SNNA-FO

1er-rapport-CE-SES2-20-12-07.pdf

COMMISSION DES COMMUNAUTÉS EUROPÉENNES

Bruxelles, le 20.12.2007 COM(2007) 845 final

COMMUNICATION DE LA COMMISSION Premier rapport relatif à la mise en œuvre de la législation sur le ciel unique: bilan et perspectives

1er-rapport-CE-SES2-20-12-07.pdf

Amendement-ETF.pdf

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

2.

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

Amendement-ETF.pdf

Comm-Press-ETF-SES2.pdf

PRESS RELEASE
EUROPEAN TRANSPORT WORKERS’ FEDERATION
FEDERATION EUROPEENNE DES TRAVAILLEURS DES TRANSPORTS

Brussels, 14 January 2008

THE COMMUNICATION FROM THE COMMISSION ON THE SINGLE SKY LEGISLATION IS NOT A SUCCESS STORY FOR WORKERS!
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 etf@etf-europe.org +32.2.285 46 60 www.etf-europe.org +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: f.ballestero@etf-europe.org www.etf-europe.org

(*) 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 – http://www.jatmwg.org/cgi-bin/20070802_ETFresponseHLGReport.pdf)

Comm-Press-ETF-SES2.pdf

Brochure FABEC

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

FR-Brochure-FABEC.pdf