Joint ATCEUC-ETF position of the development of the three Safety KPIs contained in the Performance Scheme (Reg. 691/2010)

The Single European Sky regulations have the objective ‘to enhance safety standards and to contribute to the sustainable development of the air transport system, (…) with a view to meeting the requirements of all airspace users.’
Safety shall be the paramount key performance area, which gives the framework and guidance for all other key performance areas and the targets therein.

Reality is quite different:
ATCEUC & ETF regret to notice the low ambition on strong safety KPIs. ATCEUC & ETF have continuously expressed its disappointment about the low emphasis put on the Safety KPA, compared to the other KPAs: Costs, Capacity and Environment. ATCEUC & ETF still believe that the Safety Indicators, as adopted in the Performance Scheme, are not well developed and immature.

However, ATCEUC & ETF welcomed the inclusion of a Safety and Just Culture indicator in the performance scheme. Therefore, ATCEUC & ETF welcome the latest Commission’s initiative to further develop the Safety KPIs.

All KPAs are interdependent and should be well balanced. All actors should be fully aware of the trade-off between the four KPAs. Over-emphasis of one area can be detrimental to the other. As far as Safety is concerned, that question of trade-off cannot be left unanswered.. To guarantee that safety continues to be the overall priority in the ATM service provision, safety targets must be more ambitious. At least the same emphasis should be put in Safety as it is put in the other targets. The ATM Master Plan foresees a 10-fold increase of the Safety level. ATCEUC & ETF strongly believe this will not be achievable with the current setup.

A safe ANS provision is the “output” of the ANSPs; their existence depends on the safety level of their services. Both the users and the ANSPs need quantitative tools, not only for measuring cost-efficiency and delays but also to control the quality of the service. A well developed and tested mathematic safety analysis model should be built in and implemented. The severity classification and a Just Culture system (together with automatic occurrence detection where available) could provide the initial necessary input for the system. Further work should be done, and other metrics could be incorporated in the analysis to complement the view and ensure complete and thorough analysis. Although this is outside the scope of this position expressed on those three KPIs, it should be clear that those KPIs are only a first step.

ATCEUC & ETF are not satisfied with the proposed methodology for the evaluation of the safety KPI. The self-evaluation concept, where ANSPs, NSAs and States are expected to measure their own safety level by conducting a self-evaluation, is not supported by ATCEUC & ETF. Other KPAs are assessed by an external and independent body (PRB). As far as Safety is concerned an external and independent body should conduct assessments, in order to ensure transparency and consistency.

All other KPIs are defined as quantitative targets. The assessment of these is possible through a methodology that provides quantitative results. In contrast, the safety measurement and assessment is planned through a yes/no questionnaire. This methodology will neither deliver a realistic nor impartial indication of the actual safety level. It will deliver qualitative results only, which are open to vague interpretation.

This is especially true for Just Culture, the assessment cannot properly be conducted by using a yes/no questionnaire. Other means for assessment must be used to derive a clear picture of Just Culture policy and implementation. Just Culture inside an organization is a cultural and legal issue. ATCEUC & ETF propose to use other tools, for example ‘Safety culture assessment’ by Eurocontrol, to better evaluate the policies and implementation of Just Culture.

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ETF-ATCEUC position on Safety KPI		28 Kb