DFS Deutsche Flugsicherung GmbH
DFS
DFS Deutsche Flugsicherung is the state-owned company responsible for air traffic control in Germany.
Lobbying Activity
Meeting with Magda Kopczynska (Director-General Mobility and Transport) and ENAIRE and SDIP – SESAR Deployment & Infrastructure Partnership
2 Oct 2025 · Next steps in SESAR development and deployment phases
Meeting with Maria De Las Flores Diaz Pulido (Head of Unit Mobility and Transport)
18 Sept 2025 · New Service Delivery Model (NSDM) and automation in ATM DFS Implementation Status for CP1
Meeting with Filip Cornelis (Director Mobility and Transport) and
4 Sept 2025 · Next steps in SESAR development and deployment phases
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
Response to Union-wide performance targets for the fourth reference period (RP4)
19 Apr 2024
There are two important updates proposed by the PRB as a result from the autumn consultation on the EU target range proposals, which DFS welcomes as a development into the right direction: The adjustments to the autumn target range proposals in the key areas of environment and capaci-ty leading to more moderate EU target proposals for RP4 The methodological improvements e.g. by removing the 2021 and 2022 data from historical avera-ges in the weather related delay calculation and the changes in the calculation of the baseline vaue focussing on the Member States submitted costs However, some significant critical points remain and still need to be addressed. Therefore, the proposed EU targets for ENV, CAP and Cost Efficiency, taking also into consideration the provided reference values for CAP and ENV, remain unrealistic and unachievable. Considering the objective of the SES Performance Scheme to set ambitious and realistic targets, DFS urges the EU COM to revise its proposal. Corresponding detailed comments and recommendations have been prepared and supported by respective justifications in the FABEC and the CANSO position. DFS therefore kindly invites EU COM to take those two positions as well representing our DFS position on the proposed EU targets for RP4. Based on the very recent publication of the finalised EoSM questionnaire, DFS now evaluates the proposed EU target proposal for the KPA Safety as being extremely ambitious and risk being not realistic to be achieved in RP4. DFS fully supports the continuous improvement of safety management and the revision of the RP4 questionnaire. This revision however led to considerably more demanding requirements for achieving Level C than many of the previous requirements in Level D in RP3, especially for the management objective Safety risk management. From DFS's point of view, there is therefore no reason to justify that the target value for this management objective is proposed to be higher than the other management objectives. Example: SA5.1 requires an additional, cost-intensive and too detailed qualification / certification of the deployed personnel without any comprehensible gain for safety; therefore, "Level C" (Managed) should be used as a target value. Technical issue: It does not seem to be possible to upload two annexes, therefore you will only find the CANSO position attached to the DFS contribution, but you certainly do also have access to the FABEC position
Read full responseMeeting with Henrik Hololei (Director-General Mobility and Transport)
17 Sept 2021 · SES
Meeting with Henrik Hololei (Director-General Mobility and Transport)
29 Jun 2021 · SES2, Sesar
Meeting with Henrik Hololei (Director-General Mobility and Transport)
11 May 2021 · Single European Sky, SESAR
Meeting with Marian-Jean Marinescu (Member of the European Parliament, Rapporteur)
27 Apr 2021 · SES2+
Meeting with Henrik Hololei (Director-General Mobility and Transport) and skeyes and Luchtverkeersleiding Nederland
21 Apr 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: DFS 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. DFS 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: DFS 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.
Read full responseResponse to Proposal for a Regulation - Mobility and Transport
17 Dec 2020
DFS Deutsche Flugsicherung GmbH fully supports the contributions of the German Aviation Association (BDL) e.V. and of CANSO.
As the proposed changes to the EASA Basic Regulation are part of the SESII+ package currently under discussion, we cannot any added value in this consultation to take place right now, since the requirements for the changes to the EASA Basic Regulation will depend on the general understanding of the SESII+ Framework Regulation. We need to avoid a situation in which proposed changes in this Regulation preempt the outcome of the discussions on the Framework Regulation.
While the proposal requires a clear separation at national level between the two dimensions of economic regulation (entrusted to NSAs) and safety oversight (NCAs), the opposite approach is being proposed at European level with the new PRB (in charge of economic regulation) being integrated within EASA (Safety Regulator).
We recognise there may be benefits in stability of PRB membership in the long term and a more professionalized structure, allowing for a swifter assessment of Performance Plans and Shorter Reference Periods, which in turn would make ATM less vulnerable to deviations of actual from expected traffic. However, current arrangements for today’s PRB as per Decision (EU) 2016/2296 last until 31 December
2024. We believe many of the proposals in this consultation are new and not sufficiently mature, nor have they been sufficiently discussed in relevant stakeholder fora.
Therefore we call for an impact assessment of the new organizational model as compared to the current one, including the new proposed structure of the PRB (including appeal and advisory boards) and proposed additional tasks. Clarification is also needed as to how, in this proposal, the Agency will balance its safety oversight obligations with its role acting as PRB to monitor safety under the Performance Scheme.
Specific remarks
PRB acting as Appeal Board – Article 114 k-n
We thin that such an appeal process should be detached from the ‘Agency acting as PRB’, in order to ensure independence and objectivity in the judgment of appeals. This could be done either from an institutional perspective (an Appeal Body within a different institution, to be appointed independently, e.g. by Single Sky Committee), or with an organizational approach in which Appeal Board members are convened only when necessary and paid either by service or on an hourly basis. This would also support cost-effectiveness of the appeal processes as – at least theoretically – Appeals should happen only on rare occasions. Therefore having a permanent staff seems unnecessary.
The role of the Appeal Board in the approval/denial of the approval process for Performance Plans needs to be clarified (we assume from the wording of Article 114(n) that any decision of the Agency acting as PRB can be appealed; no reference is made in Articles 13 and 14 of the SESII+ draft Regulation).
Regulatory Board for Performance Review – Role of Eurocontrol – Article 114 c
DFS believes the PRB’s independence may be compromised if in appointing members of the Regulatory Board for Performance Review, Eurocontrol, can influence the set-up. As long as Eurocontrol acts as Network Manager, thus being effectively a service provider subject to performance regulation, this consultation would lead to a clear conflict of interest and therefore should be removed.
Consultation of stakeholders by Director for Performance Review – Article 114h
The consultation mechanisms (e.g. of relevant working group before submitting proposals to a vote by the Regulatory Board) need further clarification in the wider context of the foreseen role of the Single Sky Committee and PRB in the SES II+ proposal.
Read full responseMeeting with Henrik Hololei (Director-General Mobility and Transport)
5 Oct 2020 · aviation and COVID-19
Response to SESAR Common Project 1: Concluding the pilot phase of the SESAR deployment framework
13 Sept 2020
DFS supports the direction of the changes made by the European Commission. Nonetheless, DFS sees room for further improvements. Please find attached to this high-level feedback and uploaded into the portal the full and detailed comments including the associated rational to the proposed change and clarification requests. Facilitating the stakeholder buy-in, we would like to engage with the European Commission to better understand how DFS’ feedback could be reflected into a revised draft regulation. We are happy to answer any questions the European Commission may have and to further clarify DFS‘ viewpoints.
General remark:
- DFS supports the concept of directly replacing one regulation (EU No. 716/2014) with another to increase clarity and transparency (one in, one out)
- DFS would like to advocate an incentivized decommissioning plan for legacy equipment (“CNS Rationalisation”), to enhance the long-term benefits also in terms of cost performance which can be achieved for the entire aviation system.
- Regarding recital, paragraph (6), p. 2, DFS would like to suggest to the Commission to mandate only the most performant and revolutionary „Game Changers“ in ATM for the coming decade and only those of which really require European synchronization. DFS is happy to discuss this concept with the European Commission further, also in light of the upcoming revised SES Framework.
- DFS supports the removal of SWIM Blue Profile Flight Object IOP.
In addition, we request the European Commission to change (additional details on the requested changes incl. the associated rational can be found in the attachment):
- Recital, paragraph (20), p. 3, to include Airports and Airspace Users investments.
- Recital, paragraph (21), p. 3, to delete this paragraph regarding to penalty mechanisms.
- Article 2, paragraph (10), p. 5, to delete Sub-functionality 6.1.2 and the implementation mandates for the NM concerning AF6.
- Article 4, paragraph (2), point (2.i), p.7: to define the expected performance benefits per flight, including avoided CO2 emissions for all ATM Functionalities.
- Article 4, paragraph (1), point 11, p. 6, to replace “infrastructure” with “system”.
- Article 4, p. 5 – 6, to clearly state that all types of operational groups are to be included strengthening aviation as an end-to-end system partnership and value-chain.
- Article 4, paragraph (2), point (7.b), p. 8, to correct the references towards the European ATM Master Plan.
- Article 4, paragraph (4), p. 8, to correct a reference to an Article.
- Annex, AF1, pages 1 – 3, to remove AMAN/DMAN Integration.
- Annex, AF2, 2.1.3, p. 5 – 6, to remove Airport Safety Nets or to extend the implementation target date.
- Annex, AF3, 3.1.1, p. 10, to consider the already planned removal of EAD.
- Annex, AF6, 6.3.1, p.21, to expand the airborne mandate to also include retro-fit targets for airborne equipage.
In addition, we request the European Commission to clarify (additional details on the clarification requests can be found in the attachment):
- Recital, paragraph (21), p. 3, regarding the definition and proclaimed existence of incentives for ANSPs.
- Article 4, paragraph (2), point (6), p. 7: regarding the coordination of the so-called “V4 gap” assigning a clear accountable actor.
- Annex, AF1, to ensure that the scope of EU regulations remains unchanged.
- Annex, AF2, 2.2.3, p. 7 – 8, regarding the criteria for assigning the AOP geographical scope.
- Annex, AF4, 4.3, p. 15, regarding the implementation timeframe for operational stakeholders to connect to the NM systems once available.
- Annex, AF5, 5.1.3, point h), p. 17, regarding the context of “ASM level 1” and it’s correct application into this regulation.
- why the highly anticipated so-called “AF7” on CNS (new deployment mandates and decommissioning of legacy systems) is no longer included.
Read full responseResponse to Definition of the Common European Risk Classification Scheme for civil aviation occurrences
11 Aug 2020
DFS Deutsche Flugsicherung GmbH was actively involved drafting the CANSO / EUROCONTROL Safety Team comments.
We fully support the comments.
Please find them attached.
Read full responseResponse to Implementation of the common European Risk Classification Scheme
11 Aug 2020
DFS Deutsche Flugsicherung GmbH was actively involved drafting the CANSO / EUROCONTROL Safety Team comments.
We fully support the comments.
Please find them attached.
Read full responseResponse to Exceptional measures RP3
7 Aug 2020
DFS Deutsche Flugsicherung fully supports the CANSO Position as well as the FABEC States Position on the exceptional measures for RP3, which have been proposed by the EU Commission!
While DFS welcomes the keeping of the traffic risk sharing mechanism as described in the IR 2019/317, the actual draft COM IR on exceptional measures for RP3 contains new critical elements, like e.g. the planned retroactive implementation of a new cost efficiency KPI for the crisis years of 2020 and 2021.
Both positions summarise well the details of all key issues – we therefore kindly ask you to consider the DFS position fully in line with those CANSO and FABEC States comments on the proposed revised target setting, the need to avoid a “one size fits all” approach, the unrealistic time-table for the RP3 revision process, the bypassing of NSAs in the additional monitoring requirements and the delay in starting with the unit rate adjustments.
In the context of the raised concern on an appropriate handling in case of no reliable STATFOR forecast being available in time for the preparation of data delivery by 1 November or a potential second downturn in traffic, DFS calls on the EC to foresee an interim process for the crisis years of 2020 and 2021 to ensure that no further delay is caused to payments that are due to ANSPs. In this specific context and as an appropriate overall approach, we refer to the proposed solution offered by the German Aviation Association (BDL), asking
for a compensation at Member State level through national measures, e.g. aids, grants, etc. to close the revenue gaps of ANSPs for the years 2020 and 2021 above the 10 percent mark of traffic reduction.
Finally, we would also like to raise a formal aspect. Considering the ongoing consultation on the proposed exceptional measures for RP3 via this Better Regulation Portal, we would appreciate information on how the contributions provided by stakeholders will be considered in the SSC76 Meeting on 8 September.
Read full responseResponse to Revision of Regulation on performance and interoperability of surveillance for the single European sky
9 Jan 2020
Many thanks for offering this opportunity to comment on draft Commission Regulations.
DFS is surprised that the changes are introduced at such late point in time. The more we do not understand that the now published amendment proposal does not contain all changes that were addressed during multiple Commission Workshops and EASA activities.
In the sense of "Better Regulation" the change rate of regulations should not be unnecessarily high.
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 (change proposal and justification see below). Otherwise, a positive opinion about the proposed amendment is not recommended.
With regard to the Amendment proposal for CIR (EU) No 1206/2011 in Annex II Point 3 c) we see no change in the proposed replacement compared to the current text. Is this by intent?
With regard to the Amendment proposal for CIR (EU) No 1207/2011 Annex IV we propose the following replacement:
"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."
Jusitifcation: The required process for formal arrangements for the exchange of surveillance data does not reflect existing data distribution scenarios. 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.
Read full responseMeeting with Henrik Hololei (Director-General Mobility and Transport)
21 Nov 2019 · site visit
Response to European Partnership for Integrated Air Traffic Management
27 Aug 2019
DFS welcomes the initiative of the Commission to establish a European Partnership for Air Traffic Management under the umbrella of Horizon Europe. The experience of the SESAR Joint Undertaking has clearly proven that a public-private partnership (in line with option 2 of the Inception Impact Assessment) has been the best available means to bring together all the necessary expertise from ATM stakeholders and joining their forces to expedite the modernisation of Europe´s fragmented ATM network. DFS considers it 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.
Today’s development processes and structures in the SJU are a result of a long but finally successful collective learning curve. It is therefore vital that these are adapted with caution. The following aspects are considered success critical for a new European Partnership based on option 2:
• Build on the experience of the SJU, i.e. proven processes and structures
• Strive for a seamless continuation of the established development processes
• Strive for continuity of stakeholders and key personnel
• 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 finally 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 processes for ATM systems driven at EU level jointly governed by the operational stakeholders (ANSPs, airspace users, airports, military and the Network Manager)
Read full responseMeeting with Joshua Salsby (Cabinet of Commissioner Violeta Bulc)
27 Sept 2017 · Discussion on drone project
Meeting with Henrik Hololei (Director-General Mobility and Transport)
18 Sept 2017 · SES
Meeting with Joshua Salsby (Cabinet of Commissioner Violeta Bulc)
20 Dec 2016 · Aviation
Meeting with Henrik Hololei (Director-General Mobility and Transport)
20 Oct 2016 · Single European Sky
Meeting with Joshua Salsby (Cabinet of Commissioner Violeta Bulc)
25 May 2016 · Aviation
Meeting with Henrik Hololei (Director-General Mobility and Transport)
21 Mar 2016 · A6 Alliance
Meeting with Henrik Hololei (Director-General Mobility and Transport)
1 Dec 2015 · ATM performence
Meeting with Joao Aguiar Machado (Director-General Mobility and Transport)
23 Mar 2015 · Exchange of views on SES2+ and FABEC