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.
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.
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.