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Navegação Aérea de Portugal

NAV Portugal E.P.E.

A NAV Portugal tem como missão garantir a prestação SEGURA e EFICIENTE de Serviços de Navegação Aérea, contribuindo para a criação de valor e bem-estar da sociedade, desempenhando assim um papel vital no sector da aviação.

Lobbying Activity

Response to Decision setting the Union-wide performance targets for the third reference period 2020-2024

25 Mar 2019

On behalf of NAV Portugal, I would like to thank the opportunity to comment on the target’s proposal for RP3 which are fundamental to increase the efficiency at network level without compromising current safety levels. In that sense, we believe this exercise should be driven by the right amount of ambition and yet enough realism to set achievable targets. If not, the all approach will be compromised and its credibility ruined. From our point of view, and concerning the Capacity KPA the starting point for the ATFM delay En Route seems to be completely detached of our present reality. The proposed capacity target for 2020 is 0.9min/flight although 2018 closed with 1.73 min/flight delay and 2019 may see this value rising up to 2,5min/flight. Considering the actual scenario, NAV Portugal considers that the European wide capacity reference value of 0.9 min/flight for 2020, as starting point for RP3 is completely unrealistic and urges the Commission to redraft its proposal in line with the current and future performance of the network ; Regarding the environment target KEA, the PRB target for 2020 of 2.53% seems, again, to be overambitious taking into consideration current and future European airspace scenarios. The proposed target versus the 2018 average KEA is 0.43 percentage points lower (2.40 vs 2.83, a reduction of 15%). This is well above the NM estimate of the “feasible” improvement from ERNIP initiatives of 0.2-0.3 p.p provided in the target ranges report. Thus, as for the capacity KPA, NAV Portugal opinion goes in the same direccion and furthemore it slhould be also noted that countries with full FRA are not in position to deliver additional benefits to the network in this KPA. In the attached document you may find further detail and comments to the above mentioned KPAs as well for the Cost Efficiency KPA. CANSO position is also embebed in this document since NAV Portugal fully supports it.
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