This position paper aims to give the ETF opinion on SES 2+ proposal released by the EC on 11 June 2013.

With regard to the consultation process, ETF deeply regrets the lack of willingness of the EC to organise a real consultation with the social partners and the other stakeholders before the release of the SES2+ draft proposal, despite that a lot of concerns were already identified as very important issues.

The signals sent by ETF and its members were strong enough and the EC couldn't ignore them. As a consequence, the SES2+ legislative proposal has already created social tensions everywhere in Europe as it was one of the main reasons of the European Action Day organised by ETF members on the 12thJune 2013.

Additionally ETF regrets this proposal is coming out only few years after the adoption of the last SES legislative text in 2009. This over-regulating legislative process creates uncertainty and instability in ATM industry as the legislative background is changing continuously. ETF believes it is now time to stabilise the legislation in order to give the possibility for ATM stakeholders to fully implement the already existing legislative packages.

Furthermore, this new text is presented by the EC as only an update of the previous one withno big changes in the regulation. This analysis is clearly not supported by ETF which considers that the SES2+ proposal is challenging a lot of political consensus obtained in SES1 and SES2. Such consensus is necessary to create a general agreement among all stakeholders on the SES project. Acting like this the EC takes the risk that some important categories of stakeholders, for instance workers, will withdraw their support to the SES idea.

To conclude, there is a clear divergence of opinion between ETF members and the EC on the analysis of ATM situation in Europe. For ETF, ATM is a public service with a high safety dimension and very long term investment cycles. This particular dimension of ATM is not recognised by the EC which considers ATM as a marketable sector. Therefore the general ETF comments on the SES2+ new proposals are not very supportive.

ETF position SES2+