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Navegação Aérea de Portugal E.P.E

NAV Portugal E.P.E

NAV Portugal E.P.E é a entidade pública designada pelo estado Português para prestação dos serviços de navegação aérea nas regiões de informação de voo sobre resposabilidade do Estado Português.

Lobbying Activity

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

19 Apr 2024

NAV Portugal would like to thank the opportunity to comment on this process. We believe that a constructive dialogue is essential for the successful implementation of these RP4 targets. We would also like to mention CANSO's position, as it fully reflects NAV Portugal's position on this issue. Our comments are therefore complementary to those presented by CANSO. Concerning Safety area, NAV Portugal agrees that safety must be at the core of all activities and services provided by ANSPs. However, we would like to express concerns about the level of effort required to achieve the proposed objectives, particularly those involving third parties that may be beyond the control of the ANSP. On the Environment, NAV Portugal questions the PRBs approach concerning the ERNIP benefits and suggests that the actual baseline of 2.40% to start the RP4 should be revised upwards. We also express our concerns about the proposed incentive scheme on the Environmental since the actual KPI is not controllable at ANSP level. On the Capacity side, NAV Portugal welcomes the PRBs recognition of staffing issues but considers the proposed targets unrealistic. We suggest using more recent delay and traffic data and revising the buffers relating to weather causes and system resilience. Finally, on the Cost-Efficiency, NAV Portugal considers that the targets proposed in the CEF area are not in line with PRB objectives for RP4 and questions the transparency of the PRBs approach. We suggest that the PRB should use more recent cost data and consider the years of the pandemic as outliers. In conclusion, we believe that the EU-wide targets proposed by the PRB need to be revised to bring the level of ambition closer to the current reality of performance and thus contribute to a greener sector.
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