ENAIRE

Spanish Air Navigation Service Provider / Proveedor de Servicios de Navegación Aérea

Links

ID: 51595808923-96

Lobbying Activity

Meeting with Magda Kopczynska (Director-General Mobility and Transport) and DFS Deutsche Flugsicherung GmbH and SDIP – SESAR Deployment & Infrastructure Partnership

2 Oct 2025 · Next steps in SESAR development and deployment phases

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

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

30 Jan 2025 · General overview of ENAIRE + Visit to OPS/NETO room

Response to Interim evaluation of the Connecting Europe Facility 2021-2027

24 Sept 2024

Concerning EU policies, CEF should play a central role in Competitive and Sustainable European Policies, fostering the EUs industrial competitiveness, innovation and infrastructure in a sustainable way As lessons learnt, we recommend reducing the administrative burden, in particular regarding the cost reporting which is done on a calendar year basis from the date of submission of the grant application. Doing so, and not considering calendar years, implies a huge additional workload in the costing of the staff involved and deviations from the actual cost It would be very useful keeping Programme costs management rules stable over the life of the projects, in order to avoid accounting adjustments and/or Grant amendment process Looking ahead into the future calls post 2027, we would request: 1. Increase in CEF Funding Given that the total investment by ANSPs as outlined in the next edition (dec 2024) of the ATM Master Plan 2024 exceeds 10B, compared to the 1.2B allocated for CP1, it is imperative to adjust the funding to be provided by CEF in the future to reflect this substantial increase. The significant growth in investment needs a proportional adjustment in funding to effectively address the needs of transportation infrastructure, particularly in the context of air navigation modernization and expansion. An increase in CEF funds will ensure the adequate execution of projects and support the necessary investments to enhance the resilience, efficiency and capacity of Europes ATM system, enabling the achievement of long-term objectives within the air navigation sector. 2. Allocation of Funds by Sector To improve transparency and effectiveness in resource allocation, it is essential to separate the amount of CEF funding by sector, as it has been done in previous calls. A detailed distribution by sectors such as aviation, railways, and roads will provide a clear and precise understanding of how resources are allocated and how they align with the specific needs of each sector and will lead to a more efficient resource management. This sector-specific breakdown will help identify and address potential imbalances in funding, facilitating more strategic and targeted planning. Furthermore, it will aid in the management and monitoring of projects, ensuring that each area receives the necessary support to achieve its development and modernization objectives. 3. Flexibility in Fund Allocation for Partial Implementations Considering the implementation challenges experienced with AF5 (ATM Functionality) and AF6 of the CP1 (Common Project 1) regulation, as well as other potential difficulties that may arise in the future, it is crucial to introduce greater flexibility in the allocation of CEF funds. The ability to undertake partial implementations of functionalities will allow for better adaptation to unforeseen realities and challenges that may emerge during project execution. This flexibility will help address specific issues and permit adjustments in the implementation approach without compromising the overall progress of the projects. A flexible funding framework will enable adaptation to changing conditions and ensure that resources are utilized in the most effective manner possible, promoting the achievement of long-term goals in a dynamic and evolving environment. 4. Demonstrator projects Call for demonstrators (Digital Sky Demonstrators) launched by CINEA and SESAR 3JU have the objective to incentive early movers and speed up the process of the technology reaching the adequate maturity level for deployment. As such, they have more risks in terms of solution development, both in schedule and cost and more risks to accommodate safety and regulatory requirements to run the demonstrations. Therefore, it is key that the project management will be opened to accept changes in scope and schedule, duly justified, to cope with likely changes in the scope and issues encountered during the demonstrator development and execution

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Response to Ex-post evaluation of the Connecting Europe Facility 2014-2020

24 Sept 2024

Research and innovation play a central role in air transport: helping aviation become safer, more efficient, economically viable, secure and environmentally friendly. Air transport today is experiencing major transformations, including the increasing deployment of drone technology, the launch of autonomous, suborbital and supersonic activities, as well as other innovations, such as artificial intelligence and block chain technologies. ENAIRE has been awarded with CEF Transport Calls since the first Call in 2014. The Other beneficiaries participating together with ENAIRE, as an Air Navigation Services Provider (ANSP), and depending on the type of projects that we would apply to, are also our national partners (AENA, in charge of Spanish airports) or European partners (NAV PT in the context of Southwest Functional Airspace Block, other members of iTEC Alliance Skynex, etc.). As lessons learnt, we recommend reducing the administrative burden and extent the deadlines for submitting documents. The time allowed for recording and reporting the costs incurred in each Reporting Period involved cost estimation, in particular regarding the calculation of the hourly rate of staff involved. This resulted in an important workload to justify deviations in the Action Status Report that could have been easily avoided. It would be very useful keeping Programme costs management rules stable over the life of the projects, in order to avoid several accounting adjustments and/or Grant amendment process. In the future, we envisage applying to CEF Transport concerning the areas of autonomous mobility, cross-border cooperation in virtual centers, cybersecurity, among others. Synergies between Energy and Transport play a central role in air transport since we strongly support sustainable transport.

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Response to Options for support for R&D of dual-use technologies

26 Apr 2024

To improve the synergies between the civil and military R&D, the proposed White Paper outlines three possible approaches: (1) strengthening and advancing the current framework; (2) removing the exclusive focus on civil applications in selected parts of the successor programme to Horizon Europe; and (3) creating an instrument with a focus on dual-use research and development. From our point of view, and in particular for air traffic management (ATM), cooperation and coordination between civilian and military stakeholders has a long tradition and is currently one of the nine flagships in the Digital European Sky Programme. Many members of the SESAR 3 JU are active both in the civilian and the military domains, therefore we consider that option 1 is more adequate to improve and foster synergies between civil and military (e.g. sharing the respective technology roadmaps), in addition option 1 is also feasible under the current multiannual financial framework, which speeds up its implementation.

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

19 Apr 2024

1.General Comments Some assumptions, methodologies and proposed values cannot be supported by ENAIRE, especially in the areas of Environment, Capacity and Cost-Efficiency. Volatility will have a very significant impact, not addressed in the PRB Advice. Traffic growth at regional level in States as Spain, and across ACCs is well above the equivalent references in European ANSPs. 2019 traffic level will be achieved in Spain in 2024, while in Europe this will not happen until 2029. 2.Safety The maintenance of the EoSM indicator within RP4 framework is very positive. The new questionnaire will imply greater demands and, therefore, achieving the targets will require more efforts and cost for the ANSPs. At the beginning of RP4, maturity levels could therefore descend due to the higher level of prescriptiveness of the new questionnaire (without implying a deterioration in operational safety levels). 3.Environment PRB uses the argument that an ambitious environmental objective also depends on ambitious capacity objectives (sufficient capacity provision -> improvement of horizontal efficiency). This is biased since it completely ignores the interdependence with the Cost-Efficiency area. RP4 targets should not be based on the best theoretical outcome, but rather consider actual 2022-2023 results and an in-depth analysis of feasible improvements and realistic impact on KEA. During COVID-19 pandemic, it was clear that, even with very low traffic, KEA still maintained significant levels, which have not been improved. The impact of military activity (airspace reservations for large-scale exercises, etc.) is increasing, geopolitical situation reinforces this trend, penalizing KEA results. The shortest route is not always the most efficient for environment; improvements in KEA do not directly translate into improvements in flight efficiency. KEA does not reflect the contribution of different stakeholders (airlines, service providers, military authorities, etc.) and factors (as route decisions of the airlines) so it is not suitable for the incentive scheme where accountability falls only on ANSPs. Measures aimed at managing network behaviour do not always contribute to meeting the KEA targets, they may cause a deterioration because of flows deviations from optimal (interdependence ENV-CAP). 4.Capacity European NM forecasts (NOP 24-29) are inconsistent with the proposed targets (triple in 2024 and 40% higher in 2029) leading to a lack of realism. Capacity targets should more realistic and aligned with NOP projects provided by the states, especially in 2025-2026, where additional flexibility is clearly needed. The methodology used by NM for breaking down union-wide targets to local reference values does not consider real conditions that affect capacity and its development. Huge local differences (as varying growth in ACCs/States) are not considered in the proposal and have a major impact in Capacity results making it impossible to achieve the targets. 5.Cost-Efficiency The target proposal leans towards the most ambitious extreme and is considered unreachable, especially in cases where significant efforts have already been made in recent years, penalizing those who have already made efforts in the past. The Cost-efficiency target proposed by the PRB of -2.1% year on year EU DUC2022 reduction throughout RP4, is a result of unjustified and biased modification of Evidence 1 cost data. The methodology for calculating the 2024 baseline, which has a significant impact on cost evolution, is not clear. Additionally, the academic study used by the PRB on cost base inefficiency is purely theoretical. The investment and personnel costs required represent an additional effort that needs to be addressed within the RP4 framework.

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Response to Triannual evaluation of the six Executive Agencies

28 Mar 2023

The Action 2017-EU-TM-0120-M ADS-B Deployment in SW FAB started in 12/4/2018 and is expected to finalise at the end of 2023. ENAIRE is leading the Action and CINEA Agency is responsible to manage the funds granted for the Action. The experience of ENAIRE in the relationship with CINEA within the context of this Action, is in general very positive. Since the beginning of the Action three different CINEA Officers were assigned to the project. The transfer of responsibilities implied some extra, but limited, burden for ENAIRE as they were quite well managed by CINEA. CINEA always provided answers and clarifications when requested by ENAIRE and facilitated the production of reports. Sometimes it was not completely clear when and how CINEA expected to receive the different deliverables committed by the project, but communication was fluent and effective. From our point of view and with the experience gained in the execution of the Action 2017-EU-TM-0120-M, the main area for improvement that CINEA might consider is the online webgate ASR generation process . The template is rather unfriendly and difficult to manage, and although several authors are allowed by the tool, in practice it is almost impossible to manage. CINEA officers do not seem to know in detail the limitations of the webgate online ASR template, and they expect to see information in the ASR report that is not possible to fulfill unless certain conditions are met. The online ASR generation process implies extra effort if compared with a freetext report, and makes the review process less efficient. We would suggest that the template is improved taking into account feedback from users but also requirements of CINEA Officers.

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Response to Evaluation of the European Union Aviation Safety Agency’s performance in relation to its objectives, mandate and tasks

19 May 2022

In both, the certification processes and the regulatory control inspections, discrepancies may arise between the ANSP and the corresponding National Supervisory Authority regarding the regulatory interpretation of an applicable requirement, and it would be desirable to have EASA's opinion on the matter, to ensure that it is complied with in a manner that is consistent across all States. However, EASA's position does not always interpret the regulations (despite drafting them), which does not seem consistent with the fact that EASA itself carries out certifications and inspections of Pan-European Service Providers. Regulation 2017/373 includes requirements whose content is a transcription of the requirements included in the ICAO standards, which entails the difficulty of being misaligned with them in the event that the ICAO provisions are modified. Also, Regulation 2017/373 includes generic provisions that make it difficult to prove the ANSP’s compliance with the regulation, by having to demonstrate, as part of the certification process, the fulfillment of certain requirements intrinsic to the provision of the service, for which it is difficult to associate documentary evidence of compliance. Regarding the EASA’s inspections to States, it would be advisable that the EASA agenda includes as much detailed information as possible about the items to be reviewed during the interviews with ANSPs, so that the necessary interlocutors can be properly identified prior to the visit of EASA’s team. Despite the precedents on lawsuits on dominant position, a cause of concerns stems from the growing influence in the EU legislation process of Non-European Lobbies, in particular, in the way deployment of new services like U-space can be delivered in Europe, what threats the implementation of a “true” open market and the flourishing of the very European industry. GBAS G/E: This feedback addresses the role of EASA concerning the design approval/certification of GBAS ground equipment (G/E). During the last years, several agents (both national and pan-European; public as well as private) have asked EASA to provide a framework to enable GBAS G/E design approval/certification by national Competent Authorities, so that this task could be performed with standards equivalent to those already established in other parts of the world. However, this framework has never been established, which has led to individual European States pursuing diverging approaches. European national regulators have scarcely been exposed, over the evaluation period, to the core GBAS technical knowledge needed to perform detailed design approval processes. Although this scenario already existed for GBAS CAT I systems, this has become particularly relevant now for the approval of GBAS CAT II and/or III ground equipment as Europe plays a pioneering role in their development. Moreover, the implementation of GBAS CAT II/III approaches is an ASBU of the ICAO GANP. Comparing the facts exposed above with the “purpose and scope” terms of this evaluation, we consider that EASA could: - Be consistent with other EU efforts invested before, as many resources have been dedicated to GBAS ground station R&D in the framework of the SESAR 1 and 2020 programmes; - Harmonise the diverging national approaches which were eventually applied. They were not sufficiently efficient and could have led to interoperability difficulties. The lack of regulatory support is assumed to have impaired the efforts of EU GBAS ground equipment manufacturers as compared with the non-EU industry. It is understood that EASA has already started to work in a potential solution to these problems through Rulemaking Task RMT.0161. Nevertheless, this RMT is currently in its early stages. Due to the reasons mentioned above, considering the dates when the first certified GBAS G/E entered into service in EU countries, pushing forward this line of work would ease the resolution of this existing obstacle for deployment.

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Response to A Drone Strategy 2.0 for Europe

30 Jun 2021

With regard to the consultation “A Drone Strategy 2.0 for Europe”, ENAIRE welcomes the initiative, and we would like to highlight the following general aspects that are, in our opinion quite significant: 1.Apart of “Consultation of citizens and stakeholders “, a Specific Dissemination strategy on the benefits of drone technology should be considered in the strategy 2.0. 2.ANSPs should be mentioned specifically among others at “Consultation of citizens and stakeholders” section, as very important actors in Drone Strategy.

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

15 Mar 2021

ENAIRE welcomes the opportunity to give opinion about the European revised targets for the third reference period (RP3). As a first, general comment, the process that lies ahead of us needs order and coherence. In our view, the fact that a new traffic forecast is expected to be published right after the EU targets are approved weakens the credibility of the targets proposed. We have also known that some NM papers suggest that reference values are going to be recalculated on the basis of the new forecast. ENAIRE strongly believes that coherence between EU and local targets and across KPAs with respect to the references used is needed, and, therefore, we ask for the availability of the whole pack (updated forecasts, proposed targets and coherent reference values) before voting. Safety KPA: ENAIRE supports keeping the levels of ambition for RP3 targets in the safety KPA as already approved in Decision 2019/903. Environment KPA: We propose targets revision in the light of the postponement of initial FRA implementation date in Regulation 2021/116 (new date 31/12/2022). Even keeping the final 2024 target, the proposed evolution towards it should change, showing less ambition in intermediate years. Capacity KPA: The proposed targets could be supported, but only conditioned to a change in the cost-efficiency proposal, which is not coherent with capacity, since traffic is expected to recover but costs are expected to stay flat. Capacity targets can only be accepted if costs also converge towards 2019 values, in line with the expected traffic evolution. Any different approach would jeopardise future capacity provision when traffic levels come back to normal. Cost-efficiency KPA: The proposed reduction for years 202-2021 is not realistic, since 2020 is already closed and whatever we deem possible as a one-year reduction in 2021 needs to average with the 2020 actual value for targeting purposes (e.g if 10% cost reduction in one year of exceptional circumstances is deemed possible, the target for 20-21 combined should be around 5% reduction). While exiting exceptional circumstances, exceptional measures should also be progressively deactivated. This, together with the abovementioned rationale of coherence between traffic and costs evolution leads us to propose reaching back the 2019 cost base in 2024. ENAIRE believes that there are other means to mitigate at the same time the loss in revenues by ANSPs and the consequent future impact in unit rates, therefore in the benefit of airspace users, by reconsidering potential European funds to cover the gaps. This would help the sector in a considerably more effective way than unrealistic cost cutting. In terms of future impact modulation, additional flexibility to manage differences at local level when recovering the revenue loss of 2020/21 through years 2023-2030 should be provided. Too rigid regulations sticking to enforce the average concept have proven to be irrealistic and inefficient. It should be possible to define different paths to achieve the same, common, objective. We also claim for the missing reference of the long-term compliance criterion over RP2-RP3. Please see the attached document for further details.

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Response to Proposal for a Regulation - Mobility and Transport

16 Dec 2020

The “SES II+ Recast” is currently under debate. This consultation, therefore, should be put on hold until the framework regulation SES II+ is approved, since premises presented there and inducing some of the proposed changes here still have the potential of being modified. In our opinion, this consultation will need to be repeated once the SES 2+ recast will be negotiated and approved. ENAIRE also supports CANSO position. Please find attached ENAIRE’s detailed position.

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

14 Sept 2020

ENAIRE would like to thank the European Commission for bringing us the opportunity to provide comments on the draft regulation and annex “Air traffic management – new regulation deploying technical solutions developed by the SESAR research Project (Common Project 1 - CP1)”. Please find attached ENAIRE’s feedback on this initiative that have been classified into the following main themes: • Deployment dates • Enforcement mechanisms • Cost and benefits • Impact on Regulation 409/2013 • Detailed comments per AF • Further considerations or clarification needs • Significative editorial comments ENAIRE supports the deployment of the CP1, but there is a need to ensure that it is realistic and achievable at the current time of uncertainty.

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Response to Exceptional measures RP3

7 Aug 2020

Please find attached ENAIRE’s views and main concerns with respect to this proposal. ENAIRE welcomes the opportunity to participate in this consultation, and very much appreciates the efforts of the European Commission during these past months to try finding a solution to alleviate the effects of the COVID-19 pandemic on the aviation sector. Overall, it seems difficult to adequately assess the impact of this proposal in absence of the associated targets. There is also concern about the retroactive character of some of them and the limited time that could be left to achieve them. For this reason, we recommend the decision for approval takes place only when, at least, a first proposal of such targets is available, as well as a reliable STATFOR traffic forecast, both allowing a more solid evaluation. ENAIRE shares and supports the views expressed by CANSO on this matter.

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Meeting with Violeta Bulc (Commissioner) and

17 Mar 2015 · Ignacio Gonzalez Sanchez ENAIRE