The Board of Airline Representatives in Germany (BARIG) - airline association of more than 100 national and international carriers operating to and from Germany - criticizes several aspects of the recent decisions because, in the form agreed now, they have a clearly negative impact on climate protection and, simultaneously, impose serious competitive disadvantages on European air traffic.
Michael Hoppe, BARIG Chairman and Executive Director, states: “The agreements now made may have been based on good intentions, however, a closer examination shows that they are indeed unsuitable for effectively protecting the climate. This is regrettable, because, in the run-up to the recent decisions, experts and professional associations throughout Europe and on a broad level clearly expressed their views and pointed out precisely the mistakes that have now been made.
We criticize the planned extension of emissions trading to flights from and into the EU, as for hub connections with long-haul flights, there will certainly be a significant shift of traffic out of the EU. In this way, CO2 emissions will not be saved, but merely shifted to other regions outside the EU, with ‘carbon leakage’ effects.
Moreover, the planned introduction of an increasing quota for sustainable aviation fuels (SAF) is not acceptable in its current form. In order to create a level playing field, the mandatory blending quota of SAF has to apply to all air traffic participants on a fair basis. Any unilateral additional costs must be offset. The planned free allowances for European airlines are principally a suitable means in this matter but completely inadequate in their scheduled quantities until 2030. Feeder flights to EU and non-EU hubs must be treated equally. The unfair additional costs for European airlines arising here must be offset by additional free certificates. This is the only way to ensure fair competition.”
ETF vision on how the Air Traffic Management system should function in the future
The European Transport Workers' Federation (ETF) released its vision for the Air Traffic Management (ATM) performance charging scheme given the proposal for Reference Period 4 (RP4) of the Single European Sky (SES) Performance Scheme starting is expected to arrive soon.
In its Position Paper on ATM performance, the ETF the current Single European Sky performance scheme on Reference Period 3 (RP3) for being unrealistic and disproportionate, focusing mainly on cost efficiency while disregarding the other Key Performance Areas used in the ATM system.
As explained in the Position Paper, ETF considers the 5-year timespan of the SES Reference Periods to be too stringent, thus, not allowing for more investment and flexibility to adapt to traffic deviations from forecasts which have shown to be strongly influenced by events outside of ANSPs' control, such as the crisis in Syria in 2015 or the war in Ukraine more recently.
"Before the new charging period starts" says Eoin Coates, Head of ETF Aviation Section - "the industry needs a common plan, jointly agreed with all the stakeholders, on how to update the way ATM system will work in the future so that it can properly respond to future challenges. The best way to do that is through lessons learnt, which implies assessing how the system reacted to the many different crises it has faced and making changes where it has failed."
A measure the ETF strongly advocates for is a new change management indicator designed to track and monitor changes within specific processes throughout the reference period. ETF believes that an adequate 'change management system' could reduce disruptions and chaos for airspace users through the application of managed change and is a good investment, especially considering the focus on the high levels of change-related human factors in the ATM systems.
Gauthier Sturtzer, Chair of ATM Committee at ETF, underlines: "We believe a fit-for-purpose and well-managed process is a must. It is a way to ensure we fully benefit from any new technology the European ATM system may use based on the huge EU investments. Also, the human factor should be an essential part of this process. It would be a capital mistake to ignore that the success of technological changes is directly dependent on the people using the new technologies."
ETF also calls for a single Key Performance Area, which takes into consideration the strong interdependencies between the 4 Key Performance Areas (KPAs) of the ATM system: safety, environment, capacity, and cost efficiency. A single Key Performance Area, instead of having separate Key Performance Areas, would be the best approach, as it would reflect the complexity of the system providing Air Navigation Services and the interdependencies in the sector.
Furthermore, based on a solid analysis of the 4 Key Performance Areas, ETF proposes in its Position Paper some key changes for each of the KPAs, as follows:
- An Annual ATM Safety report to be produced by EASA and the European Commission;
- Environment - To establish a mandatory route selecting service under the coordination of a centralized entity/body managing the ATM network;
- A new capacity measure based on separate evaluations of management, staff, technological means/tools, and airspace changes;
- A new 'ATM Funding' KPI to replace and regulate the cost-efficiency dimension of the ATM system, allowing it to function under national rules while also ensuring the independence of ANSPs in setting specific costs.
