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CANSO - Civil Air Navigation Services Organisation

CANSO

CANSO is the global voice of air navigation service providers, representing organizations that manage nearly 90% of world air traffic.

Lobbying Activity

Meeting with Pierpaolo Settembri (Cabinet of Commissioner Apostolos Tzitzikostas)

16 Dec 2025 · CANSO’s position regarding aviation priorities in 2026

Meeting with Filip Cornelis (Director Mobility and Transport) and

27 Nov 2025 · Structured Dialogue meeting, focusing on current policy developments in aviation, and suggested recommendations from airline industry

Meeting with Elena Donazzan (Member of the European Parliament, Rapporteur)

24 Nov 2025 · Incontro e scambio di vedute su Space Act

Meeting with Jens Gieseke (Member of the European Parliament)

5 Nov 2025 · Austausch zu EU-Politik

Meeting with Maria De Las Flores Diaz Pulido (Head of Unit Mobility and Transport)

28 Oct 2025 · Future of ATM, performance and charging, ATCO and NFIR

Meeting with Ekaterina Zaharieva (Commissioner) and

22 Oct 2025 · • R&I funding perspectives for the future MFF, including future Joint Undertakings • Presentation of the Aviation R&I strategy

Meeting with Andreas Schieder (Member of the European Parliament)

15 Jul 2025 · Field Visit

Meeting with Cynthia Ní Mhurchú (Member of the European Parliament)

15 Jul 2025 · Visit to Belgian Air Traffic Control

Meeting with Cynthia Ní Mhurchú (Member of the European Parliament)

3 Jun 2025 · EU Aviation Night

Meeting with Filip Cornelis (Director Mobility and Transport) and

13 May 2025 · Effects of shifts in traffic flows on aviation performance, Increasing importance of civil/military integration/requirements, SES, ATC, SESAR post 2027, ATM MP

Meeting with Jan-Christoph Oetjen (Member of the European Parliament)

29 Apr 2025 · Podcast recording - EU aviation topics

Meeting with Magda Kopczynska (Director-General Mobility and Transport) and Polska Agencja Żeglugi Powietrznej

17 Mar 2025 · Discussion with PANSA and CANSO representatives (together with their members from Germany and Croatia) on the challenges facing the ATM service providers. Site visit of the PANSA facilities.

Meeting with Jan-Christoph Oetjen (Member of the European Parliament)

6 Mar 2025 · Challenges in the aviation industry

Meeting with Filip Cornelis (Director Mobility and Transport) and

6 Feb 2025 · DESTINATION 2050 updated roadmap

Meeting with Elissavet Vozemberg-Vrionidi (Member of the European Parliament, Committee chair)

5 Feb 2025 · Air Traffic Management

Meeting with Peter Liese (Member of the European Parliament) and CEMEX, S.A.B. de C.V. and Techem Energy Services GmbH

2 Dec 2024 · Austausch

Meeting with Magda Kopczynska (Director-General Mobility and Transport)

13 Nov 2024 · • SES2+ • ATM master plan • Air traffic

CANSO urges removing air traffic management from aviation labelling scheme

22 Oct 2024
Topic — The consultation details a methodology for a voluntary environmental labelling scheme for flights.
Message — The organization calls for the reference to air traffic management to be removed from the regulation. They highlight that fuel-saving measures often depend on decisions taken by the pilot or airline.12
Why — This would shield air navigation service providers from accountability for emissions factors outside their control.3
Impact — Travelers would lose visibility into how air traffic management efficiency affects the environmental impact of flights.4
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Meeting with Jens Gieseke (Member of the European Parliament)

7 Oct 2024 · Austausch zur Verkehrspolitik

Meeting with Magda Kopczynska (Director-General Mobility and Transport)

16 Sept 2024 · - RP4 target setting and challenges faced by ANSPs in Europe - RP5 - SESAR

Response to Union-wide performance targets for the fourth reference period (RP4)

19 Apr 2024

CANSO members appreciate that PRB has made some improvements to its applied methodologies in comparison to the targets ranges proposals. These go in the right direction, but CANSO members are concerned that the EU target proposals are still not realistic or achievable. Safety The new EoSM questionnaire is more challenging than the current CANSO SoE. We welcome this approach, but the questionnaire should be less prescriptive regarding how ANSPs fulfill it. Due to the introduction of the new questionnaire, the Safety targets should foresee lower maturity levels before 2029 to allow time for ANSPs to adapt. Environment Analysis of historical KEA performance - Recognising that KEA remains unsuitable for target-setting, RP4 targets should not be based on the best theoretical outcome, but rather take into account actual results of 2022-2023 and an in-depth analysis of feasible improvements and their respective realistic impact on KEA. ERNIP benefits - These should be discounted as being too optimistic Capacity-environmental interdependencies - To reflect the real impact of delay on environment this calculation should be based on real 2023 CAP performance, taking into account local factors. Impact of Ukraine war - The local reference values should reflect the impact of the war, i.e. they should be higher than in a non-war situation. Incentive Scheme IR 2019/317 does not foresee a mandatory introduction - It should therefore be for the Member States to decide whether it is appropriate to introduce one and on which indicator. Capacity Allowance for weather related delay - Given the increased frequency of incidences of adverse weather, the allowance should primarily consider the most recent weather delay data, as it is the most realistic and accurate System-resilience buffer The NOP should be the basis of the CAP targets development. The PRB should then define a further level of ambition beyond that basis, which should be set at a realistic level. Recent performance - 2022 and 2023 have to represent the major element compared to the values from earlier years. The values chosen for RP4 should reflect the existing and known problems of the ASNPs. Capacity constraints / Delay hotspots - to set realistic targets, the system resilience buffer should be based on a calculation of the impact of known capacity constraints / delay hotspots. Cost Efficiency Baseline value 2024 PRB should clarify the methodology for its cost forecast for the six Member States which did not update their determined RP3 costs for 2024. 2029 Cost base forecast - The proposed CEF target should be recalculated, taking into account additional costs for additional traffic forecasted, respectively a consideration for the specific national traffic foreseen in the new STATFOR base scenario Long-term DUC trend - Non-linearity of the costs compared to the traffic - The DUC criteria were developed for a situation with continuous traffic increase, not for evaluating economic performance when traffic at the end of an RP is close to or lower than the starting point. The long-term DUC trend is clearly impossible to reach for those ANSPs most impacted by the Ukraine war or otherwise limited by recovery from the pandemic. Cost base inefficiency - Due to serious shortcomings, the EC should disregard this calculation of cost base inefficiency based on the academic study. - CANSO supports the PRBs proposal (para. 138) that additional means may be needed by some Member States to improve capacity, which could be allowed on a case-by-case basis, even though they are not reflected in the target proposal. Comparator Groups PRB should explain in detail the new arrangement of the Groups and how it will use these in its assessment of the performance plans Alert thresholds Rather than waiting for the full impact of a change which may lead to triggering the alert thresholds, countries should be allowed to revise their plan once the change can be reasonably foreseen.
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Meeting with Jan-Christoph Oetjen (Member of the European Parliament)

19 Feb 2024 · Exhibition: "Drones - Innovation to Shape Our Future Skies"

Meeting with Magda Kopczynska (Director-General Mobility and Transport)

8 Feb 2024 · - SES 2+ - SJU and Innovation - Sustainability

Meeting with Henrik Hololei (Director-General Mobility and Transport)

8 Mar 2023 · SES 2+ legislative package

Meeting with Isabel García Muñoz (Member of the European Parliament)

25 Nov 2022 · Drone Strategy

Meeting with Isabel García Muñoz (Member of the European Parliament, Shadow rapporteur)

11 Oct 2022 · TEN-T Revision

Meeting with Adina-Ioana Vălean (Commissioner) and

13 Jul 2022 · Aviation Dialogue

Meeting with Henrik Hololei (Director-General Mobility and Transport)

27 Jan 2022 · Aviation recovery

Response to Count your transport emissions: CountEmissions EU

17 Dec 2021

Europe’s aviation industry, including CANSO, has committed to decarbonise air transport and accelerate efforts to make Europe a carbon neutral continent by 2050 through the reduction of CO2 emissions in absolute terms, supported by a robust decarbonisation roadmap published in February 2021. CANSO welcomes this initiative by the European Commission. It can contribute to the reform of the Environment KPI of the EU's Performance Scheme for air traffic management (ATM), which is no longer fit for purpose. CANSO calls to avoid duplication of initiatives. We support the current work of the ATM/ANS Environmental Transparency Working Group chaired by EASA and EUROCONTROL, in which many CANSO members participate. Pillar 1 of this WG addresses 'How Providers identify environmental inefficiencies where they are responsible, or where responsibility is shared, and how they measure improvement based on certain performance criteria'. This Pillar is assessing: - Network performance indicators: How ANSPs manage traffic strategically across the airspace network - Operational tactical indicators: How ANSPs manage traffic tactically (partly dependent on airspace design) - Airspace infrastructure indicator: How ANSPs decide to use Communication, Navigation and Surveillance infrastructure - ground/space based This WG is due to conclude its work in 2022, and we call on the Commission to take account of its final report before undertaking any work on calculating GHG emissions attributable to ATM.
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Response to A Drone Strategy 2.0 for Europe

28 Jun 2021

CANSO welcomes the initiative of the Commission to adopt a Drone strategy 2.0 to develop drones into a vector for the smart and sustainable mobility of the future. CANSO generally supports the roadmap but would like to request to include ANSPs in the list of stakeholders to be consulted (see C. Better Regulation - Consultation of citizens and stakeholders) as it is clear that ANSPs have a relevant role to play in the drone services industry. Furthermore, we believe it is paramount that the strategy recognises the importance of integration of UAS/UAM with manned operations. For example, in Section B “What does the initiative aim to achieve and how”, we would expect that the second paragraph would refer explicitly to the specific need to ensure that any comprehensive policy package includes the scalable integration of UAS/UAM with manned aviation operations as an important success factor. Finally, a reference to a future charging scheme could be included. We understand that this subject is under the SES II+, nevertheless section “B. What does the initiative aim to achieve and how”, last paragraph could have a reference to it by adding: financial (charging model), for example: Currently, there is a growing number of sectors affected by the take-up of drones. To encourage private sector investments and development of new innovative services for different sectors, financial (charging model), legal and technical certainty based on a harmonised EU approach should be ensured.
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Meeting with Henrik Hololei (Director-General Mobility and Transport)

17 May 2021 · SES

Meeting with Marian-Jean Marinescu (Member of the European Parliament, Rapporteur)

17 Mar 2021 · SES2+

Response to Union-wide performance targets for the air traffic management network for the third reference period

15 Mar 2021

“It is not possible to predict when depressed demand will end”. This European Council statement from 27 January 2021 is compelling and remains accurate given the continued uncertainty. Revised RP3 targets should allow ANSPs flexibility to meet traffic demands during RP3 while preparing for RP4. Given ANSPs’ service obligations, it is not appropriate for them to make excessive short-term cost reductions that can only be reversed over several years. In Recital 9, the EC acknowledges the need to take account of interdependencies between KPAs in setting the new targets – this proposal fails to do this. Under the cost-efficiency targets a 10% reduction to a total EU-level yearly cost base of €5.64bn is not achievable without serious, undesirable consequences in the capacity and environment KPAs. ANSPs would have to reduce staffing and postpone/cancel investments needed to accommodate traffic recovery later in RP3. These measures would take years to reverse, hurting airspace users under all scenarios. Safety: Even without guidance on the interdependency between safety and other KPAs, CANSO supports the EC’s proposal. Safety will always be CANSO members’ top priority. Environment: CANSO does not support the proposed environment targets as the ability to meet them lacks analysis. While the proposed targets could be perceived as a small revision, they represent a significant additional challenge for ANSPs in the context of extreme pressure on cost-efficiency. Many factors under the environment KPA (e.g. use of FRA by airlines) are beyond the control of ANSPs. This is clearly visible in the 2020 results. Thus it is unrealistic for ANSPs to exceed 97.5% HFE even with extremely low traffic levels. Capacity: ANSPs’ ability to meet capacity targets is linked to their ability to invest for the future. CANSO could support the proposed capacity targets if they correlated with the proposed cost-efficiency targets. The EC’s proposal sets the latter at 10% below the 2019 baseline. Realistically, these should evolve in line with traffic recovery to support capacity targets and traffic demands in RP4. Despite the PRB’s argument around supposedly easy wins from overtime and cost of capital reductions, the cost reductions proposed would erode the ‘capacity buffers’ described by the PRB and jeopardise capacity provision when traffic recovers to 2019 levels. Cost efficiency: CANSO does not support the proposed cost-efficiency targets. In line with Recital 11 of IR 2020/1627 and the EC statement to the Appeal Committee in October 2020, due account should be taken of 2020 actual costs for target setting. The EC has failed to comply with this principle. Over half of 2020/21 has elapsed with actual costs c. 1% below 2019 actuals (c. €6.1bn). The PRB’s proposal for an overall DC base in 2020/21 of €11.2bn implies DCs for 2021 of c. €5.1bn. This is not a credible proposal. The targets should allow convergence towards 2019 cost levels in line with expected traffic recovery. Recital 23 acknowledges that ANSPs have high fixed costs and are obliged to maintain a continuous service. ANSPs have nonetheless applied significant crisis cost-cutting measures. The true scale of ANSPs’ cost reductions is not shown by the comparison in Recital 23 between 2019 actual costs and 2020 reported costs. This should instead be against the draft RP3 Performance Plans for 2020, which ANSPs began to implement in January 2020, with a higher overall cost base to address capacity. Using this, the revised 2020 costs represent a 10.5% reduction. If cost-efficiency targets for 2020/21 do not take account of significant ANSP revenue losses and deviate substantially from actual costs, contrary to Recital 11 of IR 2020/1627, this will worsen their already challenging finances. ANSPs would have to take money from RP3 annual budgets to pay airspace users. Cost reduction requirements in 2022-2024 would seriously impact ANSPs’ modernisation and decarbonisation programmes.
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Meeting with Henrik Hololei (Director-General Mobility and Transport)

22 Jan 2021 · Transport policy priorities

Meeting with Joost Korte (Director-General Employment, Social Affairs and Inclusion) and European Transport Workers' Federation and

16 Dec 2020 · aviation roundtable report

Response to Proposal for a Regulation - Mobility and Transport

15 Dec 2020

Please see CANSO's submission in the attached document.
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Meeting with Henrik Hololei (Director-General Mobility and Transport) and European Transport Workers' Federation and

26 Nov 2020 · Aviation Roundtable Report

Response to SESAR Common Project 1: Concluding the pilot phase of the SESAR deployment framework

14 Sept 2020

CANSO supports the concept of directly replacing one regulation (EU No. 716/2014) with another to increase clarity and transparency (one in, one out). The COVID-19 situation impacts on ANSPs capabilities for investment and CBAs will not be fully known at the end of 2020 and therefore we consider it necessary to reflect this in the proposed regulation through greater flexibility on implementation deadlines. The situation is expected to be clearer in 2021 or 2022 in accordance with actual traffic recovery scenarios. Therefore, CANSO recommends to introduce a business case gate for all sub AF by the end of 2022 to assess implementation feasibility according to investment capabilities, traffic demand and CBA and with the possibility to adopt corrective measures. Special attention should be paid to standardization activities, development of technical specifications and certification (considered "critical milestones" in implementation projects), with the establishment of concrete deadlines if standards are not developed in a timely manner. Please, clarify whether “new global cost-benefit analysis” is somehow related to this CANSO recommendation. In addition, relevant timelines and deadlines should be aligned with global timelines, e.g. the three FF-ICE related Services should be implemented by 2025 within CP1, while the ICAO regulation recommends implementation by 2028. A postponement to 2027 would secure ICAO recommendations while still in the timeframe of this IP regulation. One core ANSPs’ concern is the involvement of all stakeholders in a planned penalty mechanism. This implies that in addition to ANSPs, this mechanism should also affect other stakeholders (airlines, airports, manufacturers, NM) involved in the successful implementation of a CP project. However, a national supervisory authority could neither sanction a foreign airline nor a foreign manufacturer. These authorities would also have to be given the opportunity to sanction other foreign stakeholders. Such a penalty mechanism is not only inappropriate but also, in our view, completely unnecessary altogether. The fact that States are given the power to establish their own (national) penalty mechanisms in the event of potential non-compliance will lead to a non-homogeneous application across EU and will not contribute to the objective of a synchronized implementation that will benefit the entire EATMN network. CANSO requests the European Commission to clarify which other incentive mechanisms, if any at all, are meant since these EU subsidies do not meet the definition of a real incentive for the ANSP as they are directed to the Airspace User. While CANSO supports the lessons-learned based approach from the Pilot Common Project to the Common Project 1, it may be fruitful to consider analysing if the very broad policy, mandating many and detailed not only revolutions but also evolutions of the technical and operational dimensions of essential operational changes is the correct approach. In a more performance driven and more agile European ATM modernization environment it may prove sensible to look only towards mandating the most performant and revolutionary game changers in ATM for the coming decade and only those of which really require European synchronization. CANSO would be pleased to start such discussion with the Commission. This general consideration notwithstanding, we nonetheless provide detailed comments on the proposal put forward by the EC on CP1. [...] [The complete set of CANSO comments can be found in the attached document]
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Response to Definition of the Common European Risk Classification Scheme for civil aviation occurrences

5 Aug 2020

CANSO Major concerns: • The ‘ANNEX to the COMMISSION IMPLEMENTING REGULATION laying down the arrangements for the implementation of Regulation (EU) No 376/2014 of the European Parliament and of the Council as regards the common European risk classification scheme’ should describe the CONVERSION METHODOLOGY, however, currently has no content. • There is no evidence that the RAT and ERCS scores could be mapped in such a way, which enables the users of the ECRS to focus on all actual risk areas, whereas IR 376/2014 Article 7 Paragraph 5 states, that “the Commission shall take into account the need for compatibility with existing risk classification schemes” (e.g. RAT) • The application of ERCS requires detailed guidelines and training in order to achieve consistent results. Already in 2016, the participants of an ‘ERCS vs. RAT Testing Session’ with EUROCONTROL members, ‘did not manage to achieve a harmonized approach on scoring the barriers when using the ERCS’. ANSPs don´t have resources to assist the NSA´s in applying the ECRS • It should be avoided by all means that the ‘risk picture’ is falsified or distorted by any ‘conversion methodology’ (RAT-ERCS) • These regulations and delegated acts cannot be closed/formalised without having this detailed information about the conversion methodology because it might affect the interpretation that is made of them and the use of the risk assessment from organizations in the general risk assessment performed by the competent authority. • ERCS assesses the worst possible outcome of an occurrence [which for an ANSP occurrence is almost always a collision] – not what actually happened, thus ERCS cannot measure ANSP Performance or the ANSP contribution to the occurrence. • With regard to ATM/ANS related key risk areas, the principle of addressing the risk based on the ‘size’ of the aircraft and the overall number of possible fatalities, is considered as inappropriate as the ‘same’ ATC service is provided to all the aircraft, irrespective of their size or number of passengers This leads also to a wrong focus on occurrences with large a/c. Occurrences with small a/c could happen tomorrow with large a/c too The output of the safety management process is intended to inform improvement actions, but assessing worst case accident outcome means you may well focus on the wrong things when it comes to driving appropriate safety improvement actions. We should always take the approach of any accident is bad - how close did we get to having one? That’s because the incident involving two small business aircraft over the sea today may well have the same fundamental causes as the incident involving two heavy airliners over a highly dense population tomorrow. • The draft regulation states “The ERCS shall address the safety risk of an occurrence and not its actual outcome”. In our view, a systemic view including the actual outcome of an occurrence is essential in order to obtain a comprehensive picture of ATM related risks • The ERCS methodology does not consider the “ATM-recovery” (a statement of the resilience of the system) as a barrier. Also, the likelihood of the repeatability of an occurrence is not considered in the ERCS methodology. All contributing factors of an occurrence should be considered in order to obtain an extensive systemic picture • This Regulation provides for the Regulator to amend the organisations’ occurrence classifications using ERCS. This will result in the ERCS scores being used to set ANSP safety priorities. This may well be inconsistent with ANSP’s safety priorities and may result in nugatory effort if the ERCS does directly not relate to accident risk. There are also no details as to how this will be achieved and how the conversion procedure will work. • It’s unclear from the documentation how incident types will be translated into potential accidents e.g. will all losses of separation be considered in scope and potential airborne collisions? If so, that will be too crude as we
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Response to Implementation of the common European Risk Classification Scheme

5 Aug 2020

CANSO Major concerns: • The ‘ANNEX to the COMMISSION IMPLEMENTING REGULATION laying down the arrangements for the implementation of Regulation (EU) No 376/2014 of the European Parliament and of the Council as regards the common European risk classification scheme’ should describe the CONVERSION METHODOLOGY, however, currently has no content. • There is no evidence that the RAT and ERCS scores could be mapped in such a way, which enables the users of the ECRS to focus on all actual risk areas, whereas IR 376/2014 Article 7 Paragraph 5 states, that “the Commission shall take into account the need for compatibility with existing risk classification schemes” (e.g. RAT) • The application of ERCS requires detailed guidelines and training in order to achieve consistent results. Already in 2016, the participants of an ‘ERCS vs. RAT Testing Session’ with EUROCONTROL members, ‘did not manage to achieve a harmonized approach on scoring the barriers when using the ERCS’. ANSPs don´t have resources to assist the NSA´s in applying the ECRS • It should be avoided by all means that the ‘risk picture’ is falsified or distorted by any ‘conversion methodology’ (RAT-ERCS) • These regulations and delegated acts cannot be closed/formalised without having this detailed information about the conversion methodology because it might affect the interpretation that is made of them and the use of the risk assessment from organizations in the general risk assessment performed by the competent authority. • ERCS assesses the worst possible outcome of an occurrence [which for an ANSP occurrence is almost always a collision] – not what actually happened, thus ERCS cannot measure ANSP Performance or the ANSP contribution to the occurrence. • With regard to ATM/ANS related key risk areas, the principle of addressing the risk based on the ‘size’ of the aircraft and the overall number of possible fatalities, is considered as inappropriate as the ‘same’ ATC service is provided to all the aircraft, irrespective of their size or number of passengers This leads also to a wrong focus on occurrences with large a/c. Occurrences with small a/c could happen tomorrow with large a/c too The output of the safety management process is intended to inform improvement actions, but assessing worst case accident outcome means you may well focus on the wrong things when it comes to driving appropriate safety improvement actions. We should always take the approach of any accident is bad - how close did we get to having one? That’s because the incident involving two small business aircraft over the sea today may well have the same fundamental causes as the incident involving two heavy airliners over a highly dense population tomorrow. • The draft regulation states “The ERCS shall address the safety risk of an occurrence and not its actual outcome”. In our view, a systemic view including the actual outcome of an occurrence is essential in order to obtain a comprehensive picture of ATM related risks • The ERCS methodology does not consider the “ATM-recovery” (a statement of the resilience of the system) as a barrier. Also, the likelihood of the repeatability of an occurrence is not considered in the ERCS methodology. All contributing factors of an occurrence should be considered in order to obtain an extensive systemic picture • This Regulation provides for the Regulator to amend the organisations’ occurrence classifications using ERCS. This will result in the ERCS scores being used to set ANSP safety priorities. This may well be inconsistent with ANSP’s safety priorities and may result in nugatory effort if the ERCS does directly not relate to accident risk. There are also no details as to how this will be achieved and how the conversion procedure will work. • It’s unclear from the documentation how incident types will be translated into potential accidents e.g. will all losses of separation be considered in scope and potential airborne collisions? If so, that will be too crude as we
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Response to Exceptional measures RP3

5 Aug 2020

1 Cost efficiency targets In principle, CANSO welcomes the EC’s change of focus from its previous proposal regarding the Traffic Risk Sharing mechanism, which we understand will now remain as set out in Regulation 2019/317. We welcome that 2021 is also to be addressed by the exceptional measures as this recognises that the crisis will not be limited to 2020. However, greater clarity is required regarding the proposed approach to revised target setting. Our understanding is that the cost targets will be adopted virtually entirely retroactively for 2020 and 2021 with no opportunity for ANSPs to respond if costs do not meet targets. ANSPs are today responding to the crisis by addressing 2020 costs while keeping the skies open for the recovery. A retroactive target must recognise ANSPs’ actual costs incurred. CANSO calls for the performance requirements during the crisis years to be addressed at local level by NSAs. We recognise that the proposal envisages targets being established by the NSA in revised Performance Plans, but these still require consistency assessment against EU-wide targets. A one-size-fits-all approach would not adequately address the different solutions chosen by the various ANSPs, Member States and NSAs to cope with the loss of revenue. Each ANSP’s situation is different, and NSAs are best placed to judge what their appropriate cost bases should be for 2020 and 2021, including essential investments to provide future capacity. We call on the EC to ensure that the local NSA assessments and decisions are given more prominence. CANSO would be ready to support the EC in finding a solution. The revised EU performance targets for 2022-2024 should enable ANSPs to provide capacity during the recovery and to fund investment plans. It should not regard the exceptional situation of 2020 and 2021 as a precedent. 2 Timetable The timetable for the planned data and traffic forecast delivery by NSAs, new target setting and Performance Plans is not feasible. The submission of cost and traffic data by 1 November 2020 is expected to cover the full RP3 period yet there is no certainty that a STATFOR forecast will be available. If a stable STATFOR forecast is not available by October, the planned EU-wide target revision needs to be replaced by an interim process reduced in scope to cover the immediate crisis period (2020 and 2021). This needs to ensure that no further delay is caused to payments due to ANSPs, as our members have serious problems in covering liquidity from e.g. TRS carry-overs. 3 Additional monitoring CANSO recognises that the crisis requires exceptional reporting and monitoring. This should predominantly be a matter for the NSA to manage locally. The measures proposed in Article 6 to address the crisis are only acceptable on the assumption that they will not go into an excessive level of detail and do not set a precedent. Due to local differences regarding 2020-2021 cost-cutting measures, there is very limited comparability between ANSPs. There should not be any simple benchmarking of these measures and their impact. 4 Other elements We call on the EC to set out what should happen to the planned RP3 revision process if there is another significant downturn in traffic. While CANSO welcomes the proposed shortening to 5 years of the recovery for unit rate adjustments, the delay is too long before adjustments can start – if revised performance plans are not adopted until 2022, these cannot start until 2023. CANSO supports an earlier start and alternatively profiled adjustments. The use of the euro for the local breakdown of new Determined Costs KPI is not supported for ANSPs operating with another currency. CANSO calls on the EC to provide a worked example to clarify all the aspects in this response before any decision is taken. CANSO supports EU funding to ANSPs, airspace users and airports to maintain sufficient liquidity in the system during the crisis. Please see the attached file for our full-length position.
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Meeting with Henrik Hololei (Director-General Mobility and Transport)

22 Jun 2020 · aviation issues

Response to Revision of Regulation on performance and interoperability of surveillance for the single European sky

8 Jan 2020

CANSO believes that an amendment to SPI IR should not only focus on required exemptions in aircraft equipage and special conditions thereto, but also the elimination of the deficiencies for ANSPs. These were brought up already at the Commission’s Workshop in 2014 and were acknowledged at Meeting No 61 of the Single Sky Committee in June 2016 and at the Commission’s Workshop on SPI in July 2016. The required process for formal arrangements for the exchange of surveillance data does not reflect existing data distribution scenarios, such as the SURNET* landscape. Provisions lay the responsibility for data quality on the delivering provider, disregarding the need of the user of these data. The user alone determines the required data quality that his systems and applications need, depending on the provided support (e.g. for safety net purpose, situational awareness or separation service) and can ensure that the delivered data are suitable. This is reflected by Article 4 (3) in setting the performance requirements at the output of the surveillance chain. Note * SURNET landscape means the data communication infrastructure put in place for the exchange of surveillance data between contracted parties. Multiple civil and military partners deliver relevant data into the network and the users choose the data and ensure the required quality of these data before they are forwarded to their surveillance data processing systems. Therefore, we ask the Commission to incorporate in their amendment to the SPI IR also a replacement of Annex IV – as was proposed by the EASA “Final Report - Revision of the SPI Regulation -RMT.0679 – Surveillance, performance and interoperability - December 2017”, in order to eliminate constraints with regard to data sharing agreements between ANSPs. Otherwise, a positive opinion about the proposed amendment is not possible. ANNEX IV shall be replaced by the following: Requirements for the establishment of formal arrangements referred to in Article 5(2) Formal arrangements between air navigation service providers for the exchange or providers of surveillance data shall include the following minimum content: (a) the parties to the arrangements; (b) the period of validity of the arrangements; (c) the scope of the surveillance data; (d) the sources of the surveillance data; (e) the exchange format of the surveillance data; (f) the service delivery point of the surveillance data; (g) agreed service levels in terms of the following; — surveillance data performance as established by Art 4(3) — procedures in case of unserviceability, (h) change management procedures; (i) reporting arrangements with respect to performance and availability including unforeseen outage; (j) management and coordination arrangements; (k) ground-based surveillance chain safeguarding and notification arrangements.
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Response to European Partnership for Integrated Air Traffic Management

27 Aug 2019

CANSO welcomes the initiative of the Commission to establish a European Partnership for Air Traffic Management under the umbrella of Horizon Europe. We believe that the work done by the SESAR Joint Undertaking (SJU) needs to be continued as the future research and innovation programme for ATM will still - due to its nature - require a close coordination. It is essential that the systematic approach established by SESAR is kept and even strengthened in order to successfully address the challenges of the coming decades,i.e. the realisation of the Digital European Sky. The following aspects are considered success critical for a new European Partnership: • Build on the experience of the SJU, i.e. proven processes and structures, stakeholders and key personnel. The SESAR programme, under management of the SJU, has been instrumental in bringing together industry stakeholders. Only under the SJU has it been possible to create ATM strategic plans with the necessary cross-industry buy-in. It has enabled the execution of coordinated R&I to validate the necessary ATM solutions applicable across the network, thereby generating important economies of scale. • An ATM focused partnership is vital. As is well known, ATM has specific challenges that need to be addressed in further R&I activities. This includes the further development of digitalisation and automation solutions for future ATM performance in all main dimensions (safety, capacity, environment and cost efficiency) and in the context of significantly heightened pressure on aviation as a whole to demonstrate maximum environmental efficiency. Particular challenges also exist to address the still evolving need to accommodate and promote new classes of airspace users (e.g. drones, urban air mobility and sub-orbital flight). These are specific challenges best addressed by a dedicated ATM partnership. • Accelerate the pace of development by significantly reducing bureaucracy and administrative overhead (e.g. repeated cumbersome tendering processes, generic reporting cycles and short-term budgets) and allow for lean fast tracks • Allow for comprehensive programme coordination beyond projects • Strengthen the governing role of the operational stakeholders, they are accountable and thus ensuring focus on solutions which are essential to achieve the objectives • Address the different nature of standardisation and industrialisation processes for airborne and ground system solutions • Support a seamless standardisation and industrialisation process for ATM systems driven at EU level jointly governed by the operational stakeholders (ANSPs, airspace users, airports, military and the Network Manager) • Contribution from the industrial partners will remain crucial • Finally, in today's constellation, the Social Partners representing the "human in the loop" is small and could be reinforced. In the same spirit, the availability (and the financing) of the final users, the Airspace Users must be considered. The future arrangements should improve the efficiency of the R&I coordination and address the shortcomings identified in the ECA report on SES (e.g. Rec.9 Prioritize EU support to R&D solutions that promote defragmentation and a competitive environment). It is important to get more clarity about the possibility of participation in the new European Partnership. With the SJU construction it was only possible to become a member if the organisation also made a commitment to make a significant contribution. This raises a threshold that is disadvantageous for small organisations. The partners in future activities should not be limited only to EU Member States’ organisations. The contributions from associated countries that are not EU members should be allowed in order to have European wide developments, e.g. as recognised by Regulation 2019/123. It is also important that research results, including interim results, are fully available to the widest possible number of stakeholders.
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Response to Evaluation of Regulation on reporting, analysis and follow-up of occurrences in Civil Aviation

22 May 2019

CANSO welcomes the evaluation of Regulation 376 and offers the following comments: 1. Purpose and scope: - Interrelation with EU regulation No. 373/2017 should be considered, which is not explicitly mentioned. Given that the consultation is scheduled for 2020, it is proposed (if possible) to extend the time of scope at least until 30/03/2020, precisely so that there is opportunity to evaluate the above. 2. Consultation of citizens and stakeholders: - In the framework of the above, we would like to be able to address the difficulties encountered so far in the application of the regulation, as well as the unclear points that this regulation presents. - Due to the generic and ambiguous nature of several of the articles, we would like the evaluation to provide assurance that the application is being homogeneous in the different States to avoid being subject to “over-supervision” as an organization. 3. Data collection and methodology: - We would like to suggest to add as an input the activity carried out by the organisms defined in article 16.12, given that according to article 16.13 they must also issue a report of their activities on 15/05/2019. - It is observed that the data collection is excessively focused on the data available to EASA and high level committees to which the supervisory bodies have access, but not the organizations-ANSPs. The latter should gain more weight in the data to be considered. - Despite the title of the section, nothing is specified about the evaluation methodology to be used or the aspects to be considered. In this last aspect, it might be appropriate to see an analysis of the effectiveness of the measures provided for in the regulation (for instance: in terms of reducing the number of air accidents, which is precisely what is allegedly it is subject to evaluation according to article 24.2) vs. the associated cost of applying such measures that considers the opportunity cost, given that the resources of the organizations are not infinite.
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Response to Decision setting the Union-wide performance targets for the third reference period 2020-2024

25 Mar 2019

CANSO welcomes the consultation on the draft EC Implementing Decision setting EU-wide targets for the third reference period of the Performance and Charging Schemes. However, CANSO is disappointed that the ambition level of the proposed targets is unrealistic and not supported by strong evidence. The cost efficiency target for RP3 sets a continued downward cost trend despite all stakeholders and the entire political community agreeing that the focus for RP3 needs to be on enhancing capacity provision to minimise ATFM delays. This disregards the significant cost-efficiency improvements achieved by ANSPs through RP1 and RP2 (15% unit cost reduction by 2017 based on latest actual data – real terms). The proposed level of ambition is likely to perpetuate and exacerbate the current capacity situation by not providing for the required capacity enhancements and investments in future technology and system platforms. CANSO would like to state the following points addressing the proposed targets across the 4 Key Performance Areas (KPAs) of Safety, Environment, Capacity and Cost efficiency: o Safety – The proposed targets can be supported, Safety Levels C/D represent an acceptably ambitious challenge under the new scheme; o Environment – The ambition level is considered excessively high in the context of RP2 performance as well as in light of the potential impact of NM planned measures to address capacity issues in early RP3. The impact on the KEA of the rerouting determined by the joint NM/ANSPs initiatives for summer 2019 appears underestimated. The interdependencies between the ENV KPI and factors like traffic evolution and capacity enhancements remain essentially unexplored. o Capacity – The target proposal is not realistic; the NM’s modelled performance for all years exceeds the proposed EC targets by a factor of 4-5 in all years and for 2020 by a factor of 3 even when mitigated by the planned NM initiatives. In this context, the negligible relaxation of the annual targets to 0.9min/flight in 2020 and 2021 (reducing to 0.5 in 2023 and 2024) is wholly unrealistic. The basis for these targets continues to be the stated system-wide optimum delay average of 0.5 mins delay/flight. As average weather related and network disruptions delay are estimated statistically at 0.47 min/flight per year by NM, this leaves only a minimal delay share for ANSPs causes. This is clearly not realistic. o Cost efficiency – The ambition for RP3 is also not realistic with the currently proposed baseline value for 2019; the determination of the baseline value is not transparent as it does not reflect approved RP2 performance plans nor actual cost estimates provided by Member States for the years 2018 and 2019. The required actions for ANSPs to meet the levels of DUC efficiency implied by the EC Decision are likely to have adverse consequences for service delivery with implications for capacity and delay. In our view the evidence basis contained in the updated PRB advice does not provide further evidence in support of proposed EU-wide targets; methods and calculations continue to rely on theoretical models at the expense of empirical data provided by NSAs and the NM. Furthermore, we regret that interdependencies across the 4 KPAs have not been explored further. For instance, lessons learnt from RP2, with the strong focus on the cost side leading to a degradation of the capacity levels, is missing from the PRB analysis. Finally, the proposed targets are not compatible with the longer term challenges requiring efforts during RP3 to prepare for and create a platform for the potential longer term structural changes envisaged in support of e.g. the Airspace Architecture Study recommendations. Please find attached the CANSO note setting out our detailed views on the proposed EU-wide targets and associated PRB updated advice.
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Response to Single European Sky performance and charging scheme

22 Nov 2018

CANSO has significant concerns regarding the Commission’s proposals for the Performance & Charging Regulation: Consistency assessment of performance plans CANSO does not support the proposed use of very specific criteria based on uniform deviation thresholds to be applied for all plans without consideration for local circumstances. The proposed criteria are highly complex, mechanical in nature, too focused on individual KPAs and are likely to lead to unintended consequences, e.g. the PRB’s assessment would be driven only by a narrow focus on the values without proper consideration of the underlying factors and justifications. Consistency of targets should be assessed based on the merits of the justifications in each plan taking the whole plan into account. The criteria need to include the possibility for NSAs to deviate from the proposed mathematical approach if this is well justified by national/local circumstances. Changes to the incentive mechanism CANSO has serious concerns around the core of the proposed scheme. The financial incentive scheme remains asymmetric with parameters determined by the Commission. This has consequences in that ANSP cost of capital will be higher to compensate for the additional financial risk and lead to higher prices for airspace users. The use of NOP-based pivot values is also of concern as, based on our understanding, it could have serious adverse effects on the effectiveness and integrity of the cooperative decision making process that is central to establishing the NOP. At the same time, it adds risk to the ANSP and reduces transparency for airspace users and the NSA. Changes to traffic risk sharing CANSO does not support the +/- 2% dead-band and the 15% traffic variation limits which raise the potential ANSP revenue risk from 4.4% to 5.9%. Taking into consideration that with the greater traffic volatility observed in recent years traffic forecasts are inherently less reliable and now limited to the use of STATFOR forecasts, too much risk is transferred to the ANSPs. This will raise the cost of capital and hence prices for airspace users for no benefit. Treatment of new investment costs CANSO remains concerned about the definition and treatment of costs of “new” investments, e.g. the asymmetry in the treatment of deviations in actual costs. This approach would carry additional implementation risks for ANSPs, involve great administrative burdens with a risk of a continued lack of transparency and potentially unintended consequences. Revision of plans during the RP In CANSO’s view the proposed process does not sufficiently address the problems with delayed decision making that a number of Member States encountered during RP2. The proposals do not compel the NSA, where the thresholds are reached, to carry out a proper review of the plan and to establish that the assumptions still hold. The prospect therefore arises that an application for a revision is either delayed or abandoned and it is then potentially too late to mitigate significant performance effects. Where alert thresholds are reached there should be no delays in assessing whether the plan needs to be revised. Simplified charging scheme It remains unclear how the proposed simplified charging scheme would be applied. CANSO has significant concerns as the establishment does not require the agreement of the ANSP. It also consists of asymmetric traffic and cost risk sharing models, transferring up to 99% of traffic risk and 100% of the cost risk towards the ANSPs. Changes to the treatment of CEF funding CANSO does not support the proposal to only allow the retention of administrative costs that were not in the determined cost base. This situation would only occur if support staff for the management of CEF applications were only engaged during the reference period. This unrealistic and effectively means that ANSPs will not be able to claim for any substantial administrative cost elements.
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Meeting with Henrik Hololei (Director-General Mobility and Transport)

27 Aug 2018 · RP3

Meeting with Henrik Hololei (Director-General Mobility and Transport)

2 Jun 2018 · general aviation issues

Meeting with Henrik Hololei (Director-General Mobility and Transport)

24 Jan 2018 · SES Performance

Meeting with Joshua Salsby (Cabinet of Commissioner Violeta Bulc) and European Transport Workers' Federation and Air Traffic Controllers European Unions Coordination

7 Jun 2017 · aviation package

Meeting with Henrik Hololei (Director-General Mobility and Transport)

22 May 2017 · Single European Sky

Meeting with Henrik Hololei (Director-General Mobility and Transport)

14 Sept 2016 · SES policy and social issues

Meeting with Violeta Bulc (Commissioner) and

2 Jun 2016 · European sectoral social dialogue committee for Civil Aviation (SSDC)

Meeting with Violeta Bulc (Commissioner) and

24 Feb 2016 · Meeting with European Air Navigation Service Providers represented in CANSO to discuss Aviation Strategy

Meeting with Joshua Salsby (Cabinet of Commissioner Violeta Bulc)

19 Feb 2016 · Aviation