) aimed at addressing the current capacity issues and at preparing the European ATM system for the future traffic growth. Gate One Members believe it is pivotal to have a roadmap of actions the European Commission is undertaking not only following the publication of the final report of the study in June 2020, but also in relation to the future evolution of the Single European Sky.

Based on the events related to the study and the available information so far there are several aspects of the study that Gate One would like to appreciate:

  • Common ATM data service layer would enable enhanced ANS flight and other information management capabilities where clear business case exists.
  • Possibility for ANS providers to choose from which ATM data service provider to purchase data and further automated functions – or retain this functions in their portfolio – could give them more freedom.
  • Creation of an ADS market could bring new business opportunities for today´s ANSPs, which can provide their services also externally – on their own, in cooperation with other ANSPs and/or the industry, while fostering innovation & development of new services and applications for the benefit of all stakeholders.

Gate One Members would like to express their views on some key points that should be addressed in the interim and final reports of the study:

  • Safety first - To ensure safety, quality, service continuity, efficiency, (cyber)security etc. of the operations, ADSP should fulfil the ATM/ANS Common requirements and should be subject to the corresponding certification process. Liability issues (e. q. data quality) must be legally solved.
  • Realistic expectations: - The goal of the ADSP concept should be set realistically, including defining clearly the specific problems the concept aims to address. It should be clearly elaborated how the ADSP concept would enable in a more efficient way Virtual centres and Capacity-on-demand concepts compared to the current ANS provision, where cross border operations, data sharing and virtualisation become more and more explored. There should also be a clear analysis, including appropriate business case, with regards to the benefits of decoupling to the key performance areas. The current and future costs of the ATM data processing are also subject to realistic assessment and the voluntary principle and freedom to choose a business model should be considered therein. Clear definition of “ATM data service” boundaries should be set to enable that.
  • Clear rules for data sharing: - The applicable legislation for data sharing shall be further assessed against the various topics as described above, to provide a transparent picture and a basis for regulatory improvements and harmonisation. This shall include questions with regards to military and conditions and costs for providing raw data.
  • Fair and Robust Regulatory Framework: - The ADSP concept should be integrated in the Performance & Charging Scheme subject to a thorough analysis of various factors. Any integration should not affect the performance of the ANSPs and should not change the assumptions already in place for the on-going RP3. For the next period, balanced regulatory framework must be prepared. It is important to identify and explain how incentives for early movers, outlined in the EAAS, will be provided in the future ADSP regulatory regime.
  • Freedom to choose the business model - The ANS providers should have the possibility to choose between contracting external ADSP and maintaining internal service provision as is today. The current ANS providers should have equal right to act as ADSP as the industry. In addition, models of ADS provision considered by the study vary substantially, especially with introduction of the union-wide model. It should be analysed and supported by a clear business case, which model - including financing mechanism - will be preferred, as it will affect decision-making of ANSPs.
  • Protected competition: - The risk for a potential market monopolisation stemming from the ADSP concept and entry of new aggressive competitors should be thoroughly assessed and mitigated. Only then the goals for efficiency and technological advancement could be achieved.

Successful Gate One CEO meeting in Sofia takes collaboration among the region’s leading ANSPs to the next level.

9-10 December - CEOs of 13 ANSPs from Central and Eastern Europe, members of the Gate One Coordination Platform, met in Sofia, Bulgaria to discuss their strategic objectives and working programme in the context of the changing environment of the Single European Sky. During the meeting CEOs agreed on the importance of strengthening the strategic position of Gate One at European level and its cooperation techniques, bringing operational benefits towards the fulfilment of SES and emphasising its pivotal role as a key player in the decision-making processes in European ATM.
Chair of Gate One and CEO of HungaroControl, Kornél Szepessy stated: “This regional ANSP cooperation platform is the foundation of our common success. As we are getting ready for future challenges, collaboration has never been more important when working out emerging concepts in ATM or creating the ANSP business model of the next decade. The Gate One Work Programme for 2020 will enable us to tackle the capacity crisis and strengthen our strategic positions in coordination with CANSO Europe.”
The meeting in Sofia made for a fruitful discussion on Gate One’s action plan for 2020, stressing on the pertinence of voicing common positions on prevailing topics such as emerging concepts in ATM, new business models for Air Traffic Data Service Providers, the future economic regulation on the ANSPs and the future of the Single European Sky.

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Common Gate One position agreed in shaping future Single European Sky legislation package

Bucharest 3 June 2019 – Gate One coordination platform - CEOs of thirteen ANSPs - agreed on common positions on the Airspace Architecture Study and the Report of Wise Persons Group. Both these documents will play a crucial role in shaping future Single European Sky legislation package, which is to be prepared by the European Commission. Gate One also agreed that they support high level structural changes in European ATM and consider it an opportunity to which they would like to contribute in a constructive manner. Gate One partners will continue to closely collaborate within CANSO Europe to its advocacy activity, as they constitute a substantial part of its membership.

Ms. Regula Dettling-Ott, Chairperson of the Performance Review Body of the Single European Sky, Mr. Razvan Bucuroiu, Head of Network Strategy and Development Division of the Network Manager and Ms. Tanja Grobotek, Director of European Affairs of CANSO discussed together with Gate One partners about the future of the European Airspace in the context of the Airspace Architecture Study and Wise Persons Group Report. In the discussion they focused on future of European ATM, changes necessary to enable further development of the sector and their impact on the existing regulatory framework. ANSPs of the region, represented in the Gate One coordination platform, have seen a high traffic increase in the past years, but have managed to cope with it and contribute to the overall European ATM capacity.

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Gate One Position on the Wise Persons Group Report
Gate One Position on the final version of the Airspace Architecture Study Proposal

 

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.