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The Signatories support the European regulatory authorities in producing a robust, harmonised, EU-wide regulatory safety framework that enables the safe, secure, efficient and fair integration of drones in the aviation system, and fosters broad public acceptance. Since the Drones Helsinki Declaration in 2017, which called for simple and performance-based rules for drones, significant progress has been made in developing and delivering a regulatory framework that will support the safe and sustainable growth of the drone industry. However, in order to facilitate the integration of drones in very low-level airspace (i.e. below 500 ft) and preserve the high level of safety in the entire European airspace, we jointly call to accelerate the implementation of the following measures.
1. Extensive public awareness campaign The general public, including recreational/occasional drone users, as well as commercial clients, must be aware of the safety risks, duties, liabilities, insurance requirements, responsibilities and third-party privacy issues associated with drone operations. These are essential requirements as lack of awareness and negligence could result in safety incidents and accidents. Therefore, more resources must be dedicated to this aspect of drone integration in the airspace.
2. Mandatory training and certificate/license relevant to operations The obligation for drone pilots to obtain a certificate or license aligned with EU regulation – depending on the properties, performance and features of the drone – creates awareness and mandates knowledge of the applicable regulations and restrictions as well as helping to develop the necessary skills. Practical training and theoretical knowledge requirements for unmanned aircraft pilots constitute an important safety net to prevent drone incidents or accidents. A solid knowledge and skills base is therefore a must, considering the complexity of the national and European airspaces and related aviation regulations. We are all one in the sky There is only one sky and all stakeholders, new and traditional, need to collaborate to keep it safe, secure, efficient and fair. The Signatories
The Professional Staff Organisations would like to take the opportunity to give our views on the ongoing process of the updating of the Single European Sky Performance and Charging Regulations.
The current PRB proposals for target setting and the last European Commission proposal on RP3 legislation leaves PSOs exasperated. We seriously question how these PRB recommendations and EC proposals can contribute to solve the current problems and to allow the safe and efficient flow of traffic in the European ATM system.
An urgent action plan is needed, with 2 fundamental pillars: providing sufficient safe capacity for summers 2019-2021 and recruiting sufficient Air Traffic Controllers, ATSEPs, needed for the implementation of SESAR technologies while maintaining legacy (existing) systems, and other expert ATM staff. This has to be properly supported by an appropriate performance framework that allows this to happen.
The PSOs turn to EU members states and call for them to be the guarantor of the integrity of the EU aviation sector by pushing for a swift and comprehensive recovery plan for the ATM industry and properly preparing for the medium-term future, involving all stakeholders.
We would urge member states to reject the current proposals.
The Commission has recently published a draft text for a new combined performance and charging regulation that will govern the SES Performance Scheme. It is anticipated that this regulation will be in place for RP3, that commences at the beginning of 2020. ETF together with the other staff associations, ATCEUC, IFATCA, IFASEA and IFAIMA have for the last year been inputting into various consultation forums as well as holding bilateral meetings with the European Commission to present the staff view and influence the drafting of the regulation. On 29th May the Commission held a consultation workshop with Canso, Airspace users and Staff Associations together with members of the Single Sky Committee to gain initial feedback. This was supported with a presentation from the three stakeholder groups. The letter below summarises our main issues with the draft text, and these have been sent to the Commission and member state representatives. The Commission took away much feedback from the meeting, and we will await the outcome of the Single Sky Committee meeting, and it is likely that a revised draft text will be produced in due course.
The Expert Group on the Human Dimension (EGHD) has been asked by the European Commission for a position paper on the future of the Performance and Charging scheme regulations. These regulations govern the performance scheme which regulates ATM providers on Safety, Cost, Capacity, and the Environment. The regulations are currently being revised and amended by the European Commission in advance of RP3 which starts on 1st Jan 2020. Over the last months and as briefed at our last meeting in Madrid this paper has been the topic of some discussion, but we have reached consensus and the final paper is published below. The EGHD is made up of the ATM Social Partners (ETF, ATCEUC and CANSO) and the staff professional organisations (IFATCA, IFATSEA and IFAIMA).
Remote Tower technology is used, or planned to be used in the very next future, by more and more Air Navigation Service Providers.
Yet the ATM staff representative organizations ETF and ATCEUC do not believe that the regulatory approach to this subject by EASA is appropriate and effective. After months trying to convince EASA to reconsider the approach and to listen to our concerns, we decided time has come to go public with this joint public statement you find attached.
As part of the consultation on the performance scheme for RP3 that the Commission is currently undertaking, a study and workshop on ‘incentives’ was held recently. ETF, together with the other Professional Staff Organisations attended this workshop and have followed this up by submitting a joint written response. It is our firm view that incentives have no place in the performance scheme as these lead to short term and short sighted decisions, and distract from providing a responsible and effective long term service. We were pleased to work with our fellow staff representative organisations to provide a common staff view.
Discussions around the third reference period for the performance scheme are ongoing. It is more than time for the decision makers to update the EU regulations in order to make it a balanced and shared vision between all the stakeholders. In this context ETF has produced a position paper, summarizing the staff concerns and proposals.
Download here: RP3 Position Paper Final
Today, unmanned aircraft are being used among other things for aerial filming and photographing, safety inspections of pipelines or buildings or by farmers. Tests are being performed for delivery of goods or even transport of passengers.
The Aviation Strategy for Europe presented by the Commission in December 2015 states: "unmanned aircraft share the same airspace with other aircraft [and therefore] the safety of their operations must remain coherent with the overall aviation safety policy. Finally, unmanned aircraft operations must also be consistent with air traffic rules as laid down in the Common Rules of the Air."
Due to the rapid development of RPAS, the ETF strongly supports the inclusion of RPAS into the scope of the EASA Basic Regulation, as well as other regulatory initiatives aiming to ensure a safe co-existence of manned aircraft and RPAS in line with the principle "one sky – one safety".
download ETF views : etf-views-on-rpas-151216