Following the publication of the revised legislative SES package, known as SES 2+, on 23rd of September 2020 and the upcoming Council of Transport Ministers on Monday 28th of September 2020, IFATCA submits the following.

The impact of the COVID -19 sanitary crisis on society at large and aviation in particular is of unknown dimension. Traffic recovery will depend on the medical progress and it might be a dire and long way to achieve pre-COVID traffic numbers. The proposed legislative package is astonishingly rehashing old principles which have in the past not provided the needed impetus for a reform of the Single European Sky.  

In the view of the professional air traffic controllers / sector, the proposal of the European Commission will create additional burden on the current system and if traffic figures raise again will push the sector further down the road of fragmentation and a slowed down reform process. In a situation like the current one a legislative package using the strength of the current system and provide legislative support to raise out of the crisis in a better shape would have provided the needed support to create a competitive and modern European Air Traffic Management infrastructure. Europe deserves better to ensure the stability and resilience of its air transport industry.

The proposed reform package relies on the same mechanisms and instruments which failed to bring any reform in the past:

• Functional Airspace Blocks; instead of working towards a seamless sky as recommended by the Wise Persons Group the proposed way forward will increase fragmentation.  
• The cost recovery and charging mechanisms has shown its fragility it the current crisis.  IFATCA is proposing that part or all of the activities involved in the provision of ANS are funded independently of the current “airspace users pay all” principle. The possibility of creating an infrastructure fund at multinational level to finance ANS provision should be considered. Such a hybrid approach would prevent a situation where States have to step in to financially support commercialized or privatized ANSPs which run out of funds when traffic significantly decreases (experienced in 2001 and during the current pandemic).
• To propose the future independent economical regulator under the helm of the European Aviation Safety Agency is an error. It undermines the credibility of EASA as an agency for safety as it requires at institutional level the guardian of safety to make compromises with safety.
• Instead of providing a sustainable future funding scheme, which create a sound Air Traffic Management infrastructure the proposed Union wide unit rate without a proper backup by member states will rely on the continuous uninterrupted growth of air traffic.  
• The current crisis has highlighted that Air Traffic Management is an essential service which needs to function properly in any given situation. To this end, a robust and standardized infrastructure needs first to be set up. Liberalisation and market mechanisms as proposed in the EC proposal is the wrong strategy to achieve this.

Following the reports of the European Court of Auditor and the Recommendations of the Wise Person Group, IFATCA hoped that the European Commission would use the current crisis to come up with a real adequate proposal for a needed reform process in the sector. Is it is disappointing to see that this is not the case. Europe can only become one of the global actors if it can rely on a robust infrastructure in aviation. This needs to be built, including new technology like artificial intelligence, machine learning and possibly remote operations on a sound and commonly agreed and shared vision.  

IFATCA and its professional representatives are always standing by to assist in developing such necessary changes and to be a driving force to defend the implementation of sound solutions: a performant European ATM system for the benefit of all stakeholders, including all ATM professionals.