PRB Assessment Report of RP2 FAB Performance Plans

Transcription

PRB Assessment Report of RP2 FAB
Performance Plans
Registry of comments received after fact validation
Edition date: 06.10.2014
This comment registry includes the comments received during the fact validation period (15th to 26th September).
Comments have been treated by the PRB, and are classified according to the following criteria
Response
Accepted
Comment is accepted or explanation requested is provided.
Rejected
Comment is not accepted and explanation on the reason is provided.
Corrigendum required
FAB nee to show a formal commitment to the EC in implementing the changes. Indication is provided when the relevant report ihas been updated,
pending the provision of the corrigendum.
Not yet assessed
Comments reached PRB after the deadline and could not be assessed
Open
Comment is noted and if relevant will be discussed by the PRB in the future
RP2 Assessment - Comment Registry BALTIC
TitleoftheDocumentcommented:PRBAssessmentReportofPerformancePlansforRP2:BalticFAB
Version:2.0
Date of issue: 15/09/2014 #
1
2
Chapter/Section/Para/bullet/etc in the document
Type of comment
Comment
Response
(typo, factual
mistake, general,
etc.)
BALTIC: comments by Dariusz Wojtasik, Head of Division / Air Navigation Department - Civil Aviation Authority Poland
ACCEPTED
Chapter 1, point 1.1.5, page7
general
It is proposed to delete the last sentence that states “Poland did not
(also Chapter 9, point 9.3.1, page 53 – see below)
provide any list of exempted airports.”
List of exempted airports
Justification: There are no airports in Poland exempted from application of
Regulation 390/2013 and 391/2014. All airports in Poland where terminal
air navigation services are provided by designated entities are covered by
the scope of performance plan for RP2. Therefore it is not necessary to
provide list of exempted airports as there are none such.
The same comment is valid for Chapter 9, point 9.3.1, page 53 (see
below).
ACCEPTED
Chapter 1, point 1.5.3 second bullet, page 13
general
Meeting #3.
The information about 18 issues and agreements made during the
(also Chapter 9, point 9.3.2, first bullet, page 53)
Stakeholder consultation
consultation meeting was presented respectively in main issues and
action agreed upon tables.
The description of main issues and action agreed upon shall be treated as
minutes from consultation meeting. Point 1.3 in Annex II to the
Performance regulation states that the plan should provide the description
of the outcome of the stakeholder consultation in order to prepare the
performance plan and the agreed compromises as well as the points of
disagreement and the reasons for disagreement. This requirement is
fulfilled by the Baltic FAB performance plan.
The list of participants is attached to the CRD.
The Baltic FAB Performance Plan was Published on Polish and Lithuanian
CAA websites on 25 of April. Polish NSA sent letters to Polish
stakeholders with information about consultation meeting to PANSA, Met
providers, 20 airliners and 14 airports. It was agreed with PRB, that they
will inform all the international stakeholders.
1/10
#
3
Chapter 1, point 1.5.3 third bullet, page 13
(also Chapter 9, point 9.3.2 second bullet, page 53)
Stakeholder consultation
4
Chapter 2, point 2.2.3 page 15
Severity classification
5
Chapter 2, point 2.3.1. page 16
Just Culture
Type of comment
(typo, factual
mistake, general,
etc.)
general
general
general
Comment
Response
Meeting #2. It has to be noted that consultation meeting No 2 was
organized following provisions of the EC Charging regulation and not
article 11.2.b of the Performance regulation. In accordance with provisions
of the Charging regulation, Member State shall at the latest 7 months
before the start of RP invite the airspace users’ representatives to a
consultation on determined costs, planned investments, SU forecast,
charging policy and resulting unit rated. The meeting also covered the
requirement to consult airspace users on deviation from the forecast of
preceding year (2013). The charging regulation limits the list of
consultants to airspace users. Therefore only airspace users were invited
for this meeting which is fully in line with the regulation. The meeting
th
referred to in article 11.2.b of the Performance regulation was held on 15
May (meeting No 3), which was attended by all stakeholders, including
social partners – during this meeting also the issue of cost-efficiency was
discussed. Additionally all interested parties could provide their
questions/comments/opinions based on publically available draft
performance plan with attached reporting tables and additional
information.
Taking the above into account it is proposed to delete the third bullet in
point 1.5.3 in the draft assessment
The same comment is valid for Chapter 9, point 9.3.2 second bullet, page
53 – see below.
The list of invited stakeholders and the list of actual attendees of meeting
#2 is attached to this CRD.
As concerns list of invited stakeholders it should be also noted that
information about the meeting was published on the PRB website so it
was available to all interested stakeholders .
As regard meeting #2, all required materials (ER and TNC reporting tables
rd
with additional information) were sent on 23 April, that is no later than 3
weeks before the meeting. Copy of the email confirming meeting the
deadline is attached to this CRD.
The RAT targets were set in accordance with EU-wide safety performance
targets. Our intention was not to publish forecast for 2015 and 2016 but to
set the targets.
OPEN
President of Polish CAA closely cooperate with General Prosecutor
concerning. No date set for implementation.
PANSA has plans of activities leading to implementation of JC but there is
no date of implementation defined.
2/10
REJECTED.
Annual target values for each year of the reference
period are required for monitoring purposes in
compliance with the provisions of Article 3.1 of
Annex II of Regulation (EU) No 390/2013.
ACCEPTED.
No change.
#
6
Chapter4, point 4.1.8 page 19, point 4.4.2 page 22,
Chapter 9 point 9.3.7 page 53
en-route ATFM delays – individual ANSP contribution
Type of comment
(typo, factual
mistake, general,
etc.)
disagreement
7
Chapter 4 point 4.4.2 page 22, Chapter 9 point 9.3.7
page 53
The en-route capacity incentive scheme
mistake
8
Chapter 9, point 9.3.1, page 53
general
9
Chapter 9, point 9.3.2, first bullet, page 53
general
10
general
11
general
1
1.2.4, page 8
5.2.1 (1), page 27
(en route traffic forecast)
st
9.4.4 1 bullet
Comment
Response
EU-wide target for RP2 (each year) is 0,5 minute delay per flight which is
the same for last year of RP1. The reference value for Poland was for
2014 year 0,26 min. delay per flight. There is no reason for increasing the
PANSA contribution, having in mind significant changes in ATM
environment.
Find attached Baltic FAB calculation concerning en-route delay. The
assumptions are taken from Baltic FAB Performance Plan and STATFOR
forecast. The calculation doesn’t take into consideration all the factors
however gives us broad view on Baltic FAB contribution to EU-wide
capacity targets.
REJECTED
It is proposed to delete second and third bullet point 4.4.2. and second
bullet point 9.3.7
The intensive scheme is not symmetrical on request of IATA
representative presented during consultation meeting #3 (see main issue
2).
Mistake: The incentive scheme for Poland has the possibility of receiving
bonuses at a faster rate than penalties, for the same differential in
performance.
The incentive scheme penalties starts when delay increases by 10% while
bonuses are activated when delay is 20% below the target.
It is proposed to delete the point 9.3.1 – see justification above relating to
Chapter 1, point 1.1.5, page 7
It is proposed to delete the first bullet – see justification above relating
It is proposed to delete the second sentence starting with “It would…” and
leave only the first sentence “Poland should provide the list of invitees to
the consultation meetings.” – see justification above relating to Chapter 1,
point 1.5.3 third bullet, page 13
The figures provided in attachment do not
correspond with the STATFOR forecasts for either
Lithuania or BALTIC FAB during the entire RP2 from
the STATFOR IFR flights forecast 2014-2010 from
February 2014.
The PRB use the STATFOR forecast from February
2014, and the reference values as published in the
Network Operations Plan (2014-2018/2019) to
check for consistency of the ANSP contribution.
OPEN
ACCEPTED
ACCEPTED
OPEN
It is proposed to divide the bullet into two:
ACCEPTED

Lithuania should provide the list of invited stakeholders to
meetings #2 and # 3.
The Baltic FAB is invited to provide the list of actual participants

to meeting #1, #2 and #3.
or to integrate the last element (list of actual participants to meeting #1, #2
and #3) into the two preceding bullets concerning Poland and Lithuania.
LITHUANIA: Comments by Dariusz Wojtasik, Head of Division / Air Navigation Department - Civil Aviation Authority Poland
ACCEPTED. Report updated, recommendation
general explanation
The latest May STATFOR forecast was applied for 2014 and 2015 then
regarding ENR traffic forecast for Lithuania is
TSU 2016-2019 forecast was calculated in line with the growth foreseen in
removed.
accordance to FEB STATFOR base trend forecast as following:
TSU (2016) = TSU (2015) x (1+3.6 pct);
TSU (2017) = TSU (2016) x (1+3.2 pct);
TSU (2018) = TSU (2017) x (1+3.2 pct);
TSU (2019) = TSU (2018) x (1+3.3 pct).
PRB analyzed reference values instead of the growth impact related with
the latest STATFOR MAY forecast.
3/10
#
2
4.5.6 (incentive
scheme on arrival
ATFM delay)
9.3.9
5.1.2, 5.1.3, 5.1.4
5.2.1 (4.)
ATSPs comparators
group
3
Type of comment
(typo, factual
mistake, general,
etc.)
general
general / evident
4
5.2.1, page 29,
overall assessment
page 29
general / evident
5
5.3.1 (1), overall assessment
page 32
nd
9.4.4- 2 bullet
general / evident
6.5.3
General / evident
6
Comment
Response
Verification of compliance with requirements of 390/2013 does not spot
local conditions and historical performance. NSA LT does not intend to
charge airspace users for the bonuses certainly to be paid out to Oro
Navigacija for the excellent performance on arrival ATFM.
NSA LT does not agree that Oro Navigacija, EANS and LGS operate
under the same operational conditions.
2012 actual TSUs (ref.: www.eurocontrol.int/.../2012-service-unitsactual.pdf):
LV – 707 109
LT – 429 631
OPEN
2013 actual TSUs (ref:Eurocontrol/NMD/STATFOR: intermediate forecast
of en route SUs):
LV – 733 633
LT – 450 551
EE – 740 986
PRB may exercise benchmarking ATSPs under the same operational
conditions applying LT’s TSUs and determined costs of its comparators or
determined costs of its comparators and Lithuania’s TSUs.
The only state operating under the same operational conditions is non EU
MS Albania.
Besides, EE is not a member of Eurocontrol thus the State does not bear
Eurocontrol costs - the benchmarking between 3 states has to be carried
out excluding Eurocontrol costs from LV and LT determined costs.
NSA LT considers that STAFOR May forecast assumption could not
foresee the risk of the events in Ukraine which have influenced traffic
increase in July and August and their termination.
As pointed for Comment No 1, traffic assumption for 2016-2019 was
applied in line to the growth of STATFOR February base trend.
STATFOR February forecast for terminal services was provided in
thousands TSUs. As TSUs figures are low in respective TCZ and in order
to calculate the more precise terminal DUC, NSA LT assumed that 2014
STATFOR FEB assumption of 22.5 thousands TSUs is equal to 22 500
TSUs in full reference value and then for precise calculations used the
growth rate of terminal TSUs as explained in Comment No 1.
Besides, NSA LT wishes to draw PRB attention that Lithuania seized the
opportunity to apply exemption from traffic risk sharing in accordance to
Article 13 (6).
The only project CPDLC implementation was raised during Lithuania’s
consultation on 17 April – rationality of its implementation following
costs/benefit analysis and its feasible delay. The same investment
projects were listed in BFAB PP and no concerns or issues in that respect
were raised by airspace users.
4/10
REJECTED.
The methodology for determining the comparator
groups can be found in Annex I of the Union Wide
Targets for the 2nd
Reference Period of the Single
European Sky Performance Scheme document,
published May 2013
EUROCONTROL costs are included for all States in
the comparator group (including Estonia) for RP2.
ACCEPTED, report updated. Recommendation
removed.
REJECTED.
The 2015 TNSU value for Lithuania is 21.326 k
TNSU. It is not clear where the 22.5 value
mentioned in the comment is used.
Otherwise- comment noted.
OPEN
Noted, no change to the document
#
7
9.3.2 nd
2 , 3d bullet
8
9.3.2 – 4th bullet
Type of comment
(typo, factual
mistake, general,
etc.)
general / evident
general / evident
9
9.3.7
st
1 bullet
general
10
2.2.3
general
11
2.2.4
general
12
2.3.3
general
Comment
Response
LT is not obliged to invite stakeholders to Polish national consultation
called as No 2 therefore please delete “Lithuania should provide the list of
invited stakeholders to meeting No 2”.
It was understood during NCP Performance WG meetings that
international airspace user organizations /associations and other
international stakeholders will be invited through the newsletters and
information advertised in the PRB website (calendar of events).
National airspace users were invited through the newsletter sent by CAA
itself. Representatives from the Military, Staff associations (Oro Navigacija
and CAA), Vilnius Intl. Airport, IATA account managers and the Ministry of
Transport have been invited personally to register online. The list of
attendees of the national consultation called as no 1 was attached to the
Minutes in Annex A.
Consultation materials for national and FAB level consultations were
th
advertised at CAA website on 28 March and 31 March at PRB website
(attached request by email); FAB level consultation material - on 25 April
at CAA website and the same date at PRB website (attached request).
Everyone interested at could down load the materials.
FAB level incentive schemes have to be further developed. It may happen
that ATSPs meeting capacity reference values locally could jointly fail at
FAB level: in such case the ATSP has to be incentivized on one hand and
fined on another hand while other ATSP is fined twice. The decision by
both NSAs with support of other stakeholders was taken to establish the
schemes at national level only.
Targets on state level were set according to the provisions of regulation
390/2013 and the Commission decision (2014/132/EU). Such approach
was presented at national and FAB level consultations. CAA LT will only
perform tasks for gradual introduction of the RAT methodology and verify
the suitable RAT methodology platform (eg. Software, WEB based, ext.) in
2015-2016.
PRB interpretation was unclear by calling to find out the reasons why no
occurrences were reported as states are transparent in data provision: no
such type of occurrences had happened.
Baltic FAB Safety Committee will take part in coordination of activities in
the field of further implementation of Just culture principles taking into
account the measures laid down in PANSA and Oro Navigacija safety
culture improvement plans, especially emphasizing CISM programme
implementation at FAB level.
ACCEPTED
5/10
See new formulation.
ACCEPTED
Clarification provided
OPEN
REJECTED.
Annual target values for each year of the reference
period are required for monitoring purposes in
compliance with the provisions of Article 3.1 of
Annex II of Regulation (EU) No 390/2013.
OPEN
CORRIGENDUM REQUIRED.
#
13
9.3.5
1
Type of comment
(typo, factual
mistake, general,
etc.)
general
Comment
Response
Recommendation is not clear and should be explained as Baltic FAB
targets do not contravene the European-wide targets. Otherwise the figure
set as 90% and more could be considered as not complying with EU
target
REJECTED.
Values for the RAT methodology application for
ATM-S for ATM Ground and ATM Overall should be
the same (i.e. the ANSP target established for ‘ATM
Ground’ severity should be identical to the
NSAs/States target established for ‘ATM Overall’
severity). This is in accordance with the RAT
methodology – please see the RAT User Manual
and/or EASA AMC/GM.
The recommendation was made in order to allow
FAB to take this into consideration when adding
RAT missing values for 2015 and 2016.
POLAND: Comments by Dariusz Wojtasik, Head of Division / Air Navigation Department - Civil Aviation Authority Poland
OPEN
general/explanation
While assessing Poland’s contribution to the realization of EU costPRB Assessment Report of Performance Plans for
efficiency target the starting low level of DUC (one of the lowest in EU)
RP2 Baltic FAB – Draft for State fact validation
Comment noted – no change to assessment of this
should be taken into account. Gaining the annual average % changes in
Chapter 5.5, point 5.5.1 table “Key points for Poland
individual step
DUC at the level of -3,3% p.a. is much more difficult while the starting
en-route charging zone” point 3. ER DUC trend, page
level of DUC is low than when starting from higher level of DUC.
36
According to the above the change in DUC for Poland at the level of -2,9%
(also “Poland: Assessment of en-route charging zone;
p.a. is a huge achievement.
en-route Determined Unit Cost (DUC) trend”, page
We also encourage the PRB to take into account the fact that the EU-wide
66)
target for RP2 is calculated taking into account 2014 starting point in
which the level of DC reflects 2014 DC from performance plans for RP1
(and even is slightly higher). Therefore the national trend in DUC reduction
should also be assessed by the PRB taking into account 2014 DC as
ACCEPTED by the EC for RP1. In case of Poland the current (updated)
forecast for 2014 DC is lower than what was planned for 2014 in the
performance plan for RP1. If one takes as a starting point 2014 DC from
performance plan for RP1 and excludes Eurocontrol costs (on which
Poland had no direct influence) Poland’s DUC trend in RP2 would be fully
in line with EU-wide target. Therefore we encourage the PRB to analyze
the DUC trend for Poland taking into account 2014 DC as determined in
performance plan for RP1 and as a consequence to reconsider its
assessment and possibly change it from “Not passed” to “Passed” (with
reservation, if necessary). Otherwise, if the PRB takes into account in its
assessment revised DC forecast for 2014, local/national trend in DUC is
not comparable with EU-wide.
With reference to the statement that no justification for increase of
PANSA’s costs was presented in the PP for RP2 for Baltic FAB, we
indicate that the explanation for increase of other operating costs (due to
MET costs) and deprecation costs (due to new investments) was delivered
in PP as well as in the Annexes to the PP (Additional Information to the
Reporting Tables). What is more the forecast figures for 2014 were
updated while preparing the PP for RP2, what means that the starting
point for RP2 is lower than DUC an DC for 2014 as presented in 2014.
6/10
#
2
PRB Assessment Report of Performance Plans for
Chapter 5.5 table“Overall consistency assessment of
Poland en-route cost-efficiency KPIs”, second
paragraph, page 38
(also Chapter 9.4, point 9.4.5 first bullet, page 54)
3
Chapter 5.6, point 5.6.1 table “Overview”, first
paragraph, page 39
Chapter 5.6, point 5.6.1 table “Overview”, second
paragraph, page 39
(also Annex 1, Poland,: Assessment of terminal
charging zone, “Overview…”, (page 73))
4
Type of comment
(typo, factual
mistake, general,
etc.)
general
general
Incorrect information
Comment
Response
Concerning the proposed recommendation Poland encourages the PRB to
limit the recommendation only to costs relating to unrealized investments.
In accordance with the Charging regulation and cost risk sharing
provisions, when actual costs fall below the determined costs the resulting
difference shall be retained by the ANSPs and MS. The provision has
obligatory character (use of word shall) and it reflects the most important
principle of the determined costs approach and performance scheme. It
should be noted that majority of the surplus was generated by savings in
staff costs and other operating costs, which result primarily from strict and
conservative budget execution by entities concerned. Such efforts to
achieve cost cuts and optimization of use of resources should be
promoted as they also contribute to lowering costs over next
years/periods. Therefore states and their ANSPs should not be asked to
carry-over the surplus to next years, which was done under the full cost
recovery regime but seems to be contrary with determined costs
approach.
Concerning lower costs related with unrealized investments, Poland would
be willing to consider the recommendation provided that such a
requirement has a pan-European character and is to be followed by all EU
states and provided that it is described in the EC guidance material for
charging scheme (that was planned to be delivered in the first half of 2014
but is still missing) and is reflected in provision on the Charging regulation
following the planned technical revision (also delayed as compared to
initially planned time schedule for revision). Additionally it should be noted
that the level of DC reflects the costs incurred in the given year – on which
surplus (retained earnings) do not have an impact. Therefore it is
questionable how such a surplus can be reflected in DC (initially the PRB
considered the possibility to reflect it in “other revenues” and not lower
DC).
As a consequence we encourage the PRB to change the wording of the
recommendation to:
“The PRB advises the Commission to issue a Recommendation to the
Baltic FAB to ensure that there is no double charging of investments
unrealized in RP1 to airspace users by lowering the chargeable costs by
the amount of surplus generated in RP1 as a consequence of unrealized
investments, in accordance with EC guidance on ANS charges”.
This part should be updated taking into account the statement included in
the PP on Poland’s proposition to establish two TCZ in Poland starting
from 2017. This information was included in Annex 1 to the PRB
Assessment Report on page 73.
The sentence stating that the 14 airports represent 98,4% of TNSUs in
Poland in 2013 should be deleted. It is unclear what the source of the
calculation is. ANS in 2013 were provided by designated ANSPs only at
those 13 airports (excluding Radom) therefore in accordance with the CAA
information, there airports represent 100% of TNSUs in Poland. As stated
above, these 14 airports represent 100% of airports where ANS are
provided by designated entities – there are no airports exempted from
Charging and Performance Regulations. Therefore we assume that there
is some factual mistake or data inconsistency within the PRB which
resulted in the calculation of 98,4%.
OPEN
7/10
ACCEPTED – change implemented in report
OPEN. Sentence removed from report but to be
investigated further.
#
5
Chapter 5.6, point 5.6.1 “Key points for the Poland’s
terminal charging zone”, point 4 “Terminal cost of
capital”, page 40
(also Annex 1, Poland,: Assessment of terminal
charging zone, “Cost of Capital”, (page 75))
6
Chapter 5.6, point 5.6.1 “Key points for the Poland’s
terminal charging zone”, point 5 “Verification of the
description…”, page 40
(also 5.6.1 “Overall consistency assessment of
Poland terminal ANS cost-efficiency KPIs” (page 41)
and Chapter 9.4 point 9.4.5 second bullet (page 54)
and Annex 1, Poland,: Assessment of terminal
charging zone, “Verification of the description…”,
(page 75))
Chapter 5.6, point 5.6.1 “Overall consistency
assessment of Poland terminal ANS cost-efficiency
KPIs” (page 41)
Chapter 6.3, point 6.3.11, table 21, page 46
Chapter 6.5, point 6.5.2 Table, last line, last column
explanation
Chapter 9.4, point 9.4.5 first bullet, page 54
general
7
8
9
10
Type of comment
(typo, factual
mistake, general,
etc.)
Incorrect information
Comment
Response
The second sentence starting with “No value for the Return on equity…”
should be deleted. The terminal navigation charges reporting tables
attached to the performance plan indicate RoE for each of the entities
concerned (see table 1 for PANSA and MPL WM). The value for RoE in
the consolidated table is not computed (similarly as it is not computed in
the consolidated RT for ER charges, which was never questioned by the
PRB or CRCO or EC) as it has no sense as RoE can be assessed only for
each entity separately (which is presented in the performance plan).
Provision of ATS is a marginal activity of MPL WM (primarily it focuses on
airport managing). The company has many loans and providing
information on all of them would be disproportionate (also as regards the
necessary workload) to any possible impact of changes in the exempt
costs (which is negligible as the total amount of DC for MPL WM is
negligible).
ACCEPTED. Report updated
general
See comment above for Chapter 5 point 5.6.1 “Key points for the Poland’s
terminal charging zone”, point 5 “Verification of the description…” (page
40)
Therefore we encourage the PRB to reconsider the recommendation.
OPEN. Comment noted.
incorrect data
The data (values) should be checked once more (calculation performed by
the CAA reveals slightly different number).
OPEN
factual
Annex D for PANSA was attached to the performance plan (pages 108113). It can be argued that it should contain some additional information to
what was provided, however it should not be stated that the Annex was
missing. It also has to be noted the template for Performance plan
prepared by the PRB did not contain guidance as to what information is to
be provided in Annex D. Information contained in Annex D was provided
to the CAA by PANSA as PANSA’s investment plan.
Therefore we encourage the PRB to replace the sentence “No Annex D
available” with “Annex D for PANSA provides limited additional information
to what is presented in Section 2 of the Plan.”
See comment to Chapter 5.5 point 5.5.1 table “Overall consistency
assessment of Poland en-route cost-efficiency KPIs” (page 38) above.
No final recommendations were prepared by Commission or PRB how to
incorporate the non-realized RP1 investments into RP2. Taking into
account airspace users’ views, Poland decided to assume the realization
of the plan at the level of 85% over RP2, what has an impact on the level
of depreciation as well as on the level of cost of capital – therefore the DC
for RP2 are already lower.
This recommendation partly repeats the recommendation contained in
point 9.4.6. Therefore we encourage PRB to delete this recommendation
while leaving recommendation in point 9.4.6.
OPEN
8/10
OPEN
We accept that the mention of depreciation costs in
9.4.5 first bullet point is repeated in 9.4.6 so we
have removed the parentheses in 9.4.5 first bullet
point.
The observation in 9.4.5, first bullet point remains
under consideration.
#
11
Chapter 9.4, point 9.4.5 second bullet, page 54
12
Chapter 9.4, point 9.4.6, page 54
Annex 1, Poland,: Assessment of en-route charging
zone, “En-route Determined Unit Cost (DUC) trend”,
“Comments”, page 67
general
14
Annex 1, Poland,: Assessment of en-route charging
zone, “Cost of Capital”, “Comments”, page 71
explanation
15
Annex 1, Poland,: Assessment of terminal charging
zone, “Overview…”, page 73
zone, “Cost of Capital”, page 75
incorrect information
zone, “Verification of the description…”, page 75
explanation
13
16
17
Type of comment
(typo, factual
mistake, general,
etc.)
general
Explanation
factual
Comment
Response
See also Chapter 5.6 point 5.6.1 table “Key points for the Poland’s
terminal charging zone” point 5. Verification of the description ….(page 40)
and “Poland: Assessment of terminal charging zone; Verification of the
description …” (page 75)
Therefore we encourage the PRB to reconsider the recommendation.
See comment to Chapter 5.5 point 5.5.1 table “Overall consistency
assessment of Poland en-route cost-efficiency KPIs” (page 38) above.
OPEN.
It should be noted that increase in PANSA costs over RP2 as compared to
RP1 is partly the result of costs related to MET services which will have to
be purchased by PANSA following a public tender as a consequence of
limited designation of MET SP. At the same time costs of MET SP (IMWM)
over RP2 are not comparable with costs in RP1 as the scope of
designation, and as a consequence scope of activity covered by the MET
SP reporting table, is limited as compared to RP1. This should be
reflected in the PRB’s analysis of evolution of costs of PANSA and MET
in the description on pages 67-68.
Concerning the sentence at the end indicating that “The driver for the
increase [asset base] is unclear…” it should be noted that Poland has not
changed the value of 2014 asset base as compared to what was
contained in performance plan for RP1 for 2014. The reason for that is
very heavy workload that would be required. We expect that actual 2014
asset base will be lower.
See comment for Chapter 5.6 point 5.6.1 table “Overview”, second
paragraph (page 39) above. As a consequence the sentence stating that
the 14 airports represent 98,4% of TNSUs in Poland in 2013 should be
deleted.
The second sentence starting with “No value for the Return on equity…”
should be deleted.
See comment for Chapter 5.6 point 5.6.1 “Key points for the Poland’s
terminal charging zone”, point 4 “Terminal cost of capital” (page 40)
above.
See comment for Chapter 5.6 point 5.6.1 “Key points for the Poland’s
terminal charging zone”, point 5 “Verification of the description…” (page
40)
ACCEPTED – additional information included in
report
9/10
OPEN
ACCEPTED – additional information included in
report
OPEN. Report updated as per comment above.
OPEN
Attachments / referenced docs:






Email - publication-BFAB consultation
Email – event calendars NPP
Participants list consultation 14.05.2014
Participants list consultation 15.05.2014
Baltic FAB En-route delay
e-mail bilateral consultation meetings
10/10
RP2 Assessment - Comment Registry DANUBE
TitleoftheDocumentcommented:PRBAssessmentReportofPerformancePlansforRP2:DanubeFAB
Version:2.0
Dateofissue:15/09/2014
#
Chapter/Section/Para/bullet/etc in the
document
Type of
comment
Comment
Response
(typo, factual
mistake,
general, etc.)
1
Page 8, para 1.2.5
General
2
Page 8, para 1.5.2
3
Page 13; para 1.5.3 – third and fourth
bullets
Factual
mistake
Factual
mistake
4
5
Page 14, para 2.1.2
Page 15, para 2.2.2
General
General
6
Page 16; para 2.3 Just culture
General
7
Page 18; para 4.1
General
BULGARIA: comments by Emil – Valentin Olea, Romanian Civil Aeronautical Authority
OPEN
The deadline for submission of the PP for RP2 was 30.04.2014 (three
weeks before the consultation meeting on 20.05.2014). As of that date there
has not been any other reliable information on the traffic forecast, as well as
on the duration of the Crimea peninsula crisis. The latter has resulted into a
significant surplus which has offset the negative developments that could
have been reasonably expected due to Kosovo opening and Syria (route
UP975) closure.
The stakeholder consultation meeting for Bulgaria was held on 20 May 2014
ACCEPTED
Annex A indicates all the information required, including the materials for the
stakeholder consultation meetings. Thus, at page 120 of the PP is the list of
invited stakeholders and their activity and at page 128 of the PP there are
clear indications regarding the publication dates. On the websites of
BULATSA and DG CAA (NSA) the consultation materials have been made
available on 30 April 2014 (which is still visible on both sites).
We appreciate that these bullets should be rephrased in order to reflect the
information already provided.
Could you please justify with any facts and evidence what are the grounds
for the “perception”? Or in case it is not supported by evidence, could you
please rephrase this wording?
The statement seems rather negative. Could you please rephrase this
wording?
Additional information on the actual situation and progress made will be
provided.
The figures for en-route delay level are based on cost optimum delay.
Please check RP2 EU-Wide Targets – Indicative Performance Ranges,
section 4.4.19, Edition Date: 25/01/2013
1/9
PARTIALLY ACCEPTED
Last bullet has been erased following the information on the availability
on the website.
The list at page 120 is not the list of the invited stakeholders but of
those people who actually accessed the information
REJECTED.
Review of current perf is based on EASA audit findings.
Wording has been changed to be more precise.
REJECTED.
Monitoring of RAT application is and should be planned RP1 and RP2
activity.
CORRIGENDUM REQUIRED
REJECT
#
document
Type of
comment
8
Page 18; para 4.1.1
(typo, factual
mistake,
general, etc.)
General
9
Page 19; paras 4.1.4 – 4.1.6 and para
4.4.1 Target for delays and incentives
General
10
Page 18; para 4.4.1
General
11
Page 23; para 5.1.2 Comparator or
peer group
General
12
Page 26; Key point 1. Traffic forecast
assumptions
Factual
mistake
Comment
Response
COMMISSION IMPLEMENTING REGULATION (EU) No 390/2013
Article 14
Assessment and revision of performance plans and targets
“The Commission shall assess the performance plans, their targets and in
particular their consistency with and adequate contribution to the Union-wide
performance targets, as well as with the criteria laid down in Annex IV,
taking into account the evolution of the context that may have occurred
between the date of adoption of the Union-wide targets and the date of
assessment of the performance plan. Where targets are set at local level
without reference to a Union-wide performance target, the assessment shall
be based on the criteria laid down in Annex IV.”
Comment - By the time of the finalisation NOP (June 2014), Sofia ATCC
was experiencing 30% increase in traffic due to the situation in Ukraine. By
some reasons the assessment did not take into consideration any significant
conditions for providing ATS services neither before nor after the adoption of
NOP.
BULATSA has excellent historic performance on delays (zero delay).
However, historically there have occurred sudden events in the airspace of
neighbouring states (Greece in Sep/Oct 2011) followed by the situation in
the FIR Simferopol and FIR Dnipropetrovsk. These have resulted in
immediate traffic flow shifts through our airspace which have been managed
properly. Taking this into account, we would further analyse the possibilities
for a better balance between the delay and the incentive scheme related
thereto.
“No independent verification of delay classification.”
Please provide clarification, since BULATSA is communicating any
imminent regulation through NM systems. Primary tool is NM CHMI.
We would appreciate clarification/justification of the criteria and reasons for
the establishment of comparator groups. On which metrics are based the
conclusions that the some states are similar in operational and economic
environments?
OPEN
The developments in Ukraine since April 2014 and the related events
thereafter in respect of air traffic, have resulted in an unexpected situation,
which could not have been foreseen in the Danube FAB RP2 PP. At the
moment of submission (end of April 2014) of the PP for consultation with the
users the effects could have been listed only, but the magnitude of all of
them could not have been estimated. It is clearly stated in Annex A of the
FAB RP2 PP that during the consultation held in Bulgaria on 29 May 2014
all participants have the common understanding that additional meetings
regarding the update of the traffic forecasts are to be considered in October
– November 2014. Situation is closely monitored as stated in the draft PP
(items 1.2.5.3 and 1.2.5.5) and an update is under consideration.
2/9
OPEN
OPEN
ACCEPTED
The ANSP comparator groups used for the cost efficiency
benchmarking analysis are presented in Table 23. Comparator groups
were determined using a two-step approach combining the use of
statistical tools (cluster analysis) with expert judgment. For a full
description of the process, methodology and results see
“Benchmarking Report prepared in the context of the PRB advice to the
Commission in setting Union-wide performance targets for RP2”, June
2013.
OPEN
#
document
13
Page 26; Key point 3-5. En-route DUC
trend, En-route DUC level, En-route
cost of capital
14
Page 27; Key point 4. En-route DUC
level
15
16
Page 27; Key point 5. En-route cost of
capital
Page 27; Key point 6. Verification of the
description and if applicable, the
justification,
of economic assumptions provided in
the Performance Plan
Type of
comment
(typo, factual
mistake,
general, etc.)
Factual
mistake
Factual
mistake
General
General
Comment
Response
It is stated in the report that for RP2 Determined costs are planned to
increase. An optimization between the expected level of traffic in RP2 and
the cost base is under consideration. However, since the traffic has proved
to be quite volatile, we would expect from the PRB to assess the
performance when the situation is normal and separately if a significant
changes of traffic levels do occur in reality. It is stated nowhere that the
assessment of the trends is made between the actual and planned
costs/traffic. The performance scheme, as well as the setting of EU-wide
targets’ are based on the determined costs and planned traffic, and not on
the mix between actual and planned. On the basis of which data is the
conclusion of the PRB based, provided that (please refer to page 66 of the
draft PP for RP2) Bulgaria is most probably one of the very few states, to
meet the SES High level goals in terms of cost-efficiency by 2020? With this
performance plan Bulgaria is expected to reach a reduction of more than
70% in 2020 per unit vs. a SES target of 50%. On different occasions the
PRB has estimated that the SES HLG in terms of cost effectiveness are to
be met by 2028 or by 2033. We would very highly appreciate if the PRB
makes a similar assessment of the other states in terms of their progress vs.
SES HLG and present it officially.
It is stated that Bulgaria’s en-route DUC profile is always higher than its peer
group’s average. It is not clear how this conclusion corresponds to the fact
stated in the same paragraph of the RP2 Assessment report that in 2019
Bulgaria’s en-route DUC is planned to be 2.2% lower than its peer group’s
average.
OPEN
Please provide clarifications on the statement “assumptions used for the
different components of the WACC calculation are sometimes outside the
range of recommended values”
Bulgaria could not provide information regarding the pension costs due to
late transmission of the template and corresponding amount of work
required to be completed in a short period of time but additional information
will be presented.
3/9
ACCEPTED
the PRB reports on 2015-2018 and 2019 when adjusted for cost of
living:“Bulgaria en-route DUC profile is always higher than its peer
group average and decreasing over 2015-2018: 2015 (+11.5%); 2016
(+8.4%); 2017 (+4.9%) and 2018 (+2.0%). If adjusted to account for
exchange rates and cost of living (PPP), Bulgaria’s en-route DUC in
2019 would be much higher than its two comparators and some 37%
higher than the peer group average.”
OPEN
Please refer to Annex C Guidance Material on the Recommended
values for the cost of capital calculations
OPEN
#
document
Type of
comment
(typo, factual
mistake,
general, etc.)
General
17
Page 27; Key point 7. Costs exempt
from risk sharing
18
Page 29; Key point 1. Traffic forecast
assumptions
General
19
Page 30; Key point 4
General
20
General
21
General
22
Page 30; Assessment; a)
Factual
mistake
23
Page 30; Assessment; b) – Downward
revision of the terminal costs
General
24
Page 43; 6.3.7
Factual
mistake
Comment
Response
As stated in AI3 b) no feedback by the European commission (EC) is yet
received on the costs stated as uncontrollable in the NPP for RP1. At the
SGR48 meeting it was stated that uncontrollable costs are to be further
detailed and looked into during the coming years until end of RP1 and that
the data provided prior to the completion of the work on this item it shall be
treated as provisional. In this relation confirmation is expected from the EC
on the treatment of these costs before the effects of their variations (actual
vs. planned amounts) are reflected in the PP for RP2. At present moment
only advice by PRB has been issued, dated 15 Sep 2014. Once these
effects are clearly identified, they are going to be included in RP2. A general
statement on that will be made in the PP. These most probably will be
known in the first half of 2015.
The events affecting the overflight traffic do not have positive impact in
terms of increase on the international and domestic flights. Although there is
some improvement in the number of international flights it is compensated to
a degree with the noticeable decrease of the domestic flights. We also
analyse what could be the potential outflow of tourists from Russia (resulting
in less flights) in 2014 and the subsequent years due to the situation in
Ukraine. As at the moment we consider a conservative forecast to be
justified. The TNSU forecast for 2019 is 1.4% or 750 SU lower than the low
STATFOR forecast. Given that the difference is clearly not a material one.
The same comments are applicable as for the en-route cost of capital.
Please refer to point 15 above.
OPEN
The same comments are applicable as for the en-route pension plan
information. Please refer to point 16 above.
Cost exempt from risk sharing in TNC have not been part of the PP in RP1
for Bulgaria. Thus the conclusion is to be revised as “Not applicable”.
A recommendation is made for revision of TNSU forecast in light with the
agreement with airspace users. Such an agreement was not made
regarding the TNSU.
The TNC costs are to be revised taking into account the latest
developments related to the terminal ANS provision.
The comment “None of the projects is described as a joint project at FAB
level or with other Member State” is not correct. According to the PP some
of the main investments are common projects and are expected to bring
synergies, as follows:
VCS System – Bulgaria Capex 6 and Romania Capex 3 and 4 – pages
32, 40 and 41 – common project and synergies.
4/9
OPEN
OPEN
please refer to point 15 reply
OPEN
ACCEPTED
OPEN
OPEN
ACCEPTED
#
document
Type of
comment
25
Page 43; 6.3.10
(typo, factual
mistake,
general, etc.)
General
26
Page 46; 6.5.4
General
27
Page 62, second paragraph
General
1.
2.
1.2.7. Overall Assumptions Romania –
page 9
1.2.10. Overall assumption - page 10
3.
1.5.3. – third and last bullet – page 13
Comment
Response
As agreed during the consultation held on 20 May 2014 the excess in
depreciation costs that was included in the charges during RP1 will be
returned during RP2. For this purpose appropriate provisions have been
already made for 2013 and also as of the end of 2014.
BULATSA strictly follows the ICAO guidelines Doc 9161 (ref. p.105)
embedded in the EUROCONTROL Principles and the IFRS when adopting
its policy on depreciation of assets. Additional information is to be provided.
The depreciation costs are to be established in line with the Principles as a
generic requirement. A EUROCONTROL member state should not be asked
to establish its cost base not in line with the Principles.
Why the comparison is made between the en-route and the gate to gate
trend?
OPEN
OPEN
ACCEPTED
This checks aims at showing whether the TNC trend substantially
affects the gate-to-gate trend. It is referred to in Annex IV of regulation
No390/2013
ROMANIA: comments by Armand PETRESCU Director Genera of Romanian Civil Aeronautical Authority
The word „Bulgaria” should be replaced with „Romania”.
ACCEPTED
Typo
Factual
mistake
Factual
mistake
There is no justification and/or reference regarding ”confusion in the
terminology used to differentiate traffic forecast and en-route Service Unit
forecast”. The report should be more explicit and to indicate what confusion
has been done.
Annex A indicates all the information required, including the materials for the
stakeholder consultation meetings. Thus, at page 120 of the PP is the list of
invited stakeholders and their activity and at page 128 of the PP there are
clear indications regarding the publication dates.
We appreciate that these bullets should be rephrased in order to reflect the
information already provided.
5/9
OPEN
PARTIALLY ACCEPTED
Last bullet has been erased following the information on the availability
on the website.
The list at page 120 is not the list of the invited stakeholders but of
those people who actually accessed the information
#
4.
document
5.5.1. Key points for Romania en-route
charging zone – point 5 – En-route cost
of capital – page 35
Type of
comment
(typo, factual
mistake,
general, etc.)
Factual
mistake
5.
5.5.1. Key points for Romania en-route
charging zone – point 6 – page 35
General
6.
5.5.1 – Overall consistency – page 36
Factual
mistake
7.
5.6.1. Key points for Romania terminal
ANS KPI assessment – point 3 – page
38
General
Comment
Response
The assessment is not mentioning ”the assumptions used for different
components of WACC calculation” that are outside the range of
recommended values. We appreciate that more details should be included
in the assessment as long as Romania provided full description of those
assumptions. Romania assumptions for cost of capital calculation are as
follows:
%debt 60% recommended - 60% applied;
Corporate tax rate Recommended to be applicable only if ANSP pays tax on
profit, which is the case for ROMATSA; however using the SDG vanilla
model the weighted combination of the pre-tax cost of debt and the post-tax
cost of equity was applied;
Risk free rate recommended 1-2% in real terms; 2% was applied. Inflation
rate applied was according to IMF for RP2 (check passed on assessment)
Market Premium – Damodaran recommended; Damodaran rate was
applied, source was indicated; the premium (7,35%) is less than the
recommended cap of 8,75%
Asset beta : 0,3-0,5 recommended, lowest 0,3 was applied;
Debt beta 0-0,1 recommended, zero applied;
Debt rate – no recommendation in the template, recommended SDG study
values were applied.
Romania could not provide information regarding the pension costs due to
late transmission of the template and corresponding amount of work
required to be completed in a short period of time.
b1) There are no indications regarding investments and associated
depreciation that been included in both RP1 and RP2. The assessment
contains just a high level appreciation that it do ”not seem” to reduce the
depreciation in accordance to RP1 postponed investments. The assessment
should make reference to certain depreciation costs that are included in
both RP1 and RP2.
b2) Regarding the cost of capital assessment we appreciate that the total
en-route revenue risk exposure is not adequately calculated by taking into
account just the traffic risk exposure.
At page 90 of the PP we included a detailed sensitivity analysis. According
to this analysis the cost of capital related to risk premium corresponds to the
revenues loss generated by the traffic risk sharing mechanism for -2,5%
traffic decrease.
Another financial risk is related to the volatility of exchange rates. A -5%
depreciation of the national currency corresponds to 17.318 (‘000RON)
more the cost of capital related to risk premium (for 2015).
Last but not least according to art. 7.3 of the Charging Regulation
(391/2013) the return on equity “shall be based on the actual financial risk
incurred by the air navigation service provider” and not just to the traffic risk.
In our opinion Romania cost of capital calculation is fully compliant with all
requirements and the report should reflect this aspect.
From 2014 the cost allocation for the units that provides services in terminal
area has been changed by allocating more costs to the terminal cost base.
Therefore, the comparison of 2013 and similarities with the en-route are not
fully relevant. Please revise accordingly or use a different reporting base.
ACCEPTED - Please refer to Annex C guidance material
6/9
Please note that as Romatsa and Bulatsa have no debt, the gearing
assumption to be used is 0% not 60%.
OPEN
OPEN
OPEN
#
document
Type of
comment
(typo, factual
mistake,
general, etc.)
Factual
mistake
8.
5.6.1. Key points for Romania terminal
ANS KPI assessment – point 4 – page
38
9.
6.5.7. Romania – page 47
Factual
mistake
10.
6.7.2. Key points – page 47
Factual
mistake
11.
6.5. Ancillary assessments
Factual
mistake
12.
9.2.3. Recommendations for the costefficiency KPA – page 51
Factual
mistake
13.
9.3. Compliance issues – pages 51-52
14.
All
Factual
mistake
General
Comment
Response
There are no justifications for not passing the terminal cost of capital check.
Cost of capital is calculated on the same basis as for the en-route activity.
We appreciate that the same comments are applicable for the terminal
analysis.
There are no indications of what information needs further clarifications with
regard to ATM system.
OPEN
The comment “None of the main projects planned for RP2 is foreseen to be
a joint project or expected to bring synergies at FAB level or with other
Member States” is not correct. According to the PP some of the main
investments are common projects and are expected to bring synergies, as
follows:
VCS System – Bulgaria Capex 6 and Romania Capex 3 and 4 – pages 32,
40 and 41 – common project and synergies;
ATM 2015 (Step 2) – page 38-39 – expected synergies.
The comment “ROMATSA investment plan is not consistent with RP2
Performance Plan for all projects or for the planning of amounts per (e.g.
ATM ROMATSA System 2015+ no amounts planned for 2016 to 2019 whilst
€13,7M planned for RP2 Performance Plan” is incorrect. According to PP
page 49 ATM System ROMATSA 2015+
(STEP 1) indicates 65.820.555 lei for 2015 which corresponds to the
positions 7 and 8 from page 439 of Annex D. Thus, the comment should be
deleted or rephrased accordingly.
Recommendations are not linked with Romania key points mentioned in the
assessment (pages 34-36 and 38-39). Thus, the first recommendation is not
in-line with the assessment that indicates the en-route DUC trend and level
passed the compliance check. Moreover, the overall consistency of
Romania en-route cost-efficiency KPI (page 36) indicates 3 bullets in which
is not included the recommendation of ”revise downwards the en-route
determined costs planned over RP2, in the light of the level of determined
costs observed in 2013”. The same situation can be observed for the fourth
bullet – revise downwards the terminal ANS determined costs planned for
RP2 which is not consistent with the information provided on page 36. The
last bullet (revise the TNSU forecast) is not consistent with the key point for
Romania terminal ANS KPI assessment (page 38) that stipulates the
consistency of the traffic forecast assumptions.
On the basis of the above mentioned we appreciate that Romania
recommendations from bullets 1, 4 and 5 should be deleted.
Compliance check issues for the general criteria require revision on the
basis of the above mentioned factual mistakes.
For the purpose of data validation the data should be provided in Excel
format, not only in pdf.
7/9
REJECTED
In Annex D, items 7 and 8, no amounts are planned beyond 2015.
ACCEPTED
REJECTED
In Annex D, items 7 and 8, no amounts are planned beyond 2015.
OPEN
OPEN
#
15.
document
Type of
comment
2.2.3 – Safety, RAT methodology
application for ATM-S
(typo, factual
mistake,
general, etc.)
To provide
clarification
Comment
Response
Indeed, in theory, the Ground Score and the Overall Score for RAT
methodology application for ATM Specific Occurrences should be the same,
as the case was in 2013 when Romania reported 100%. Please note that is
our intention to continue to provide this performance in relation to the RAT
methodology application for ATM Specific occurrences.
In practice, from experience, we have identified several risks that could
induce differences between the Ground Score and the Overall Score.
These are:
1. The process/ protocol established between ROMATSA, CIAS and RCAA
allows RCAA and CIAS to question the severity of the occurrences
established by ROMATSA. This could result in delays in establishing the
severity ATM Overall, in line with ATM Ground. We believe that is an
enabler for effective supervision.
2. The process to report ATM Overall for ATM Specific occurrences is
complex and requires coordination between the actors on all aspects,
including the databases/ tools that are used (ECCAIRS, AST, Romania RAT
Community, Internal Databases).
3. There are cases when there might be several reports for the same
occurrence (technical, operational).
This has to be properly analysed.
OPEN
For all these reasons, considering the provided performance for RAT
methodology application for ATM – S occurrences in 2012 and 2013, we
propose to maintain the current targets. We do not want to be in the position
in which because of an exception we do not meet the target.
We could establish the same target for ATM Overall as for ATM Ground
(80%), but this could lead in some particular cases to unnecessary safety
detrimental “adjustment measures” just to meet the target.
16.
2.2.3 – Safety, RAT methodology
application for ATM-S
Remove the
following text
Therefore, the PRB expresses concern as it appears that the DANUBE FAB
Member States may not be aware how the classification of ATM-S
occurrences should be performed.
For justification please refer to the above explanation.
8/9
OPEN
#
17.
document
2.3 – Just Culture
Type of
comment
(typo, factual
mistake,
general, etc.)
To provide
clarification
Comment
Response
The elements corresponding to the actual presence and absence of Just
Culture are presented in the Just Culture report for 2013.
The necessary actions to achieve the implementation of Just Culture by the
end of 2019 are:
1. To discuss the questions contained in the Just Culture questionnaire for
which a NO answer was provided into the technical groups of the State
Safety Programme and to include the actions into the SSP implementation
plan.
2. To discuss, coordinate and approve the proposed Just Culture actions at
FAB level into the DANUBE FAB governance boards.
Please note that the information was provided using the available template
for RP2 Performance Plans.
The main actions and the most difficult ones that have to be implemented
are referring to the legislation related to the prosecution and administration
of justice.
As already indicated in the RP2 performance plan, coordination with the
Romanian Minister of Justice on the necessary actions was initiated.
The local target is to implement Just Culture by the end of the last year of
RP2.

Letter from Lazar Iliev, NSA Bulgaria, Danube FAB Coordinator
9/9
RP2 Assessment - Comment Registry DK – SE
TitleoftheDocumentcommented:PRBAssessmentReportofPerformancePlansforRP2:DK‐SEFAB
Version:2.0
Commentsby: AllanHansen,DanishTransportAuthority,CenterforTransportMarkets #
Proposal for
modification /
addition
Rationale
Response
1
PRB Assessment Report of Performance Plans for RP2,
DK-SE FAB, Section 1.1.3
Typo
[DE] should be [DK]
ACCEPTED
Typo
“Copenhagen-Kastrup” should be “Copenhagen Airports” since TNC covers the whole
charging zone.
We agree that the list of exempted airports was not provided.
Here it is for the Danish part:

BILLUND

BORNHOLM/RONNE

ESBJERG

KARUP
ODENSE – HCA AIRPORT


SONDERBORG

AALBORG

AARHUS
ACCEPTED
2
3
4
5
General
Factual mistake
General
Swedish airports exempted from performance and charging Regulations.
Arvidsjaur, Borlänge, Eskilstuna, Falköping, Gällivare, Gävle, Göteorg/Landvetter,
Göteborg/Säve, Hagfors, Halmstad, Hemavan Tärnaby, Jönköping, Kalmar, Karlstad,
Kiruna, Kramfors-Sollefteå, Kristianstad, Linköping/SAAB, Ljungbyhed, Luleå/Kallax,
Lycksele, Malmö, Mora/Siljan, Norrköping/Kungsängen, Pajala-Ylläs, Ronneby, Skellefteå,
Skövde, Stockholm/Bromma, Stockholm/Skavsta, Stockholm/Västerås, Storuman,
Sundsvall/Timrå, Sveg, Torsby, Trollhättan/Vänersborg, Umeå, Vilhelmina, Visby,
Växjö/Kronoberg, Åre/Östersund, Ängelholm, Örebro, Örnsköldsvik
Meeting #3 was conducted 12 May 2012
th
Material was published at the website www.eusinglesky.eu 16 April which gave the
interested stakeholders almost one month to prepare themselves for the joint consultation
th
12 May.
Invited stakeholders were a combination of email addresses provided to the PRB
chairman and a list of stakeholders that the PRB chairman had. The list provided by the
1/9
ACCEPTED
ACCEPTED
#
Proposal for
modification /
addition
Rationale
Response
Danish and Swedish NSAs contained several social partners. However none of them
attended the consultations.
Please see the Danish and Swedish list below.
The Danish:
[email protected]; [email protected];
[email protected]; [email protected]; [email protected];
[email protected]; [email protected]; [email protected]; [email protected]; [email protected];
[email protected]; [email protected]; [email protected]; [email protected];
2/9
#
Proposal for
modification /
addition
Rationale
Response
[email protected]; [email protected]; - Henrik Carstensen (Dansk
Erhverv) - <[email protected]>; - Kristian Durhuus (Københavns Lufthavn) <[email protected]>; - Michael Svane (DI) – <[email protected]>; - Per Henriksen (DI)
– <[email protected]>; - Dan Banja (Erhvervsflyvningens sammenslutning <[email protected]>; Anders Madsen (Kongelig Dansk Aeroklub) – <[email protected]>; Lars
Andersen (SAS) – <[email protected]>; - Erik Jakobsen (Karup Lufthavn) –
<[email protected]>; Susanne Isaksen (Naviair) – <[email protected]>; - Thilde Waast
(Flyvebranchens Personale Union) – <[email protected]>; - Kjeld Jørgensen (Billund
Lufthavn <[email protected]>; 3F - Fagligt Fælles Forbund <[email protected]>; Akademikerne
<[email protected]>; Alex Klug <[email protected]>; Bo Feldberg
<[email protected]>; Cabin Union Denmark <[email protected]>; Claus Gerlen
<[email protected]>; Dansk Flyvelederforening ([email protected]); Dorthe Vest
Nielsen <[email protected]>; Flemming Christensen <[email protected]>;
Flyvebranchens Personale Union FPU <[email protected]>; Flyvertaktisk Kommando
([email protected]); Forsvarskommandoen ([email protected]); Hans Christian Holst
<[email protected]>; Jess Nørgaard <[email protected]>; Kate Søs Hansen
<[email protected]>; Keld Ludvigsen <[email protected]>; Landsorganisationen i
Danmark LO <[email protected]>; Lars Andersen <[email protected]>; Michael Thomsen
3/9
#
Proposal for
modification /
addition
Rationale
Response
CL <[email protected]>; Niels Remmer <[email protected]>; Per Coulet
<[email protected]>; Per Henriksen (Dansk Luftfart) <[email protected]>; Peter Lundsgaard
<[email protected]>; Peter Thorsen <[email protected]>; Ryan Sørensen
<[email protected]>; Susanne Isaksen <[email protected]>; Søren E. Olufsen
<[email protected]>; Søren G. Andersson <[email protected]>; Torben Lundbeck
<[email protected]>; Ryan Sørensen <[email protected]>; Alex Klug
<[email protected]>; 'Noréus Eva ([email protected])'; 'Blomberg
Jenny ([email protected])'; 'Söderberg L Staffan
([email protected])'; 'Landqvist Lotta'
<[email protected]>; Tingwall, Eva
([email protected]); 'Berlin Christina - Norrköping'
<[email protected]>; [email protected];
Alex Dyrgaard <[email protected]>; Allan Hansen Ekstrand
<[email protected]>
The Swedish list:
[email protected]
[email protected]
[email protected]
[email protected]
[email protected]
[email protected]
[email protected]
[email protected]
[email protected]
[email protected]
[email protected]
[email protected]
[email protected]
[email protected]
[email protected]
[email protected]
[email protected]
[email protected]
[email protected]
[email protected]
[email protected]
[email protected]
[email protected]
[email protected]
[email protected]
[email protected]
[email protected]
[email protected]
[email protected]
[email protected]
[email protected]
[email protected]
4/9
#
Proposal for
modification /
addition
Rationale
Response
[email protected]
[email protected]
[email protected]
[email protected]
[email protected]
[email protected]
[email protected]
6
7
DK-SE FAB, Section 4.1.4 and 9.2.5
DK-SE FAB, Section 4.5.8 and 9.2.6
Factual
General
General
The PRB chairman will have to provide the rest addresses that was used for publication.
Traffic forecast applies to service units - since this is the basis of calculating the unit rate.
Reference values at national level were not provided. The NSAs wanted only FAB targets
for en-route capacity. However reference values (not targets) at ACC level could be
provided:
2015 2016 2017 2018 2019
Naviair
Købanhavn
0,08
0,08
0,07
0,07
0,06
LFV
Stockholm
0,07
0,06
0,07
0,07
0,07
LFV
Malmö
0,07
0,07
0,07
0,06
0,06
Source: European Network Operations Plan 2014-2018/19
The Danish and Swedish NSA found it incorrect to setup an incentive scheme for airport
capacity for two main reasons:
1. Naviair and LFV are performing at almost zero delay in Copenhagen and
Stockholm if you take away weather as parameter.
2. We have very little data in this field which provides some uncertainty on the right
levels.
ACCEPTED
OPEN
In order to stay in line with the aim of SES (decreasing cost and delays) it is important not
to create something that increase financial uncertainty and which would not provide any
advances for capacity.
As already stated in the Performance Plan the NSAs will reconsider an incentive scheme
in 2017.
DK-SE FAB, Page 26, 1
Factual
8
Page 44, Bullet 6.3.5
Factual
9
Factual
Since the performance plan has been delivered to the Commission the latest GDP growth
rate expectations for Denmark has been adjusted downwards which is just one more
argument for the Danish choice of traffic forecast (the low case scenario).
We suggest that AGDL and the brackets are removed from the sentences, since the
COOPANS upgrades are relevant to more than the data link.
Referring to our submission we suggest that the last part of bullet 6.3.5 is rephrased to the
following:
“”…However, only 11.4M€2009 is expected to be spent during RP1, “due to a slight
revision in Prize, Scope and Schedule” and the unspent amount is not carried-forward to
5/9
OPEN
comment noted
ACCEPTED
ACCEPTED
#
Proposal for
modification /
addition
10
Factual
11
12
Page 47, 6.5 “Overview, impact and date of expected
benefits per KPA
Page 47, Table 26
General
Factual
Rationale
Response
RP2.”
The planning of the project has been shifted within RP1. The project will meet the
demands of the Implementing Rules. Furthermore the depreciations from the project are
set for RP2, and do not and have never been intended to fall in RP1.
ACCEPTED
We suggest a rephrasing to the following:
“Another important main project for RP2 refers to CNS upgrades (i.e. VoIP) planned for
8.3M€2009 in addition to 5.1M€2009 planned for RP1. However, only 3.9M€2009 is
expected to be spent during RP1 due to a shift in the planning phase of the project, which
moves some investments to after 2014, which is in line with the Implementing Rules. The
depreciations of the project will come after 2014 (i.e. RP2) and are not a part of the
Performance Plan for RP1.”
Regarding the benefits from the COOPANS-alliance we would prefer to use the following
sentence from our Technical-Operational
Development Plan 2014-2018, page 9: “If Naviair had not been part of the COOPANS
alliance, the system development costs would have been approximately 30 per cent
higher.”
Thus we suggest the following sentence:
“FDP-COOPANS, the major project in partnership with several other ANSPs (27.2M€2009
planned CAPEX in RP2). Had Naviair not been part of the COOPANS alliance, system
development costs would have been approximately 30 per cent higher.”
Firstly we are uncertain at what level the table report (State/ANSP?).
ACCEPTED
ACCEPTED
The status on ITY-AGDL is “Late” (Orange) in table 26. The current status for Naviair is
“Planned” (light green) and for Denmark it is “No plan” (red).
13
Page 53, 9.3.9, and 6.1.1/6.7.7)
General
Therefore the status reported cannot be “Late” (orange). If the table is at ANSP-level the
correct color should be “Planned”.
With regards to PCP ATM functionalities the ability to deploy within RP2 is considered to
be included in the investment-level.
The information provided by Naviair is not on a basis of “earmarked” amounts or named
projects.
We kindly suggest the PRB to remove or rephrase the remark about “risk” in 6.7.7 and
other places where the PRB concludes about the PCP functionalities (6.1.1).
14
Page 56
General/ Factual
mistake
The sentence regarding the proportion of costs allocated to en-route/terminal and whether
or not there is significant influence.
The principles for allocation between en-route/ are not changing in RP2. Therefore we see
no basis for the PRB’s conclusion about “not significantly influence”.
As a consequence we do not understand the relevance of this part of the sentence to the
6/9
ACCEPTED
Comment partially accepted. Action:
modification in 6.1.1 and 6.7.7. PRB
notes that DK/SE show foresight of
the PCP functionalities however in
the tables provided for the RP2 PP in
the common project field it was not
directly marked which PCP ATM
functionalities will be covered by the
mentioned projects.
ACCEPTED. Wording in report
modified.
#
Proposal for
modification /
addition
Rationale
Response
analysis of the trend in the en-route DUC.
15
Page 27/30, point 5 en-route cost of capital and page 58
(cost of capital), page 30 and 62 (for terminal).
General
16
Page 27/30, point 6 Verification of the description etc.
and page 59/62 (verification of the description) and
9.3.5 on page 53.
General
We suggest removing this part of the sentence.
As stated in the additional information Naviair is capitalized based on the activities of
Naviair and the ownership of the state. This affects the capital structure of the company as
a whole.
The reporting tables and the elaborations in the additional information provide a true
reflection of the distribution/allocation of interests on debt to either en-route, TNC or a third
activity. In addition to that the return on equity varies across activities, be it either en-route,
tnc or a third activity.
We do however note that en-route activity is considered to be of less risky than TNC.
The additional information elaborates on the principles of the distribution between
activities for Naviair as a whole. The distribution of the assets is in the reporting tables.
Therefore we do not see any inconsistencies.
OPEN.
Comment noted.
OPEN.
Comments under consideration.
Correction regarding the RoE and
WACC levels for Terminal and enroute has been ACCEPTED.
Sentence has been removed from
report.
In the PRB assessment report the PRB describes that “the Return on Equity and WACC
used for the TCZ is the same as used for en-route”. This is not true. The additional
information describes that Naviair considers the en-route area to hold less risk – therefore
the return on equity is lower than that for the TCZ.
17
Page 25, Table 12
General
18
Page 26, 2. Economic assumptions.
General
19
assessment report Sweden, page 64 “Economic
assumptions”
general
20
21
22
Sweden: Overview of en-route charging zone
assessment 5.5.1, page 35
Sweden: Overview of terminal charging zones
assessment 5.6.1, page 38
Sweden: Assessment of terminal charging zones, page
70
Regarding the further validation and details of the subordinated loan please refer to our
annual report, note 18.
The Danish NSA agrees that the table is mathematically correct. However we still find it
misleading since it is stating that the yearly evolution in the determined unit costs from
2014 to 2019 is -2.1 %. The real Danish contribution to the EU-wide target is something
around -3.5 %. This is how it appears in the performance plan and is also more in
compliance with the text in the Commission decision setting the Union-wide performance
targets for the air traffic management network and alert thresholds for the second
reference period 2015-19.
This should be noted under the table in order not to indicate that the Danish en-route cost
efficiency target is not consistent with and adequately contributing to the EU-wide target.
Danish reporting tables, TNC, RP1 and Danish reporting tables, en-route RP1 and RP2
have been corrected using the right IMF inflation forecast for 2014 at 1.5 %. Tables are
attached to the e-mail that was used to send this document
We don’t agree that the Swedish inflation assumptions are equal to the Eurostat HCIP.The
Swedish inflation assumptions use different methods than Eurostat HCIP, however the
result in this table are same.
typo
DC for 2014 are forecast at 2,067 MSEK shall be 2,065 MSEK
factual mistake
“..no increase in the costs in nominal terms for LFV during ..” shall be “...no increase in the
DUC in nominal terms for Sweden during
The number of airports included in the performance scheme is reduced from 2 to 1 from
RP 1 to RP 2 and hence from 2014 to 2015. Change sentence to “The number of airports
typo
7/9
OPEN.
Comment noted.
Update noted in assessment report.
ACCEPTED.
Comment noted. No change to report
(if the numbers are equal in value the
sentence remains correct)
ACCEPTED.
ACCEPTED.
ACCEPTED.
#
Proposal for
modification /
addition
Rationale
Response
does change between 2014 and 2015.”
23
24
25
Thoughts about recommendations
Overall consistency assessment of Sweden’s en-route
efficiency KPI, page 37
a) reconsider the traffic forecast in the light Address of
the latest available year-to-date actual situation (key
point 1);
b) the inappropriate level of the cost of capital and RoE
for ACR. The PRB notes that the small provider of enroute services in Sweden (ACR), which accounts for
some 4% of the total DCs in RP2, applies an RoE of
17.0% and a pre-tax WACC of 11.3%. As its costs are
subject to the same risk sharing arrangements as LFV,
this apparent inconsistency should be addressed. (key
point 5).
c) provide further information on the detailed differences
between Swedish legal requirements on the accounting
of pensions and depreciation of fixed assets as
compared to International Accounting Standards and on
the value of the pension liabilities used to calculate the
cost of debt in the WACC calculation (based on key
point 6); and,
d) provide greater clarity on how it has reflected the
costs exempt from cost sharing identified in RP1 in 2014
and RP2 projections – particular given the intention to
smooth these costs evenly over the five years of RP2
(based on key point 7).
Overall consistency assessment of Sweden’s terminal
ANS cost-efficiency KPI, page 40
a) provide further information on the detailed differences
between Swedish legal requirements on the accounting
of pensions and depreciation of fixed assets as
compared to International Accounting Standards and on
the value of the pension liabilities used to calculate the
cost of debt in the WACC calculation
(based on key point 5); and,
b) to provide greater clarity on how it has reflected the
costs exempt from cost sharing identified in RP2
projections (based on key point 6).
9.2.8 Sweden should:

Provide further information on the detailed
differences between Swedish legal requirements
on the accounting of pensions and depreciation of
fixed assets as compared to International
Accounting Standards and on the value of the
pension liabilities used to calculate the cost of
debt in the WACC calculation.
OPEN
OPEN
recommendation
Sweden will evaluate recommendations made by PRB’s assessment Report of
Performance Plans for RP2.
OPEN
recommendation
OPEN
information
OPEN
information
OPEN
OPEN
information
OPEN
information
The intention is to smooth the costs exempted from cost sharing evenly over RP2.
OPEN
The intention is to smooth the costs exempted from cost sharing evenly over RP2.
8/9
Comment noted.
OPEN
#
Proposal for
modification /
addition
Rationale
Response
Provide greater clarity on how it has reflected the costs
exempt from cost sharing identified in RP1 in 2014 and
RP2 projections - particular given the intention to
smooth these costs evenly over the five years of RP2.


Updated Danish reporting tables, TNC, RP1
Danish reporting tables, en-route RP1 and RP2
9/9
RP2 Assessment - Comment Registry FAB CE
TitleoftheDocumentcommented:PRBAssessmentReportofPerformancePlansforRP2:FABCE
Version:2.0
Commentsby: FranzNirschl,ChairmanFPB,AustrianFederalMinistryforTransport,InnovationandTechnology
#
document
Type of comment
(typo, factual
mistake, general,
etc.)
1
Traffic forecast assumptions:
General
Comment
Response
FAB CE
See footnote
OPEN
1
For the purpose of the Performance Plan for RP2, FAB CE representatives
became members of the STATFOR User Group and actively participated in
the definition of assumptions.
Paragraph 9.4.2
No change required in the report.
Having an in-depth understanding of the local conditions and assumptions
used by STATFOR, FAB CE states have selected STATFOR scenarios that
in their view represent the most likely traffic forecast for the period of RP2.
2
Missing information for stakeholder
consultations:
-
Paragraph 1.5.3
Paragraph 9.3.4
General
All the material for consultation was provided to stakeholders at least three
weeks before the consultations, as required by the EC Regulation No
390/2013.
It is to be noted, that Annex II, Point 1.3 of the performance Regulation does
not require to submit such data as mentioned in the assessment report (i.e.
lists of participants). Therefore the item should be noted as an observation
rather than a compliance issue. This would ensure consistency with item
1.5.3 which refers to the same issue as an observation.
The evidences and additional missing information will be provided in the
updated version of the FAB CE Performance Plan.
1
Footnote : This response is actively supported only by Austria, Czech Republic, Croatia, Slovakia and Slovenia. Not supported by Hungary.
1/11
#
document
3
Capacity KPA:
-
Type of comment
(typo, factual
mistake, general,
etc.)
General
Comment
Response
See footnote 1
OPEN
The FAB CE reference values have been provided by the NM using the topdown approach while FAB CE states have used a bottom up approach that
reflect the specific local conditions. During the preparation of the FAB CE
Performance Plan, the NSA targets were consulted with the NM who noted
they were satisfactory. FAB CE is in constant consultation with the NM and
capacity data is verified by NM as consistent and sufficiently contributing to
then pan-European targets. There is also sufficient consistency with the
NOP and the ERNIP.
Paragraph 9.1.4
Paragraph 9.2.1
Paragraph 9.3.7
Regarding the inconsistencies between the Performance Plan and LSSIP
capacity plans, the Performance Plan is the higher level document and the
LSSIPs will be adopted accordingly in forthcoming meetings.
4
FAB CE Capacity Incentive Scheme:
General
OPEN
See footnote 1
FAB CE noted the feedback from PRB but in any case, FAB CE considers
that the proposed incentive scheme fulfills all requirements of the EC
Regulation No 390/2013 and 391/2013.
Paragraph 9.3.8
Nevertheless FAB CE requests the PRB elaborates further on their
comments and FAB CE will consider this further feedback for the updated
version of the FAB CE Performance Plan.
Footnote 1: This response is actively supported only by Austria, Czech
Republic, Croatia, Slovakia and Slovenia. Not supported by Hungary
5
FAB CE Capacity Incentive Scheme:
General
Paragraph 9.3.9
6
Cost efficiency:
Paragraph 9.1.5
General
In the legislation there is no explicit requirement for an incentive scheme for
arrival ATFM delay. FAB CE will adopt an incentive scheme for arrival
ATFM delay when there are European targets defined for terminal capacity.
OPEN
OPEN
See footnote 1
FAB CE does not agree with this assessment result and related
recommendations. Although the assessment is carried out at charging zone
level, the aggregated DUC is already significantly lower than the EU-wide
average and will continue to decrease. The PRB also noted that the FAB CE
unit cost planned for 2019 will be still 14.9% lower than the union wide
aggregated DUC. FAB CE therefore considers all the individual targets as
consistent and sufficiently contributing to EU-wide targets.
As far as the initial starting point is concerned, the FAB CE view is based on
the criteria formulated together with setting the EU-wide targets. FAB CE
figures are consistent with both initial starting point options discussed at the
beginning of the year.
The artificial starting point, as elaborated by PRB in their assessment, is
perceived by FAB CE as changing the rules mid way during the process.
Footnote 1: This response is actively supported only by Austria, Czech
Republic, Croatia, Slovakia and Slovenia. Not supported by Hungary
2/11
Opinion of the States noted
#
document
7
Paragraph 1.4.2 Compliance checks and
Type of comment
(typo, factual
mistake, general,
etc.)
Mistake
Comment
Response
The text refers to section 0, which does not exist in the report.
ACCEPTED
The last sentence of the first paragraph says: “State and ANSP EoSM
performance is calculated for all Management Objectives (MOs) separately.”
REJECTED
rd
Chapter 9 Conclusions, 3 bullet
8
Paragraph 1.3.1
Factual
Proposal: Delete the sentence.
9
10
Chapter 1.3
Chapter 2.2, Paragraph 2.2.4,
General
General
Paragraph 9.3.5:
(RAT methodology for 2015 and 2016 is
a zero percent value target or an input
error.)
Justification: The performance is calculated separately for the Safety Culture
Management Objective and for all the other Management Objectives, i.e. not
for all Management Objectives. The calculation mentioned in the original
sentence was not taken on board in the Performance Plan template.
Missing information on Just Culture: a reference to PRB Annual Monitoring
Report 2013 (Volume 2) and the PRB Dashboard.
EoSM target is set for all MOs separately.
REJECTED
It is zero percent.
Dashboard contains 2013 data already. Also data will be
available via Monitoring Report once published.
REJECTED
Since there are no targets set for 2015 and 2016 the understanding is that
no inputs are required.
Annual values are required for monitoring purposes as per Reg
390/2013 Annex II, 3.1 of the performance Regulation.
Explanation:
Paras 2.2.4 and 9.3.5 to be deleted (assuming that zero values
are taken as annual values)
NSA/State needs time to develop to provide effective and correct results.
See COMMISSION IMPLEMENTING DECISION of 11 March
2014(2014/132/EU) Article 1, Point 3(a), (b)
AUSTRIA
1
2
Paragraph 6.3.8 page 94
Factual
Concerning the investment cost for NG-AATMS (implementation phase), the
planned value of 33,7MioEuro has been met. The project was started in
2008 and finished for ACC in Feb. 2013. No costs are carried forward to any
other period.
General
The use of the word “common project” is very much confusing in the PRBdraft report. Once it is used for the SESAR Term “(Pilot) common project”,
then it is used for projects done on FAB-CE level (with one or more partners
is not defined!) and thirdly it is used for projects in common with other
industry partners, such as airports, or COOPANS (5 ANSPs). Austria
proposes to clarify the understanding and consistently apply the wording. It
is planned to update the investment reporting to clarify the type of common
project (Type1: SESAR (PCP, CP1, CP2,…); Type 2: FAB-CE all 7; type 3:
FAB-CE partially; type 4: Industry partnership general (eg COOPANS, ACDM)). Please note: COOPANS and the NG-AATMS system are common
projects with one FAB-partner (Croatia) and they are an industry partnership
of 5 ANSPs (type 3 and type 4 common project)
OPEN
3/11
Comment noted. In the guidance material sent out together with
the template for RP2 Performance Plan (Explanations on how
to fill in the RP2 FAB Performance Plan template dated
03/03/2014) the definition for common project and investment
were provided. More clarification will be developed in line with
Austria’s comment for the annual reporting mechanism.
#
document
3
Type of comment
(typo, factual
mistake, general,
etc.)
General
Comment
Response
Austria is thankful for the assessment report and the given opportunity to
clarify some misunderstanding. Austria closely cooperates with the FAB CE
partners to identify the need for adaptations and their incorporation.
ACCEPTED
Noted, thanks.
No change to the document
CROATIA
1
Paragraph 1.1.5
General
It will be discussed in more details and reviewed in the updated version of
FAB CE Performance Plan.
OPEN
2
Paragraph 1.1.6
General
“This appears” form does not provide clear view of PRB. Is it in contradiction
with clarification and Regulation or not?
ACCEPTED
3
Paragraph 1.2.8
Mistake
In FAB CE Performance Plan, section 1.2, it is clearly stated which traffic
scenario is used.
ACCEPTED
3
Paragraph 1.2.8
General / Factual
The FAB CE Performance Plan is the higher level document and the
LSSIPs will be adopted accordingly in forthcoming meetings. Updated data
have already been sent to NM in May 2014 (planned ACC capacity values
are aligned with the reference values for 2018 and 2019)
5
Chapters 5.5, 5.19
General
The issues related to Croatian cost-efficiency performance and underlying
assumptions are under discussion with the PRB and EC. It will be explained
in more details and reviewed (if needed) in the updated version of FAB CE
Performance Plan.
OPEN
Modification of
Regulation No
29/2009
ITY-AGDL cell should be green – with 2016 inside.
REJECTED
General
Croatia
The information provided in the 2013 ATM Master Plan
reporting mechanism (which served as a basis for the
assessment) at the time of the assessment for the ITY-AGDL
was Not Applicable
REJECTED
Paragraphs 9.3.1, 9.3.10 first two bullets,
9.4.2 and 9.1.5
6
7
Chapter 6.6
Capacity KPA:
-
Paragraph 9.1.4
Paragraph 9.2.1
as far as the service units are concerned. Reworded.
OPEN
This is a FAB performance plan, not a national one.
Paragraph 9.3.7
CZECH REPUBLIC
1
Page 50
Paragraph 5.7.5
Factual
mistake/Additional
information
The economic surplus has no relevance to setting of these targets as the
cost development is part of the cost risk sharing as stipulated in the relevant
SES legislation.
4/11
OPEN
Opinion of the State noted
#
document
2
Page 53
Key point 3
Type of comment
(typo, factual
mistake, general,
etc.)
Factual
mistake/Additional
information
Comment
Response
The en-route DUC is better than European average and still decreasing.
Therefore both the DUC trend and its value are contributing to the EU-wide
targets.
OPEN
The starting points were clearly defined during the process of target setting
(determined cost and determined traffic for RP1 or determined cost for RP1
and updated traffic for year 2014). According to any of the two the Czech
Republic fulfils the requirement on average DUC decrease.
Any modification of the defined staring points later in the process is
unacceptable for us and is understood as significant change of the agreed
principles.
3
Page 54
Key point 5
Factual
mistake/Additional
information
The methodology of calculating Cost of Capital remains identical to the one
used in RP1 and uses values that were then recommended by PRU.
Risk profile of the company has remained unchanged since that time. The
risk increased due to extension of the reference period.
The relevant ICAO document allows ANSPs surplus to ensure their ability to
cover future CAPEX not only to cover traffic risk sharing.
4
Page 54
Key point 6
5
Page 55
Overall consistency of en-route cost
efficiency KPIs.
Page 56
Key point 1
The methodology and values provided by the PRU indeed refer
to the fact that it may be helpful to compute the efficient
WACC, but also to the fact that “the level of the asset base
used to compute the cost of capital and the financial risk
incurred
by the ANSP have also to be considered when establishing the
return on equity and the WACC for
the determined cost of capital”.
The pre-financing of capex referred to in ICAO and Eurocontrol
Principles foresee these through the calculation of cost of
capital on assets which are already financed (under
construction) but which have not yet entered into operation.
Such assets are included in the asset base used for the
calculation of the cost of capital.
REJECTED
Factual
mistake/Additional
information
Description of the pension system was part of reporting tables submitted
with the Performance Plan. The pension scheme is based on Defined
contribution; the employer is obliged to pay to the national system 25% of
gross wages. We will copy the details into this chapter in version 2.0.
Factual
mistake/Additional
information
Ad a) please see the comments above
The assumptions, description and justification of pensions costs
and description of national pensions regulations are not
consistent with the FAB Performance Plan template and
guidance. No figure has been provided and explanations are
insufficient.
OPEN
Ad b) please see the comments above
Ad c) will be described in version 2.0
Ad d) please see the comments above
6
REJECTED
Factual
mistake/Additional
information
The SU forecast will be updated in version 2.0 in accordance with
STATFOR prediction to be available at the end of September.
As presented during the Stakeholders meeting the Czech Republic will not
use the N+2 mechanism to recover potential loss of revenues due to lower
than expected traffic volume.
5/11
We also understand that missing information and additional
information will be provided in the revised plan.
OPEN
Clarifications are needed on the intention not to “use the N+2
mechanism to recover potential loss of revenues due to lower
than expected traffic volume.”
#
document
7
Page 56
Key point 3
Type of comment
(typo, factual
mistake, general,
etc.)
Factual
mistake/Additional
information
Comment
Response
Taking into account significant loss of terminal traffic during past years the
effort made by ANS CR in order to keep constant UR was more than
sufficient (please consider the IATA remarks on this topic).
ACCEPTED
The DUC charged to users corresponds with our assumptions and with the
budget.
Key point 3 status has been changed to “Pass with reservations
as the traffic forecast issue is already taken into account in Key
point 1.
The Czech Republic does not charge any Cost of Capital. There is no any
kind of cross-subsidising between en-route and terminal services.
8
Page 56
Key point 5
9
Page 58
Overall consistency of terminal ANS cost
efficiency KPIs.
10
Page 87
Factual
mistake/Additional
information
Factual
mistake/Additional
information
Ad a) please see the comments above
insufficient.
OPEN
Ad b) please see the comments above
Opinion of the State and additional information noted
General
Comment accepted, details will be provided in version 2.0 of the
Performance Plan.
OPEN
Factual
mistake/Additional
information
It is correct that the CAPEX for the new main ATM system was included into
the Czech Republic Performance Plan for RP1. However there were no
plans to put the system into operation and start its depreciation in RP1. The
system is expected to be operational and therefore depreciated at the end of
RP2.
ACCEPTED
Factual
mistake/Additional
information
The planned costs of terminal services for the start of RP2 do not fully cover
the expected actual costs in order to maintain the unit rate at stable level.
REJECTED
Factual
mistake/Additional
information
Ad a) The en-route DUC is lower than European average and still
decreases. The starting points were clearly defined. Using any of the two
confirms the decrease of DUC. Any modification of the defined starting
points later in the process is unacceptable for us and is understood as
significant change of the agreed principles
Paragraph 6.1.9
11
Page 96
Paragraph 6.3.18
12
Page 109
Paragraph 9.1.6
13
Page 110
Paragraph 9.2.4
Please see also comments on page 56 key point 3
Ad b) Please see relevant comment above
Ad c) Please see relevant comment above
Ad d) Will be updated in version 2.0
6/11
REJECTED
Noted. No Action
Note that the Terminal ANS DUC trend has been modified to
“Passed with reservations”. However, the TNSU forecast
assumptions check remains as “Not Passed” due to the
significant divergence with the STATFOR forecast and the lack
of justifications for the chosen TNSU forecast figures. Upon
revision of the TNSU forecast, the RP2 determined costs
should be revised accordingly.
OPEN
Opinion of the State noted.
See also above responses
#
document
14
Page 112
15
Paragraph 9.3.11
Type of comment
(typo, factual
mistake, general,
etc.)
Factual
mistake/Additional
information
Comment
Response
REJECTED
Page 113
General
Will be updated in version 2.0 of the Performance Plan.
Factual
mistake/Additional
information
The planned costs of terminal services for the start of RP2 do not fully cover
the expected actual costs in order to maintain the unit rate at stable level.
Factual
mistake/Additional
information
•
•
•
insufficient.
OPEN
Paragraph 9.4.7
16
17
Paragraph 9.1.6
Paragraph 9.2.4
Please see also comments on page 56 key point 3
See the response to comment on Page 53, key point 3
REJECTED
(See Comment 12)
OPEN
(See Comment 13)
18
Paragraph 9.3.11
Factual
mistake/Additional
information
REJECTED
(See Comment 14)
19
Paragraph 9.4.7
General
Comment accepted, details will be provided in version 2.0 of the
Performance Plan.
OPEN
20
Paragraph 9.3.5
Factual
mistake/Additional
information
Despite lower CAPEX than anticipated in the Czech Republic RPI
Performance plan the actual amount of depreciation is roughly (higher in
2012, lower in 2013) the same as included into previous Performance Plan.
This is caused by two main factors:
OPEN
•
•
Postponement of the main CAPEX (new ATM system) – this system
was expected to put into operation at the start of the second RP and
therefore no significant depreciation cost was expected
New investments not included in the Performance Plan were procured.
It was the case for further development of CDM-A project, introduction
of CIV-MIL coordination, e-strip development etc. Most of these
investments were initially planned for RP2 but were realised in course
of RP1 already.
Taking these facts into account the users will not be double charged for the
delayed or cancelled investment projects.
HUNGARY
7/11
#
document
1
Monitoring of Hungarian cost-efficiency
Type of comment
(typo, factual
mistake, general,
etc.)
Factual
mistake/Additional
information
Comment
Response
When defining the net ATSP gain/loss of 2013, the change in the Hungarian
asset management fee calculation should be taken into account. As a result
of the agreement with users, the asset management fee of 2013 was
decreased by 714.9 million HUF in case of en-route activities. Thought the
performance plan was not modified, this amount cannot be recognized as a
gain or surplus of the ATSP since it had to be reimbursed to users in 2014.
Therefore the net ATSP gain/loss on en-route activity, the overall estimated
surplus for the en-route activity and the calculated profitability indicators
(RoE, surplus in percent of revenues) have to be modified. The resulting
RoE should be 24.19% due to this correction.
ACCEPTED
The surplus calculation for 2013 has been recalculated to take
account of the reimbursement of the asset management fee.
2
Hungarian cost of capital comments ,
Page 151
Factual mistake
Based on EU Regulation 391/2013 Article 13/6 Hungary asked for
exemption for traffic risk sharing for terminal air navigation services.
ACCEPTED
3
KFOR Compliance issue - Paragraph
9.3.12
Additional
information
Hungary started bilateral discussion with the European Commission and will
adjust the cost-efficiency submission accordingly.
ACCEPTED
Chapter 5 Cost-Efficiency /
Factual mistake
The text was modified to reflect the agreement reached with the
European Commission in respect of the presentation of the
costs relating to services to the KFOR sector.
SLOVAKIA
1
Paragraph 5.14.1 –Slovakia: Overview of
en-route KPI assessment/
Chapter 6 Investments/ 6.2 FAB and / or
Regional Dimension / Paragraph 6.2.14
Slovakia / page 91 / last sentence
ACCEPTED
We presume that decrease -7.0% applies to actual 2012 not 2013 and
decrease -2.0% applies to actual 2013 not 2012.
page 70, par. 4
2
The unit cost percentages of –7.0% and -2.0% are swapped between the
years 2013 and 2012.
Factual mistake
We suppose that in the sentence “Those projects can be traced back in the
RP2 Performance Plan of Hungary, namely in the CAPEX 1, 5, 6 and 7
projects.” instead of Hungary, it should say Slovakia.
SLOVENIA
8/11
ACCEPTED
#
document
Type of comment
(typo, factual
mistake, general,
etc.)
Comment
Response
1
Chapter 5.17 -Overview of en-route KPI
assessment,
General
Even though the en-route DUC trend for Slovenia is the same as for the
Union-wide targets for the period 2014-2019 (-3.3% p.a.) and is better than
the trend for the Union-wide targets for the period 2011-2019 (-2.1% vs. 1.7%), the PRB intends to advise to the Commission to recommend
Slovenia to revise downwards the level of DCs in RP2 through revision of
the FAB CE PP. This is being linked to Slovenia’s 2015 DCs (28.6 M€2009)
being substantially higher than 2012 (+9.7%) and 2013 (+5.8%) actuals and
the generated economic surpluses of Slovenia Control in the first two years
of RP1 (+3.6 M€2009 in 2012 and +1.85 M€2009 in 2013), which is being
understood as not taken into account when setting the profile of determined
costs for RP2.
REJECTED
Chapter 9.2 ,Paragraph 9.2.7
Slovenia
(clarification)
As clarified by Slovenia, the reasons for the significant differences in 2012
and 2013 actuals were mainly linked with:
significantly lower staff costs compared with forecasts from approved
Performance Plan 2012 – 2014, because of successful social dialogue,
resulting in agreed non-fulfilment of collective agreements on state as well
as ANSP level, which is no longer expected in 2015; and
significantly lower depreciation in 2012 due to late entry into operation of the
new ATC Centre at Ljubljana Airport.
With the above two reasons removed, Slovenia considers the planned DCs
in RP2 as appropriate and necessary for the provision of services while
respecting the contractual obligations on state as well as international level.
We therefore kindly ask PRB to remove the proposed recommendation to
the Commission and consequently:
delete a) in ‘’Overall consistency assessment of Slovenia en-route costefficiency KPIs’’ on page 80;
delete 1st bullet in chapter 9.2.7 on page 110.
9/11
These elements have been taken into account in the RP2 PP
assessment. As a result, the en-route DUC trend check has
been assessed as “Passed with reservations”.
#
document
Type of comment
(typo, factual
mistake, general,
etc.)
Comment
Response
2
Chapter 5.18 –Assessment: overview of
terminal ANS cost-efficiency KPI,
General
Slovenia forecasted the total Terminal Navigation Service Units (TNSUs) at
a higher level than the STATFOR base case scenario published in February
2014 for all years of RP2 and since the proper justification was missing, the
PRB intends to advise to the Commission to recommend Slovenia to revise
the TNSUs forecast for RP2 or provide detailed justification for the
significant deviation against STATFOR forecast.
REJECTED
(clarification)
Chapter 9.1
Assessment result, Paragraph 9.1.6
Slovenia
The additional clarifications provided are noted and
appreciated.
Nevertheless, the divergence with the STATFOR forecast is
very significant, whether in profile or in value.
We kindly ask PRB to note, that the TNSUs forecast was prepared on two
relevant assumptions, which influences faster growth forecast compared to
the STATFOR February 2014 forecast:
Chapter 9.2 Recommendations,
Paragraph 9.2.7

Slovenia.

Aerodrom Ljubljana, Ljubljana Jože Pučnik Airport is being privatised,
the new owner expected to formally become Fraport within a few
weeks’ time, contract with Fraport already signed, waiting approval of
the Slovenian Competition Protection Agency;
New passenger terminal was put in operation in 2014 at Airport
Maribor and according to the plans of the airport owners, new
connections are expected to be attracted in 2015 already.
With the two reasons listed we hope, that sufficient explanation/justification
is provided for the deviation against STATFOR forecast to be used in the
Terminal Navigation Service Units (TNSUs) forecast in the RP2 PP. We
therefore kindly ask PRB to remove the proposed recommendation to
the Commission and consequently:
delete a) in ‘Assessment: overview of terminal ANS cost-efficiency
KPI’’ on page 83;
nd
delete 2 bullet in chapter 9.2.7 on page 110.
3
Chapter 9.3.14 Compliance issues for the
Cost-Efficiency KPA,
General
(information)
assessment,
Please note, that in the updated version of the RP2 Performance Plan,
Slovenia will complete the information provided on the underlying pension
costs assumptions in line with the requirements of the FAB Performance
Plan template and guidance (for both en-route and terminal).
OPEN
Slovenia will complete the information provided on interest on loans in line
with the requirements of the FAB Performance Plan template (for terminal).
OPEN
We understand that missing information and additional
information will be provided in the revised plan
th
4 bullet
nd
2 bullet
4
Chapter 9.3.14 Compliance issues for the
Cost-Efficiency KPA,
General
(information)
nd
2 bullet
10/11
#
document
Type of comment
(typo, factual
mistake, general,
etc.)
Comment
Response
5
Chapter 9.4.6 Observations for the CostEfficiency KPA,
General
Slovenia will provide explanations and justifications on the significant
decrease in the net current liabilities deducted from the en-route asset base
compared to RP1.
OPEN
Slovenia will describe and/or justify the cost, nature and contribution of its
investments in a more detailed, less generic way, allowing proper
understanding of the importance and need for such investments.
OPEN
(information)
assessment,
rd
3 bullet
6
Chapter 9.4.8 Observations for the
Investments.
General
(information)
11/11
RP2 Assessment - Comment Registry FABEC
Title of the Document commented: PRB Assessment Report of Performance Plans for RP2: FAB EC
Version: 2.0
Date of issue: 15/09/2014
#
Type of comment
(typo, factual mistake,
general, etc.)
Comment
Response
FABEC: comments from Bernhard Mayr, Chairman of the FABEC Financial and Performance Committee, Federal Ministry of Transport and Digital Infrastructure
1
4.1.1
disagreement
2
4.1.2, table 7
missing
data/disagreement
3
4.1.3
disagreement
4
4.1.12
mistake
5
4.1.12, 4.4.6
disagreement
A consistency check based on the comparison of FABEC reference values (resulting
from an theoretical break down methodology conducted on purely political targets set)
with a FABEC target based on a bottom-up delay forecast methodology without any
consideration regarding the up to date information concerning FABEC system
implementation and airspace design projects impacting capacity given in the FABEC
performance plan is not supported.
Comparing the annual actual performance with the annual targets in this way is unfair.
Indeed, the actual performance in 2012 and 2013 was better than planned partly as a
result of a lower traffic (RP1 targets had been set considering a base case traffic
growth scenario, while traffic decreased during 2012 and 2013), and not as a result of
an inefficient target setting process. The year-to-date value for 2014 should be added
in order to be more fair. It shows, that the target for 2014 is expected not to be reached.
YTD performance of FABEC until July 2014 is 0.69 instead of so 0.50 in 2013
(+25.4%).
FABEC requests PRB to revise its comment taking into account this remark.
The assertion regarding the diversion of FABEC ANSPs’ effort from providing much
capacity is maybe a subjective view of PRB but does certainly not reflect reality.
FABEC ANSPs are continuously working hard to ensure the provision of capacity.
This sentence should be deleted.
The Belgocontrol annual contributions presented in the table 11 are not the right ones.
According to the FABEC Performance Plan §3.1.(c).(i), those contributions are the
following :
2015 : 0.08
2016 : 0.08
2017 : 0.08
2018 : 0.08
2019 : 0.09
The correction of those values should also lead to a revision of the aggregated ANSP
contributions (last row of table 11).
The inconsistency of capacity targets at FABEC and ANSP level identified by PRB is
most probably related to the use of differing traffic scenarios.
PRB should provide more information on the methodology used to aggregate ANSP
1/21
OPEN
OPEN
OPEN
ACCEPTED
but findings do not change.
OPEN
#
Type of comment
general, etc.)
6
4.4.4
disagreement
7
4.4.5
8
Page 107, Chapter 8
9
9.2.1
1
PRB assessment Report of FABEC performance
plan for RP2,
Chapter 1.3.2
2
3
4
5
plan for RP2,
Chapter 5.5.6
plan for RP2,
Chapter 5.6.1, 3. En-route DUC trend
plan for RP2,
Chapter 6.6.2 table 52
plan for RP2,
Chapters 4.5.5 and 9.2.2
Comment
Response
figures to FABEC level.
The definition of 78% CRSTMP share is based on facts and historical data. In its
assessment PB should use a period equivalent to RP2 (5 years) including e.g. large
ATM system implementations.
disagreement
The incentive scheme as described by FABEC is compatible with the article 15 IR
391/2013. The statement made in 4.4.5 is unfair and suggests that ANSPs would cheat
on the selection of delay reasons.
disagreement
Clarification of phrase “The FABEC Performance Plan contained no specific details on
how the FUA
legislation would be applied to provide additional capacity” is appreciated as the military
dimension is included in Chapter 7 (Worksheet 5) of FPP
disagreement
FABEC en-route capacity targets are only slightly above the PRB reference values for
the year 2015 to 2018 and equal for the year 2019. The temporal capacity shortages of
FABEC ANSPs are mainly due to major system implementation within RP2. From an
economical point of view, it wouldn't be efficient for ANSPs to continuously hold spare
capacity available for this kind of non-recurring event.
FRANCE: comments from Stéphane LAFOURCADE DTA / MCU / Pôle Ciel Unique
Lack of explanation
PRB is kindly requested to add a comment regarding 2013 FR ATM-S RAT application:
55%.
This comment could read: “The provision of RAT use was formally introduced by DSNA
in July 2013 and is not available for the all reporting period, explaining the 55% 2013
value.”
General
PRB ex-post RoE calculation is not clear and the economic relevance of such a
theoretical ex post analysis can be challenged and has no added value.
general
The complete analysis and subsequent conclusion should refer to 2011-2019
timeframe, including both RP1 and RP2 periods.
Mistake
First French cell is referring to German capex: shall be corrected.
disagreement
According to IR 390/2013 there is no obligation of defining terminal capacity targets per
airport. This would tremendously increase complexity.
OPEN
OPEN
OPEN
OPEN
REJECTED
Irrelevant info for overall RP2
assessment.
OPEN
ACCEPTED
Text changed to:
“The en-route DUC trend is also worse
if considered over the period 20112019, even if normalised for the
STATFOR base case traffic forecast.
The en-route DCs trend is also much
worse than that for the DCs profile
underlying the Union-wide targets,
whether considered over the
periods 2014-2019 (+0.2% p.a. vs. 2.1% p.a.) or 2011-2019 (+0.7% p.a.
vs. -0.8% p.a.).”
ACCEPTED
REJECTED
IR390 requires the Member States to
establish a national target on arrival
delay with a breakdown for monitoring
2/21
#
6
7
1
2
3
Type of comment
general, etc.)
plan for RP2,
Chapter 5.7.1, 1. Traffic forecast assumption
Factual
plan for RP2,
Chapter 5.6.1, 2. Inflation
Factual
Comment
Response
PRB states that forecast TNSU for 2017 – 2019 are slightly below STATFOR base
case published in February 2014 : this is only due to the rounding effect : the traffic
assumption is STATFOR base case.
PRB suggest to adjust 2013 actual inflation to be in line with EUROSTAT HICP rate
published in April 2014 : DSNA value is EUROSTAT value but more precise, not
rounded.
BELGIUM: comments from Théodomir NSENGIMANA BELGIAN CIVIL AVIATION AUTHORITY, Airspace and Airports Directorate
4.1.12 (The contribution of the individual ANSPs),
Factual/mistake
The Belgocontrol annual contributions presented in the table 11 are not the right ones.
table 11, Belgocontrol’s data.
According to the FABEC Performance Plan §3.1.(c).(i), those contributions are the
following :
•
2015 : 0.08
•
2016 : 0.08
•
2017 : 0.08
•
2018 : 0.08
•
2019 : 0.09
The correction of those values should also lead to a revision of the aggregated ANSP
contributions (last row of table 11).
4.2.3 (Breakdown of arrival capacity target at
General/mistake
In following sentence from the FABEC performance plan Belgium has informed that the
Belgian airports)
arrival capacity target has only been set at two airports due to the lack of reliable data
at other three airports. That is why the breakdown of the target was limited at these two
airports (Brussels and Liège). “Although five airports should be subject to target setting,
this was not possible at three of them due to the absence of ad hoc traffic volumes. The
two airports on which a draft target has been set represent almost 80% of total IFR
flights.” This issue of missing data has been bilaterally discussed between Belgian
NSA, Commission and PRB.
4.4.9 a not fully transparent incentive scheme for
General/mistake
It was probably not fully clear that the targets have been set only at 2 of 5 Belgian
Belgium
airports (namely Brussels and Liège). Where the performance plan is referring to the
3/21
purpose per airport (c.f. IR390, Annex
I, 3.1.b). While not specified, it is
acceptable to provide an aggregated
monitoring value for airports with a low
share of arrival ATFM delay.
ACCEPTED
Text changed to:
“The forecast total TNSUs is based on
France’s own forecasts. They are
higher than the STATFOR base case
published in February 2014 for 2015
and 2016 (by +0.8% and +1.4%,
respectively). For the remaining years
of RP2, the forecast TNSUs
correspond to the STATFOR base
case published in February 2014 .”
ACCEPTED.
Following text removed: “
Note that the 2013 actual inflation rate
will need to be slightly adjusted to be
fully in line with the EUROSTAT HICP
rate published in April 2014, in
compliance with the Charging
Regulation.”
ACCEPTED
but no change to findings
OPEN
OPEN
#
4
5a
5b
6
7
8
4.5.9 a not fully transparent incentive scheme for
Belgium
RP2 - FABEC, Chapter 5, item 5.1.5. (page 36)
Chapter 5, item 5.2.1. Top of the page 38 (no use
of updated TSU)
Chapter 5, item 5.2.1. Top of the page 38 (no use
of updated costs)
Page 38, Key points for Belgium-Luxembourg enroute charging zone, 1. Traffic forecast
assumptions.
Page 38, 3. En-route DUC trend:
Type of comment
general, etc.)
General/mistake
General comment on
methodology
Mistake/Factual
General/mistake
General/mistake
Comment
Response
incentive scheme applicable at airports it has to be understood that it is only these two
airports which are meant.
In the following sentence from the performance plan (chapter 4.1, line 68) there is a
typo (number 2 was missing). “The target has been set at 2 of 5 airports for the
following reason”.
Same as the previous comment
OPEN
We would like to comment on the methodology for calculating the gain/loss on the En
route activity.
It is not correct to consider the cost and traffic risk of one specific year. Art. 14 of the
charging regulation stipulates that the cost risk has to be calculated over the whole
reference period and not on a yearly basis. Traffic and cost risk have to be managed
within a reference period, not within a single year. Some cost cutting measures may
have a one shot effect, others may affect several years.
The adjusted en-route TSU have been provided in annex E to the Belgian-Luxembourg
en-route cost efficiency target. This adjustment consists in the use of low growth
scenario for the starting point of 2014 in order to be consistent with the same low
growth scenario which is used (also for EU wide target setting) during RP2. According
to annex E the updated TSU amount 2.324.045 compared to 2.422.721 of the PP RP1
year 2014.
The decision not to update the determined costs of 2014 was taken in line with the
decision of the Commission not to update these costs for EU wide target setting (see
“whereas 12” of the EC decision).
Please note that the annex E to the Belgian-Luxembourg en-route cost efficiency target
provides information on the adjustment of the determined costs of the PP RP1 year
2014 in order to neutralize the effect of the new costs of Luxembourg ANSP introduced
as from RP2.
See also comment on comment # 5. The use of low case scenario in RP2 is in line with
the decision of the EC to use low case scenario for setting EU wide targets (see
“Whereas 12” of the Commission’s decision.
General/mistake/factual
The Be-Lux DUC trend of -0.2% p.a. is compared to the union-wide cost –efficiency
trend of
-3.3% p.a (2014-2019). However, the union-wide trend was calculated on
the basis of the original 2014 costs in the RP1 performance plan in combination with an
update of the number of service units, while the trend of the Be-Lux DUC is now
calculated on the basis of the original DUC of 2014 without taking into account the
downturn in traffic. The original DUC is lower than the updated DUC because the
projected traffic volume for 2014 is lower than originally assumed in Commission
Decision 2011/121/EU.
Taking into account the same parameters as the EC decision (-3.3%), the Be-Lux DUC
decreases with 1.7% p.a. instead of 0.2% p.a. This implies that we realize 52% of the
EU wide target and not only 6%.
4/21
REJECTED
Article 14 of the Charging Scheme
regulation (EU N° 391/2013) relates to
the costs exempt from risk sharing.
The analysis provided on p.36 of the
PRB assessment Report presents an
economic analysis of the surplus
generated by Belgocontrol with respect
to the en-route activity in 2012 and
2013.
ACCEPTED
A note has been inserted in the
assessment report to capture this
issue.
ACCEPTED
issue.
OPEN
Comment noted.
ACCEPTED
issue.
#
9
10
Page 39, point 4. En-route DUC level
Type of comment
general, etc.)
General
Page 40. 6. Verification of the description and if
applicable, the justification, of economic
assumptions provided in the Performance Plan
General/mistake
Page 40 - 7. Costs exempt from risk sharing (the
level and composition of costs exempt from risk
sharing for RP2)
General/mistake
12
Page 40. Overall consistency assessment of
Belgium-Luxembourg en-route cost-efficiency KPIs
General
13
Page 42, Key points for Belgium terminal charging
zone; 1. Traffic forecast assumptions
General
11
Comment
Response
Moreover, the trend of Belgium-Luxembourg DUC should be assessed on the basis of
annex E to the Belgian-Luxembourg en-route cost efficiency target which is an integral
part of the performance plan. This annex takes into account the new costs introduced
for the first time in RP2 by Luxembourg ANSP. The adjustment of the starting point with
these costs together with the adjustment of TSU (from base to low case scenario)
results in a yearly reduction of the DUC by -1,7% corresponding to a yearly reduction of
DC by -0,2% and a yearly increase in the SU by +1,5%. Belgium requests PRB to base
the assessment on the information provided in this annex E.
There are doubts about the comparability of ATC organizations in cluster groups.
Comparing ANSP with the ‘best in class’ of the cluster is not an objective approach as
the ANSPs will be treated differently depending on the cluster they belong to. A cluster
of 2 ANSPs is rather limited to make comparisons.
When assessing the level of DUC of Belgium-Luxembourg in comparison with the DUC
of the Netherlands the following external and objective factors need to be taken into
account:
1. The traffic in the Dutch airspace generates more SU (2,9 million in 2019)
than in the Belgian-Luxembourg one (2,5 million in 2019) among others due
to the traffic mix with less heavy aircraft in the Belgian airspace, smaller size
and higher complexity of the Belgian airspace.
2. The Belgian-Luxembourg share in the MUAC costs (31%) is 11% higher than
the share of the Netherlands (20%).
3. New costs have been introduced in the cost base of Belgium-Luxembourg.
This represents around 6 million euro p.a. (€2009) . It is about the costs of
the Luxembourg ANSP.
The consideration of these factors gives a totally different picture.
No detailed information has been given on the pension costs due to the fact that the
pension costs are paid through the State budget and not through the user charges.
Moreover Belgocontrol does not claim exemptions to cost-sharing related to pension
costs (see point 4, b; of additional information to the reporting tables).
With regard to the information on the interest rates there is no information to be
provided as Belgocontrol does not plan to have new loans during RP2. The current
loans will be totally reimbursed in 2015 (see also point 4, c; of the additional information
to the reporting tables).
With regard to IAS, it is correct that no adjustments are made beyond the provisions of
the International Accounting Standards as described in point 1, c; of the additional
information to the reporting tables.
Belgium confirms its intention to consider costs exempt from risk sharing but it was not
possible to include the level and the composition the cost items which are foreseen in
article 14, 2, b, of the charging Regulation.
There could be for example a decision to reallocate the Agency support costs from part
I budget to part II budget but no decision has been taken yet.
Belgium requests PRB to take into account this and the above provided information
when drafting the draft recommendations with regard to en-route cost-efficiency for
Belgium-Luxembourg
The use of low case scenario in RP2 is in line with the decision of the EC to use low
case scenario for setting EU wide targets (see “Whereas 12” of the Commission’s
decision.
5/21
OPEN
Belgium opinion on this issue was
noted by the PRB.
REJECTED
It is expected that States provide
information on the contribution rates
and corresponding amounts of pension
contributions that are included in the
staff costs reported for RP2. See p.27
of the PRB guidance on how to fill
Annex C of the RP2 FAB Performance
Plan template.
ACCEPTED
Comment noted.
ACCEPTED
Comment noted.
OPEN
Comment noted.
#
Type of comment
general, etc.)
Comment
Response
14
Page 43; Key points for Belgium terminal charging
zone; 5. Verification of the description and if
General
See comment on comment #10
REJECTED
15
Page 43; Key points for Belgium terminal charging
zone; 6. Costs exempt from risk sharing
General
Plan template.
ACCEPTED
16
Page 43; Overall consistency assessment of
Belgium terminal ANS cost-efficiency KPIs
General
Belgium requests PRB to take into account the above provided information when
drafting the draft recommendations with regard to terminal cost-efficiency for Belgium
17
RP2 - FABEC, Chapter 6, item 6.4.5. Belgium
ANSP investments (page 90)
Factual mistake
18
Factual mistake
The amounts mentioned per project are not correct (nominal terms instead of €2009?).
ATM automation system: 14,3 M€ planned for RP2
A-SMGCS EBCI, EBLG, EBBR: 13,8 M€ for RP2
Other not detailed projects: 18,7 M€
The total cost of the project "approach radars Brussels, Ostend and Charleroi" amounts
to 21,5 M€ in nominal terms. From this amount 4,4M€ in nominal terms (3.9M€2009) is
planned in RP2.
Comment
RP2 - FABEC, Annex 1, figure 29 ( p. 115)
Comment
19
20
21
22
23
24
Page 108, Chapter 9.1.4 (breakdown capacity
target per airport)
Page 109, chapter 9.2.2 (breakdown capacity
target per airport
Page 109, chapter 9.2.3 (draft recommendations)
Page 111, chapters 9.3.10 – 9.3.11 (pension &
cost sharing)
It is not clear for us how the percentages are calculated: En route + terminal EBBR? Or
at company level? Nominal or in €2009? Actual or planned or combination
actual/planned?
Comment noted.
ACCEPTED
Comment noted.
ACCEPTED
REJECTED
The assessment is based on Belgium
previous reporting. No action.
ACCEPTED
The calculation is computed using
States submission for the charging
reporting in €2009.
ACCEPTED
General
In changes over the time frame 2011-2019, a correction should be made for the one
shot effect of IFRS implementation in 2011 for MUAC and Eurocontrol Agency. The
effect of IFRS in 2011 distorts the percentage change.
In figure 29, the one shot effect in 2011 should be neutralized for MUAC and
Eurocontrol Agency.
General
OPEN
General
See comment on comments # 12 and # 17
ACCEPTED
See comment on comments # 10 and # 11
See answers to comment on
comments # 12 and # 17
REJECTED
General
Note that this issue is documented on
p.116 of the assessment report.
OPEN
for the underlying pension costs
assumptions
6/21
#
Type of comment
general, etc.)
Comment
Response
Plan template.
ACCEPTED for the costs exempt from
risk sharing
1
2
THE NETHERLANDS comments by Ad van der Westen, Civil Aviation, DG Mobility, Ministry of Infrastructure and the Environment
Page 10, para 1.1.5, lack of list on the exact Flight
General remark
Considered to be generally known information
Information or Upper Information Regions
(FIR/UIRs)
Page 14, para, 1.2.17
Factual mistake
3
4
Page 13-14, Para 1.2.14 1.2.18, 1.2.22,
Page 25, paras 4.1.2 and 4.1.3
5
Page 26, paras 4.1.8 and next
6
Page 29, para 4.1.15
Factual mistake
7
Page 29, Table 12
Factual mistake
8
Page 29, para 4.2.3
Factual mistake
Factual mistake
Factual mistake
Increase of GDP in 2014: 0,8% (source IMF/WEO April 2014)
“France” to be replaced by respectively “The Netherlands”.
The text of these paras is not based on facts. FABEC has indicated time and again that
the Eurocontrol/PRU figures on the capacity development were not right and has
offered to cooperate with PRU to come to a common understanding and point of view.
Furthermore, no account seems to have been taken from the observation in the FPP
that new systems will always have temporarily negative effects on the capacity. FABEC
has taken account of these negative effects.
Related to the previous remark:
a decision to postpone investments could have been based on good reasons, a.o.
technical causes, financial problems, airport restrictions, interdependencies between
the various targets.
FABEC has responded to Commission’s letter and indicated that a FABEC target of 0.4
as expressed by PRB was not possible
The values for all causes and CRSTMP causes seem to have been mixed up for
France and Germany. All causes should be the larger value.
Table is not consistent: all causes and CRSTMP values should be mentioned (? table
based on Performance Plan data)
The context of the ATFM arrival delay makes it clear that the Dutch figures were
applicable only on Schiphol Airport, simply because the other airports are too small.
See also para 4.2.19
REJECTED
Information mandate by legislation
shall be provided
REJECTED
Noted but no change to the report,
source used in the report is the
European Economic Forecast
ACCEPTED
OPEN
OPEN
OPEN
ACCEPTED
REJECT
IR390 Annex I, 3.1.b requires Member
States to provide a breakdown of the
national target per airport for
monitoring purposes.
Note: An aggregated monitoring value
7/21
#
Type of comment
general, etc.)
9
Page 30, para 4.2.8
Misunderstanding
10
Factual mistake
11
12
Page 32, para 4.4.2
Page 32, para 4.4.5
13
General remark
14
Page 67, The Netherlands: Setting the scene for
the RP2 cost-efficiency
Assessment, para 5.11.2
General remark
Assessment, para 5.11.2, para, 5.11.5
General remark, factual
mistake
Assessment, table 24
General remark
15
16
Comment
Response
The Dutch target is established based on the historical performance and in line with
the performance observed throughout the last years. Baseline is that no additional
airport delay is introduced with growth of traffic.
New legislation on noise abatement will be introduced during RP2. The effects on total
arrival delay are uncertain.
The LVNL measurement methodology used to derive the historical performance is
completely in line with PRB’s methodology (airport ATFM-delay per arrival of inbound
Schiphol traffic; http://prudata.webfactional.com/wiki/index.php/Airport_ATFM_delay).
LVNL will use another methodology until the end of 2014 (total delay per flight)
The context of the ATFM delay makes it clear that the Dutch figures were applicable
only on Schiphol Airport, simply because the other airports are too small (see also para
4.2.19)
Clarification of the last sentence is appreciated on the last sentence
The Netherlands has always assumed that the CRSTMP classifications in the
Regulations 390/2013 and 391/2013 were part of a well-defined, well managed and
well supervised Eurocontrol NM classification system.
The CRSTMP part in the total delay fluctuated substantially in the past. The average
CRSTMP is about 25% of the total delay. This 25% is used to set the both the total and
the CRSTMP delay target.
Due to the lack of experience The Netherlands decided to use the historical CRSTMP
terminal value as starting point for the incentive scheme.
No dead band was used as a PRB representative clearly stated that every under
performance should be penalized.
Based on Article 15.1c of Regulation 391/2013 the bonus/malus system is symmetrical.
It is also explained that a higher (under/over performance will result in a higher
penalty/bonus. The maximum financial effects of the incentive scheme are limited.
PRB does not mention that both Belgocontrol and LVNL are obliged to maintain an fully
equipped organization in order to provide navigation services, while they do not deliver
services in UAS and even have to deliver some services to MUAC free of charge. Due
to the resulting reduction in economies of scale the costs of both organization are
higher.
The Dutch government decided that LVNL was not allowed to include capital cost on its
equity capital during RP1, due to the fact that the equity capital had to be built up.
Note that profit margin in the way it is used in this para does not represent the actual
ANSP’s profit margin, because it concerns only the ATC activities in the year
concerned and does not include the financial effects of activities in /or income from
other sources in that year
8/21
for a set of airports with a historically
and anticipated low share of arrival
ATFM delay is acceptable.
OPEN
OPEN
OPEN
OPEN
OPEN
ACCEPTED
New text inserted in the Report to
reflect this comment.
ACCEPTED
Text was amended on p.68 to reflect
this comment.
ACCEPTED
Note that the purpose of the analysis
provided on p.68 is not to show the
accounting profit of LVNL. The
objective is to present an economic
analysis of the surplus generated by
LVNL with respect to the en-route
activity in 2012 and 2013.
#
Type of comment
general, etc.)
Comment
Response
17
Page 70, Key points for the Netherlands en-route
charging zone, 1. Traffic forecast assumptions;
Page 155, Traffic forecast assumptions, 2014
development of TSUs
General remark
PRB uses traffic figures stemming from a date after the submission date of the
performance plan.
The Netherlands has explained the rationale behind the traffic figures, which were
based on the most recent insights and expert judgment at that moment.
Recent events (Ukrain-Russian situation, Syria, Iraq-IS developments and unrest in
Libya, ebola could have a substantial effect on economic developments and traffic
volumes.
The Netherlands will adopt the 2014 IMF WEO inflation rate for RP2. DUC 2019 will
increase from € 59,10 to € 59,80.
OPEN
18
19
20
21
22
23
Page 70, 2. Economic assumptions;
Page 156, Economic assumptions, Inflation rate
2014
Page 71, 3. En-route DUC trend, third para;
Page 158, en route determined unit costs,
(“If these costs (some 14 M€2009) were excluded
from the 2009 en-route costs, then the adjusted
DUC profile over the 2009-2019 period would be 1.6% p.a. which is substantially below the Unionwide cost-efficiency target (-2.5% p.a.”).
Page 71, En-route DUC trend, fifth para;
Pag 158, En-route Determined Unit Cost (DUC)
trend, third para (“If STATFOR February 2014 base
case forecasts were used to compute the planned
DUC, then the adjusted profile over the 2014-2019
period would be -1.6% p.a. which is still below the
Union-wide cost-efficiency target (-3.3% p.a.).
Similarly, the adjusted profile over the 2011-2019
period would be -1.2% p.a. which is below the
Union-wide cost-efficiency target (-1.7% p.a.”).
Page 71, En-route DUC trend, sixth para;
Pag 158, En-route Determined Unit Cost (DUC)
trend, sixth para (“It is noteworthy that the level of
MUAC costs in 2011 was exceptionally low
reflecting the impact of a one-off exceptional
reduction mainly relating to the implementation of
IFRS budgeting.”)
General remark
General remark
General remark
Page 71, En-route Determined Unit Cost (DUC)
trend, last para;
trend, third para on depreciation costs
General remark
trend, last para;
General remark/
Factual mistake
These costs were made to enable LVNL to reduce the costs and unit rates from 2010
onwards and to freeze the unit rates (after an additional reduction) from 2012 onwards.
We are of the opinion that this cost reduction is still important and relevant, the more so
as it has reduced LVNL’s possibilities of further cost reductions substantially.
1.
Your comment has been noted.
CORRIGENDA REQUIRED
Report updated with the assumption
the corrigendum is delivered.
OPEN
The Netherlands has explained the rationale behind the traffic figures, which were
based on the most recent insights and expert judgment at that moment. Recent
events (Ukrain-Russian situation, Syria, Iraq-IS developments and unrest in Libya,
ebola could have a substantial effect on economic developments and traffic
volumes.
Strikingly that the DUC trend in the period 2009 – 2019 is not mentioned in this
paragraph The DUC trend in the period 2009 – 2019 shows a decrease of around 20%
OPEN
1.
OPEN
There seem to be a change in the opinion on the one-off IFRS effects on he
MUAC cost base. Up until now they were not deducted/excluded from the MUAC
cost base, while PRB’s comment now seem to indicate that they are not to be
considered as part of MUAC’s cost base.
The development of MUAC’s staff costs is related to the remuneration systems of other
international/
intergovernmental international organizations and thus hardly manageable for MUAC’s
management and MUAC’s member states
The Netherlands has explained in its additional information and in the PP that a number
of LVNL’s assets are completely written off. A replacement of these assets will result in
an immediate increase in the depreciation costs.
Furthermore, capex are cash flows and not costs; as such capex have only an effect on
the cost base after their implementation. The AAA replacement and LVNL’s new ACC
building will have only a marginal cost effect, if at all, in RP2.
The following part of this statement is omitted by PRB:
The Netherlands is willing to plough back the depreciation and capital costs of non
implemented capital expenditure projects to the users, if
9/21
Your comment on the traffic figures has
been noted.
An analysis of the Netherlands enroute DUC trend over the 2009-2019
period is provided on p.71 (see third
paragraph).
There is no change in the opinion on
the one-off IFRS effect on MUAC costbase.
The factual analysis provided on p.158
highlights the impact of this one-off
effect on the trend in MUAC en-route
DCs per SU when computed over the
2011-2019 period.
OPEN
ACCEPTED
Your comment has been noted and the
#
Type of comment
general, etc.)
trend, fourth para
(“The Netherlands stated during the consultation
meeting that depreciation costs associated with
non-realised capex would be returned to users.”)
24
25
26
27
trend, first para
General remark
Page 72, 6. Verification of the description and if
assumptions provided in the Performance Plan;
Page 162, Verification of the description and if
General remark
Page 73, 7. Costs exempt from risk sharing;
Page 162, Description, level, composition and
justification of costs exempt from risk sharing
Factual mistake
Page 73, Overall consistency assessment of the
Netherlands en-route cost-efficiency KPIs
General remark
Comment
Response
1.
2.
text provided on p.71 and 159 was
modified.
this rule would be applied to all member states;
ANSPs have a right to recover the depreciation and capital costs of that project
retro-actively in case a capital expenditure project is implemented before its
planning date.
Of course, the reimbursement will only take place after the start of RP2 PRB’s
statement that the Netherlands stated during the consultation of the draft RP2
Performance Plan that depreciation costs associated with non-realised capex over RP1
would be returned to users is a factual mistake and never said as such.
Note that the profit margin concept in the way it is used in this para does not represent
the actual ANSP’s profit margin, because it concerns only the ATC activities in the year
concerned and does not include the financial effects of activities in /or income from
other sources in that year
The reasons for not passing this check are not clearly stated.
It is not clear which information on interest on loans is missing.
A clarification would be appreciated, the more so as the economic assumption on the
terminal charging zone passes the check
1.
There seem to be a misunderstanding about the RP1 uncontrollable costs. These
costs will not vanish into thin air at the end of RP1, but as far as they are now
foreseeable and expected to be part of the RP2 cost base, they have been
included in that cost base.
2. The structural effect of the RP1 uncontrollable costs on the RP2 cost base makes
it more difficult for LVNL to achieve a local Cost efficiency target consistent with
the EU wide CE target.
3. The question whether the RP1 uncontrollable costs are controllable or
uncontrollable is without prejudice to the inclusion of these costs in the RP2 cost
base.
The PP and the additional information on the reporting tables contains the necessary
information on the basis of the possible/likely uncontrollable costs in RP2.
1. Strikingly that the DUC trend in the period 2009 – 2019 is not mentioned in this
paragraph.
2. Neither seems the level of performance achieved in the past period to be taken
into account, the more so as the above mentioned cost reductions in the
Netherlands limit the room for manoeuvre in respect of cost efficiency
substantially.
Issues mentioned:
see previous remarks
10/21
ACCEPTED
Note that the purpose of the analysis
provided on p.72 is not to show the
accounting profit of LVNL. The
objective is to present an economic
analysis of the surplus generated by
LVNL with respect to the en-route
activity in 2012 and 2013.
REJECTED
No information on interest rates on
loans is provided in Annex C of the
Performance Plan (see Additional
Information 4-c). The information that
should be reported in item 4-c of the
Additional Information is described on
p.28 of the PRB guidance on how to fill
Plan template.
ACCEPTED
There is no misunderstanding, it is
clear for the PRB that costs exempt
from risk sharing relating to the first
years of RP1 (3.8 M€ for 2012 and 2.0
M€ for 2013, mostly staff costs) were
taken into account for RP2 (see p. 159
of the PRB report).
REJECTED
period is provided on p.71 (see third
paragraph).
#
Type of comment
general, etc.)
Comment
Response
28
Page 74, para 5.13 The Netherlands: overview of
terminal charging zone assessment, Overview,
third para;
Page 163, Overview of terminal charging zone in
the Netherlands, third para:
Page 75, Key points for the Netherlands terminal
charging zone; 1. Traffic forecast assumptions;
Page 163, Traffic forecast assumptions
General remark
It is not clear what is meant by “Total TNSUs for the TCZ accounted for 94.9% of the
TNSUs in the Netherlands in 2013.”
A clarification would be appreciated.
OPEN
A clarification of the reasons for passing this check with reservations would be
appreciated
ACCEPTED
charging zone; 3. Terminal ANS DUC trend;
Page 165, Terminal ANS Determined Unit Cost
(DUC) trend
General remark
29
30
General remark
A clarification of the reasons for not passing this check with reservations would be
appreciated, the more so as substantial cost containment measures were taken in the
past (2009/2010), which limit the room for manoeuvre in respect of an increase in cost
efficiency currently
Further investigation needed.
When the traffic forecast provided in
the RP2 Performance Plan is between
STATFOR low and base scenario, this
check is passed with reservation. This
methodology has been applied
consistently to all the charging zones.
ACCEPTED
This check was not passed for two
main reasons:
1)
31
charging zone; 5. Verification of the description and
if applicable, the justification,
of economic assumptions provided in the
Performance Plan:
Page 166, Verification of the description and if
General remark
See also previous remark on en route, in particular in respect of the information on the
interest on loans
Over the 2015-2019 period, the
profile of terminal ANS DUC for
the Netherlands TCZ (-0.8% p.a.)
is well below the SES aggregated
DUC trend (-2.2% p.a.), and;
2) The DCs used to compute the
Netherlands TCZ DUC for the
year 2015 (52.7 M€2009) are
+7.0% higher than 2013 actual
terminal costs (49.2 M€2009).
However, the PRB considered that that
it was important to take LVNL particular
context (no equity prior to RP1,
relatively low ratio of current assets
over current liabilities in 2013) into
account when assessing the
Netherlands terminal cost-efficiency
targets for RP2. As a result, it was
decided that this Check was not
passed with reservations.
REJECTED
11/21
#
Type of comment
general, etc.)
Comment
32
charging zone; 6. Costs exempt from risk sharing;
Page 166, Description, level, composition and
justification of costs exempt from risk sharing
Page 76, Overall consistency assessment of the
Netherlands terminal cost-efficiency KPIs
General remark
The PP and the additional information on the reporting tables contains the necessary
information on the basis of the possible/likely uncontrollable costs in RP2;
See also remarks on uncontrollable en route costs
33
34
35
1.
General remark
General remark
36
Page 102, table 53, Consistency of the information
on CAPEX provided in the Performance Plans with
the ANSPs’ investment plansfor the reference
period, if available
Page 103, table 55
37
Page 105, para 6.8.27
General remark
38
39
Page 108, paras 9.1.5 and 9.1.6
Response
Factual mistake
General remark
General remark
Strikingly that the DUC trend in the period 2009 – 2019 is not mentioned in this
paragraph and the cost reductions in the Netherlands in 2009/2010, which limit
the room for manoeuvre in respect of cost efficiency substantially.
Issues mentioned: see previous remarks
The fluctuations in the percentage of the investment expenses vs the gate to gate costs
show that this relation is rather questionable, if there is a relation at all.
LVNL did not draft a specific investment plan for RP2, as a five years investment plan
is part of the regular annual budget cycle.
The drafting ofa specific RP2 investment plan would only result in more inefficiency
Strange that the third column is headed “EU” and that neither Belgium, nor
Luxembourg are mentioned in this table
As stated before (and not mentioned by the PRB):
The Netherlands is willing to plough back the depreciation and capital costs of non
implemented capital expenditure projects, if
1. this rule is valid for all member states;
2. ANSPs have a right to recover the depreciation and capital costs of that project
retro-actively in case a capital expenditure project is implemented before its
planning date.
Of course, the reimbursement will only take place after the start of RP2
See also previous remarks on this issue;
The Netherlands has explained the reason for the establishment of a national target on
arrival ATFM
delay only for Schiphol (see also para 4.5.9).
Unfortunately, the PRB has not taken the cost containment measures in the
Netherlands in the period 2009/2014 into account
Plan template.
ACCEPTED
Comment noted.
OPEN
Comment noted.
REJECTED
The fluctuations are based on
Netherlands planning for both CAPEX
and costs. Assessment is correct. No
action.
OPEN
Noted
ACCEPTED
OPEN
Noted
REJECT
OPEN
and 2011-2019 periods is provided on
p.72 of the PRB assessment report.
12/21
#
Type of comment
general, etc.)
Comment
Response
40
General remark
The Netherlands has explained the reason for the establishment of a national target on
arrival ATFM
delay only for Schiphol (see also para 4.5.9) and para 9.1.4).
REJECTED
41
9.2.2
Dis-agreement
airport. This would tremendously increase complexity.
REJECTED
42
General remark
43
Misunderstanding
44
Page 111, para 9.3.14
The Netherlands is willing to adapt the inflation rate 2014.
The Netherlands is not willing to adapt neither the en route nor the terminal TSU for
reasons explained above.
See also remark on para 4.2.8
The Dutch target is established based on the historical performance and in line with
the performance observed throughout the last years. Baseline is that no additional
airport delay is introduced with growth of traffic.
New legislation on noise abatement will be introduced during RP2. The effects on total
arrival delay are uncertain.
The LVNL measurement methodology used to derive the historical performance is
completely in line with PRB’s methodology (airport ATFM-delay per arrival of inbound
Schiphol traffic; http://prudata.webfactional.com/wiki/index.php/Airport_ATFM_delay).
LVNL will use another methodology until the end of 2014 (total delay per flight)
See also previous remarks
1. There seem to be a misunderstanding about the RP1 uncontrollable costs. These
costs will not vanish into thin air at the end of RP1, but as they are now
foreseeable and expected to be part of the RP2 cost base, they have been
included in that cost base.
2. The structural effect of the RP1 uncontrollable costs on the RP2 cost base makes
it more difficult for LVNL to achieve a local Cost efficiency target consistent with
the EU wide CE target.
3. The question whether the RP1 uncontrollable costs are controllable or
uncontrollable is without prejudice to the inclusion of these costs in the RP2 cost
base.
4. The PP and the additional information on the reporting tables contains the
necessary information on the basis of the possible/likely uncontrollable costs in
13/21
OPEN
Comment noted.
OPEN
ACCEPTED
There is no misunderstanding, it is
clear for the PRB that costs exempt
from risk sharing relating to the first
years of RP1 (3.8 M€ for 2012 and 2.0
M€ for 2013, mostly staff costs) were
taken into account for RP2 (see p. 159
of the PRB report).
#
45
46
47
1
2
Page 111, para 9.3.15
trend, eighth para
(“Although, these costs certainly affect the level
of 2015 determined staff costs, their impact on the
planned trend over RP2 should be rather
limited.”)
Page 159
Type of comment
general, etc.)
General remark
General remark
Factual mistake
Comment
Response
RP2.
It is not clear which information on interest on loans is missing.
A clarification would be appreciated, the more so as the economic assumption on the
terminal charging zone passes the check
Plan template.
A change in the regulations is necessary to solve this problem
The structural effect of the RP1 costs exempt from cost risk on the RP2 costs are
somewhere around 2% of LVNL’s total en route costs.
This structural effect makes it more difficult for LVNL to achieve a local Cost efficiency
target consistent with the EU wide CE target.
Argumentation on difference in cost of capital is not correct: it is not due to interest rate
but due to the addition of return on equity in RP2
Note that the Check on the verification
of the economic assumptions provided
in the Performance Plan is not passed
for terminal ANS.
OPEN
OPEN
Comment noted
OPEN
This comment is not consistent with the
information provided by the
Netherlands in Annex C of the
Performance Plan which indicates that
LVNL cost of capital for RP2 will be
computed by only taking into account
the cost of debt (the capital structure
indicates 100% of debt and no equity).
The Netherlands also specifies in
Annex C that since the substantial part
of their assets is financed through debt,
it was decided to assume that LVNL
capital structure is 100% based on
debt over RP2.
This apparent inconsistency would
deserve a clarification from the
Netherlands.
SWITZERLAND comments from Florian Kaufmann, ANS Performance Manager Deputy Head Section Regulation ANS/Airspace, Federal Office of Civil Aviation (FOCA)
1.2.22, p.15
General
France is mentioned instead of Switzerland
ACCEPTED
The figures for Switzerland are not correct!.
1.3.2, p.17, Table 2
Factual mistake
OPEN
In CH the RAT is only applied at ZRH and GVA (=airports under performance scheme).
Hence, as basis for calculation of the “assessed %”, only the reports concerning ZRH
and GVA must be included. The correct figures to be included in the report are the
following ones (Values are for ground and overall):
-
SMI: 100 cases, 91 assessed with RAT = 91%
14/21
#
Type of comment
general, etc.)
Comment
-
3
4
5
5.15.1, p.80
5.15.1, p. 81
5.15.1, p.81
Factual
mistake
Factual mistake
General
Response
RI: 3 out of 5 = 60%
Tech.: 6 out of 6 =100%
“It appears that in its Performance Plan, Switzerland took into account the latest
information in terms of en-route costs and traffic in order to set the starting point for its
en-route DUC profile over RP2” and “Switzerland forecasts a -1.0% annual en-route
DUC decrease over the 2014-2019 period which is significantly below the Union-wide
cost-efficiency target (i.e. -3.3% p.a.)”:
This statement is not correct!
The starting point for the RP2 En route Cost-efficiency target is defined in the
Common Implementing Decision of 11 March 2014 (2014/132/EU), (12): “The
expected improvement in cost-efficiency for the second reference period should
be measured against determined costs for 2014…On the basis of the most recent
traffic assumptions for 2014…”
o The Determined cost baseline is equal to the Determined cost for 2014
 164.7 MCHF
o The traffic baseline is equal to the forecast 2014
 1.401 MTSU
o DUC 2014 Starting point  164.7 / 1.401 = 117.56 CHF
o Change DUC 2019 / 2014  (104.32-117.56) / 117.56 *100 / 5 = -2.25 %
(and not -1% as stated in the report)
Even if we would set the cost for 2014 at the level according to the Commission
Decision setting the RP1 targets, the performance achieved in RP2 would be
greater than -1%:
o Adjusted Determined cost 2014  161.3 MCHF
o DUC 2014 Starting point  161.3 / 1.401 = 115.13 CHF
Change DUC 2019 / 2014  (104.32-115.13) / 115.13 *100 / 5 = -1.9 %
“Around 14% of the capex planned by Skyguide for RP2 is associated with the Virtual
Centre project. It is understood that the overall aim of this project is to establish
(beyond 2016) a single “virtual ACC” covering the operations of Geneva and Zurich
ACCs”:
A virtual ACC covering Geneva and Zurich should be achieved only in the frame
of RP3 (Virtual Center 2 and 3)
Virtual Center 1, as it is explicitly mentioned in the selection of investment for RP2,
includes mainly Stripless as well as the closing of the Zurich center at low traffic
conditions.
“In 2019, Switzerland’s en-route DUC is planned to amount to 69.13 €2009 per SU
which is +26.6% higher than the average of the comparator group (54.62 €2009)”:
In general terms, Switzerland supports the launch of benchmarks (in particular
ACE), but has in previous consultations always rejected and still does not
accept the rationale of being in the same peer group as Austrocontrol and
Naviair, for the following reasons:
o Aggregated complexity score (ref. ACE 2012, p. 125): skyguide = 11.97,
austro control = 7.48 (-37.5%), naviair = 3.36 (-71.9%). The complexity
score of Switzerland (skyguide) is at the top of the list of complexity
scores! This important factor is not mentioned in a single word in the
15/21
REJECTED
The 2014 en-route costs, SUs and unit
costs reported for Switzerland in the
PRB assessment report correspond to
the information provided by
Switzerland in the body of FABEC
Performance Plan (see column
“2014F” in the table on p.146).
ACCEPTED
The text on p.81 was amended.
OPEN
#
Type of comment
general, etc.)
Comment
Response
assessment of DUC level, which is not acceptable.
Cost of living index (ref. ACE 2012, p. 29): impact of PPP adjustment on
employment cost per ATCO-hour is ~30€ for skyguide, ~10€ for austro
control, ~10€ for naviair
o Scope: More than 10% of Austro control service units are managed by other
ANSPs without cost compensation; meaning Austro control gets part of its
revenues without delivering the service
In summary, comparing Switzerland with Austria and Denmark without any adjustment
for complexity, cost of living and alignment between service units and cost is not
appropriate and leads unavoidably to wrong conclusions.
“Taking into account the above key points, in particular 3, the FABEC Performance
Plan, and in particular Switzerland terminal ANS cost-efficiency target is assessed as
not being consistent with the criteria laid down in Annex IV of the performance
Regulation”:
Annex IV refers to a Union-wide target, however there is NO Union-wide target for
terminal ANS CEF in RP2!
In this case, Switzerland wonders how it cannot be consistent? In the absence of
an EU wide target, there is no legal basis nor a rational for any consistency
checks! The “SES aggregated TANS DUC trend” is not more than a arbitrary
figure.
Besides, could you please be specific regarding criteria from Annex IV that are not
fulfilled?
“Switzerland’s ANSP investments are planned to be on average 57% lower for RP2
than for the period 2010-14”:
The total investment for RP2 will reach around 300 M CHF, yearly average 60 M, +7%
versus RP1 (ref. FABEC FAB RP2 PP Annex A-4-CH Presentations, page 19/50). The
investments included in the PP are only the main ones (“abstract”) and not the total
MUAC is mentioned under Switzerland (3rd line of table 54)
o
6
7
5.16, p. 86
6.8.36, p. 106
General
Factual mistake
8
6.6.2, Table 54
General
9
Annex1, p.169
General
“Following a revision of the Swiss Federal Aviation Act, from 2011 onwards and until
2019, these costs are borne by the Swiss Confederation and therefore not charged to
airspace users. If these costs were deducted from the en-route costs disclosed in 2009,
then the “adjusted” profile for Switzerland would be around -0.6% p.a. over 2009-2019
which is well below the Union-wide cost-efficiency target (-2.5% p.a.)”
There is no rationale and no justification to “adjust” the profile for Switzerland. The
changes in the law that are correctly mentioned did result in a true reduction of the
En route Determined cost as well as chargeable cost to the benefit of the airspace
users (without any increase of Terminal charges as a counterpart!).
The correct statement is that “Over the 2009-2019 period, the planned reduction in
Switzerland DUC (-2.4% p.a.) is in line with the Union-wide cost-efficiency target (-2.5%
p.a.)”. All additional statements regarding the “adjusted profile” should be removed.
16/21
ACCEPTED
It is correct that there is no Union-wide
target on terminal ANS. However,
Annex IV refers to a number of
assessment criteria specific to terminal
ANS (e.g. inflation, economic
assumptions, traffic trends, the efforts
planned compared to historical cost
trends for terminal ANS, etc.).
REJECTED
In RP2 Total CAPEX reach 87.9MCH
(68.6 M€2009) (See your table in page
8). No action
ACCEPTED
REJECTED
The decrease of Switzerland en-route
costs between 2009 and 2010 is not
due to a genuine improvement in costefficiency performance but reflects the
fact that, from 2010 onwards, some
costs were not financed by user
charges but borne by the FOCA. This
is a charging issue. In order to ensure
consistency when computing the
trends in en-route unit costs, the 2009
cost-base has been adjusted so that
the percentage changes over 20092019 are not affected by this change in
reporting.
#
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
Type of comment
general, etc.)
Comment
Response
GERMANY comments from Holger Kowoll, Head of Division Economic Oversight, Bundesaufsichtsamt für Flugsicherung (BAF) Federal Supervisory Authority for Air Navigation Services (NSA)
General
General
The method of rounding needs to be clarified and to be consistent over the whole
OPEN
document (number of decimal places, time/step of rounding, see e.g. page 94).
PRB-Assessment Report, page 13, Chapter 1.2.14
Typo
“France” -> “Germany”
ACCEPTED
Factual Mistake
In Table 2 most of the German RAT methodology application values are incorrect. It
ACCEPTED
has not been taken into account that according to the FABEC Agreement (notified to
the EC) only the ANSPs DFS and MUAC (related to the services provided in German
airspace) are included into the Performance Plan.
PRB has received- the correct figures in a separate email.
Typo
“Section 1.5” -> “Section 5”
ACCEPTED
Factual Mistake
Meeting #1 was on 26th February 2014
ACCEPTED
PRB-Assessment Report, page 22, Chapter 2.2
Typo
In Table 4 “Overall score (state level)” in cell Union-wide targets ATM-S 2018 “≥80%” is OPEN
missing.
Typo
“2108” -> “2018”
ACCEPTED with thanks
Factual Mistake
In Table 11 the figures of Belgocontrol do not correspond to the submitted FABEC PP.
ACCEPTED
PRB-Assessment Report, page 29, Chapter 4.2,
Factual Mistake
The values for “all causes” and “CRSTMP causes” for Germany (and France) are
ACCEPTED
Table 12
interchanged. This needs to be corrected.
PRB-Assessment Report, page 30, Chapter 4.2.7,
General / Factual
This is a false interpretation of the target calculation. To calculate the target the
ACCEPTED.
second sentence
Mistake
average of the period 2008 – 2013 served as the basis, which was even the last six
years, from this basis the efficiency path of the two RP1 years was then deducted.
The actual calculation of the target is
noted.
PRB Assessment Report, page 30, Chapter 4.2.12
Disagreement
REJECTED
airport. For reporting a breakdown will be provided.
The statement is correct. The
monitoring values (breakdown per
airport for monitoring purposes) were
expected to be provided as part of the
plan template.
General
The percentage value of 14.4% cannot be assessed/retraced. To verify this figure
ACCEPTED
last sentence
further explanation of the calculation method is necessary.
This ratio corresponds to the share of
DFS gate-to-gate ATM/CNS provision
costs in the total European system in
2012. The underlying data is available
in the ACE 2012 Benchmarking Report
which was published in June 2014.
General
The comparator group average values cannot be assessed/retraced in detail. To verify
ACCEPTED
these figures further explanation of the calculation method is necessary.
Comment noted.
General
From an economic point of view the calculation of the gearing using the WACC based
OPEN
on the “fixed” Return on Equity rate (actual) is questionable and may cause problems
regarding their interpretation.
Opinion of Germany noted.
General
The German starting point was based on the Determined Costs 2014 from PP RP1
OPEN
last paragraph
according to the SSC decision, adjusted (increased) by the interest effect of the
pension system (bAV). Therefore, the starting point is not dependant on the current
Comment noted.
traffic development.
17/21
#
Type of comment
general, etc.)
Comment
Response
16
Section 3, « Important note »
General
The DUC and its trend can be calculated, but the DC breakdown is missing.
OPEN
17
Section 3, third-to-the-last paragraph
General / Factual
Mistake
The additional staff costs for RP1 are noted as amounting to 7 M€ p.a. in RP1. This
must be 17M€ p.a. which leads to approx. 50 M€ for RP1, not “20 M€ p.a.” as stated in
the assessment report.
18
19
Section 3, penultimate paragraph
Section 3, 1st paragraph, last sentence
General
Factual Mistake
MUAC is providing services over the North-Western part of Germany not the Eastern
part
20
Section 3, second paragraph, last sentence
General
Remark: MUAC/Eurocontrol are covered by the Dutch section.
21
Section 3, third paragraph, last sentence
General
This issue was presented by NSA/DWD in the German national Consultation on RP2
targets, held on 5th June 2014 (see consultation documents).
22
Section 3, penultimate paragraph, penultimate
sentence
Factual Mistake
The stated 739.3 M€ cannot be retraced. This sentence needs a revision.
23
Section 3, second paragraph
General
24
General
25
Factual Mistake
26
27
second bullet
last bullet
second bullet
General
Typo
28
29
30
Typo / Factual Mistake
The terminal starting point was according to the SCC decision based on the terminal
cost base for 2014 (which was approved in November 2013), adjusted (increased) by
the interest effect of the pension system (bAV).
The data for 2010 in Figure 26 is not comprehensible.
In the Performance Plan for RP2 are links or references to the NSP for 13 projects, not
for 11 projects. The missing 2 references are not visible because of the size of the box
in the PP. There are also links to the NSP for Capex 1 “iCAS programme (iTEC Centre
Automation System)” and for Capex 5 “product management iCAS”.
The percentage value of 43% cannot be retraced.
For the RASUM project amount the reference on 2009 prices is missing.
Comment noted.
ACCEPTED
The text on p.60 was amended
according to your comment.
OPEN
Comment noted.
ACCEPTED
ACCEPTED
Remark noted.
ACCEPTED
Comment noted.
REJECTED
The figure reported on p.61 of the PRB
assessment report (i.e. “unrecognised”
actuarial losses amounting to 739.3
M€) was published in DFS 2013
Annual Report (see p.102).
OPEN
Comment noted.
OPEN
Could you please specify what do you
mean by “not comprehensible”?
OPEN
OPEN
OPEN
OPEN
Typo
For the Remote Tower Control project the amount (5.7 M€2009) is slightly different to
the one reported in the PP (5.5 M€2009).
For the MaRS project amount the reference on 2009 prices is missing.
General
Table 37 cannot be assessed/retraced. To verify these figures further explanation
OPEN
18/21
OPEN
#
31
32
33
34
PRB-Assessment Report, page 99, Chapter
6.5.5/6.5.6
Type of comment
general, etc.)
General
General
Typo
Disagreement
Comment
Response
regarding the calculation method is necessary. It cannot be identified where this data is
taken from.
The calculated percentage values cannot be assessed/retraced. To verify these figures
further explanation of the calculation method/basis is necessary.
For Table 55 any source citation is missing.
„2104“ -> „2014“
airport. For reporting a breakdown will be provided.
OPEN
OPEN
ACCEPTED
REJECTED
35
36
37
38
Germany: Assessment of en-route charging zone,
Section Traffic forecast assumptions
Factual Mistake
Section Traffic forecast assumptions
General
Section Traffic forecast assumptions comments,
second paragraph
General
Section En-route Determined Unit Cost (DUC)
Typo
In Figure 58 the actual Service Units figures for the years 2011 to 2013 are wrong. do
not correspond to the data submitted by Germany.
STATFOR May 14 base figures for 2016 to 2019 in Figure 58 cannot be assessed,
because these figures are not available in the STATFOR short-term forecast that is
only covering 2014 and 2015.
The figures 125.3 M€ and 103.5 M€ cannot be assessed/retraced. To verify these
figures further explanation of the calculation method is necessary.
Figure 60 seems to show the comparison between 2019 Determined Costs and 2011
Actual cost, but this is not mentioned in the legend.
ACCEPTED
Figure 58 was amended according to
your comment.
ACCEPTED
These figures were provided by
STATFOR. The figures reported for
2014 and 2015 correspond to the
short-term forecast. The planned
number of SUs for the years 20162019 have been computed by applying
the percentage rate of the medium
term forecast (released in February
2014) to the number of SUs planned
for 2015 as part of the short-term
forecast process.
ACCEPTED
Germany decided to use STATFOR
low traffic forecast for RP2. The figures
mentioned on p.144 of the assessment
report refers to the net gains that would
be generated by Germany and the
airspace users if the actual traffic over
RP2 is in line with STATFOR base
case scenario.
OPEN
Comment noted.
19/21
#
39
40
41
42
43
44
45
46
47
trend
trend comments, third-to-the-last paragraph
trend comments, last paragraph
Type of comment
general, etc.)
Comment
Response
General
The additional staff costs for RP1 are noted as amounting to 7 M€ p.a. in RP1. This
must be 17M€ p.a. which leads to approx. 50 M€ for RP1, not “20 M€ p.a.” as stated in
the assessment report.
ACCEPTED
General
trend comments, third paragraph, last sentence
trend comments, fourth paragraph, first sentence
General / Factual
Mistake
trend comments, fourth paragraph, third sentence
trend comments, penultimate paragraph
trend comments, third paragraph, third sentence
Factual Mistake
Section En-route Determined Unit Cost level
Comments, fourth paragraph
Germany: Assessment of terminal charging zone,
General
The percentage values -2.4% p.a. and -0.2% p.a. are wrong; based on the STATFOR
February 2014 forecast figures (-2.7% and -0.3%).
Remark: MUAC/Eurocontrol are covered by the Dutch section.
REJECTED
When the German DUC trend is
normalised using STATFOR SUs
figures (12 739 932 for 2011,
12 617 867 for 2014 and 14 114 149
for 2019), the annual percentage
changes amount to -2.4% p.a. between
2014 and 2019, and -0.2% p.a.
between 2011 and 2019.
ACCEPTED
Remark noted.
Factual Mistake
“13.3 M€” -> “13.8 M€”
REJECTED
The issue was presented by DWD in the consultation held in June 2014.
Based on the information provided by
Germany for DWD in Annex C of the
Performance Plan, en-route MET costs
amount to 31.46 M€2009 in 2018 and
44.73 M€2009 in 2019. This represents
a difference of 13.27M€2009.
ACCEPTED
Comment noted.
General
General
Factual Mistake
From an economic point of view the calculation of the gearing using the WACC based
on the “fixed” Return on Equity rate (actual) is questionable and may cause problems
regarding their interpretation.
OPEN
The mentioned 655.2 M€ cannot be retraced.
REJECTED
The mentioned STATFOR low scenario figures for 2015 are wrong as they differ from
the corresponding STATFOR low scenario February 2014 publication (1,268.4 kSU).
20/21
Opinion of Germany noted.
This figure corresponds to the amount
reported as adjustment to total assets
for DFS in 2013 in Annex C of the
Performance Plan.
OPEN
Comment noted.
ACCEPTED
#
Type of comment
general, etc.)
Comment
Response
Section Traffic forecast assumptions, second
paragraph
48
49
Section Terminal ANS Determined Unit Cost (DUC)
trend, second paragraph
Section Terminal ANS Determined Unit Cost (DUC)
trend, last paragraph
General
General
The terminal starting point was according to the SCC decision based on the terminal
cost base for 2014 (which was approved in November 2013), adjusted (increased) by
the interest effect of the pension system (bAV).
The comments confirm that the German terminal ANS DUC profile is better than the
SES aggregated DUC trend, nevertheless the overall assessment says not passing this
check.
21/21
The STATFOR figures provided on
p.151 of the assessment report have
been amended according to your
comment.
OPEN
Comment noted.
ACCEPTED
This is correct that the German
terminal ANS DUC profile over the
2015-2019 period is better than the
SES aggregated DUC trend. However,
the PRB notes that the determined cost
base used to compute Germany TCZ
DUC for the year 2015 is +12.1%
higher than 2013 actual terminal costs.
This difference contributes to a
relatively high starting point for RP2
terminal cost-efficiency targets in terms
of DUC. Although they are expected to
decrease by -1.6% p.a. between 2015
and 2019, Germany terminal DCs are
planned to be +5.2% higher than 2013
actuals.
RP2 Assessment - Comment Registry NEFAB
TitleoftheDocumentcommented:PRBAssessmentReportofPerformancePlansforRP2:NEFAB
Version:2.0
Commentsby: JukkaHannolaDevelopmentManagerFinnishTransportSafetyAgencyTrafiInfrastructureApprovals
#
Type of
comment
(typo, factual
mistake,
general,
etc.)
1
PRB Assessment Report of Performance Plans for RP2
general
2
ch 9/page 93/Cost of capital
general
3
ch 9/9.2.6
General
Comment
Response
Finland
In generally, the recommendations for NEFAB will be taken into account.
OPEN
In WACC calculation Finland has used the method set in ”Study on Cost of
Capital, Return on Equity and Pension Costs of Air Navigation Service
Providers” by Steer Davies Gleave. Finland has used the recommend method
form page 80 “the industry should move towards the calculation of an efficient
cost of capital over the long term, since this will ensure cost reflective charges
and align with the broad objective of economic regulation in other sectors to
encourage an efficient allocation of resources across the economy”.
More specific, Finland has used option 1: an efficient cost of capital calculated
on the assumption that the ANSP is an independent, commercial entity.
In their comment PRB says “the assumptions used to compile this figure are not
fully in line with the methodology laid down in Annex C guidance, with the risk
free rate slightly lower and risk premium slightly higher than the guidance”.
Finland has used 10 y government bond as a risk free rate. This is what is
recommended in Steer Davies Gleave study (page 72, 6.63)“ yields on a
Member State’s government bonds should be used as a proxy for the risk free
rate…”. As a risk premium Finland has used an average from three sources as
suggested by Steer Davies Gleave study (page 73, 6.65).
The cost of debt is provided by Swedbank. This is based on recommendation
by Steer Davies Gleave (page 73, 6.70) “in the event that there is no sufficiently
liquid domestic bond market in the relevant Member State, the cost of debt
should be estimated based on that of similar entities in another, similar country.”
This estimation was asked from Swedbank and they made comparisons to
Avinor and Swedavia. The estimation is based on the assumptions that the
credit rating of Finavia at the time of calculation was BBB+/A-. 10y corporate
bond was used in the calculations.
RPB comments: “No information is provided to reconcile that actual cost of debt
with this”, “no supporting information on a breakdown of these loans is
provided” and “During RP1 the average interest on debt is reported at 1.9 %,
however no supporting breakdown of the average cost of debt is provided”.
1/3
OPEN.
Comment noted
OPEN.
4
ch 9/9.2.8
5
ch 9/9.3.9
Finnish Transport Safety Agency has consulted about these remarks with
Finavia and Finavia is able to produce the needed information in a reasonable
time.
Finland/Finavia is able to provide more information in a reasonable time.
General
6
ch 9/9.3.10/9.3.11/9.3.12
General
1
9.2.4/ Compliance issues for the capacity KPA - Norway
General
2
9.2.7/ Information pensions, loans, asset base – Norway
General
3
9.2.7/ details on the costs exempt from risk sharing planned for RP2 Norway
9.2.8/ Link between main
investments and the ATM Master Plan requirements - Norway
General
5
9.3.10/ Common Project and
adequate reference to the proper PCP ATM functionalities - Norway
General
6
9.3.2/ The NEFAB should specify, in the FAB Performance Plan,
which traffic assumptions were used, and establish a clear distinction
between traffic and Service Unit forecasts - Norway
9.3.9/ The NEFAB should ensure that the airspace users are not
paying for cancelled or delayed investments in RP1 and are not
charged again in RP2 for the part of the investments already charged
in RP1. It should provide detailed information in the performance plan
on how this is ensured - Norway
9.3.11/ The NEFAB States should better describe and/or justify the
cost, nature and contribution of their investments in a more detailed,
less generic way, allowing proper understanding of the importance
and need for such investments - Norway
9.3.12/ The NEFAB States should provide evidence of the existence
of CBAs for their planned main investments - Norway
6.3.24/ Table 30 - Norway
General
4
7
8
9
10
General
Finavia does not have a watertight calculation system to ensure that cancelled
or delayed investments are no charged again. Regulation 391/2013, article 7
says: “Depreciation costs shall relate to the total fixed assets in operations for
air navigations service purposes.” When calculating determined costs, this is
obviously forecast which is based on a planned investments. However, during
the reference period the situation can change. To our understanding there is
nothing in the regulation or in the guidance material (Principles) how these
costs should be handled between reference periods. Should the already
charged depreciation costs (but cancelled investment) be paid back? How and
when? How should the partially charged depreciation cost (but delayed
investment) be handled? What if there are some cancelled investments but also
new investments? For these reasons Finavia has not created a comprehensive
method to ensure this. It would take a lot of time and effort to build this system.
Finland proposes that guidance material to this question will be created in order
to have similar method for every MS.
Finavia/Finland is able to provide more information to these in a reasonable
time.
Norway
Updated figures for the national target on arrival ATFM delay per airport will be
included in the revisions of the NEFAB PP
Information regarding pensions and loans will be included in the revisions of the
NEFAB PP.
Information regarding asset base already exists in Annex-C and MS Excel
sheets. Updated assed base information will be added to the add. info.
Document annex C in the updated NEFAB PP
Detail regarding costs exempt from risk sharing will be included in the updated
NEFAB PP
Link between main
investments and the ATM Master Plan requirements will be included in the
updated NEFAB PP
Common Project and
adequate reference to the proper PCP ATM functionalities will be included in
the updated NEFAB PP
Traffic assumptions will be included in the updated NEFAB PP
OPEN.
Comment noted
OPEN
OPEN
OPEN
OPEN
OPEN
OPEN
General
We will re-assess the investment plans and Information from this will be
included in the updated NEFAB PP
OPEN
General
More information around investments will be added in the updated NEFAB PP.
OPEN
In some investment projects cost reductions is already identified, we will still try
to add more CBA info. in the updated NEFAB PP
According to the NEFAB PP the Capex for 2015P should be changed from
32,6MEUR to 31,8MEUR in table 30, and the total in RP2 from 113,3MEUR to
OPEN
mistake
2/3
REJECTED
112,5MEUR.
3/3
The total for RP2 years in €2009 was
computed by adding up all the project
amounts divided at 8.728 (NOK:EUR)
and inflation and the difference stands
for rounding.
RP2 Assessment - Comment Registry SW
TitleoftheDocumentcommented:PRBAssessmentReportofPerformancePlansforRP2:SWFAB
Version:2.0
Commentsby: AnaGómez‐PinedaLunaSpanishNSAFABFocalpoint
#
1
PRB Assessment Report of Performance Plans
for RP2 SW FAB/page.7,Item
1.1.4/Introduction/accountable entities
2
for RP2 SW FAB / 1 General criteria / 1.3.1
Type of
comment
(typo, factual
mistake,
general, etc.)
Clarification
Typo
Comment
Response
SAR is not an entity. The providers for SAR service are Portuguese Air Force and Navy.
In the accountable entities there’s no reference to NSA for MET services for Portugal
CORRIGENDUM
REQUIRED
Table 1: EoSM minimum levels achieved in 2013.
At ANSP level, Spain should be level C instead D in the Safety Culture MO
ACCEPTED Typo corrected.
1/21
#
3
for RP2 SW FAB / 1 General criteria / 1.3.1 and 2
Safety / 2.1.2
4
for RP2 SW FAB / 1 General criteria / 1.3.2
Type of
comment
(typo, factual
mistake,
general, etc.)
Factual
mistake – or
typo
Factual
mistake
Comment
Response
In Table 1 (point 1.3.1): EoSM minimun levels achieved, it is indicated that the State level of Spain is A.
However, the State level of Spain is B taking into account the Annual Monitoring Report. We believe is a
mistake.
ACCEPTED
As it is indicated above, in Spain, the State level is B and not A. The last Annual Monitoring Report took into
account the EASA audit result, so the elements are not overrated. Please, remove the text in point 2.1.2
because it is confusing.
REJECTED
Anyhow, the following the comment in point 2.1.2 is not acceptable, because is not related to RP2: "In
addition, during EASA audits in 2013, results of both States have been verified (i.e. EoSM results provided by
States were comparad with the results of the audit via 'thorough' verification process). lt was found that sorne
of the elements scored as Level 'C' were overrated and did not correspond to what was found during the
audit"
The data regarding the RAT application current performance (2013) do not match with the data provided by
Spain in the NSA RP1 Monitoring Report 2013. The data provided:
This comment is complemented by comments #5 and 24
2/21
Typo in Table 1 is corrected.
it is the PRB opinion based
on EASA observations.
Hence, no change as it is
based on
ACCEPTED
#
5
for RP2 SW FAB / 2 Safety / 2.2.2
6
PRB Assessment Report of
Performance Plans for RP2 SW FAB / 2 Safety /
2.3.2
Type of
comment
(typo, factual
mistake,
general, etc.)
General –
factual
mistake
General
Comment
Response
The comment is not acceptable as the PRB is assuming without information, that there is a lack of knowledge
in the NSAs and ANSPs of the SW FAB:
“PRB expresses concern that the SW FAB States may not be aware of how the classification of ATM-S
occurrences is performed.”
AESA has established its annual targets considering a gradual progression over RP2 period. However, once
established agreements with ANSPs and appropriate internal procedures, the “overall” target will match the
“ground” target proposed by ANSPs.
Regarding the comment "the SW FAB has reported different figures for the RAT methodology application for
ATM-S for ATM Ground and ATM Overall" ,the template for the NSA RP1 Monitoring Report shows in a note:
"For consistency, the figures used here should correspond to the following definition:
Severity Classifications A (or A-A) to C,
Occurrences related to all Air Traffic Control Centres and Airports with over 50,000 Commercial Air
Transport (CAT) Movements per year (or the airport with the highest number of CAT Movements per year, if
no airport in the State has more than 50,000 CAT movements per year)."
The ATM Ground and ATM Overall figures provided do not match because the number of occurrences
categorized as A, B or C by the service provider when it performs the ATM Ground evaluation only, usually is
lower than the number of occurrences categorized as A, B or C by the Authority when it performs the overall
evaluation. When within the Authority it performs the overall evaluation, it has more information and the
category could be higher.
Regarding the different targets in ATM-S, in accordance with the Article 4 of the Regulation (EU) No
376/2014, an unpredictable number of incidents could be reported directly to the State Occurrence Reporting
System. The figure is different from the ANSP one because in the Overall score at State level the figure
correspond to the target as the Authority analysing directly the incidents reported
This comment is linked to #32
Currently, there is not a requirement to establish a
common SW FAB approach in certain areas for Just Culture improvements. So please remove the first
sentence of the paragraph. However, we plan to establish a common SW FAB approach in certain areas of
Just Culture. In particular, we will develop a common policy and will produce training material.
OPEN
3/21
REJECTED
Intention to develop and
establish a common FAB
approach should already
exist.
#
7
Performance Plans for RP2 SW FAB / 2 Safety /
2.4.4
8
9
Performance Plans for RP2 SW FAB / 4 Capacity
/ 4.1.4
PRB Assessment Report of PRB Assessment
Report of
Type of
comment
(typo, factual
mistake,
general, etc.)
General
Comment
Response
As it has been indicated, we plan to develop a common
just culture policy and we plan to produce training material. More descriptions cannot be provided, due to this
activity is a planned one.
REJECTED
General
Incorrect opinion about the ANSP believes.
General
What it is described in the report as “postponement or downgrading of the plan” is simply a natural reaction in
a context of the recently experienced drop in traffic and the
associated incertitude with respect to its recovering pace.
No change as it refers to a
kind suggestion that
guidance material exists and
should be consulted in the
future.
OPEN
OPEN
With respect to the “need of remedial action”, this comment is inappropriate as Spanish target is more
ambitious than the NOP delay forecast, reflecting a commitment to perform better than currently predicted in
the NOP for most of the period.
Note that, generally, comments made with respect to Spain in the area of capacity sound relatively negative,
even if results recorded for the first reference period actually deserve recognition.
10
Performance Plans for RP2 SW FAB / 4 Capacity
/ 4.1.8
General
This comment is linked to comments #34, 25 and 27
With respect to the potential impact of FUA measures in
RP2, please note that our assessment foresees a considerable greater impact in the flight efficiency area
than in the capacity KPA, where no significant improvement in terms of the current metrics is expected.
4/21
OPEN
#
11
Performance Plans for RP2 SW FAB / 5 Costefficiency / 5.1.5
Type of
comment
(typo, factual
mistake,
general, etc.)
Factual
mistake
Comment
Response
As we had already commented concerning PRB 2013
Monitoring Report, we consider that the so called “Aena’s economic surplus” is a kind of theoretical exercise
that does not reflect the economic result of the ANSP and therefore, in our opinion, it should be
recommended to be very careful in the treatment of the results in its true meaning.
OPEN.
Comment noted
Surplus analysis should incorporate actual revenue analysis (See Comments to Monitoring Report 2013)
12
13
14
PRB assessment of the RP2
FAB Performance Plans-SW FAB5.2.1– Spain Continental – Overall Consistency
(page 30)
PRB ASSESSMENT
REPORT OF PERFORMANCE PLANS
FOR RP2/ para 5.2.1.1- Spain Continental en
route and 9.4.4, first para–Observations for the
cost-efficiency KPA
Typo
The arithmetic calculation does not reflect actual benefit/losses borne by the ANSP, as it does not take into
account other important factors such as income from other sources or over/under recoveries from previous
years and before RP1. Therefore, the results from this calculation should not be conclusive.
On recommendation b), reference is made to key point 4, when it should be referred to key point 5.
General
Spain Continental key point 1:
PRB Assessment Report of Performance
Plans for RP2 SW FAB / 5 Cost-efficiency /
5.2.1.7 and 9 Conclusion /
9.3.9 (second bullet) (compliance issues) and
Annex 1: Detailed Cost Efficiency
Assessment – Spain Canarias- Description,
level, composition and justification of costs
exempt
from cost sharing (page 70)
General factual
mistake
The evolution of traffic in Spain Continental for the period from January to August 2014 is around 4.4%,
nevertheless for the next months it is foreseen a slowdown without expectations of improvement at the
moment.
However traffic forecast could be analyzed considering the latest information available.
Spain Canarias Key Point 7:
Not specified why it is “not passed”. Only included that the justification is the same that the one provided for
Continental, and in this case it has passed.
OPEN
5/21
ACCEPTED.
Report updated
ACCEPTED.
Report updated and Key
Point 7 for Spain Canarias is
now passed.
#
15
PRB ASSESSMENT
REPORT OF PERFORMANCE PLANS
FOR RP2/ 5.3.1.5- Overview of Terminal
charging zone assessment
Performance Plans for RP2 SW FAB / 5 Costefficiency / 9 Conclusions
16
17
18
Performance Plans for RP2 SW FAB/ page.38
Item 5.4.7/ATSP estimated surplus/ 2013A
for RP2
SW FAB/page 40 Item 5.5/Traffic
forecast assumptions/
Recommendation 9.2.3(page 56)
Type of
comment
(typo, factual
mistake,
general, etc.)
General
Comment
Response
Please consider that the same information and
explanations pointed out with regard to point 5.2.1.6 (comment 2 above) are valid for Spain TNC
OPEN.
See comment 37
General
General
General
Spain has the political commitment of frozen the enroute unit rate (71.69 € Spain Continent and 58.36 € for Canary Islands) during RP2. This policy has been well
applauded by users and runs the constriction cost policy for the stakeholders of the system, and it is in line
with main objectives of the performance cost-efficiency regulation.
To adjust figures to frozen the unit rate, the account "revenues from public authorities" is used. This quantity is
calculated on a per year basis, and can´t be recover on future years. It works as a subvention to the system on
a year basis, and it is supported mainly by AENA. The rest of the adjustments are applied on year N+2 if it is
compulsory by the regulation. The rest of them are delayed in time, until they can be recovered without
increasing the unit rate. The recoveries of carry overs until 2011, have preference of application, due to it can´t
be delayed to the third reference period.
In line with RP1 PRB Annual Monitoring Report 2013 / Comment Response Sheet / item 6 En-route ATSP
estimated surplus (2013) the value for the Estimated ex- post RoE pre-taxe rate (in %) is 27.3% instead of the
29.1% as calculated in PRB AR RP2 SW FAB.
The choice by the STATFOR February 2014 low forecast for the Portugal en-route charging zone, in line with
Commission Decision 2014/132/EU, of March 11, is considered the most adequate to the reality and already
incorporates the strong growth recorded in 2014.
Estimate for this year – 3.072 kSU – is in line with the performance of the first eight months and it’s even
higher than May’s STATFOR base scenario, while PP 2015 estimate represents an increase of 3.8% and also
above May’s STATFOR base scenario. For the remaining years, the low scenario growth rates has been
chosen, due to the volatility of the European economy and also the past experience of the first reference
period, where base scenario has been considered to fix unit rates and significant revenue losses have been
assumed by the ATSP (-4.7 M€2009). The aim of this choice is to reduce traffic risk impact, instead of
obtaining any advantage from lowering unit costs based on a more optimistic traffic forecast. In meanwhile,
Portugal considers to review traffic forecasts based on new Low Scenario STATFOR Sept14 estimate.
6/21
OPEN.
Comment noted.
OPEN
OPEN.
Comment noted.
#
19
Performance Plans for RP2 SW FAB/page 43
Item 5.6/Traffic forecast assumptions/
Recommendation 9.2.3
( page 56)
Item 5.5/En-route DUC trend/Recommendation
9.2.3
(page 56)
20
21
22
23
Item 5.6/Terminal ANS DUC
trend/ Recommendation 9.2.3 (page56)
Performance Plans for RP2 SW FAB/page51
Item 6.5/Ancillary assessments/ Table 27
Item 9/Conclusion (DRAFT)/ Last bullet
Type of
comment
(typo, factual
mistake,
general, etc.)
Factual
mistake General
Comment
Response
The forecast TNSUs for the Portugal TCZ are in line with
the STATFOR low case scenario, for every year between 2015 and 2019.
OPEN.
Comment noted.
Identical comments, as per above, apply to TSU forecast.
General
General
In fact, NAV Portugal foresees a 2% salary increase
considered in RP2 following a period of five years where salaries have been frozen (and even reduced 5% in
2011 and 2012) and without any career progression, due to the fact that Portugal was under the “European
Support Mechanism”, situation that is not sustainable for a longer period where labour stability is the main
objective to safeguard. Increases in salaries also aim to compensate for higher productivity that is required in
a period where traffic is growing and number of staff is decreasing.
Depreciation costs growth according to the Investment Plan, designed to comply with ESSIP and other
technological improvement plans.
Similar comments, as per item 3, apply to terminal ANS
DUC trend. Worth to mention that despite those increases, terminal ANS DUC for Portugal TCZ is expected
to reduce in average 1.8% p.a., during the period 2011-2019.
Typo
“DANUBE FAB” should be replaced by “SW FAB”.
Typo
“In section 0 the PRB presents” should be replaced by
““In section 9.4 the PRB presents”.
7/21
ACCEPTED.
Comment noted and text
included in report. No
change to result.
OPEN.
Comment noted.
ACCEPTED
#
24
for RP2
SW FAB / 9 Conclusion / 9.1.3, 9.2.1, 9.3.4
(assessment result, recommendations and
compliance issues)
Type of
comment
(typo, factual
mistake,
general, etc.)
General –
factual
mistake
Comment
Response
SW FAB target for RP2 (0.50 minutes of ATFM delay per flight for each year of RP2) is built on the basis of a
reference value of 0.48 for Spain. This value is above the reference provided by the PRB (around 0.27).
Assuming a cost of 83 Euros per minute of delay (2010 prices), this difference between the SOWEPP and the
PRB reference, can be quantified at an aggregate 157
MEuros throughout all RP2 in nominal terms (the same cost estimate is reached by the PRB in its report:
points 4.1.2 and 4.5.3).
OPEN
According to the tool facilitated by the European Commission, both Spain Continental and Spain Canarias
targets go beyond the values resulting from the breakdown the EU wide target.
This over-performance is quantified at 249 MEuros (2009 prices) throughout all RP2 for Spain (Continental +
Canarias charging zones).
This extra cost saving in the cost-efficiency targets, allows dealing with the extra cost of delay. Even
including the extra cost of delay as a share of the determined unit costs, aggregated Spain targets would
represent a global save (total cost value save) of 110 MEuros (2009 prices) for all RP2. In addition, DUC
would also be met every year of RP2.
Considering inter-dependencies, which are explained qualitatively in chapters 4 and 7 of the RP2 SOWEPP
document, and the total cost value quantitatively analysed in this response (see calculations below), the SW
FAB en-route capacity targets and in particular the Spanish contribution, are consistent with the EU-wide
targets as a whole.
8/21
9/21
#
document
25
Performance Plans for RP2 SW FAB /
9 Conclusion / 9.1.3, 9.2.1, 9.3.4
(assessment result, recommendations
and compliance issues)
Type of
comment
(typo, factual
mistake,
general, etc.)
General
Comment
Response
In addition to previous comment:
OPEN
The differences between the individual ANSP contributions to en-route capacity indicated in this plan and
reference values produced by the NM in September 2013 and quoted in the NOP finally approved in June 2014
are undoubtedly not a compliance issue. In this regard please consider that:
•
Reference values are an indicative value allocating local desired (not required) levels of
performance, which, when aggregated, might lead to the EU target achievement. The NM recognizes that they
are the result of a theoretical exercise, where other potential sets of solutions could also lead to the same
result. Even the PRB, in the capacity assessment made in chapter 4 (secondary check) of this document,
recognizes other values could potentially be adopted.
•
As it has already been remarked in other consultation processes, any comparison with the reference
values deserves caution, since they are referenced to September 2013 STATFOR low scenario, which does
not correspond to the traffic assumptions used for the construction or the evaluation of this plan.
•
We also point out the fact that the assessment criteria for the capacity area, according to Regulation
390/2013 Annex IV include both the comparison against the reference values and against capacity plan annual
delay forecast reflected in the NOP. We note that when compared with the capacity plans and associated delay
forecasted in the NOP, the expected level of delays is above the proposed targets. Thus, the proposed targets
are not only coherent -with the values they have to be compared with- but also ambitious, requiring effective
and efficient accomplishment of all the planned actions.
Comments related to differences between proposed targets and NM reference values do not, therefore,
constitute a compliance issue, even though they might merit being registered as an observation.
10/21
#
document
26
Performance Plans for RP2
SW FAB / 9 Conclusion / 9.1.4
Type of
comment
(typo, factual
mistake,
general, etc.)
Factual
mistake
Comment
Response
The PRB concludes the cost-efficiency targets for the en-route charging zones of Spain Canarias are not
consistent with and do not adequately contribute to, the achievement of the en-route Union-wide target.
REJECTED.
This assessment result is judged incorrect:
•
based on the use of the tool provided by the Commission to breakdown the EU wide target: see
calculations to comment #24, demonstrating a 21 MEuros (2009 prices) overall RP2 save in determined costs
with respect to the breakdown of the EU-wide target.
•
and the explanations provided in various comments on cost-efficiency: #11, 14, 16, 28,
29, 38 and 43.
The RP2 cost-efficiency breakdown
tool aimed at providing an example of
how to possibly break down at FAB
level the Union-wide en-route costefficiency target.
It is important to stress that the
individual local values derived from
the tool are strictly indicative and
were not used for the assessment of
the local cost-efficiency targets
comprised in the FAB RP2
performance plans.
The PRU applied a methodology
which assessed each State’s
Performance Plan according to the
different criteria defined in the
Performance Scheme Regulation,
Annex IV.5. This methodology was
applied in a fair manner and individual
circumstances for each State were
also taken into account for the final
assessment.
11/21
#
document
27
9 Conclusion /
9.2.2 (first bullet) (recommendations)
Type of
comment
(typo, factual
mistake,
general, etc.)
Factual
mistake
Comment
Response
The PRB concludes States should mandate its ANSPs to
revise and implement en-route capacity plans to meet the required level of en-route capacity performance for
RP2. This comment is based on the delay forecast extracted from the 2014-2018/19 Network Operations Plan
(see point 4.1.6 of the PRB assessment report).
OPEN
The delay forecast is above the reference values proposed by the PRB (on the basis of information provided by
the Network Manager). This circumstance leads the PRB to the conclusion that the capacity plans are not
sufficient to meet the targets.
Nonetheless, this assumption made throughout the document ignores two essential facts:
 The delay forecast is not made on the basis of the traffic forecasts included in the RP2 SOWEPP.
 The delay forecast is not compared against the capacity targets in the RP2 SOWEPP (0.52
min/flight for all RP2).
Taking these elements into consideration, the capacity plans detailed within the 2014-2018/19 NOP (which are
those included in the RP2 SOWEPP), are consistent and sufficient to meet RP2 targets. Appropriate
explanations are provided in chapter 4 of the RP2 SOWEPP document, as well as in chapter 11 as part of the
answers to stakeholders.
12/21
#
document
28
9 Conclusion / 9.1.4, 9.2.2 (first bullet),
9.4.4 (first bullet) (assessment result,
recommendations and observations)
and 5 Cost- efficiency / 5.2.1.1
Type of
comment
(typo, factual
mistake,
general, etc.)
Factual
mistake
Comment
Response
PRB’s assessment recommends the revision the enroute TSU forecast for Spain Continental in the light of the latest available information, judging current forecast
present in the RP2 SOWEPP is too conservative.
OPEN.
Section 1.5 of the RP2 SOWEPP provides a sound justification of the en-route TSU forecast selected for Spain
Canarias, which is below STATFOR low scenario for 2014 and 2015.
According to PRB’s assessment the situation should be revised upwards. Nevertheless, although STATFOR
February 2014 forecast (base and low) presented increases for TSUs 2014 (+8.5% and +6.5% respectively),
actual data in period January-August
present a variation of -0.8% (2014 vs 2013). This variation is greatly lower than forecasted in STATFOR and
even lower than Performance Plan traffic. For this
reason we consider that traffic forecast assumptions
for Spain Canarias are realistic.
Conclusions are based on the data below:
13/21
#
document
29
Performance Plans for RP2 SW FAB
/ 9 Conclusion / 9.1.4, 9.2.2 (second
bullet),
9.4.4 (second bullet) (assessment
result, recommendations and
observations) and 5 Cost- efficiency /
5.2.1.5
Type of
comment
(typo, factual
mistake,
general, etc.)
Factual
mistake
Comment
Response
See also Spain Canarias key point 4 & 5 (section 5.2.1.5):
REJECTED.
The process to obtain the en-route cost of capital is the same as in Spain Continental. The evaluation of this key
point in Spain Continental is "passed", therefore, the evaluation for Spain Canarias should be the same.
The PRB considered that the analysis
had to be done at Charging Zone
level rather than Country level since
the cost-efficiency target are set at
Charging Zone level. This applies to
all checks under key point 5 (en-route
cost of capital) apart from the WACC
check, which due to lack of
disaggregated data was undertaken
at organisation level (i.e. AENA). For
the charging zone level checks
additional charts have been
developed for Spain Canarias and
have been included in the
assessment report.
It seems that Spain Canarias is being compared with a different comparator group than Spain Continental. We
consider that this must be a mistake. Since Aena has similar assets and services level at both charging zones
and both share the same economic environment (similar wages and assets) we believe that Spain Canarias
has
t o be com p ar ed w it h t h e “F iv e Larg est ” grou p . For
this group, DUC level is more than -10% below the average.
The assessment result of these two criteria is negatively affected by this wrong comparison and
should be corrected.
In our opinion it would be reasonable that the comparisons related to RP2 Spain Canarias were made with the
same group as Continent, as it is done in the ACE report, where the comparisons refer to the totality of AENA
Air Navigation and also as reflected in the following documents: "PRB advice to the Commission in the setting of
Union-wide performance targets for RP2", 27/09/2013 and “EUROCONTROL's methodology to calculate the
indicative RP2 targets at FAB level”
14/21
Regarding the groups - for
consistency purposes it was decided
to consider the Spain Canarias
Charging Zone in a group of Charging
Zone sharing relatively similar
economic and operational
characteristics i.e. Ireland and
Portugal. If Spain Canarias Charging
Zone would be compared to the
Charging Zones of the 5 largest
States, then there would be significant
differences in terms of size, level of
costs and operational complexity.
#
document
30
Performance Plans for RP2 SW
FAB/page 56 Item 9.3/Compliance
issues/9.3.1
31
32
FAB/Item 9.3/Compliance
issues/9.3.2 ( page 56)
/ 9 Conclusion /
9.3.3 and 9.4.2 (compliance issues
and observations)
Type of
comment
(typo, factual
mistake,
general, etc.)
Clarification
Clarification
General,
missing
information,
not all
elements
considered in
assessment
Comment
Response
For the List of airports submitted to RP2 please see at
Annex E, item 1.5, page 22.
ACCEPTED. Remark removed but
formal CORRIGENDUM is
REQUIRED for the correction to the
submitted PP
At Annex E, item 1.5, the number 6, mentioned as the total number of airports is not correct. The correct value
should correspond to the total number of airports listed - 14.
At Annex E, item 3.1.(c).(ii), the number 2, mentioned as the total number of airports for Portugal is not correct.
The correct value should be 9 airports, in line with the Portuguese names listed under item 1.5 of the same
annex E and under item 4.2 of the RP2 SOWEPP. Thus, for Portugal all the nine airports are under the
Performance and Charging regulation
At Annex A, there is available almost all of the information related to the consultation meetings. The missing
elements will be added.
The ANSP percentage of application of RAT
methodology ground score is 100% each year according to their data.
The overall score describes a different evolution and was filled by the NSA to reflect the need to put in place
and run the processes for the oversight of the RAT application data facilitated by the ANSP. The RP2
SOWEPP wanted to show this difference, which is in fact, part of the target itself:

The compromise of the ANSP, to applicate the RAT methodology to 100% of the ATM-s
occurrences as from 2015.

The need for a less ambitious evolution while the NSA puts the necessary oversight processes in
place so there is a common understanding on the
data and its quality can be granted.
Anyway, the difference in the figures is not due to a mistake or a lack of knowledge as suggested by the PRB.
The comment is inappropriate, erroneously pre- judges an organizational situation completely unknown to the
PRB, and is completely un-acceptable.
More thorough explanations are given in comment #5
15/21
OPEN
#
document
33
/ 9 Conclusion /
9.3.6 (compliance issues) and 4
Capacity / 4.4.2 and 4.5.4
Type of
comment
(typo, factual
mistake,
general, etc.)
General
Comment
Response
The PRB considers the incentive mechanisms defined in
the RP2 SOWEPP allow ANSPs to be paid full bonus when capacity performance is significantly lower than the
required level, scheme does not encourage the entities to achieve a high level of performance and that Article
15 of the charging Regulation is not applied in a consistent manner.
OPEN
According to the explanations provided in the corresponding chapter, the incentive does not foster higher
performance due to the target level, not to the definition of the mechanism itself. Therefore it is a capacity
target issue, and the mechanism (formula, distribution, etc) does not necessarily have to be affected.
According to the assessment report incentives are considered: Effective and proportional, non- discriminatory
and transparent, and known ex ante by stakeholders. Only one requirement of the Article 12 of the
Performance Regulation is put into question:
As regarding Article 15 of the Charging Regulation, the report does not specify which provisions are not
applied consistently. The incentive mechanism included in the SOWEPP is deemed as being consistent with
all the provisions of this article. The only possible exception could be point 1.(b): “[…] There shall be no
bonuses for performance that is at or below that expected in performance targets;”; due to the fact that the
report
states that the incentive mechanism in the SOWEPP does not foster high level of performance. In this case,
the compliance issue is reiterative, and once again is not
a problem of the mechanism itself, but a problem of the target levels.
Nevertheless, the formula of the incentives could be revised to take comments in the PRB report into
consideration:

The dead band could be changed to be asymmetrical and span from 0.30 min/flight to 0.54 min/flight
(the target staying at 0.52 min/flight).
Full bonus could be provided below 0.18 min/flight.
16/21
#
document
34
9 Conclusion /
9.3.6 (compliance issues) and 4
Capacity / 4.4.2
Type of
comment
(typo, factual
mistake,
general, etc.)
General
Comment
Response
As stated in the SOWEPP, the incentives shall be
applied on the KPI defined in Annex I, Section 2, point 3.1.(a), i.e. including all delay causes.
Nevertheless, when for a given year the delay causes other than those identified in Article 15.1 (g) of the
Charging Regulation (called non-ATC causes in the SOWEPP), are more than a 20% higher than the
average of the three previous years, that excess of minutes above the 20% is not included in the
application of the incentive mechanism.
OPEN
This clause was introduced to avoid ANSPs are not over-penalised when unexpected and uncontrollable
events rise delay above usual performance.
No additional validation was specified in the mechanism in the understanding that Article 15.2 of the
Charging regulation already tasks the NSA with the responsibility of the correct application of the incentive
mechanism: “National supervisory authorities shall monitor the proper implementation of these incentive
schemes by air navigation service providers”.
NSAs will proceed in compliance with the regulation, it cannot be assumed a-priori that it would be
otherwise, as PRB’s report seems to suggest. ATFM supervision is an on-going activity of the NSA.
Nevertheless, some control and verifications could be specified with the aim of transparency and to avoid
gaming:
•
ANSPs should generate a report justifying unusual non-ATC delays if they want the clause to
apply.
•
NSAs will revise the report and the actual situation, and ask independent bodies for opinion in
case it is found necessary.
•
The application of the clause would be consulted with the users.
17/21
#
document
35
FAB/Item 9.3/Compliance issues/9.3.7
(page 57)
36
Performance Plans for RP2
SW FAB / 9 Conclusion /
9.3.8 (compliance issues)
Type of
comment
(typo, factual
mistake,
general, etc.)
Clarification
General
Comment
Response
At RP2 SOWEPP pages 30 & 31, it is stated :
ACCEPTED
“The TNZ Portugal is composed by 9 airports, from which only Lisbon has more than 70.000 IFR flights.
Thus, all airports but Lisbon, could be kept out of the scope of the Performance Regulation. From the nine
airports, and in the past five years only two major airports have contributed to the global ATFM arrival
delay in Portugal: Lisbon (LPPT) and Porto (LPPR). The remaining airports (LPFR, LPMA, LPPS, LPHR,
LPSM,
LPPD and LPFR), present an insignificant contribution to the total delay according to the past data.
Consequently, although all the nine airports are included
in the ATFM arrival delay KPI, only two of them have a strong contribution to this particular indicator, Lisboa and
Porto. In addition, these two airports have been
monitored during the RP1 and have reliable data. The Portuguese targets for RP2 are set within the table
below. Reference values for monitoring purposes are
only individually provided for Lisboa and Porto airports for the reasons explained above. The rest of the
airports are grouped as “others”:
It is important to note that for Porto the weather weights between 85% and 95% of all the ATFM arrival delay,
causing a great uncertainty when forecasting future delays.”
PRB is of the opinion that an
aggregation of a set of airports with
low share of arrival ATFM delay is
acceptable based on this example.
If there is a need for some additional details, they will be provided.
The justification for not including a capacity incentive scheme associated to arrival ATFM delay is extensively
developed in the SW FAB performance plan (section 4.3) and supporting consultation material, including the
legal aspects, as recognized and shared by the PRB in this Assessment Report (see paragraph 4.4.4) when
concluding a clear case is made on the immaturity of establishing the incentive scheme for this indicator.
We are grateful for the understanding and would suggest a recommendation fostering maturity instead of a non
compliance statement would be more appropriate in light of the former.
18/21
OPEN
Pending PRB decision on enforcing
EC clarification on the requirement to
establish an incentive scheme for the
national target on arrival ATFM delay.
#
document
37
9 Conclusions / 9.3.9, first para –
Compliance Issues for the costefficiency KPA and 5 Cost-efficiency /
5.2.1.6 and
38
39
PRB ASSESSMENT
REPORT OF PERFORMANCE
PLANS
FOR RP2/ 9.3.9, second para
–Compliance Issues for the costefficiency KPA and para
5.2.1.7- Spain Canarias enroute
FAB/Item 9.3/Compliance
issues/9.3.10 (page 57)
Type of
comment
(typo, factual
mistake,
general, etc.)
General
Comment
Response
Spain Continental and Canary key point 6:
OPEN,
Annex C of the Performance Plan includes information concerning interest rate assumptions for loans
financing the provision of air navigation services (pages 85 and 135, Additional Info related to Canarias
and Continental respectively) and the information is the same because it relates to Aena Air Navigation as
a whole. Nevertheless we have to point out that the “debt” reflected does not correspond to bank debt, but
mainly to a long term accounting provision for "active reserve" ATCO personnel salaries, and are therefore
reflected in the liability section of the balance sheet. The related financial expenses are also reflected in
the profit and loss account.
Comment noted – please could
information be provided that explains
the relationship between the interest
rate stated in the cost of capital table
in the Additional Information to the
Reporting Tables and the long term
provision for ATCO salaries. This
would also be important in future
potential submissions of costs exempt
from cost risk sharing.
See also Spain Canarias Key Point 7 (section 5.2.1.7):
The report has been updated to
reflect this comment and the result of
key point 6 changed from ‘not passed’
to ‘pass with reservations’
ACCEPTED. Change implemented in
report.
Annex C of the Performance Plan includes information concerning costs exempt from risk sharing related
to Canarias (page 88) in a similar way as it is detailed for Spain Continental (page 138). While for Spain
Continental the assessment is “passed” in the case of Canarias the assessment is “not passing this
check”. Since there is no justification to explain those contradictory conclusions, we assume that there has
to be a mistake and therefore the assessment for Canarias should also be positive.
General
Portugal will assure that same investments are not charged in both reference periods. This fact will be
achieved by comparing investment programmes for each period, analysing individual items and
correspondent “enter into operation” dates. Assurance that cancelled investments are not charged to
airspace users can be verified by comparing Investment Plan with actual capital expenditure for RP1.
19/21
New understanding is reflected in the
text subject to provision of the
corrigendum
#
document
40
Report of Performance Plans
for RP2 SW FAB / 9 Conclusion / 9.4.3
(observations) and 2 Safety / 2.4.5
41
42
Type of
comment
(typo, factual
mistake,
general, etc.)
General
FAB/Item Annex1/Detailed costefficiency assessment/En- route
Determined Unit Cost (DUC)
trend/Comments (page77)
Clarification
FAB/Item Annex1/Detailed costefficiency assessment/En- route
Determined Unit Cost (DUC)
trend/Comments (page77)
Pointless
Comment
Response
The PRB considers SW FAB should use the existing guidance material providing support to the
development of Just Culture implementation plans (allowing a common FAB approach in certain Just
Culture areas).
REJECTED
With this comment the PRB is interpreted to give an opinion: NSAs and ANSPs in the SW FAB have an
unusual lack of knowledge regarding just culture. This kind of comments and uninformed opinions are not
acceptable in the context of the assessment of the FAB Performance Plans.
Reference to sentence:
No change as it refers to a kind
suggestion that guidance material
exists and should be consulted in the
future.
OPEN
“It is not clear from the Performance Plan whether the projects labelled as “Lisbon ACC New ATM System”
in RP2 and “iTEC” in RP1 relate to the same project. This issue deserves a clarification from Portugal.”
The project named as “new Lisbon ACC ATM system” has the scope, and is the same investment, in fact,
as the project previously named “iTEC”.
In three consecutive paragraphs the same sentence is duplicated on two paragraphs:
“For RP2 there are no indications in the FAB Performance Plan that significant structural or organisational
changes are planned in the delivery of services within NAV Portugal or amongst other ATSPs.”
20/21
ACCEPTED.
Report updated.
#
document
43
PRB ASSESSMENT REPORT OF
PERFORMANCE PLANS
FOR RP2/ Annex I
Type of
comment
(typo, factual
mistake,
general, etc.)
Factual
mistake
Comment
Response
In Annex I: Detailed cost-efficiency assessment, Spain Canarias en-route, comments regarding traffic
forecast assumptions, page 66: “If the outturn en-route traffic…….”
It is not clear how the results related to the net potential gains to be retained by the State/ANSP are
obtained.
On the one hand, it is a comparison with a scenario that, as we have pointed out before, we do not believe
very realistic and, on the other hand, we think, according to our calculation, that the net potential gains to
be retained by the State/ANSP would be 15.6 M€2009 or 4.4% of the total costs subject to traffic risk
sharing for RP2.
21/21
The potential gain to be retained by
the State/ANSP is calculated by
applying the traffic risk sharing
mechanism to the en-route
determined costs submitted in the
RP2 performance plan, given the
difference in SUs between the
STATFOR base case scenario (Feb
14) and the SUs in the submitted RP2
performance plan.
RP2 Assessment - Comment Registry UK – IRL
TitleoftheDocumentcommented:PRBAssessmentReportofPerformancePlansforRP2:UK‐IrelandFAB
Version:2.0
Commentsby: AnnaZalewska,PolicyAdviser,CAA
#
Chapter/Section/
Para/bullet/etc in the document
1
2
3
Page 7 para 1.1.3 7 bullet
Page 7 para 1.1.3 last bullet
Page 10 para 1.3.2, Table 2
Type of
comment
(typo, factual
mistake,
general, etc.)
general
factual
factual
4
Page 13 para 1.5.3
General
5
6
Page 14 para 2.1.5
Page 10 para 2.4.2
general
general
7
th
Page 16 para 2.3.5
general
Comment
Response
(NSL) inserted after “..NATS Services Limited” for clarity on the use of terms.
The name of the UK MET service provider is Met Office: 'Meteorological Office' needs to be changed to 'Met Office'.
The table calculates the percentage application of the RAT at FAB level by a simple average of the FAB partner scores. This is misleading. The more accurate way of presenting the information would be to calculate as a percentage the total number of applications of the RAT from the total number of events. Both figures are known, and this sum would give a much more realistic figure.
PRB noted that a list of invited stakeholders was not attached to the Plan, only the list of actual attendees. Invitations to the FAB Stakeholder Consultation meeting are attached in Annex A to this Comment Response Sheet.
NATS (NERL) should just say NERL For clarity on the use of terms.
Although the PRB concludes that the local FAB target for reporting on the level of presence or absence of Just Culture has been set, the report goes on to say that the PRB believes that a Just Culture target set only on training requirements might not be sufficient, as evidence of completed Just Culture training cannot be an indication that Just Culture is in place. Apart from the JC training target, the NSAs also committed to monitoring JC generally. In the Supporting Document of the UK‐Ireland FAB Performance Plan (Page 31, Chapter 3, para 3.21‐3.22) NSAs stated that they will identify common measures to analyse the quality and the outputs from JC training and the achievement of the targets. NSAs specified that these measures will include: ‐establishing in each year of RP2 the percentage of staff completing the training ‐adoption of a formal tool for the analysis of the effectiveness of the training ‐monitoring the level and quality of incident reporting and investigation ‐monitoring the level of JC as validated annually and reported in the EASA questionnaire. ACCEPTED
ACCEPTED
ACCEPTED.
With reference to the second bullet, the NSAs have already developed a survey designed to measure the level of presence or level of absence of Just Culture within NSAs. The survey will be carried our first at the IAA (NSA) and later at the CAA prior to the commencement of JC training. A second survey will then be carried out when the 100% training target is reached. The second survey will also assess the effectiveness of the training. NSAs expect ANSPs to carry out a similar assessment. The Irish NSA is satisfied that the principles of Just Culture are already being applied in practice within the ANSP. Notwithstanding that formal agreement on Just Culture policies is still subject to ongoing IR discussions, the day to day 1/10
ACCEPTED
ACCEPTED
ACCEPTED
ACCEPTED.
#
Chapter/Section/
Type of
comment
(typo, factual
mistake,
general, etc.)
8
Page 17 Table 6 (para 3.3.6) and para 3.4.2 general
Page 52 Compliance Issues para 9.3.2
Comment
Response
activities of the ANSP reflect the application of Just Culture.
The report states that payment of financial incentives on 3Di should be conditioned on the achievement of the FAB KEA target. The report also states that the 3Di incentive does not foster high level of performance as it's not linked to KEA. OPEN
As mentioned in the Supporting Document to the UK‐Ireland FAB Performance Plan (Chapter 5, paragraphs 5.3 second bullet and 5.8), the big improvements in flight efficiency in UK airspace over RP2 are expected to arise from a major redesign of airspace around London (LAMP) and to a lesser extent in the Northern Terminal Control Area (NTCA). The expected gains in flight efficiency, amounting to £180 million p.a. by the end of RP2 are expected to arise as much from improving vertical trajectories as horizontal trajectories, some of it within 40NM from airports. It is conceivable that some worsening of the KPI for horizontal route extension outside 40NM may be consistent with the wider gains from all sources. In comparison, the scope for enabled fuel savings in delivering the KEA target is more limited (c. £6m of enabled fuel savings) compared with those covered by 3Di including those in TMA airspace such as LAMP and NTCA. The objective of a metric based on flight path efficiency is that it acts as a proxy indicator for fuel inefficiencies in flight paths flown within UK airspace. Therefore, it provides a mechanism by which NATS can be incentivised to deliver optimal flight paths, in order to reduce customers' fuel burn. 9
Page 17 Table 6 (para 3.3.6) general
10
Pages 19‐20, Capacity, en route delay general
This will incentivise improvement in the horizontal KPI to the extent that this is consistent with improving fuel efficiency overall. The UK is concerned that in certain circumstances the pursuit of horizontal flight efficiency per se could work to the detriment of overall flight efficiency. However, UK and the UK‐Ireland FAB are committed to reaching the KEA EU target and therefore adopted the FAB reference value as the FAB target. A non‐financial incentive scheme is also attached to the FAB target.
The report states that the incentive on delivery of transition altitude (TA) is not proportional as it is penalty only. The TA incentive is closely linked with the 3Di incentive. Delivering TA on target will therefore allow NERL to earn bonuses for 3Di. TA is a project crucial for the delivery of LAMP and in line with obligations under the Future Airspace Strategy. PRB noted that the UK‐Ireland FAB target for 2015 is not consistent with the respective FAB reference value. UK and Ireland decided to amend the FAB target for 2015 to make it consistent with the EU target. The FAB incentive scheme will also be amended accordingly. OPEN
Page 51 Conclusions para 9.1.3 A corrigendum to the Plan will be submitted to the Commission shortly. A copy of the amended capacity target and FAB incentive scheme is attached in Annex B.
Page 52 Recommendations para 9.2.1 Page 52 Compliance Issues para 9.3.3 11
Page 53 Observations para 9.4.4
Page 22, 4.4.2, 1st bullet
factual 12
Page 22 para 4.4.2, third bullet
general
The reference value for the FAB‐wide C1 target is set out in Figure 4.1 of the UK‐Irish performance plan (note that the value for 2015 will be amended in a Corrigendum to make the FAB target consistent with the EU target). For the purposes of the incentive scheme the C1 target has been allocated between the ANSPs and those figures are references in the mentioned Figure 4.8.
A decision was made to apply a consistent incentive scheme across the entire RP2 period. While it appears that the par 2/10
OPEN
#
13
Chapter/Section/
Page 23 para 4.4.3 Type of
comment
(typo, factual
mistake,
general, etc.)
general
14
Page 27 para 5.2, Key Point #3, En Route DUC trend. Page 52 para 9.2.2, first bullet
general
15
Page 27 para 5.2, Key Point #1, En Route Traffic Forecast Assumptions Page 52 para 9.2.2, second bullet
general
16
Page 28 para 5.2, Key Point #5, En Route Cost of Capital. Pge 52 para 9.2.2, third bullet
general
17
Page 28 para 5.2, Key Point #6, Justification of economic assumptions Page 53 para 9.3.5, first bullet
Page 28 para 5.2, Key Point #7, Costs exempt from risk sharing Page 53 para 9.3.5, second bullet
Page 29 para 5.3, Key Point #1, Terminal Traffic Forecast Assumptions Page 52 para 9.2.2, fifth bullet
Page 30 para 5.3, Key Point #3, Terminal DUC trend. Page 52 para 9.2.2, fourth bullet
general
18
19
20
general
general
general
Comment
Response
value is less stringent than the ANSP contribution, due to the dead band the ANSP would still have to exceed target performance before a bonus is earned. PRB points out that the Plan presents no capacity incentive scheme for national target on arrival ATFM delay for UK or Ireland. Provision of terminal ANS in the UK is covered by commercially negotiated contracts between the ANSP and the airport. Those contracts have incentive schemes build into them. UK considers that not cutting across these commercial contracts is a crucial transitional measure in developing competition. Given the justification provided in the supporting document accompanying the UK‐Ireland FAB Performance Plan, in particular with respect to staff costs and depreciation, Ireland does not feel that any sustainable reductions can be proposed to en route determined costs at this stage. Specifically, it was noted that significant and unexpected levels of staff retirements in both 2012 and 2013 requires the recruitment of additional controllers. Two new student controller programmes commenced in early 2014 with a further class planned for 2015. Training costs, included in operating costs, are therefore budgeted to increase significantly. It was also noted previously that exceptional cost constraint around wage increases could not be expected to continue into RP2. Depreciation and cost of capital profiles are in line with the agreed capital expenditure programme. The Determined Costs as submitted have been carefully considered and validated by the NSA. Also, the Determined Costs should be considered in the context of the significant overall cost reductions to be delivered by the UK‐Ireland FAB over RP2. The UK‐Ireland FAB has proposed a reduction in Determined Costs of 3.6% pa (2014D to 2019D) which exceeds the EU‐wide cost efficiency target.
The en‐route TSU forecast is based on the STATFOR MTF of February 2014, which is the latest available information. Given the limited traffic growth in recent years, Ireland feels that use of a forecast that is more cautious than the STATFOR base case is justified. Some additional commentary is supplied in Annex C to this document. We also note that the proposed forecast passed the PRB’s check.
As per the ‘En Route Additional information’ ‐ Section 1, Part (e) submitted in June 2014, an independent assessment of the IAA’s cost of capital was carried out by ‘First Economics’, covering the years 2015 to 2019. Based on their findings, a real weighted average cost of capital rate of 6.7% was calculated. The cost of capital has been calculated using the weighted average cost of capital (WACC) approach, consistent with previous years. The key parameters on which this calculation is based are very much still valid and subsequently there is no justification to amend this calculation.
th
It is not possible to fully address this item within the PRB response timeframe (26 September 2014). Work is ongoing to prepare and validate the additional information sought by the PRB. This will be forwarded as soon as it is available (Annex H). Where relevant, this information will be included in a corrigendum to the Plan that will be submitted to the Commission shortly.
Further information in this area is provided in Annex D accompanying this Comment Response Sheet.
The terminal TNSU forecast is based on the STATFOR MTF of February 2014, which is the latest available information. Because the STATFOR forecast only covers Dublin, the PP forecast had to be developed using STATFOR’s expected growth rates, to include Cork and Shannon. Some additional commentary is supplied in Annex C to this document. We also note that the proposed forecast passed the PRB’s check.
Given the justification provided in the supporting document accompanying the UK‐Ireland FAB Performance Plan, in particular with respect to staff costs and depreciation, Ireland does not feel that any sustainable reductions can be 3/10
OPEN
PRB decision on enforcement of EC
clarification on requirement to establish
incentive scheme.
OPEN
OPEN
OPEN
OPEN
#
Chapter/Section/
Type of
comment
(typo, factual
mistake,
general, etc.)
21
Page 30 para 5.3, Key Point #4, Terminal Cost of Capital. Page 52 para 9.2.2, sixth bullet
general
22
Page 30 para 5.3, Key Point #5, Justification of economic assumptions Page 53 para 9.3.5, first bullet
Page 30 para 5.3, Key Point #6, Costs exempt from risk sharingPage 53 para 9.3.5, second bullet
Pages 33 Figure 10 and Table 16
additional information
23
24
additional information
error
Comment
Response
proposed to TANS determined costs at this stage. Specifically, it was noted that significant and unexpected levels of staff retirements in both 2012 and 2013 requires the recruitment of additional controllers. Two new student controller programmes commenced in early 2014 with a further class planned for 2015. Training costs, included in operating costs, are therefore budgeted to increase significantly. It was also noted previously that exceptional cost constraint around wage increases could not be expected to continue into RP2. Depreciation and cost of capital profiles are in line with the agreed capital expenditure programme. The Determined Costs as submitted have been carefully considered and validated by the NSA.
As per the information submitted in June 2014, an independent assessment of the IAA’s cost of capital was carried out by ‘First Economics’, covering the years 2015 to 2019. Based on their findings, a real weighted average cost of capital rate of 6.7% was calculated. The cost of capital has been calculated using the weighted average cost of capital (WACC) approach, consistent with previous years. The key parameters on which this calculation is based are very much still valid and subsequently there is no justification to amend this calculation.
th
It is not possible to fully address this item within the PRB response timeframe (26 September 2014). Work is ongoing to prepare and validate the additional information sought by the PRB. This will be forwarded as soon as it is available (Annex H). Where relevant, this information will be included in a corrigendum to the Plan that will be submitted to the Commission shortly.
Further information in this area is provided in Annex D accompanying this Comment Response Sheet.
OPEN
The service units recorded for 2014F have been entered incorrectly in the UK‐Ireland FAB Performance Plan (the erroneous number appears to represent the actual TSU for 2012). The correct number should be 10,025k (as per STATFOR February 2014 forecast). The correction of this value will affect a number of other figures in the tables on this page and referenced later in the report e.g. the determined unit cost for 2014F (which should read £60.51 and €67.94 per SU rather than the values of £63.14 and €70.89 shown in the table), as well as the 2014‐2019 CAGR% for Service Units (which should be 1.8% pa rather than 2.6% pa) and the 2014 – 2019 CAGR% for the DUC (which should be ‐4.5% pa rather than ‐5.3% pa). The value of €70.89 for 2014F in figure 10 should read €67.94, and values for individual components of this e.g. NERL, CAA, MET will also need to be recalculated to reflect the correct TSU value. This amendment will be covered in the abovementioned Corrigendum. A copy of the updated UK En route tables is attached in Annex E to this response.
PRB observes that the 2014 TSU update is significantly below the observed actual TSU in the first semester of 2014 and also below the STATFOR 2014 forecast. This is caused by the error mentioned in Comment # 24 above.
25
Page 34
error
26
Page 34, 3. DUC trend
error
See Comment # 24 above. UK 2014‐2019 DUC trend as calculated by the CAA (see Comment # 27 below) remains unchanged at ‐4.7%. UK 2014‐2019 DUC trend as calculated by the PRB should be ‐4.5% pa rather than ‐5.3% pa.
27
general
Just to note, for the purposes of calculating the UK en route cost efficiency target the CAA applied the same methodology to the 2014 baseline as applied in the development of the ‐3.3% EU‐wide target. PRB calculations use a different 2014 baseline of the 2014 forecast. After applying the correction mentioned in Comment # 24, the difference in the trends is less than previously noted (‐4.7% calculated by the CAA v ‐4.5% calculated by PRB).
4/10
Correction noted in report.
No change to assessment result
No change to assessment result
OPEN.
Comment noted.
#
Chapter/Section/
28
Type of
comment
(typo, factual
mistake,
general, etc.)
factual
Comment
Response
Words 'per year' or 'pa' should be added to the % trends in the second sentence. Once error mentioned in Comment # 24 is corrected the sentence should read "Over RP2, the planned reduction in the DUC is the result of decreasing DCs (‐
2.8% pa) along with increasing traffic (+1.8% pa)."
ACCEPTED
29
Page 34
general
It is worth noting that the PRB assessment focuses solely on the annual % change between the baseline 2014 forecast and the end point (2019D), rather than cumulative savings delivered over that period.
30
Page 35, 5. En route cost of capital and page 69‐70 on NERL cost of capital factual
Allowance for tax: The CAA has used the effective rate of tax in its calculations to be consistent with the basis of calculations in earlier control periods. The differences arise because the allowances for taxation vary from the depreciation used in statutory accounts and in this case from regulatory depreciation. In earlier periods the effective rate of tax has been lower than the statutory rate of tax. The CAA considers that it is important to be consistent over time – applying either the statutory or the effective rate of tax. Page 54 Observations para 9.4.5
The effective rate of tax has been calculated as follows. The corporate tax rate used for NERL in the UK‐Ireland FAB Performance Plan is the statutory tax rate on the taxable profit. This generates the expected tax bill. The CAA has converted the estimated tax bill, at the statutory tax rate, in pound terms into a percentage of the regulatory asset base in order to allow it to estimate the required pre‐tax WACC. The “effective” tax rate of 37% (that is derived from the cost of capital calculations) is simply the number that is necessary to ensure that the pre‐tax cost of equity generates sufficient allowances to cover NERL’s expected tax payments at the statutory rate. PRB correctly states that the Plan refers to the fact that NERL RP2 capital allowances are lower than regulatory depreciation. However, the comment about “higher expected profits” is misleading. It should be made clear that profit before tax in RP2 is not forecast to be higher than in RP1 – in fact, profit before tax is forecast to be substantially lower than in RP1. Relationship between cost of equity and maximum traffic risk exposure: the pre tax rate of return on equity for NERL for RP2 (10.9% pre tax real) includes an allowance for tax. Once this is removed, the ROE is more closely aligned to the maximum post tax traffic risk exposure (i.e. a variance of less than 10% rather than 38.5% currently referred to in the PRB report). It is unclear exactly what conclusion can be drawn from this simple comparison. Traffic is not the only risk ‐ equity would require a risk free return even if NERL were otherwise free of risk. Higher equity beta: The incorporation of a tax rate into the equity beta calculations is not normally used by UK regulators or the competition commission (now CMA) and although this is implied by the methodology laid down in the Annex C guidance it is not the approach that either NERL or CAA have used previously. In addition, the PRB has previously stated in meetings that this is guidance only at this stage and not mandatory methodology. 5/10
Report updated. Changes related to
comment 24 remain open.
OPEN.
Comment noted.
OPEN.
Comment noted for all points apart from
point about “higher expected profits” which
is ACCEPTED. Report has been updated
to reflect this.
#
Chapter/Section/
Type of
comment
(typo, factual
mistake,
general, etc.)
Comment
Response
En Route asset base per SU: In isolation, this measure is not a meaningful reference point for risk or, therefore, the cost of capital. 31
32
33
34
35
36
37
Page 35, 6. Verification of the description and if applicable, the justification, of economic assumptions Page 53 Compliance Issues para 9.3.6
st
nd
Page 37‐38, 4. Terminal cost of capital Page 54 Observations para 9.4.5
Page 38 4. “Terminal cost of capital” nd
2 paragraph
Page 38, 5. Verification of the description and if applicable, the justification, of economic assumptions
Paragraph 6.3.7 Paragraph 6.5.2 Paragraph 6.7.12 Paragraph 9.3.7
general
general
general
general
general
Additional information
Furthermore the CAA would like to make the following more general comments: ‐the SDG guidance is not binding ‐the NERL asset beta is only just outside the SDG range ‐NERL is the only ANSP with fully commercial financing. It is therefore important to consider the cost of capital on a specific case basis, rather than taking a general approach as the impact on obtaining finance can have a more immediate and serious effect. ‐CAA has a statutory duty to ensure that NERL does not find it unreasonable difficult to finance its functions ‐within small tolerances, the downside to users of allowing the cost of capital below the true cost of capital (a squeeze on investment) would be worse than allowing a cost of capital above the true cost of capital (some potential excess profit to ANSP) ‐nevertheless the cost of capital for RP2 is of a whole percentage point less than in RP1. Comments on information provided on pension costs already discussed with PRB (information was provided in template format). Additional information on interest on loans will be provided separately (Annex F).
For pension: ACCEPTED
For interest rates on loans: CORRIGENDA
REQUESTED
Replace NATS (NSL) with NSL for clarity on the use of terms.
Replace NATS (NERL) with NERL for clarity on the use of terms.
It is not appropriate to compare the cost of capital of a monopoly by government licence to a commercial provider. The commercial provider does not benefit from some of the risk mitigating factors associated with the licence. The commercial provider is inherently subject to more risk exposure due to the possibility of losing contracts to other providers or airport closure. The level of NSL cost of capital therefore reflects that NSL’s contracts are service based and commercially negotiated; have very little capital employed (unlike En Route) and have margins that reflect the risk of these contracts.
Insert “provided by NERL” following “For the TCZ C”. This is to ensure clarity between discussion surrounding the en route provide and the major TANS provider.
On comment on NSL pensions ‐ as mentioned earlier, terminal ANS is provided under commercially negotiated contracts. NSL bares all the risk if it fails to deliver.
In line with the monitoring requirements for RP2, the Irish NSA will verify that Investments included in the RP2 submission are matched with subsequent expenditure, on a project by project basis. The ANSP reporting formats are being updated to reflect this. With regard to airspace users potentially being charged twice for investments in both RP1 and RP2, the Irish NSA monitoring report for 2014 will provide a detailed and transparent reconciliation of total RP1 planned expenditure vs. actual expenditure. OPEN
6/10
Noted
#
Chapter/Section/
38
Page 45, Table 23
39
Page 45, Table 24
Type of
comment
(typo, factual
mistake,
general, etc.)
factual
factual
Comment
Response
The planned RP2 capex values (both total and main) in this table are incorrect. It appears that the PRB has taken capex from the Performance Plan which are already in 2012 prices and then further deflated these (i.e. the PRB incorrectly assumed that the Performance Plan figures were in out‐turn rather than in 2012 prices). The total planned values (2009 prices, €m), should read: 129.7; 125.7; 107.9; 98.0; 89.2; 550.5 total; 110.1 avg. The main planned values (2009 prices, €m), should read: 116.6; 115.1; 98.3; 88.5; 76.7; 495.2 total; 99.0 avg. The percentages do not need to change. Planned capex values for 2012‐2014 are correct, however we cannot validate the updated plan capex values in 2009 prices. CORRIGENDUM REQUIRED
The CAA asked NATS to validate the capex figures. NATS analysed the numbers and concluded that the figures for ‘updated plan’ are correct for years 2013 and 2014 but incorrect for years 2010, 2011 and 2012 for the following reasons: 1. 2010 – the actual data used by the PRB (from the SEID 2010,Table F.7/Line F37 from NATS submission no. RO11812 (2010 PRU Revised)) is not like for like with the scope of years 2012 to 2014. It includes capital
expenditure relating to airports (which needs to be removed) and uses an allocation basis which, amongst other things, excludes expenditure that benefits both military and civil customers (but which forms part of NERL’s asset base, and needs to be added). A revised table (see Annex G) showing the ‘like for like’ values for lines B34 – B36 (i.e. the relevant Capex for the categories of Land and Buildings, Systems and Equipment, and Intangible Assets) has been created and is attached to this email. 2. 2011 – the data used by the PRB (from the SEID 2011,Table F.7/Line F37 from NATS submission no. RO41913 (2011 PRU Revised)) needs a similar adjustment to the 2010 data (see Annex G).
3. 2012 – the GBP value quoted of £118m is correct, but when we convert this to 2009 prices using the final actual deflator of 1.110, and to Euros at a rate of 0.8906, the value in Euros (2009 prices) should be €119m
rather than €122m shown in the document.
There is no mention in the PP for RP2 that
UK CAPEX is in 2012 prices. No change to
the report.
ACCEPTED
Table 24 updated.
Other issues are relevant for the 2013
Monitoring report and not for the RP2
assessment
The calculation of the ‘Main’ and ‘Total’ split for the 2010 and 2011 years seems to have been taken from the PRU revised tables described above, and these simply distinguish expenditure between ‘Systems and Equipment’ (taken by the PRB to be ‘MAIN’) and other spend. It is uncertain that this distinction is on the same basis as the MAIN / OTHER capex that is broken down in the reports for 2012 – 2014. Therefore the split may not be ‘like for like’ with the 2012 – 2014 data. 40
Page 46, Table 27
factual
41
Page 46, Table 27
typo
42
Paragraph 6.5.2 Paragraph 6.7.4 Paragraph 6.7.11
43
Page 70, para 7.1.2 and 7.1.3 on Monitoring general
Third row, UK ANSP (NATS)
PRB states that there was no information on the existence of a CBA. To note, capex mini business cases attached to the UK‐Ireland FAB Plan included an overview of the costs and the benefits of individual projects.
Third row, UK ANSP (NATS)
Wording of the third paragraph needs revising (first sentence is hanging).
In Paragraph 6.5.2 the assessment report states “No information on the existence of a CBA, but each project “is subject to the normal tendering procedure and business case appraisal process.” To clarify, the Irish NSA confirms that business case appraisal of each investment includes a cost benefit analysis. The process clearly identifies the objectives, options and associated risks for each investment. Each option (do nothing, partial investment, full investment, etc.) is appropriately “priced” using traditional CBA techniques.
PRB states that these is no description in the Plan regarding measures in place to monitor and report and that no description could be found on how the situation would be addressed, in practical terms, if targets were not met during 7/10
ACCEPTED
ACCEPTED
OPEN
#
Chapter/Section/
Type of
comment
(typo, factual
mistake,
general, etc.)
44
general
45
General
48
general
49
Page 65, Figure 24
factual
50
Page 66, Table 32
factual
51
Page 67, Figure 26
factual
Comment
Response
the RP. Section 7 of the UK‐Ireland FAB Plan (page 73 of 251) included a description of the planned monitoring of the Plan. The FAB specified that in case of any performance shortfalls (i.e. where targets are not met), the appropriate NSA shall make enquiries with the entity concerned, identify causes and potential corrective measures. Any shortfalls will be reported to the FAB NSA Performance Group (FNPG) who will monitor the implementation and impact of the corrective measures and determine their effectiveness. The FAB cannot specify in advance what exact corrective measures will be applied as this will depend on the degree and cause of the shortfall in performance and will be assessed on individual basis.
The FAB Performance Plan supporting document outlines the Irish NSA’s contention that since all three Irish airports are covered by a single charging zone, and because it is not considered easily possible for the ANSP to allocate its TANS costs to individual airports, Ireland will include Cork and Shannon in the performance plan specifically for the cost efficiency target, but not for targets in any other KPA as these would add to the Regulatory workload and cost‐base but would not make any meaningful contribution to the achievement of the Union‐wide targets. For example, setting targets for ATFM delay for Cork and Shannon would mean extensive additional effort in terms of monitoring once RP2 gets underway but given the relatively low traffic volumes at these airports, their potential impact on network performance is so small as to render their inclusion in the Capacity KPA ineffective.
Noted. PRB states that UK should review the parameters used to calculate NERL cost of capital (both for en route and terminal). It is not clear if this was intended at NERL en route and London Approach (terminal zone C) or NERL and NSL (terminal zone B).
The 2014 Forecast TSU value needs to be corrected from 9,608k TSUs to 10,025k TSUs (see Comment # 24).
Table 32 shows the same errors that were referred to on page 33 i.e. the service unit forecast for 2014 incorrectly shows 9,608k TSUs rather than 10,025k TSUs. The DUC efficiency between 2014 and 2019 needs to be revised from ‐
5.3% pa to ‐4.5% pa and other values adjusted in the same way that Table 16 needs to be corrected (see comments above).
The top half of the bar chart in figure 26 should read as follows: ‐12.2% ATSP, ‐18.5% MET, +1.4% CAA, ‐11.3% TOTAL. There is an erroneous reference to a total figure of +13.9% which should be removed.
OPEN
OPEN
No action
ACCEPTED.
Report text updated. PRB asked to review
cost of capital for both en-route and
terminal.
OPEN.
Related to comment 24
OPEN.
ACCEPTED.
Chart replaced with correct chart for 20112019 period.
52
Page 67, comments section
factual
53
Page 68, Figure 28 and comments section
factual
54
Page 72 1 bullet
55
Page 72 2 bullet
Paragraph 5 incorrectly references a ‐5.6% pa DUC reduction for NERL but this should read ‐4.8% pa once the 2014 forecast TSU issue (9,608k TSUs v 10,025k TSUs) has been corrected. Paragraph 6 should then also reference the ‐4.8% pa (currently it is showing ‐5.3% pa).
The 2014 traffic TSU error commented on above also affects the graph in figure 28 (lines to be redrawn for the UK) and the reference to a ‐5.3% pa reduction in the UK’s DUC, which should be corrected to ‐4.5% pa
OPEN.
OPEN.
st
general
Replace NATS (NSL) with NSL for clarity on the use of terms
ACCEPTED.
nd
general
Replace NATS (NERL) with NERL for clarity on the use of terms
Report updated
ACCEPTED.
8/10
#
Chapter/Section/
Type of
comment
(typo, factual
mistake,
general, etc.)
Comment
56
Page 75 “Cost of capital” 5
paragraph
general
Insert “provided by NERL” following “For the TCZ C” This is to ensure clarity between discussion surrounding the en route provide and the major TANS provide
57
Page 75 first line of page
factual
The sentence should say that UK DCs are planned to decrease by ‐2.0% pa not just ‐2.0%.
th
Response
Report updated
ACCEPTED.
Report updated
ACCEPTED.
Report updated
9/10
Annexes:








Annex A – Invitations to FAB consultation meeting
Annex B – FAB CAP update CORRIGENDUM REQUIRED
Annex C – Additional Information on traffic assumptions (Ireland)
Annex D – Additional information on costs exempt (Ireland) CORRIGENDUM REQUIRED (has been taken into account in the final report)
Annex E – UK en route reporting tables CORRIGENDUM REQUIRED (has been taken into account in the final report)
Annex F – Further information on NERL interest on loans (provided on 1st October) CORRIGENDUM REQUIRED (has been taken into
account in the final report)
Annex G – Corrected 2010 and 2011 capex data (UK) CORRIGENDUM REQUIRED
Annex H – Further information on Irish economic assumptions (to be provided in the week commencing 29 September) CORRIGENDUM
REQUIRED (has been taken into account in the final report)
10/10

PRB Assessment Report of RP2 FAB Performance Plans

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