Brussels, January 18, 2008 ETF-POSITION PAPER ON EASA NOTICE OF PROPOSED AMENDMENT (NPA) No 2007-16 Extension of the EASA system to the regulation of Air Traffic Management and Air Navigation Services (ATM/ANS) The purpose of this NPA is to find and develop appropriate regulations and rules by the EASA (European Aviation Safety Agency) while extending its scope to the safety and interoperability of Air Traffic Management and Air Navigation Services (ATM/ANS). Hereby, the EASA is directly involved in the rule-preparation process and assists the Commission in its executive tasks by defining specified amendments and draft regulations. Though the text of this NPA has been developed by the EASA, it is submitted for consultation of all interested parties in accordance with the appropriate Basic Regulation and Articles of the Rulemaking Procedure in the European Communities. Therefore, the EASA has called all the stakeholders concerned, to work out comments on the content of NPA 2007-16 and send them in before 21st January 2008, in order to support the Commission by the provision of an Agency opinion in due time, to meet its own objective to issue a legislative proposal addressing the safety regulation of Air Traffic and Air Navigation Services before this summer 2008. ETF and her member organisations all across Europe have analyzed and evaluated NPA 2007-16 very carefully and focused the nucleus of their comments and statements by answering all the 10 questions explicitly asked by the EASA in its document, now being listed as followed: 1. The establishment of the concept of operations should rest with the air traffic control service providers since it is them to have the expertise necessary to model and define the operations. The definition of the objectives that has to be met by the concept of operations should also rest with the air traffic control service provider since they must manage the requirements and expectations of the various stakeholders who may have conflicting requirements. The authority to proceed with the implementation of a given concept of operation should require regulatory agreements since the scope of service provision is greater than the technical solution of it and the air traffic service provider can only be really accountable for the appropriate service associated with the technical solution concerned.
President Wilhelm Haberzettl Vice President Graham Stevenson

General Secretary Eduardo Chagas


The suggested essential requirements cover a wide range of topics and do certainly constitute the basis for further progress work on it. Nevertheless, numerous items will have to be checked in details and sound consultation should be carried out on them. The removal of Member States being allowed to impose their own safety standards must not lead to a rounding down of standards across Europe. ETF shares the opinion that, as far as ASM (Airspace Management) and ATFM (Air Traffic Flow Management) are concerned, they are mainly to be regarded as service provision matters. But, with respect to the pan-European dimension, they obviously could produce the need to treat them as regulatory subjects as well. ETF clearly states that the definition of systems and components used in the context of the European Air Traffic Management Network (EATMN) will need to be subject to the extended basic regulation. ETF demands that the appropriate regulating authorities should be directly involved in the regulation and inspection of design, manufacture and maintenance of safety critical systems and components. There, the attention paid on the maintenance of the operational systems concerned must be higher than the one for the designers. Nowadays, within the overall European ATM-performances, all services related to ATM must be considered as safety critical up to a very high degree. ETF does not see any service related to ATM which should not be certified. That is also the reason why the ETF strictly rejects any attempt of unbundling of ATS-services, because these services are clearly involved as integrated partners in the ATM-safety chain and ATCservices are very much dependant on them in order to deliver safety and high quality standards during their daily business. Besides that, licensing of personnel (ATCOs, ATSEPs AIS staff and other jobs within the ATM-safety chain) combined with high training standards are essential and of great value to us as workers representatives. ETF thinks that it would be very useful that ATM/ANS service providers should be certified for the provision of multiple services under a single certificate. ETF agrees with the EASA in certifying pan-European ANS/ATM service providers, for example such as the Eurocontrol-CFMU function as well as future FABmanagement components of importance, too. ETF will not support any concept of so-called “assessment bodies” because we do not see any good use in the accreditation of such third assessment parties. We suggest to rely on the still existing well- experienced National Supervisors where EASA just will have to delegate some of its certification processes in the countries involved




Brussels, 14 January 2008

The ETF has read with astonishment the Commission Communication on the Single European Sky (SES)* stating that the “Community policy in aviation is a success story”. The loss of thousands of jobs and the general precariousness of the industry following liberalisation should have led the Commission to a more humble claim. It has not been a success story for the workers! This approach indicates that the European Commission assesses social aspects as negligible and that trade unions cannot expect it to take social issues into account. ETF Joint Air Traffic Management Working Group (JATMWG) President Laurence King said: “Instead of prioritising safety and capacity issues, the Commission puts forward consolidation as a major objective, thus ignoring the consequences of defragmenting the sector. The quoted reduction to 10 area control centers (ACC) out of the current 50 and the many hundreds of job losses that will follow will enable the Commission to boast a success story in the European ATM. ETF rejects this approach.” ETF Political Secretary François Ballestero added that “the ETF and its unions remain committed to the concept of the SES and to bringing enhanced capacity to the sector. Reductions in the number of ACC and the restructuring of airspace has already been undertaken in a number of member states. The crucial difference is that workers have been consulted.” “The EC is fully aware that there has been insufficient progress in the area of ‘Safety Reporting’. It is regrettable that this issue is absent in the communication because extensive and correct safety data is needed to properly assess ATM performance“, he continued. The ETF notes that the Commission rightly underlines the lack of commitment of member states regarding the removal of difficulties in the establishment of Functional Airspace Blocks (FABs). “However there has also been a complete lack of support from the European Union on the sovereignty and liability issues which have been identified”, Laurence King stressed. The ETF agrees that the environment has to be brought forward as a new and major challenge that had not been highlighted in the first package. ATM has a role to play but this should be put in the context of a general policy framework concerning air transport and all the other transport modes. The EC communication acknowledges that traffic delays have reduced considerably since 1999 and continue to remain at a very low level despite a significant traffic increase in the last years. For the ETF, the work of European ATM personnel and the efficiency of the European ATM system should be recognised at this stage and this positive result should influence the context of the SES second package. The ETF notes the nomination of a network manager, but would like the Commission to give a clear definition of this new position. The ETF would also like to see more commitment from the Commission to involve ATM personnel as key players in the future development of ATM.
The ETF represents more than 2.5 million transport workers from 223 transport unions and 40 European countries, in the following sectors: railways, road transport, maritime transport, inland navigation, civil aviation, ports & docks, tourism and fisheries. Rue du Midi 165, B – 1000 Brussels +32.2.285 46 60 +32.2.280 08 17

Once again, the EC ignores the positive role played by Social Partners (CANSO and ETF) and barely mentions the importance of social partners for the future. This role should be underlined as crucial for the FABs establishment. Ballestero concluded: “The Commissioner refused to involve Staff Representatives in the work of the High Level Group (HLG) on the Future of the European Aviation Regulatory Framework. This last Communication demonstrates that the Commission is not committed to taking account the views of ATM staff“. For more information, please contact: François Ballestero ETF (European Transport Workers’ Federation) Political Secretary for Civil Aviation and Tourism Phone: +32 (2) 285 46 65 E-mail:

(*) ETF regrets that this Communication is mainly based on the recommendations put forward by the HLG report since this report was issued without proper consultation of the ATM staff. (We recall the ETF response to this report –


Brochure FABEC

FAB Europe Central : “Redéfinir le contrôle du trafic aérien au cœur de l’Europe.”
La Brochure du FABEC en version francaise.



FAB Europe Central fleshes out its strategy
Since the official launch, in November 2006, of the feasibility study into the creation of a Functional Airspace Block in the heart of Europe (FAB Europe Central, FAB EC), the project has been taking more concrete shape. For the first time in European ANS, six States, the civil and the military air navigation service providers (ANSPs) agreed in 2007 on a common strategy and a first set of common performance targets. 2008 is also set to make history: the feasibility study is due in the summer and a Declaration of Intent by the States is scheduled this year.

Promising first results of feasibility study
The intermediate results of the feasibility study are encouraging and have convinced the FAB EC partners that their project will lead to sustainable benefits. The first deliverables of the seven Working Groups which will form the basis for the final study already show how much has been achieved by the cooperation at the level of information exchange and coordination. And the further closer cooperation that is planned in a future FAB EC presents many good opportunities, some of which can even be implemented in the short term. For example, the Operational Working Group has identified short-term (within five years) ATM capacity improvements in three high traffic density areas called «hot spots». As for the Technical Working Group, it has highlighted different areas of cooperation for the short and medium term, for example in CNS infrastructure. Indeed, the first results of the feasibility study prove the success of the bottom-up approach, one major factor for the quality of the study having been the integration of the customers’ various requirements and all the stakeholders’ opinions.

Common strategic guidelines for a «high performance» FAB EC
The FAB EC vision is becoming a reality, and its governance is to be based on a performance model. In 2007 the six States and the ANSPs involved in the project defined the common performance guidelines to follow irrespective of national boundaries within the joint FAB development in the heart of Europe. The concrete criteria and a concrete roadmap for the decisions they will have to make were developed as the result of a consultation process with the different stakeholders and customers, and presented to the public in December 2007. Defined in six areas, the first set of FAB EC performance targets is ambitious and in line with SESAR principles and technical developments. The definition of performance targets and the evaluation of their fulfilment will be an ongoing, closely monitored process.

Area Safety Environment Cost-effectiveness

Performance targets – to ensure an improved safety level, despite the growth in civil traffic – to reduce the impact on the environment by improvements to routes, flight profiles and distances flown – expected 50% increase in civil traffic by 2018 (Eurocontrol forecast) not to result in more than 25% increase in total cost based on current rules of cost recovery (leading to a 17% reduction of the real en-route unit cost) – to achieve a decrease in military ATM cost – to help to improve flight efficiency by improvements to routes, flight profiles and distances flown – to reduce the average route extension per flight by two kilometres per annum by 2010, increasing to an accumulated total of 10 km by 2018 – to meet the demand of increased civil air traffic in the range of 50% by 2018 – while taking into account the current agreed delay target of 1 minute per flight as well as military needs – to enable the improvement of military airspace use and avoid the cancellation of missions due to ATFCM

Flight efficiency

Capacity Mission effectiveness

The role of the six States
The FAB EC is a joint project by the civil aviation and military authorities of the six States and the ANSPs. While the roles of the States and the ANSPs are closely interwoven, they are clearly defined. Whereas ANSPs are responsible for the management and the agenda setting for the working groups, the six States: ? define a general common approach to the project with the five following issues to be considered regarding the long-term development and implementation of the FAB EC: 1. the performance of the FAB EC 2. the organisation of the airspace 3. the optimal model of cooperation between ANSPs 4. the military requirements 5. the future of MUAC as a part of the future FAB ? define objectives for each of the five issues to serve as guidance for the ANSPs ? provide, via their participation in the working groups, constant feedback/advice to the ANSPs, and, where appropriate, guidance on issues of specific interest ? after the feasibility study, decide on the implementation of the FAB EC.