EN    EN EN 
EN    EN  COMMISSION OF THE E UROPEAN COMMUNITIES 
Brussels, 25.6.2008 
SEC(2008) 2086 
  
COMMISSION STAFF WORKING DOCUMENT 
 
accompanying the 
 
Proposal for a 
 
amending Regulation (EC) No 216/2008 in the field of aerodromes, air traffic 
management and air navigation services a nd repealing Council Directive 06/23/EEC 
Impact Assessment  
{COM(2008) 390 final} 
{SEC(2008) 2087} 
EN 2   EN TABLE OF CONTENTS 
Executive summary 
1 Procedural issues and consul tation of interested parties 
1.1 Organisation and timing 
1.2 Consultation and expertise 
2 Problem definition 
2.1 Background and Scope of the Impact Assessment 2.2 Three safety challenges calling for action 
2.2.1 Growth of air traffic requires new harmonised approaches  
to retain safety level 
2.2.1.1 Accidents and Occurrences 2.2.1.2 Aerodromes and ATM/ANS: Top threat areas 
2.2.2 The current regulatory framework 
2.2.2.1 The Global Player: ICAO 2.2.2.2 Intergovernmental Bodies in Europe 
2.2.2.3 Regulatory actions by the European Community 
2.2.3 Lack of harmonized and enforceable rules 
2.3 Conclusion and justification of intervention 
3 Objectives 
3.1 General Objectives 3.2 Specific Objectives 
3.3 Operational Objectives
 
4 Policy options 
4.1 General 
4.2 Affected areas of competence 4.2.1 Aerodromes 4.2.2 ATM/ANS 4.3 Option A: "Do nothing" 
4.4 Option B: Extend EASA competences 
4.5 Option C: Extend EUROCONTROL mandates issued by the COM 4.6 Option D: Establish a new Agency 4.7 Option E: Extend EASA competences and include some other functions
 
5 Analysis of impact of alternative options 
5.1 Option A: "Do nothing" 
5.2.1 Safety impact 
5.2.2 Economic impact 5.2.3 Environmental impact 5.2.4 Social impact 5.2.5 Other impacts 
5.2 Option B: EASA extension 
5.2.1 Safety impact 5.2.2 Economic impact 5.2.3 Environmental impact 5.2.4 Social impact 5.2.5 Other impacts 
5.3 Option C: Extend EUROCONTROL mandates issued by the COM 4
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EN 3   EN 5.3.1 Safety impact 
5.3.2 Economic impact 5.3.3 Environmental impact 
5.3.4 Social impact 
5.3.5 Other impacts 
5.4 Option D: Establish a new Agency 
5.4.1 Safety impact 5.4.2 Economic impact 5.4.3 Environmental impact 
5.4.4 Social impact 
5.4.5 Other impacts 
6 Comparing the options 
7 Monitoring and evaluation Annex 1: Figures Annex 2: List of Abbreviations Annex 3: References  32 
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38394647
EN 4   EN EXECUTIVE SUMMARY 
This report assesses the impact of the intended extension of the competence of the European 
Aviation Safety Agency (EASA) to the regu lation of aerodromes, Air Traffic Management 
(ATM) and Air Navigation Services (ANS). 
Based on extensive and public cons ultation of stakeholders as we ll as per advice by expert 
partners, safety of the rapidly growing Euro pean aviation is foun d to be increasingly 
challenged by a still fragmented regulatory framework as well as by a persisting lack of harmonized and binding safety rules covering all areas of aviation. The in tention to overcome 
this situation by implementation of a structur ed and sole competence for regulation of key 
aviation safety areas such as aerodromes and ATM/ANS is based on a ve ry broad and clearly 
indicated consensus. 
Building on the results of the Preliminary Imp act Assessment launched by the Commission in 
2005, elaborated by an independent consultant , and on the Regulatory Impact Assessment 
(RIA) by EASA, the present report assesses se veral options to meet the above mentioned 
intention. As the concerned stakeholders are al ready subject to Communi ty legislation in the 
field of ATM/ANS, as are other parts of the av iation chain, i.e. airworthiness, flight crew 
licensing and air operations, the centre of gravity of this assessment is put on the aerodrome 
share of the project which will represent a new area of Community competence. 
Five available policy options are identified to either:  
• "Do nothing"; 
• Extend the EASA competences; 
• Extend the scope of the existing arrangeme nt to issue mandates to Eurocontrol; 
• Establish a new Agency; or  
• Extend the EASA competences to include some other functions.  
All those options are balanced against the "d o nothing" option as a benchmark by analysing 
their impact in the fields of safety, economy, environment, social and others. These impacts 
pertain to the envisaged shift of regulatory competence in qu estion, whereas potential impacts 
triggered by the implementation of future rules following the actual measure will be subject to assessment at the corr esponding later stage. 
A comparison of those impacts leads to the very cl ear indication that the preferred option is to 
extend the EASA competences to include regulatory respons ibility for aerodromes and 
ATM/ANS matters. For this option, no adverse effect could be identified in the fields 
mentioned above. 
This conclusion is in line with the "total  system approach" to be taken to encounter 
future aviation safety challenges, to support internal market prin ciples and to reduce 
burden of regulated organisations. By integr ating the safety elem ent into the Single 
European Sky initiative, it ensures that  the de-fragmentation of the sky will be 
implemented without impacting negatively on the level of accident rates. For this reason, 
EN 5   EN the safety module will form the complement ary, inseparable part of the "aviation 
legislation package" 2008, as rightl y requested by all stakeholders. 
Furthermore, a complete set of monitoring and evaluation tools is made available to ensure 
proper implementation, execution and conti nued quality of the application of the 
consequences of the intended measure. 
1 PROCEDURAL ISSUES AND CONSULTATION OF INTERESTED PARTIES 
1.1 Organisation and timing  
This Impact Assessment has been prepared by DG TREN, based on an Inter-Service Steering 
Group (IS-SG) which met nine times and includ ed, besides the Secret ariat General and the 
Legal Service, contributions of the followi ng Directorates General: ENTR, ENV, MARKT 
and BUDG. Furthermore, the European Aviation Safety Agency (EASA) participated in the 
process. 
The following major milestones and achievements formed the basis for the development of 
the final findings of this Impact Assessment: 
• A Preliminary Impact Assessment launched by the Commission a nd performed by the 
independent consultant ECORYS in 20051. This assessment included an extensive 
stakeholder consultation. 
• The Commission Communication "E xtending the tasks of the European Aviation Safety 
Agency: An agenda for 2010"2. 
• A Regulatory Impact Assessment (RIA) performed by EASA3 which established the basis 
for the EASA Opinion to extend its scope to the regulation of safety and interoperability of 
aerodromes4. Following the formalised EASA rulema king procedure, this work also was 
based on an extensive consulta tion, resulting in very broa d feedback of the affected 
stakeholders. Furthermore, it reveals many elemen ts and details pertaining to the execution 
of the regulatory function, hence it even addr esses matters beyond the scope of the actual 
extension of competence of the Agency. 
• A "High Level Group", appointed by Vice Pres ident Barrot for the Future European 
Aviation Regulatory Framework in November 2006 as a response to a strong demand from 
industry, EU member states and other stak eholders to simplify and increase the 
effectiveness of the regulatory framework for aviation in Europe. Vice President Barrot requested the High Level Group to present a vision for the development of the aviation 
regulatory framework - with a particular focus on Air Traffic Manageme nt - and to provide 
a roadmap to achieve this visi on with practical next steps. 
• Other expert insights as i ndicated in this document. 
                                                
 
1 ref. [2] 
2 ref. [1] 
3 ref. [7] 
4 ref. [5] 
EN 6   EN The advice and momentum created by the above achievements fully supported the decision to 
include the project in the Commission Legi slative and Work Programme 2008, item 8b. This 
item of extension of the Agency system to  the regulation of aer odromes, ATM and ANS 
forms one pillar of the "aviation package", which also comp rises the amendment of the Single 
European Sky regulations (item 8a) a nd the SESAR Master Plan (item 8c).5 Legislative 
proposals containing this package will be  submitted by the Commission in June 2008. 
1.2 Consultation and expertise  
As indicated above, a very high amount of consu ltation effort was put into the development of 
those cardinal documents. 
While the preliminary ECORYS assessment wa s based on the mechanism of questionnaires 
distributed to and answered by key stakehol ders as well as related interviews, the 
aforementioned EASA opinion and attached RI A followed the formal rulemaking procedure 
of the Agency. Therefore, the project was fully  available and transparent to the public and 
produced some 3000 contributions, mainly from stakeholders across the board of aviation. 
The reaction of stakeholders reflec ted the fact that the intention to extend the safety regulatory 
competence to aerodromes will create a new area  of Community competence in this field. All 
the comments were taken into account to fo rm the Agency Opinion, again based on the 
publication of a Comment Respons e Document (CRD) and stake holders' observations hereto.6 
In addition to the above, EASA performed a nother consultation focusing on the ATM/ANS 
part of the extension project . A related Notice of Proposed Amendment (NPA) was published 
in November 20077 and lead to a further CRD issued  by the Agency on 18 March 2008. This 
CRD formed a basis for the Agency's opinion published on 15 April 2008. 
However, in contrast to the aerodrome part, for the regulation of AT M/ANS matters European 
competence has already been established, first on a case-by-case basis through specific legal 
Community instruments and then comprehe nsively through the Single European Sky 
regulations, adopted in 2004.8 
Therefore, the direct overall impact of safe ty related regulatory activities in the ATM/ANS 
field to be performed by EASA will mainly affe ct such regulated persons, whose activities are 
already regulated through Commu nity rules, and issues of  regulatory governance in the 
Community system.  
                                                 
5 Commission Legislative and Work Programme 2008, Annex 1, item 8: Communication "Developing 
the single European Sky" including the SESAR Master Plan and accompanied by legislative proposals modifying the Single European Sky regulations and extending EASA tasks to airports and air traffic 
management 
6 ref. [7], page 19ff; also: EASA CRD 06-2006, ref. www.easa.eu.int/home/r_crd.html  
7 ref. [8] 
8 ref. Regulation (EC) 549/2004 laying down the framework for the creation of the single European Sky, 
Regulation (EC) 550/2004 on the provision of air navigation services in the single European Sky, Regulation (EC) 551/2004 on the organisation and use of airspace in the single European Sky, 
Regulation (EC) on the interoperability of the European Air Traffic Management network and 
Regulation 2096/2005 laying down common requirements for the provision of air navigation services. In particular, EUROCONTROL Safety Regulatory requirements (ESARRS) 3, 4 and 5 were adopted by 
Regulation 2096/2005, while the remaining ESARR 2 is covered by Council Directives 56/1994 and 
42/2003 and the adoption of ESARR 1 and 6 will be subject to future legislation. 
EN 7   EN In addition, a manifold informal consulta tion has been carried out by the Commission 
Services and EASA to include advice from th e stakeholders of the broad aviation community, 
as for example from aerodrom es, ATM/ANS service providers,  air carriers, labour unions, 
military aviation organisations and manufacturing industry. 
A draft of this present report was issued to  the Commission Impact Assessment Board on 19 
March 2008, a related hearing took place on 16 April 2008. The positive opinion of the Board 
was given on 23 April 2008. The Board's recommenda tions to improve the draft report were 
implemented in the present final report. 
Overall, by the elements listed above, the level of coordination and expert ise involved in this 
Impact Assessment and the included analysis of  the most proper way ahead were performed 
in accordance with all applicable standards an d form a very sound and clear picture of the 
optimal way to proceed. The broad consensus appearing from the consultation lead to the strong political commitment to establish European  Aviation Safety Agency (EASA) as strong 
and sole body for European aviation safety re gulation aspects and to have related measures 
integrated into the Single European Sky development. 
2 PROBLEM DEFINITION 
2.1 Background and Scope of the Impact Assessment 
The EASA system
9 was established by the Regulation (EC) No. 1592/2002 of the European 
Parliament and of the Council of 15 July 2002 on common rules in the field of civil aviation 
and establishing EASA, having regard  to Art. 80(2) of the Treaty.10 EASA is a Community 
Agency and so its foundation is based on the legal framework of the European Communities. 
This framework establishes that the Community  acts as a legislator, while Member States 
apply Community law under Community control.  Community legislator consists of the 
Council of the EU Member States and of the European Parliament acting in cooperation 
through the legislative co-decision procedure. Community law is directly applicable in 
Member States and hence supersedes respective national laws. Where Community 
competence has been established, Member Stat es may no longer act individually, but may be 
given powers to deviate or gr ant exemptions, subject to Commission authorisation. The 
Community framework allows conferring legi slative powers to the Commission (hard law) 
and to an Agency (soft law) or industry, subj ect to clearly specifying the nature of the 
delegated powers so as to allow political  and judicial contro l of their exercise. 
The main objective of EASA is to establish and maintain a high uniform level of aviation 
safety in Europe. In addition to this the Basi c Regulation lays down additional objectives to 
facilitate the free movement of goods, person s and services, to ensure a high level of 
environmental protection, to promote cost-eff iciency in the regulatory and certification 
processes, to assist Member States in fulfilling their ICAO obligations, to promote 
Community views with third countries and intern ational organisations and to provide a level 
playing field for all actors in the internal aviation market.  
                                                 
9 I.e. centralization of the rulemaking and standardisa tion processes in the Agency, as well as exploitation 
of the competent authorities designated by Member States for the vast majority of the tasks concerning certification and oversight 
10 Treaty, Art. 80(2): "The Council may, acting by a qualified majority, decide whether, to what extent and 
by what procedure appropriate provisions may be laid down for sea and air transport." 
EN 8   EN The mandate to EASA is to prepare the safety  regulatory implementing rules to be adopted by 
the Commission and to issue explanatory material  to facilitate their und erstanding and support 
their uniform implementation. This is the basi s for the rulemaking activity of the Agency. 
Therefore, it is to develop its know-how in all fields of aviation safety following the principle 
of a "total system approach" in order to assi st the Community legislator in the development 
and application of common and binding rules for the aviation system. The Basic Regulation 
also requires the Agency to assist the Comm ission in monitoring that  the Member States 
implement safety rules effectively and un iformly. It is thus empowered to conduct 
standardisation inspection of na tional competent authorities and to report cases of incorrect 
implementation to the Commission, which can then  trigger infringement  procedures under the 
Treaty or direct sanctions as appropriate. Moreover, the Basic Regulation creates a necessary 
framework in those areas, where a centralised ac tion would be the most appropriate means to 
provide for uniformity, when it comes to th e approval of certain  products (e.g. type 
certificates for aircraft) or organi sations (e.g. Design Organisations).  
Initially, the aforementioned Regulation esta blished the basis of Community action in 
applicable domains to ensure the airworthine ss and environmental compatibility of aircraft, 
including personnel and organisatio ns involved in their design, production and maintenance.  
Further work was then undertaken to address all other fields of aviation safety as the aviation 
system behaves as a network with  all parts inte racting with each other, as fragmentation at 
any level would be a significant impediment to the efficient func tioning of the overall 
network. The scope of the EASA system was ther efore to be extended progressively to cover 
these other aspects of safety, bu ilding on a total system approach.11 A first step of 
enlargement of the Agency's competences by the European legislators to  cover air operations, 
licensing of flight crew and safety of third co untry aircraft operating in  Europe entered into 
force by Regulation (EC) No. 216/2008 of the European Parliament and the Council on 09 April 2008. 
Corresponding to the univocal political commitme nt to remove the existing fragmentation 
from European aviation safety  regulation, the endeavour now  is to further extend and 
complete the competences of EASA in the fiel d of safety and interoperability regulation of 
aerodromes and ATM/ANS. The legislative propos al by the Commission s hould be issued in 
June 2008, in view of its formal  adoption in 2010. On the basis of the Essential Requirements 
which form an integral part of the proposal the Agency will be mandated to issue Implementing Rules to be adopted by the Co mmission through comitology procedure in the 
following years. 
Given this background of the EASA sy stem, the present Report aims at: 
• analysing the challenges faced by Europe to main tain or further improve the safety level of 
aviation activities; 
                                                
 
11 Ref. Regulation (EC) No. 1592/2002, recital 2: "As a consequence, aeronautical products should be 
subject to certification to verify that they meet essential airworth iness and environmental protection 
requirements relating to civil aviation. Appropriate essential requirements should be developed within 
one year after the entry into force of this Regulatio n to cover operations of aircraft and flight crew 
licensing and application of the Regulation to third-country aircraft and,  thereafter, other areas in the 
field of civil aviation safety.  
EN 9   EN • identifying the regulatory competences necessa ry to mitigate the risks of accidents and 
exploring various polic y options to do so; 
• carrying out an impact assessm ent of the various options; 
• selecting the most suitable option for the e nhancement of the safety of aerodromes and 
ATM/ANS. 
By doing so, the report shall de al with impacts emerging from the question of "if and by 
whom to regulate", while actual rules followi ng a shift of regulatory competence and their 
related possible impact are not visible yet but will need to be assessed at the corresponding 
implementation level later. 
Therefore, the aim of this report is not to provide  an impact analysis of individual future rules, 
esp. regards the economic side – as this is not fe asible – but to focus on the rather qualitative 
impact created by the competence shift providi ng a mere platform for the later rules. 
2.2 Three safety challenges calling for action 
2.2.1 Growth of air traffic requires new harmon ised approaches to retain safety level 
The current European air transpor t system is a very safe system; European aviation safety is 
on the leading edge. However, the prominent Eur opean safety factor is not meant to comfort 
but must be kept. It faces the tremendous chal lenge of the air transport volume in Europe 
growing at the commonly predic ted rate of 2-5% per year12. If nothing was done to further 
improve safety, i.e. if the accident rate would remain at the current level, the consequence 
would be a significant and continuous ri se in European aviation accidents: 
2.2.1.1 Accidents and occurrences  
Aviation accident statistics is an exercise of low numbers, comparatively; however, each of 
those mishaps involves the potentia l of huge and catastrophic cons equences. In order to allow 
for a maximum of lessons learned from those trag ic events, intense efforts are put in place to 
ensure mandatory and in-depth accident investigations.13 This endeavour is flanked by the 
effort to collect all possible data by mandatory reporting of occurrences14, which are 
understood to show th e potential for an accident which did not occur due  to fortunate 
circumstances.  
Based on the prevailing and still unsatisfactory level of reporting culture15, it has to be pointed 
out that a total of about 400 accidents in Europ ean commercial European aviation over the last 
                                                 
12 Scientific forecasts indeed differ on the actual numbers of the continued growth. The figure given, 
though, is conservative also in the light of the aver age growth experienced in Europe in the years 2003 
to 2008, which arrived at 5,4% annually. 
13 Ref. Directive (EC) 56/1994 establishing the fundam ental principles governing the investigation of civil 
aviation accidents and incidents 
14 Definition as of Directive (EC) 42/ 2003: ‘occurrence’ means an operational interruption, defect, fault or 
other irregular circumstance that has or may have influe nced flight safety and that has not resulted in an 
accident or serious incident, hereinafter referred to as ‘accident or serious incident’, as defined in 
Article 3(a) and (k) of Directive 94/56/EC; 
15 Ref. EUROCONTROL, Performance Review Report 2006: 10 States show insufficient legislation / 
culture with regard to occurrence reporting, only 11 rated "good" (ECTL PRC 2006) 
EN 10   EN decade16 is only the top of the iceberg of some 1000 occurrences per year involving 
aerodrome and ATM/ANS contributions, of wh ich 25% show "high severity" criteria.17 
It is this potential for mishap which, in comb ination with the disast rous effects of only a 
single major aviation accident – regards not only loss of liv es but also to social and 
economical effects – calls for upgrade of safety systems throughout the globe, to include Europe. As even single, discrete mishaps have sh own to be potentially fatal to whole airline or 
aerodrome operations, all involved players should  put in place tremendous efforts to defend 
the high value asset of the existing safety level.  
In doing so, the importance of harmonisation, as opposed to the cu rrent fragmentation is well 
understood: As safety matters ra rely affect one segment only, th e integration of all aspects 
into a single approach promotes  safety in the best way. This solution also reduces the number 
of interfaces to other bodies, centralises knowle dge management and provides for the shortest 
possible coordination. Overall, this solution ensure s the best efficiency and effectivity of the 
process. 
2.2.1.2 Aerodromes and ATM/ANS: Top threat areas  
Recent findings from risk analyses as well as in cident and accident data  clearly indicate the 
shortcoming in certain regulatory aspects playing an important role
18, in particular with regard 
to the fact that about 60-70% of air accidents occur in the very initial or final phases of 
flight.19  
The evaluation of data performed by the In ternational Air Transport Association (IATA)20 
confirms for 2006 the most prom inent phases of flight leadi ng to a total of 77 accidents 
involving substantial damage or hull loss of western-built jet airc raft being the take off (9), 
the approach (5) and the landing phase (41), of which 8 occurrences were fatal. The total costs 
incurred by the accidents over the last decade are detailed in Annex 1, figure 2.2.1, indicating 
an annual average above 1200 Mi o. US$ (about 920 Mio. €, based on an exchange rate of 1.3) 
In particular, for the above mentioned accide nts in 2006 the airport facilities and the ATC 
score high among the identified "Top Threats"  by figures of 24% and 21%, respectively.21 
Annex 1, figures 2.2.2 to 2.2.4 reveal airport faci lities and related ground operation being a 
top threat to runway excursions, ground incidents and approach and landing accidents by even up to 33%. 
This picture is demonstrated even more  visibly by recent – though non-European – well 
known accidents in Toronto, Quito and Sao Paulo, all being major and catastrophic 
misfortunes involving factors as aerodrom e infrastructure, aerodrome operations and 
ATM/ANS service provision.  
The Sao Paulo accident in 2006, claiming 200 lives due to an overshoot of a runway which 
did not benefit of an appropriate overshoot area,  could happen in an id entical way on all those 
                                                
 
16 Ref. EASA, Annual Safety Review 2006; about 50 % of those involve aerodrome and or ATM/ANS 
contribution 
17 Ref. EUROCONTROL, Perfor mance Review Report 2006 
18 ref. [2], page 33 and [7], page 25ff 
19 ref. "Annual Safety Review 2006", EASA, page 13ff 
20 ref. 11 
21 ref. 11, page 23 
EN 11   EN EU aerodromes which do not feature this core aerodrome infrastructure safety criterion. A 
recent major accident in Heathrow was non fatal only due to the very comfortable undershoot 
area provided in Heathrow, being the longest available in UK. 
The most recent element in this chain of se rious events was provided by an accident in 
Germany, which incurred no fatalities, except th e writing off of the ai rcraft which overshot 
the runway and crashed into a wall. 
Consequently, the EUROCONTROL "Annual Safety Report 2007"22 identifies the following 
operational key risk areas for the future of European aviation: Runway incursions23, 
unauthorised penetration of airs pace, level busts, controlled flight into terrain (CFIT) and 
level of ATS at aerodromes, wh ich all involve ATM/ANS and aer odrome regulatory factors.  
The reliable prediction of a significant increase of air traffic demand will obviously constitute 
a formidable challenge for European aviation that requires additiona l measures even to 
maintain the risk of accidents at today's level.  
In total, the rapidly growing traffic development, inducing new technologies as well as 
capacity bottlenecks to both aerodromes and ATM suggests to  encounter thos e challenges in 
an orchestrated way and not to allow discrete , isolated and peculiar  "island" solutions 
developing which aggravate existing interface and harmonisation problems. As those sectors 
are "top threats", exponential rise in risk could be fo reseen in these areas.  
Responding to such challenges, the aforementione d first extension of EASA competences was 
performed as well as the SAFA programme was enhanced24. Another, strong mitigation tool 
was put in place by the "Black List"25. However, this set of current safety improvement 
measures is a partial approach only, since it l eaves aside the regulatory safety aspects of 
aerodromes and ATM/ANS despite their prominent safety relevance. 
If no further mitigation measures were implemented, it would not be possible to maintain an 
adequate level of safety in part icular at aerodromes and in ai rspace with a high traffic density 
but also and increasingly in those regions which experience air traffic growing at a rate even 
above the mentioned average.  
Furthermore, the need to enlarge the ATM/ ANS and aerodrome capacity and performance and 
to counteract foreseeable congestion will result in  more dependency of flight safety on newly 
introduced technology, procedures and automated functions with their individual risk of 
failure and new vulnerable interfaces. Thus, the increasing complexity, integration, and necessary new technology, as composed by pan- European services (data link, EGNOS, 
                                                
 
22 ref. [9], page 20 ff 
23 Runway incursions, that is events leading to ai rcraft hitting other moving objects when landing or 
taking off, is one of the worst scenarios and understood to be "a n accident waiting to happen". They 
involve mostly aerodrome and ATM f actors, which are attached to th e traffic congestion and related 
pilot / ATM workload development.   
24 Safety Assessment of Foreign Aircraft; ref. Commission Regulation (EC) No 768/2006 of 19 May 2006 
implementing Directive 2004/36/EC of the European Parliament and of the Council as regards the 
collection and exchange of information on the safety of aircraft using Community airports and the 
management of the information system 
25 ref. Commission Regulation (EC) No 1400/2007 of 28 November 2007 amending Regulation (EC) No 
474/2006 establishing the Community list of air carri ers which are subject to an operating ban within 
the Community 
EN 12   EN Galileo, digitalised aeronautical information)  and as emerging for example from the SESAR 
development all call for a more streamlined  and integrated approach to safety.  
The optimum efficiency of a safety system supporting a total approa ch has therefore to 
be established to cover the safety of ATM/ ANS and aerodromes as key aviation safety 
players and as vital elements in the air tran sport chain. Based on this notion it has 
become evident that further action is required  to ensure that the current safe system will 
evolve to match the above mentioned challenges.  
2.2.2 The current regulatory framework 
To be able to grasp the comparative analysis of the various options consid ered in this report it 
is necessary to have a clear picture of the cu rrent framework of the European safety system, 
its rules and its rulemaking actors. 
A complete regulating function has to be composed  of three pillars forming the overall area of 
competence of a regulating body. Should any of thes e three pillars be ab sent, the regulatory 
action would be ineffective:  
(1) Rulemaking 
(2) Certification / Licensing / Oversight 
(3) Standardisation / Enforcement of compliance 
This rationale involves merely the basic princi ple of the need of constant and complete 
feedback (i.e. oversight tools)  by constant monitoring and evaluation tools following the 
actual rule. Adjustments found necessary th rough this procedure may pertain to the 
rulemaking side (adjustment of legislation) or  to the market players. Therefore, ensuring 
proper application of rules requires enfo rcement tools if and where needed.  
This management principle of the closed loop  of regulation is applied in many areas, for 
instance road traffic, where it becomes appa rent that if the loop was incomplete or 
disconnected, no quality of rule application can be assured. Wher e subsidiarity and level of 
criticality permit individual issues or parts of th is loop could be delegate d to different players. 
The two sections below describe which organisations deal with the three above mentioned 
aspects in Europe. This will demonstrate the fact that all such organisations detailed in sections 2.2.2.1 and 2.2.2.2 are lack ing the competence of the second and third pillar, and 
none of them provides rules which are directly applicab le and mandatory. 
2.2.2.1 The Global Player: ICAO 
A global and highly recognised instrumental lega l framework with respect to aviation safety 
has been established by the International Civil Aviation Organisation (ICAO). In the 
convention of Chicago in 1944 the ground-rules ha ve been established that are meant to 
ensure the safe and orderly growth of civil av iation throughout the worl d. All European Union 
countries have ratified this treaty. 
EN 13   EN The set of rules, standards and recommended practices (ICAO SARPs) form the so called 
"Annexes", signed and transposed, in part and partially with reservations, by the different 
ICAO Contracting States.26  
While this can be regarded as constituting a basic foundation for a potential global “level 
playing field” the ICAO system suffers of crucial limitations: 
The remit of ICAO is limited to rulemaking. The tw o other pillars of the sa fety system are left 
to the ICAO Contracting States. Even in the fiel d of rulemaking it can be  argued that this is 
still for a large part a national affair, as SAR PS rules are of a non mandatory nature and have 
to be transposed into national law. The often generic language used to define the standards 
permits a large diversity of interpretation in the transposition phase. Furthermore, Compliance 
with the standards can be circumvented by filing formal differences. Other ICAO regulatory material is of non binding character per se.
27 
Despite the very valuable achievements by IC AO, those weaknesses of the international 
system led to significant differences in rules,  their application and enforcement, thus in 
differing levels of aviation safety across  the world as well as in the EU . 
2.2.2.2 Intergovernmental Bodies in Europe 
There is not one Europe if the membership of  different organisations  involved in aviation 
safety in Europe is compared. Besides being co ntracting States to ICAO, Member States are 
individual members of the organisati ons ECAC, JAA and EUROCONTROL. These 
organisation themselves have memoranda of co -operation between them, but are not directly 
represented in the decision making bodies of  each other. A visual overview of the 
Membership situation of those organi sations is given by Annex 1, figure 2.2.2.2. 
Before the establishment of EASA , the role of individua l States has been exclusive. Each state 
assumed responsibility on national level for a ll domains, from airworthiness to ANS, ATM 
and aerodrome legislation, sta ndardisation, respect ive standard adoption, certification, 
licensing and inspection. 
• European Civil Aviati on Conference (ECAC): 
The ECAC currently consists of 42 Member  States comprising almost all European 
States. Its objective is to promote the cont inued development of a safe, efficient and 
sustainable European air transport system. ECAC issues resolutions, 
recommendations and policy statements wh ich should be brought into effect by its 
Member States. The uneven implementation and lack of enforcement role reflect the same weakness of the ICAO system. 
Without negating its contribution to safety  in Europe, ECAC by its funding nature 
misses all three pillars of the safety system mentioned above. 
• Joint Aviation Authorities (JAA): 
                                                
 
26 ref. esp. to Annexes 2 (Rules of the Air), 3 (Met  Services), 4 (Aeronautical  Charts), 10 (Aeronautical 
Communications), 11 (ATS), 14 (Aerodromes), 15 (AIS) 
27 ref. [1], page 5 f. 
EN 14   EN The JAA is an associated body of ECAC, representing the civil aviation regulatory 
authorities of all the 42 ECAC States. For so me areas in civil aviation (airworthiness 
and aircraft certification, flight crew li censing and air operations) JAA members 
agreed to coordinate th rough the JAA the development of common safety rules 
which were supposed to be transposed in  national law. The domains ATM/ANS and 
aerodromes, though, are not covered by the JAA. 
By establishing EASA, the JAA areas of rulemaking detailed above were gradually 
transferred to the Agency. This led to the decision to terminate the JAA activity, 
before the end of 2010.28 
• EUROCONTROL: 
The EUROCONTROL agency, comprising 38 St ates, is mainly committed to service 
provision tasks, provision of certain central ized functions, training, research as well 
as planning and management of joint development programmes.  
However, before 2004 it also played a rulemaking role (namely it has adopted and published 
the EUROCONTROL Safety Regul atory Requirements, ESARRs29), with the same drawback 
characteristics of ICAO and JAA. Accordi ngly, developed rules s hould be enacted by 
transposition into national law by the Member States which lead to substantial differences in the progress of implementation of ESA RRs among the EUROCONTROL Members. 
Furthermore, and again as above , no actual legal enforcement mechanisms do exist in that 
regard.
30After the adoption of the legislative p ackage on the Single European Sky (SES) by 
the EU legislator, EUROCONTROL assumed th e responsibility of supporting the European 
Commission in the development of Common Requirements for the domains of ANS and 
ATM, based on individual “mandates” issued by  the Commission itself. Hence, different from 
the bodies mentioned above, EUROCONTROL serves  as "draft" rule ma ker directly within 
the European context. However, also the EU ROCONTROL system has important limitations 
in the safety area. Since it operates under sp ecific mandates within the SES legislation31, it 
does not deal with aerodrome sa fety matters. Furthermore, it has neither certification nor 
enforcement rules, hence two pillars of the sa fety system are not within its remit. In 
conclusion, any rule, standard or require ment adopted and published by any of the 
intergovernmental organisations mentioned ab ove, is not immediately applicable unless 
legally transposed at national level and applicat ion is hardly uniform in the EU. In addition, 
none of them ever had the competence of the second nor the third regulatory pillar, i. e. 
issuing certificates or licenses and any so rt of enforcement powers following oversight. 
                                                 
28 ref. "FUJA Report", Roadmap for JAA, August 2005 . Pending Board approval, the JAA system will be 
closed by end of June 2009. 
29 ref. ESARR 1: Safety Oversight in ATM, ESARR 2: Reporting and assessment of safety occurrences in 
ATM, ESARR 3: Use of Safety Management Systems by ATM service providers, ESARR 4: Risk Assessment and mitigation in ATM, ESARR 5: Requirements for ATM services' personnel 
30 As SES II and SESAR do not focus on aviation safety; the only safety aspect of SES has been the 
automatic transposition of ESARRs into Community la w. However this has been very problematic, not 
only because it forces the Community to adopt texts of  an external body, but most importantly because 
the ESARRs are standalone documents, that fit poorly in the general Community legal framework and 
legislative policy. They are not aligned with the requirements of other aviation safety fields (such as operations or airworthiness) and seek to develop only high level administrative frameworks.  
31 ref. Art. 8 of "Framework Regulation for the creation of the single European sky", Regulation (EC) 
549/2004 
EN 15   EN 2.2.2.3 Regulatory actions by the European Community 
As already explained above, a fundamental prin ciple of the aviation policy of the European 
Union has been to aim at a high and uniform level of safe ty through common action at 
Community level and high and uniform protectio n of the citizens by providing common safety 
rules and by ensuring that all re gulated persons (legal or natura l) comply with such rules. 
Contrary to the frameworks of  the international organisatio ns mentioned above, the EASA 
system, established in 2002 as per Regula tion (EC) 1592/2002, is desi gned to execute the 
complete set of regulatory work, i. e. all three pillars as described before: 
1. Rulemaking, including development of “O pinions” proposed to and adopted by the 
Commission through comitology, leading to  legally binding common Implementing 
Rules immediately applicable throughout the territory of the EU Member States to 
which the Treaty applies (i.e. without the need of trans position at national level); 
2. Issuing certificates and approvals, directly  (for the cases specified in the Basic 
Regulation and where a centralised action ha s been regarded most efficient) or 
through the competent Aviati on Authorities usually nomin ated at national level; 
3. Oversight and standardisation, through insp ections of the competent Authorities and 
reporting to the Commission, as well as enforcement powers.  
As of 2003, the Agency assumed responsibility for airworthiness and environmental 
compatibility of aeronautical products. On 19 March 2008, the scope  of competence was 
extended by "the first step" to include air op erations, licensing and safety of third country 
aircraft.  
Taking this into account, it becomes transparent th at some crucial safety factors are subject to 
the EASA competence already, following the "tot al system approach" with aerodromes and 
(ground) ATM/ANS not yet being incl uded in the scope of the Agency. 
For ATM/ANS, however, it needs to be clearly poi nted out that especia lly by the legislation 
package of Single European S ky (see section 1.2 above), cert ain ATM/ ANS safety matters 
were already made subject to EU  competence. While this legisl ation package, which will be 
further developed in 2008 as part of a more comprehensive aviation package in order to 
respond to challenges in that se ctor, is meant to foster the de velopment of European aviation, 
it does not explicitly address th e regulation of safety matters. Therefore, a total system 
approach towards the key safety factors as aerodromes and ATM/ANS would constitute 
complementary, indispensable element of the Si ngle European Sky initi ative, as it would 
serve as its safety module. 
2.2.3 Lack of harmonized and enforceable rules 
As detailed above, the actual rulemaking and application of harmonized  standards developed 
by ICAO, JAA, Eurocontrol is, apart from the areas already covered by EASA's competence, 
up to the Member States to implement. The sa me applies for the functions of the second and 
third pillars of regulation, i. e.  for certification / licensing and oversight / enforcement action.  
Due to this fact and the incurred severe level of regulatory fragmentation, a cacophony of 
differences with regard to application and execution of rules has arisen among Member 
States. This situation can neither be regarded as meeting the requirements of interoperability 
EN 16   EN within the international aviati on market, nor can it respond to the described upcoming safety 
challenges, nor to the developmen t of a true internal market.32 
Recent, both aerodromes and ATM examples indicate the safety problem emerging from this 
situation: 
• One of the core runway safety criteria  is composed by the "Runway End Safety 
Area (RESA)", meant to allow for erro r in case of an aircraft under- or 
overshooting the runway. The ICAO sta ndard for RESA is 90 m, with 
recommendations from different parties to  up to 600 m. Implementation in Europe 
varies widely, starting from 0m. Very unsaf e conditions persist,  which could lead 
to accidents provoked by this cardin al matter as listed in section 2.2.1.2.  
• One Member State alone filed 640 ATM re lated differences to ICAO standards, 
differences in other Member States are assumed to amount to an equal level. 
Among others, this leads to peculiar, hi ghly individual airspace setups in every 
Member Sate (i.e. different airspace en try and clearance procedures; while a 
certain class of airspace may be entere d without clearance re quirement, the same 
airspace requires an Air Tr affic Control clearance in the neighbouring State. This 
provides for transparency and complianc e challenges to the operators, finally 
resulting in frequent violations and uncle ar situations to the crew involving hazard 
of mid air collisions. 
• Lack of common specifications for ne w technology lead to observed major 
implementation problems for urgently requi red hardware: While the airworthiness 
of state of the art Collision-avoidance e quipment following the tragic Überlingen 
and Linate accidents could be ensured by EASA, it was found that the interoperability level of such equipment hence their actual use was very limited. The interoperability specifications are gi ven at national level only, as no European 
level competence exists in this area. 
Beside the actual immediate lack  of safety emerging from thes e, in general any lack of 
harmonised ATM and aerodrome procedures turns in to a lack of transparency to the aircraft 
operator, creating another area of safety defi ciencies. Therefore, identical signs, signals, 
markings, communication pro cedures etc are required. 
All in all, the diff erent endeavours to harmonise pr ocedures and to improve this 
situation could create some achievements, but the systemic and inherent weakness of 
lack of regulatory functions within the curren t fragmented system lead to aviation safety 
rules in Europe still falling short of adequate harmonisation and enforcement considerations in two fundamental components of the global aviation safety system, and 
precisely in aerodromes and ATM/ANS. 
2.3 Conclusion and justification of intervention 
The current high European safety performan ce is achieved by the collective efforts of a 
professional, highly skilled and safety c onscious workforce and safety framework.  
                                                
 
32 A prominent and illustrative example of frequent non uniform compliance co mes with the surfaces 
adjacent to aerodrome runways and related obstacle criteria. As those criteria tend to imply severe 
safety but also certain economical impacts to  aerodromes, a huge variety can be observed. 
Consequently, with regard to competition among aerod romes, this can lead to a distorting effect. 
EN 17   EN However, the challenges descri bed above call for more than th e preservation of the safety 
level achieved, they call for an improved safety performance. This improvement is urgently required using related orchestrated and harmoni zed mechanisms as well as common resources 
in order to also achieve necessary quick wi ns. Refer to Annex 1, figure 2.3 which illustrates 
related factors of threat to European aviati on safety as mentioned in the sections above. 
Hence, it is increasingly recogni zed that air transport safety st rongly requires a holistic, total 
system "gate-to-gate" approach which also integrates ATM/ANS and aerodromes. Such a 
total system approach shall c over all involved in the safety process - people, procedures, 
equipment and organisational stru ctures. It can eliminate risk s of safety gaps, conflicting 
requirements and confused responsibilities a nd may reduce burden on the regulated persons 
by streamlining approval processes. Specifically in the area of ATM/ANS this is well adapted 
to the regulation of future systems, where eq uipment on the ground, on board  aircraft or in the 
space link together and constitute a single sy stem providing or supporting the provision for 
services essential to ensure the safety of air traffic.  
As above, this identifies th e strong demand for a common inte rvention above na tional level, 
whilst making use of the framework and competen ces at national level in compliance with the 
principles of "better regulation", especially  as regards proportionality and subsidiarity. 
Therefore, and in accordance with the Treaty, the Commissi on shall lay down measures to 
improve transport safety.
33 In this context the Commission shall submit a related legislative 
proposal to the European Parliament and the Council.34 
The High Level Group referred to under section 1.1, sees the continuation of improvement as 
one of the key challenges for European aviati on and requests safety to be aligned with the 
market growth35. Particularly, the "patchwork of respons ibilities and regulato ry structures" is 
addressed36, leading to one of its recommendati ons to "develop EASA into the single 
instrument for aviation safety regulation"37. Also, the HLG saw the total system approach as 
the cornerstone of that framework and r ecommended that safety regulation should be 
conducted independently from other forms of regulation and that a ll safety regulatory 
activities should be dealt with under the to be established holistic safety system. Very 
importantly, the HLG gave strong recommendations on the application of the Better Regulation agenda in the future aviation regulatory framework, c ontaining such vital 
principles as proportionality, subsidiarity, best allocation of roles and consultation. The 
Agency is already today fully governed by these principles, as demonstrated e.g. by its formal 
rulemaking procedure.  
Moreover, this approach is supported by the findings of the "Agenda for 2010"
38. From here it 
becomes apparent that the regulatio n of key safety factors is an integral element of the future 
of European aviation framework, to be insepa rably linked to the Single European Sky and 
SESAR initiatives. 
Furthermore, the imminent demand for change also is illustrated by Regulation (EC) No. 
1592/2002 on the establishment of EASA, which alr eady mentions the foreseen extension of 
                                                 
33 ref. Treaty establishing the European Co mmunity, part three, Title V, Art. 70f 
34 ref. Treaty establishing the European Community, part four, Title I, Art. 251 
35 ref [3], page 3 
36 ref. [3], page4 
37 ref. [3], page 31ff 
38 ref. [1], page 4ff 
EN 18   EN competences of the Agency to other areas in the field of civil avia tion safety, under the 
supervision of the Commission and in line with the Treaty.39 
Appropriately, the stakeholders  strongly confirmed the need for change, as indicated by 
consultations performed in the course of the Preliminary Impact Assessment and the 
subsequent EASA consultation processes.40 
Based on this broad consensus and the relate d political commitment , any other line than 
integrating the aerodrome and ATM/ANS regula tory competence into the remit of EASA 
would have to be seen as de viation from the commonly future  approach to a systemically 
improved safety system. 
For clarification purposes, it should be pointed out that the findings above pertain to those 
aerodromes which serve as platform for commer cial traffic and show ATM relevance, while 
very small aerodromes used in the recreationa l sector are much less affected by the given 
rationale. This will be explained in  more detail in section 4.2.1 below.  
3 OBJECTIVES 
The overarching objective of the proposal is to extend the syst em conceived to ensure the 
safety of transport by air in the EU to aerodrom es and ATM/ANS, i.e. to those two sectors of 
the total system which are not regulated to th e level required by the challenges of rapidly 
growing air traffic. 
Identified objectives of this intended measure ca n be classified according to the three levels 
normally used by the Commission services  for impact assessment, such as: 
• The general objectives, which represen t the overall wide policy goals;  
• The specific objectives, which are the more imme diate objectives of th e planned legislative 
initiative contribu ting to achieve the overall objectives; 
• The operational objectives, which are related to the precise outputs of the proposal and 
which can then be assessed or even measured by appropriate indicators. 
3.1 General Objectives 
General societal objectives of the European Commission as describe d in the Commission’s 
work programme and the Annual Policy Strategy41, in turn broadly based on the Lisbon 
strategy, which is, with regard to the project in question, to  put Europe on the track of 
prosperity, which, in addition to building an internal market (com prehensive of facilitation of 
labour mobility) based on fair competition, also comprises greater efficiency and effectiveness of the transport system, and to offer citizens, including aviation passengers the 
same high level of protection. 
Overall, safety is regarded the dominant aspect as the measure in subject focuses on fostering 
aviation safety. However, it should be stressed that safety matters are not followed for their 
own safety sake, but for the imp lications of increased safety which touch on the scope of the 
                                                
 
39 ref. Regulation (EC) 1592/2002, recital 2 
40 ref. [2], page 15ff and 35ff, ref. [5], 27 f, ref. [13] 
41 ref. http.//europa.eu.int/comm/atwork/programmes/index_en.htm 
EN 19   EN Lisbon strategy: Social and economical elements , sustainable developmen t, internal market 
development and, though to a limited effect only gi ven the nature of the project, environment. 
It is in this light that the safety of air transp ort is stressed as being a crucial element of these 
objectives. 
3.2 Specific Objectives 
The specific objectives are relate d to specific air transport objec tives, which are also followed 
by other initiatives such as the creation of a Single European Sky. More in detail these 
specific objectives can be identified in th e White Paper on the Euro pean transport policy 
published in 2001 and its mid term review published in 200642. The proposed measure is 
closely related to some of these specific objec tives, of which those applicable are summarized 
below: 
• Establish and maintain a high uniform leve l of civil aviation safety in Europe; 
• Perform "Better Regulation"; Reduce the co sts connected to safety regulation; 
• Complement and support SES and SESA R by enhancing safety elements; 
• Ensure most efficient use of aerodromes and airspace for all stakeholders by introducing 
common rules; 
• Facilitate evolution of t echnology by timely application of appropriate regulatory 
functions. 
3.3 Operational Objectives 
The operational objectives are strictly related to the concrete actions triggered by the 
proposal. As such their output is observable or ev en measurable and can be directly attributed 
to the action carried out. These observable/ measurable operational objectives are: 
• Enhanced aviation safety by the establishmen t of harmonized, binding  safety rules based 
on improvement of the existing rules and pr ovisions (SARPS, GASR works, SES). This 
uniform set of rules will be proportionate a nd will establish an op timum balance between 
binding rules and best industr ial standards as appropriate means of compliance; 
• Enhanced aviation safety by completing th e regulatory loop and by establishment and 
implementation of appropriate  certification, standardisat ion and oversight activities; 
furthermore by establishment of measures pr oviding for the Enforcement of compliance 
with the rules; 
• Enhanced aviation safety by establishment of a highly skilled and efficient working 
organisation; 
Hereby it should be underlined that the proposed  measures will be closely based on existing 
legislation as mentioned, while providing impr ovement compared to this where and if 
necessary. 
                                                 
42 ref. "Keep Europe moving: Sustainable mobility for our continent", COM 314/2006, 22 June 2006 
EN 20   EN 4 POLICY OPTIONS 
4.1 General 
This chapter describes policy options that are available in theory in order to single out the 
most appropriate vehicle to develop common ru les and ensure their uniform application as 
well as appropriate standardisa tion, oversight and enforcement of  compliance with rules in the 
fields of aerodromes and ATM/ANS. A comparativ e analysis of the options will take into 
account the findings indicated in section 2 whic h have clearly shown that the non-regulatory 
approach used so far is not adequate to face the safety challenges stemming from the aviation 
trends. The impacts created by those alternative po licy options will be assessed in detail in the 
subsequent chapter 5.  
Following this rationale, the policy opti ons that have been discerned are: 
• Option A: ‘Do nothing’: Continue with pres ent organisation of responsibilities. This 
options serves as the reference situation; 
• Option B: Extend the EASA safety system  of rulemaking, certif ication, licensing, 
standardisation and oversight to th e domains of aerodromes and ATM/ANS 
• Option C: Extend the process of EUROCONT ROL mandates issued by the Commission 
to the domains of aerodromes and ATM/AN S (including certification and inspection 
responsibilities); 
• Option D: Establish a new Agency responsible for aerodromes and ATM/ANS; 
• Option E: Extend the EASA system as far as option B, but to include also other 
regulatory or service provision functions. 
Each of these policy options is outlined from section 4.3 onwards. First, by section 4.2 the 
affected scope of competence will be detailed. 
At this point it should be explic itly stressed that the intended  measure does not concentrate on 
the development and enactment of entirely new safe ty rules, but rather intends to promote the 
harmonisation and enforcement of uniform rule s throughout the Community. Hence, it is not 
intended to "reinvent the wheel" but to make use of existing voluntary standards or rules, 
namely the ICAO SARPS and GASR43 works and the existing SES and other ATM/ANS 
related rules mentioned above. Also, the exis ting regulatory bodies at  national level will 
remain largely unaffected by the measure, as their scope of competence for oversight and certification will not be interfered with by the m easure. Thus, it is expected that the remit of 
Member States' bodies such as aerodrome aut horities and National Supervisory Authorities 
(NSAs) will remain substantially unchanged. 
The options are based on the Preliminary Imp act Assessment and take into account the 
conclusions achieved by the c onsultation processes performed by EASA. This focuses more 
on the aerodrome safety part of the project as the Community has not yet legislated in this 
area. 
                                                
 
43 "Group of Aerodrome Safety Regulators"; inform al working group encompassing 28 States putting 
effort into improving aerodrome rela ted rules; ref. to figure 2.2.2.2 
EN 21   EN The EASA RIA, to a certain degree, deals with t echnical impact matters which rather relate to 
and will be further developed by future Implementing Rules. Th erefore, the RIA will not be 
fully reflected at this stage, which shall merely  deal with the overall competence extension, i. 
e. the focus is mainly on the question "if  to do" rather on "how  to do" it, as per above 
However, related potential developments are referred to if and where needed.  
As regards the ATM/ANS safety regulation, a shor ter analysis is required, since this domain 
is already the subject of Community rules and very closely linked to the existing SES 
legislation and the SESAR initiative. Followi ng the same rationale as applied for the 
aerodrome part above, potential variations of the execution of the regulatory competence with 
r e g a r d  t o  A T M / A N S  w i l l  n o t  b e  i n  t h e  f o c u s of the assessment, but  the question of the 
regulatory competence itself. 
4.2 Affected areas of competence and responsibility  
Before elaborating on the indi vidual policy options, the areas  affected by regulation of 
aerodromes and ATM/ANS are detailed below.  They correspond to th e three pillars of 
regulation forming the circle of proper regulato ry action and of its qual ity assurance within a 
safety system. 
For clarification purposes, it s hould be pointed out that the lis t of aspects covered under the 
areas of air navigation services , air traffic management and aerodromes, does not imply that 
in one of the policy options EASA (or a differe nt organisation as propos ed by the option) will 
carry out or provide such service itself. Th e responsibilities of the intended measure will 
purely be limited to the safety re gulatory circle and will include preparation of safety related 
rules, certification (where appropriate) as well as standardisation inspection, so clearly 
maintaining the principle of “separation” between regulation and operational activities, 
already well established in the EU aviation legislation. 
4.2.1 Aerodromes 
For the aerodrome part, the aerodrome related definitions shown below will be taken into 
account, again leading to a rela ted affected scope of respons ibilities with regard to 
infrastructure and operation. This definition is in line with the definition used in other parts of 
EU legislation and based on the ICAO definition44: 
• Aerodrome  means any especially adapted area on land, water or man made structure or 
vessel, for the landing, taking-off and manoeuvr ing of aircraft including the aerodrome 
equipment, installations and services, wh ich these operations may involve for the 
requirements of aircraft traffic. 
• Open to public use  means aerodromes which are include d in the official Aeronautical 
Information Service (AIS) publication and offe r services not to a defined group of users 
only but to any user without di scriminatory access provision. 
Based on those definitions, the variety and scope of aerodromes affected by the intended 
measure needs to be illuminated: 
                                                 
44 ref. to [5], page 6 and [7], page 49 for details on the evolution of this definition 
EN 22   EN Within Europe, currently about 700 aerodrom es exist serving commercial traffic and 
operating under Instrument Flight Rules (IFR), wh ich are typically referred to as "airports".45  
2145 aerodromes are included cu rrently in the EUROCONTROL data base used for 
Aeronautical Information Service.46 Therefore, all these aerodrom es are open to public use. 
The consultation and impact assessment perf ormed by EASA clearly indicates that 
aerodromes not open to public use should not be included in the scope of European regulation 
due to the transparent lack of both justification and added value for safety.47 Therefore, this 
subset of aerodromes is ruled out at this stage.48 
The fundamental question that needs to be addressed is whether all these 2145 aerodromes 
should be affected by the proposed measures of whether this should be limited to those 
aerodromes mostly or even exclusively servin g commercial air traffic to include passenger 
operation. In short, should 2145 or rather only 700 "big" aerodromes be subject to European 
rules. Annex 1, figure 4.2.1 indicates the different  aerodrome criteria an d their typical frame 
characteristics as well as their total numbers in Europe. 
In fact there is no doubt about the fact that t hose aerodromes with infrastructure capable of 
serving commercial passenger service should be regulated. These aerodromes must be capable 
of adverse weather operation and therefore are dependable on Instrument Flight Rules (IFR). 
As indicated above, the number of such aerodromes in Europe  is 700, while thousands of 
smaller, non-IFR aerodromes exist which are not us ed by large aircraft but nearly exclusively 
by recreational flying and other el ements of general, non commercial aviation with very small 
aircraft. 
Those 700 IFR aerodromes are affected by signif icant traffic growth, and have substantial 
interfaces with ATM/ANS services. Furthermore,  the accident and incident data provided in 
section 2.2.1 imperatively calling for mitigating actio n strictly pertain to the operation of such 
aerodromes only, while the safety of recreational and general aviation seemingly is much less 
affected by related small aerodrom es. Taking is as we ll as principles of  "better regulation" 
like proportionality and esp. subsidiarity into account, no safety driven need can be seen to 
include non-IFR aerodromes in the scope of the proposed measure.49 
Therefore, it is proposed th at for the time being, only those (today about 700) aerodromes 
open to public use and serving IFR procedures sh ould be made subject to the suggested scope, 
                                                 
45 ref. [7], page 52 
46 ref. [7], page 53 
47 ref. [7], page 54ff 
48 Beyond the figure of 2145 aerodromes open to public use it is estimated that a total of up to another 
3000 aerodromes exist throughout Europe. However, those to a vast majority pertain to the 
"recreational" sector mentioned above which will not be  subject to European regulation. Others of such 
3000 aerodromes do not oper ate in a way which is regularly accessible to public use. 
49 It should be noted that in the fields of airworthiness, operations and licensing Community regulatory 
competence is established also for general aviation. Whereas this could suggest to include related 
aerodromes in this scope, it must be found that other than the sectors above small aerodromes, owing their stationary character, do not interfere with "bigger" commercial operation and show, besides, a 
positive safety record. Hence, an air safety contributio n by those smaller aerodromes to the operation of 
typical air carrier operation as well as to ATM/ANS issues can not be identified. Furthermore, it should be stressed that the largest number of those aerodro mes largely or even exclusively serves aircraft 
operation even outside the existing scope of Eu ropean Community competence (i.e. microlight 
operation etc.) 
EN 23   EN leaving the smaller and non-IFR aerodromes in th e remit of national aviation regulation. This 
regulation may be based on related guidance material which may be developed by EASA. 
4.2.2 ATM/ANS 
In this Impact Assessment the definitions of Air Navigation services, Air Traffic Management 
and Air Traffic services as laid down in Re gulation 549/2004 on the SES framework will be 
applied, which clearly triggers th e scope of responsibilities aff ected by the intended measure, 
in terms of both infrastructure and operation. These definitions stipulate50: 
• ANS being composed of: 
- Air Traffic services,  
- Communication (COM), Navigation ( NAV) and Surveillance (SUR) services, 
- Meteorological services (MET), - Aeronautical Information services (AIS). 
• ATM means the aggregation of Air Traffic se rvices (ATS), Airspace Management (ASM) 
and Air Traffic Flow Management (ATFM) (to include related airborne and ground 
systems). 
• Air Traffic services (ATS) contains flight info rmation services, alerti ng services, air traffic 
advisory services and air traffic control serv ices (area, approach and aerodromes control 
services).
                                                
 
50 ref. Art. 2 of "Framework Regulation for the creation of the single European sky", Regulation (EC) 
549/2004, 10 March 2004 
EN 24   EN 4.3 Option A: "Do nothing" 
This option considers a continuation of the presen t situation. This situa tion has been described 
in chapter 2 in detail and has lead to the co nclusion that "business as usual" can not be 
retained since there is a comp elling need for improvement. Ther efore, the ‘Do nothing’ option 
serves as reference and benchmark for the other policy options. 
4.4 Option B: Extend EASA competences 
The adoption of the initial "B asic Regulation" (EC) No. 1592 /2002 paved the way for a new 
Community system of air safety  and environmental regulation. 
This second option considers the extension of EASA's tasks to the areas of aerodromes and 
ATM/ANS, by an amendment to the Basic Regulation. 
The Regulatory Impact Assessment (RIA) pe rformed by EASA dealt with potential 
variations, which also could be looked at as sub-opti ons of this option i ndicating potential 
impacts in different fields triggered by possibl e provisions of future Implementing Rules. 
Some of those variations include the scope of aerodromes which was addressed in section 
4.2.1 above. Variations of the scope  and procedures for certificati on of affected aerodromes as 
well as details of certification criteria will form the content of the Implementing Rules which will be prepared by the Agency and a dopted by the Commission through comitology 
procedure, following another extensive consul tation and fully fledged impact assessment 
process.  
4.5 Option C: Extend EUROCONTRO L mandates issued by the COM 
This policy option is to extend the current fi elds of mandates to EU ROCONTROL, which are 
limited to the drafting of SES related rules, to cover the complete set of safety related rulemaking in the aerodrome, ATM and ANS field. EUROCONTROL was chosen for this 
option as it is prominent among the European bod ies listed in secti on 2.2.2.2 having a kind of 
rulemaking preparatory function through SES manda tes. Hence, it already has, to a limited 
degree, a formal function within the European  framework. Furthermore,  the development of 
rules proposed by EUROCONTROL follows processe s very similar to the ones used for the 
preparation of Implementi ng Rules proposed by EASA. 
Many of the affected responsibilities, especial ly in the aerodrome sector, would represent a 
new domain for the organisation, while some others are touched alr eady in the light of 
ESARR and SES related work. 
For the purpose of assessing this option, it will be assumed that the administrative procedure 
within EUROCONTROL to prepare and support rule s in this option would be the same as for 
the current mandate to develop the SES Implem enting Rules. This is different from the 
procedure used to adopt the ESARRs, which n eeded to be approved by the specific decision 
mechanisms of this international organisation. 
4.6 Option D: Establish a new Agency 
Rather than extending the mandates to  EUROCONTROL or extending the EASA 
competences beyond its current scope, another theoretical policy option to address the 
EN 25   EN competence in question would be to create a fully new Community Agency with specific 
regulatory responsibilities in the areas of aerodromes and ATM/ANS. 
Following the path of other Community Agencies  as EASA, this would be a Community body 
governed by the applicable legal framework of  EU and having its own legal personality. It 
would be set up by an act of secondary legislat ion defining clearly it s scope and advisory 
and/or regulatory role. 
This option was developed starting from the pr eliminary impact assessment in 2005, and is 
regarded a logical, necessary element to perfor m the complete assessment required. However, 
it should be noted that such option may not be vi able with regard to most recent Commission 
policy development towards Agencies. Nevertheless, this option shall be fully examined in order to prevent a potentially meaningful op tion from being ruled out solely on policy 
grounds. 4.7 Option E: Extend EASA competences  and include some other functions 
This option is referred to for th e sake of consistency and completeness, as it was developed by 
the preliminary Impact Assessment, following the idea of performing as specified under option B, but also including the provision of  other additional functions by EASA. Those 
functions were understood to possibly reflect areas  of paramount public interest, necessity of 
separation of regulator and pr ovider and areas pot entially deserving imp roved efficiency, 
hence this option could incur a set of ec onomical and safety related incentives. 
These functions could contai n, but are not limited to: 
- Performing Research and Development (R&D) 
- Technical training - Rulemaking for accident and incident  data collection and investigation 
- Development of contingency plans - ATM/CNS development planning and coordination - R&D coordination; - Airspace design; 
- Flow management 
- Charge collection However, the preliminary Impact Assessment cl early indicated that this option was less 
favourable for a variety of reasons.
51 Moreover, many establis hed fundamental Community 
regulatory policies would also have to be ch anged if such approach would be chosen. 
Therefore, and as this opti on goes beyond the actual scope of  the intended measure to be 
assessed, this option will not be ha ndled with in more detail but w ill be ruled out at this stage. 
                                                 
51 ref. [2], page 57ff: Concerns such as reduced efficiency, negative cost impact and duplication lead to 
the understanding that this option was not suitable;  furthermore it did not receive the support of 
stakeholders. 
EN 26   EN 5 ANALYSIS OF IMPACT OF ALTERNATIVE OPTIONS  
Below, the impacts of the extension of EASA competences and the ot her policy options are 
determined towards the "do nothing" option A that  serves as a reference line and benchmark. 
The assessed impacts are grouped into safety, ec onomical, environmental, social and others. 
These fields of impacts, which are derived from the Commission impact assessment 
guidelines, should be given different  appraisal factors, as certainly the safety factor  shall be in 
the focus of the aviation safety measure in quest ion and shall be regarded  the driving issue.  
Regards the economic factor, it should be pointe d out that, as detailed  in section 2.1 above, 
actual economic burden or benefit to stakehol ders emerging from potential later rules are 
beyond possible assessment now. Therefore, the present repor t focuses on the economical 
effects of the actual measure, i.e. the shift of regulatory competence and its related, rather 
qualitative economic effect to the market.  
Furthermore, with regard to the administrative cost, by centralising th e effort in terms of 
rulemaking an overall saving will be reached. Th is rationale applies to both personnel and 
related administrative cost. Note that certificat ion and oversight relate d administrative cost 
remain unaffected by the measure, as this leaves the on-site execution to the Member States. Therefore, in this Impact Assessment Report th e administrative costs will not be scrutinized 
by a standardized Excel sheet typically referred to by Commission servic es, as the necessary 
detail required by such exercise  will emerge from the enactment of individual Implementing 
Rules which will follow the adoption of this  proposal. Those Implementing Rules, whose 
results must not be made subject to the current analysis as they are still open, will undergo a 
full scale Impact Assessment and consultation at appropriate place and time. At this stage, the 
cost figures pertaining to the EASA system as  established will be used as validated grounds 
for the related cost effort to be expected by the measure 
Looking at the environmental impact, it should be  understood that enviro nmental standards of 
aerodromes are not subject of the measure in question but will form  part of a related 
independent proposal, the content of which is the subject of a separate assessment presently 
carried out by EASA. Hence, the overall enviro nmental contribution of the measure is limited 
to the results of the regulatory competence, le aving aside actual consecutive technical rules 
which render the environmental aspect a side aspect only. 
5.1 Option A: "Do nothing" 
5.1.1 Safety impact 
Without any mitigating measures in the field of aerodromes and ATM/ANS, the air safety in 
these high risk areas will be significantly affected by the combination of traffic growth, congestion and inevitable progressive penetratio n of new technologies in  the aviation sector. 
The existing safety level, which would pr oduce unacceptable numbers of incidents and 
accidents even if unchanged, would inevitably deteriorate. Facing this development over the years, a significant adverse safety impact would have to be expected. 
5.1.2 Economic impact 
The negative development in th e paramount criterion of safety will have a direct and major 
negative economic impact due to the forecasted hi gher accident rate (refer to Annex 1, figure 
EN 27   EN 2.2.1 indicating the significant cost incurred by av iation accidents). Furthermore, European air 
transport would suffer competitiveness drawbacks as it would be prone to loose its leading 
position regards safety aspects. Taking the signifi cant role of air transport for the aggregated 
economical progression into account, and looking at the objectives as per section 3, the overall economical impact is assessed to be significantly adverse.  
5.1.3 Environmental impact 
No environmental impact by this option is visible,  apart from the remote consideration of very 
limited ecological damage following accidents. 
5.1.4 Social impact: 
By doing nothing to defeat the European air safe ty challenges, a negative social impact would 
emerge from the lack of achievement of the pr ime goal to prevent the loss of lives and related 
major damage by air traffic accidents. Beyond that  important matter, the adverse effects to 
competitiveness and attractiveness to the globa lly working aviation market is expected to 
provoke negative job growth impacts on the European aviation market, though certainly not quantifiable at this stage. 
5.1.5 Other impacts: 
Other impacts are not foreseeable, which include s those impacts listed for the options below 
which are not applicable in the "do nothing" option regarded here. 
5.2 Option B: EASA extension 
5.2.1 Safety impact 
In general, extending the EASA mandate from the current areas - airworthiness, 
environmental compatibility, air operations, crew licensing and safety of third country aircraft 
operating in Europe - to the regulation of aerodromes and ATM/ ANS would lead to a 
significant improvement from a safety perspective, as it would constitute an integrated, total 
aviation safety approach  that ensures interoperability, harmonised rules and most efficient 
transition of voluntary, non uniform  safety standards into Comm unity rules via a complete 
and controlled regulatory system . It would also be fully in line with the established aviation 
regulatory policies of the Community to separate  regulation from service provision and to 
ensure the independent role of safety regulatio n from other modes of regulatory actions, such 
as economic regulation and mana gement of scarce resources. 
This integrated and truly holistic approach towa rds aviation safety is also crucial since the 
future aviation system will head for a gate-to-gate  concept, with future characteristics such as 
stronger integration of the air side of aerodromes into th e ATM system, close integration and 
even amalgamation of some ground based and air-bor ne roles related to di gital data exchange, 
collision avoidance and aircraft separation and inclusion of ground movements on the apron 
and taxiways. Furthermore, high traffic densities require integration of safety procedures for 
surface movement and arrival/departure mana gement, as well as for flow and capacity 
management. This necessity would be fully reflected by the present option. 
Also, the process of timely conversion of regul atory proposals into co mmunity law is well 
served by the extension of EASA competences , since EASA is fully integrated in the 
regulatory process of the Eur opean Commission and is empow ered to adopt certification 
EN 28   EN specifications and acceptable means of compliance itself. Furthermore enforcement and 
standardisation inspections mechanisms  already in place in the current EASA system could 
easily be extended to these new areas. 
Regulatory gaps as well as overlaps , as existing today would be eliminated by a sole EASA 
rule making and certification. Wh en the responsibilities of the re gulatory system for all parts 
of the aviation domain are in EASA hands, a uniform and high level of safety in 
aerodromes and ATM/ ANS safety  can be achieved across the domains and across the 
Member States countries. 
By following this option, EASA could develop a nd enforce compliance with uniform sets of 
safety rules for the whole aviation domain whic h would be beneficial as there would be a 
reduced amount of interfaces . 
Since per this option all aviation safety matters  would be contained w ithin the EASA system, 
this option provides also for an optimum knowledge management  solution with regard to 
possible interchange and reference. 
Furthermore, by the separation of the regula tory function from th e service provision as 
mentioned above this alternative would come free of a potential conflict of interests . Also, it 
would allow for political arbitration between conflicting objectives to take place at the appropriate political level. 
All in all, the introduction of  a common regulatory framework is expected to reveal a key 
improvement for the overall safety level. Taking the above mentioned key safety 
improvements into account, the strong point of the extension of EASA competences is 
the introduction of a common approach across the whole safety system, fully integrated 
into the Community policy and inseparably embedded into the Single European Sky 
initiative . 
Those very positive findings remain valid for all possible variations of this option as assessed 
by the RIA
52. 
5.2.2 Economic impact 
Though certainly not accurately quantifiable at this  stage, an improved safety record resulting 
from the impact of a complete and efficient safe ty regulatory system in  European aviation will 
lead to economical benefits for the involved market players as ai r carriers, airports and service 
providers, all emerging from an increased competitiveness, attractiveness, as well as less accident related cost. Details of this positive im pact could be given only by future experience 
on related cost savings due to reduced acciden t/incident rates and the budgetary consequences 
of future Implementing Rules, if and where appl icable. The latter will be subject to a complete 
Impact Assessment at the time of their submission to the Comitology process. 
With regard to the economic effect created by the overall administrative effort emerging from 
this option, the considerations below should be taken into account:  
• Aerodromes: 
                                                
 
52 ref. [7], page 49ff 
EN 29   EN In the course of the IS-SG consultation, a preliminary cost impact analyses was 
performed by the Commission with regard to the administrative cost incurred by the 
regulation of aerodromes by DG TREN.53 This work scrutinized the related 
regulatory action into indivi dual subparts and attached as sumptions of effort and 
frequencies to those. Overall, a 10 step a pproach has lead to a potential, indicative 
picture of related ad ministrative cost.  
In particular, this applies to the number of affected aerodromes, for which the 
analysis assumed three scenarios: 500, 1000 or 1500 affected aerodromes, for each 
scenario a sensitivity analysis and cost  impact assessment was performed. The 
number of aerodromes affect ed by the intended measure will  be in the area of 700 as 
detailed in section 4.2 above. 
Therefore, the basic rationale of the cost  analysis as performed by the preliminary 
assessment can be used for this assessment, by interpolating the results of the 500 and 1000 scenarios: 
• By assuming an average number of aerodrome regulatory personnel between 2 
and 6 Full Time Equivalent (FTE) per Me mber State currently occupied with 
aerodrome rulemaking as assessed in the above mentioned analysis
54: 
• The sensitivity analysis shows that the EASA extension to aerodromes would be 
more economical in all cases between those 2 and 6 FTE, with major annual 
savings compared to the current effort of the Member States, depending on the 
actual number of FTE assumed. The wide ra nge of FTEs and incurred savings are 
explained by the fact that, while rule making would be performed by EASA, the 
certification and regular oversight still would remain in the remit of the national authorities. With the developing aviation market it can not be ruled out that 
personnel currently working in the rulemaki ng sector would be realigned to those 
certification or oversight areas. However, this  effect rather should be attributed to 
national adjustments to the new situation rather than a redu ced saving created by 
the measure. 
• This indicates the relation of savings co mpared to the actual cost: With a cost 
estimate between 5.2 and 13.2 Mio €/a, the measure was assumed to lead to an 
effort between 3.4 and 5.5 Mio €/a. Theref ore, the saving of administrative and 
substantial cost is assume d be in the area of around 50 % of the current level 
(Refer to Annex 1, figure 5.2.2). 
• Those figures are obtained assuming a total of 17 additional EASA personnel 
needed for rulemaking, sta ndardisation and overhead.
55 This fully matches the 
figures of the Preliminary Impact Assessment56 which have been used for the 
EASA Business Plan approved by the Management Board of the Agency.57 
                                                 
53 ref. [10] 
54 ref. [10], step 9 and 10: Assessment  of affected entities and extrapolation 
55 ref. [7], page 59ff and ref.[10], Step 9 
56 ref. [2], Annex D, page 40ff 
57 ref. EASA Business Plan 2008-2012 
EN 30   EN • With regard to the total EASA related cost, an update  of the calculation above 
using the EASA Business Plan tool (avera ge cost per EASA employee to include 
overhead, infrastructural and travel cost  amounts to 140 000 € annually) is even 
more illustrative: Based on this figure, the expected 17 additional personnel would 
lead to an increase in ad ministrative cost for EASA of 2.380.000 € annually. This 
substantially corresponds to the resu lts of the analyses performed by the 
Preliminary and Regulatory Impact Assessm ents, which arrives at slightly higher 
annual costs of about 3 Mio. €.58 
• A stated in section 5 above, the assessm ent of actual economi c burden or relief 
created by later rules will be performed during the impl ementation level of those 
rules and, as being not feasible, is ex cluded from the scope of the present 
assessment. 
• However, by the above it become s visible that the indicated level of effort will not 
come with an overall affection to airport charges, or, following this vein, airline 
tickets or change in the traffic development. For example, German airports alone collect a total of about 1500 Mio. €/a, so the administra tive effort indicated above 
must be regarded comparatively minimal. Ho wever, as a cost increase is ruled out, 
a negative impact in that sense is not foreseeable.  
• ATM/ANS 
As mentioned before, safety rulemaking as  one pillar of ATM/ANS safety regulation 
is currently performed by EUROCONTROL. This involves an estimate of up to 12 
personnel.
59 Using the same approach for the relation between rulemaking and other 
EASA personnel required for inspection and adjacent tasks as used for the aerodrome 
effort above, an estimate of 16 additional personnel for the ATM/ANS part can be assumed to be carried by EASA. The f our additional posts (as compared to 
EUROCONTROL) are created to fulfil th e standardisation inspection functions. 
Consistently, a related annual cost of the same order of  magnitude as above, i. e. of 
2.240.000 € can be expected.
60 
Taking into account these estimated total admi nistrative cost of 2.380.000  € for the aerodrome 
part plus 2.240.000 € for the ATM/ANS part and th e attached annual savi ngs compared to the 
status quo, the economic impact of this  option is assessed to be positive. 
                                                 
58 ref. [7], page 102f. This corresponds to ref. [2], which adds up the equal shares of aerodrome and 
ATM/ANS efforts arriving at 4.4 to 6.5 Mio. € as per Annex D, page 39. 
59 ref. [2], Annex D, page 40. Note that the estimated effort currently is not performed by employers fully 
assigned to the safety area, but related duties are split across the organisation.  
60 ref. [2], Annex D, page 39.  
EN 31   EN 5.2.3 Environmental impact 
In general, it should be pointed out that a centralization of regula tion and complete, highly 
effective and harmonized rule ma king action should provide for an  optimum platform to take 
into account future matters which are not direct ly affected by the intended measure. Hence, 
with regard to the environmental impact of th e extension of EASA, wh ile no direct link to 
environmental aspects exists, this option is rega rded beneficial on to p of the reduction of 
possible ecological damage by decreased accident  rates following improved air safety. This 
was also indicated by the former assessments.61 A negative impact to the environment is not 
foreseeable.  
5.2.4 Social impact 
The most meaningful positive social impact will be achieved by reduction of air transport 
casualties, injuries and damages.  However, as for the economical  impact above, this important 
social contribution can not be quantified yet. 
With regard to aerodromes a nd linked to the economical assessm ent above, the very detailed 
analysis performed by EASA, broken down in 5 di fferent areas, each w ith 3 variations of 
potential social impact depe nding on technical ways of im plementation, has evidenced a 
certain variety of possible social impacts, a ll with nearly exclusiv ely beneficial impacts.62 
The impact of the transfer of aerodrome safety rulemaking tasks from national administrations 
to EASA is expected to be minimal. Indeed  the number of staff in  charge of drafting 
aerodrome safety rules in each Member State is  rather limited and should be relatively easily 
effected to other functions. 
As for the ATM/ANS part, it is estimated that  12 persons are currently  occupied by related 
rulemaking action within EUROCONTROL. The imp act on these persons of the transfer of 
these tasks to EASA could vary depending on  the implementation options retained. These 
options might vary from "outsourcing" by EASA  of these tasks to the affected staff of 
EUROCONTROL to the direct employment of th ese personnel by EASA. Also, a realignment 
within the organisation could emerge from this situation. In total, it  is found that possible 
negative impacts to EUROCONTROL staff could be very limited or even nullified by close 
consultation between COM, EASA and EUROC ONTROL in the implementing phase of the 
measure.  
In addition, it must be pointed out that a remain ing adverse social effect to Member State and 
EUROCONTROL personnel would be overcompens ated by the EASA jobs covering same 
and additional duties and by the pos itive social, also job growth related impacts following the 
overall European air transport s timulation as indicated above. 
Thus, all in all the social impact of this opti on is expected to be po sitive, while a negative 
balance can be ruled out. 
                                                 
61 ref. [2], page 40 and [7], pages 70, 81, 87 and 95 
62 ref. [7], page 70ff, 81, 87, 96ff and 99f 
EN 32   EN 5.2.5 Other impacts 
Timeline : Regards the timeline of implementation hen ce effect of the measure in question, a 
period of transition for ATM/ANS matters  from EUROCONTROL to EASA would 
materialize. Furthermore, also for aerodrome matters the related staff would need to be built 
up and familiarized. However, those start up rela ted challenges would fall into the period of 
rule development and take place prior to th e active oversight and certification tasks.  
Third countries:  As the current ATM/ANS safety achievements performed by 
EUROCONTROL encompass non-EU Member Stat es, a shift to EASA could lead to 
"abandoning" those States. However, as most of those States are Members to EASA or signed 
an ECAA agreement, this effect would current ly pertain to the States of Moldova, Turkey, 
Armenia, Monaco and Ukraine only. However,  the Basic Regulation, through its Article 66, 
offers them the possibility to join the European safety system through the conclusion of 
specific safety agreements. Overall, therefore a negative impact to t hose countries therefore 
can be ruled out and no such effect is assumed to materialize. 
Furthermore, it can be found that the above  mentioned, significantly positive safety and 
economic are not limited to the Community Member States but will benefit also third countries' airlines and passengers.   
Civil-military interface : The proper co-ordination of the civil and the military side is of 
utmost importance to airspace management, calling for a stable civil-military interface when applying a change to the regulatory framework affecting this area.  
So far, this interface has been assured via coor dination at national level as well as through the 
Single Sky Committee (SSC). The transfer of ATM/ANS safety matters to EASA should be 
designed to ensure that negative impacts are avoided. This question is limited to the technical 
issue on how to ensure a proper coordination, which will be ela borated in the course of the 
implementation of this option. Therefore, whil e pointing out the need for an appropriate 
solution, the actual nature of this solution is beyond the scope of this assessment. 
5.3 Option C: Extend Eurocontrol mandates issued by the COM 
5.3.1 Safety impact 
Extending the EUROCONTROL mandate to the areas of aerodromes and ATM/ANS offers 
the advantage of keeping curren t ATM/ANS rulemaking expertise
 in place at 
EUROCONTROL. However, a number of drawbacks have been identified: 
• In the field of aerodrome regul ation, no regula tory experience  is available in 
EUROCONTROL. Therefore, this matter w ould form a totally new and unaccustomed 
subject of the EUROCONTROL remit. For EU ROCONTROL, this would mean to adapt 
the existing organisation which is tailored to ATM/ANS needs to integrate the very 
different aerodrome subject without being able to benefit from sharing in house experience  
pertaining to all other sa fety aspects of aviation. 
• This option would fall short of the total system approach  mentioned above, with a sole and 
independent safety body dealing with safety matters. All hazards emerging from interfaces  
with other safety players will occur. As airworthiness, operations and licensing matters are 
EN 33   EN subject to EASA competence already, this issu e forms an inevitable safety (and efficiency) 
drawback .  
• The tasks of inspecting and auditing Member  States as regards their obligation to 
implement Community legislation, are abse nt from the remit of EUROCONTROL. To 
change this situation would call for a substantia l change in the international system of this 
organisation. A task which is out of proportion with this objective whic h, as we have seen 
under option B, can be fulfilled by four persons.  
• Conflict of interest : EUROCONTROL today accommodates competence for service 
provision and rulemaking includ ing safety. These competences are functionally separated 
within the EUROCONTROL organisation to avoid any mix of interests and 
responsibilities. However, sin ce they remain within the sa me organisation a conflict of 
interest might arise which could be even seen in violation of the se paration requirements as 
per European law63. 
In total, the safety impact created by this option is assessed to be slightly positive. 
5.3.2 Economic impact 
With regard to the actual administrative cost, the option to extend the EUROCONTROL 
mandates is considered to follow in close analog y the costs calculated above for the option to 
extend EASA. After all, the distri bution of responsibilities between the central agency and the 
national level would be the same in both op tions. Furthermore, the salary levels at 
EUROCONTROL and EASA are very similar. Ho wever, due to the increased coordination 
effort created by the split into two safety bodi es a certain surcharge compared to option B 
would have to be expected. 5.3.3 Environmental impact 
Provided the related responsibilit ies are executed to the same qua lity as per the above EASA 
extension policy option, the impact to environment would follow the same rationale as described under sections 5.2.3. 
5.3.4 Social impact 
Beside the crucial positive social effects emergi ng from increased air safety as detailed in 
section 5.2.4 above, the social impact incurred by this option would show slightly beneficial 
as the up to 12 personnel mentioned in sections 5.2.2 and 5.2.4 would not be affected. However, as this would pertain to potentially required mobility only rather than to an actual 
decrease in employment, this impact is regarded  minimal, while in addi tion and as highlighted 
by section 5.2.4 this could also be mitig ated by proper transition arrangements. 
With regard to the personnel de aling with aerodrome matters, the same rationale applies as 
explained for the EASA option above, i. e. the small group of Member States staff is expected 
to be realigned within the individua l national Civil Aviation Authority.  
Hence, the total social impact by this option is regarded still slightly positive. 
                                                
 
63 ref. "Framework Regulation for the creation of the single European sky", Regulation (EC) 549/2004, 
and "Regulation on the provisions of air navigation services in the single European sky, Regulation 
(EC) 550/2004, 10 March 2004 
EN 34   EN 5.3.5 Other impacts 
Timeline:  Regards the implementation of the opti on, no effects are visible opposing a timely 
and fully adequate taking up of related duties. 
Third countries:  It is fair to assume that, to a certain degree, the positive safety and 
economic impact detailed above would still lead to a slightly positive imp act even in countries 
outside the European Community. The extent of th is effect will be determined by the order of 
magnitude of those triggering impacts, though. 
Civil-military interface:  As mentioned under 5.2.5 above, th is issue which attracted some 
attention by stakeholders raised  the question of the treatment of  related safety issues through 
the proper body and Committee. However, if a regulatory competence for aerodromes and 
ATM/ANS was given to EUROCONTROL, the imp act to the necessary solution of this 
matter would be neutral. 
5.4 Option D: Establish a new Agency 
In this section, the impacts of the option to es tablish a new, independent Agency are briefly 
benchmarked against the status quo.  
5.4.1 Safety impact 
Certainly, the establishment of a new Agency as a regulatory body on the areas of aerodromes 
and ATM/ANS is expected to lead to im provements in the overall safety level. 
However, as under 5.3.1 above and for similar reasons, those improvements would be very 
limited: 
• This new agency would exist beside EASA  and EUROCONTROL, which would create a 
triangle of distributed regulatory activities . Although all intended safety competence areas 
would be covered by one of th ese bodies, the aviation safety  system would suffer from a 
significant lack of efficiency  which would arise as the resu lt of having even an additional 
regulatory body. 
• Therefore, this option could not overcome the mentioned efficiency, integration and 
interface challenges .  
• In addition, as a fully new entity would be put in place, significant start up difficulties  with 
related performance degradation would have to  be expected. Furthermore, the building up 
of organic expertise would be aggravated by th e sole thus distant character of this entity, 
which does not provide for in-house knowledge exchange  and cross referring. 
For the reasons indicated above, the safety impact  of this option is assessed to be slightly 
negative. 
5.4.2 Economic impact 
Certainly, the establishment of a New Agency would lead to a decrease of multiplication in 
rulemaking activity and of existing overlaps  compared to the benchmark situation. 
EN 35   EN However, as again not being integrated into a total system approach by being responsible for 
the entire European aviation system, this achievement will be rather limited and does still provide an open door for reduced efficiency a nd duplication of related efforts and provisions 
in areas such as certification. The same applie s for harmonisation and interoperability issues. 
This effect would be very pronounced as the number of players hence interfaces would be 
even increased by the present option. 
Being forced to coordinate within a tria ngle between EASA a nd EUROCONTROL, the 
complexity of the attached decision making process also would be enlarged. A reduced 
efficiency and the inevitable higher overhead e ffort would lead to a strong limitation of 
possible cost reduction. 
Hence, similar to the findings in section 5.3.2, a va riation in cost due to the reduced efficiency 
of this option has to be foreseen, while a quantification of this effect is neither feasible nor necessary at this stage. 
5.4.3 Environmental impact 
With regard to this impact emerging from opt ion D, no significant difference can be seen to 
the general impact considera tion as created by options B a nd C as discussed under section 
5.2.3 ff. However, looking at the overall reduced efficiency of the option in question it is 
assumed that the slight beneficial impact pos sibly created by reduction of accidents would be 
nullified in this case. 
5.4.4 Social impact 
Again, a social contribution might  arise from a possible reductio n of accidents, a more healthy 
aviation market and related collective job grow th. Furthermore, option D does not include the 
advantage of making use of mana gement, administrative and suppor t staff already in service. 
Therefore, the total social impacts asse ssed for this option is regarded nil. 
5.4.5 Other impacts 
Timeline: The same consideration applies as  described in sections 5.2.5 and 5.3.5 above. 
However, as the set up of a discrete body requires additional effort thus time, this additional 
start up friction has to be taken into  account for the option in subject. 
Third countries: The slight positive safety im pact emerging from this option might provoke 
very minimal positive impacts in other countri es; however, as this option would not come 
with an additional economical element supporti ng this tendency, the overall impact of the 
option on third countries is regarded nil. 
Civil-military interface: Agai n, and for the same reasons as  stated under 5.2.5, this matter 
would have to be treated with  attention during the implemen tation phase of the measure in 
order not to provoke potential sa fety gaps by this interface. 
EN 36   EN 6 COMPARING THE OPTIONS 
In order to reach final conclu sions by isolating the most pref erable option, all the options 
above need to be compared to each other and their benefit balanced against the objectives listed in section 3. The table below provides an overview of the identified impacts as detailed 
in section 5 above, especially hi ghlighting the safety impact as  this needs to be given the 
highest amount of gravity. The given ratings in dicate the nature of the individual impact by 
following classification against the refere nce line established by the status quo: 
+ + + significantly positive 
+ + positive + slightly positive 0 unchanged - - - significantly adverse 
- - adverse - slightly adverse n/a not applicable 
Option A 
"Do 
nothing" B 
EASA C 
Eurocontrol 
mandates D 
New Agency 
Safety deteriorating 
level,  
not compatible 
with 
challenges  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
- - -  integrated, holistic 
approach 
 
 
high overall efficiency  
 
integrated enforcement 
mechanisms 
 
standardisation tools in 
place 
 
no interfaces problems 
 
 
separation regulation / 
service provision 
 
integrated knowledge 
management 
 
SES, community policy 
 
+ + +  improvement limited by 
disintegration of safety 
matters 
 
overall reduced efficiency 
 
enforcement legally 
open 
 
no standardisation 
platform 
 
persisting interfaces 
problems 
 
reduced separation of 
regulation and service 
 
split knowledge 
 
 
against policy 
 
+ +  as option C, but even less 
efficient as distinct from 
all other safety matters 
 
  
 
 
 
 
 
 
 
more interfaces problems 
 
 
 
 
 
knowledge management 
challenges 
 
against policy 
 
+ 
Economy - - high efficiency, best cost 
/saving ratio 
best positive impact to 
aviation market and 
economy 
 
+ +  
 
 
 
 
 
+  
   
 
0
 
Envmt - + + 0 
Social - - + + + 0 
other n / a 0 0 0 
EN 37   EN Looking at this comparison, and based on the reference line given by the status quo 
imperatively requiring action, firs tly it is pointed out that the assessment of option D 
(Establish a new Agency) revealed that it doe s not include any advantage over the options B 
(Extend EASA) or C (Extend EUROCONTROL mandates). In c ontrary, this option adds up 
the individual partial disadvantages incurred by the other two. Therefore, it can be excluded 
as clearly being inferior, limiting the furthe r, detailed comparison to options B and C. 
With regard to the safety impact , the option C suffers from the consequences of the failure to 
achieve a holistic approach. Option C will fail to provide standardisation inspections and enforcement of competence functions. It will maintain a split of safety competences between two organisations, EASA and EUROCONTROL. Th erefore, in spite of a certain degree of 
positive safety results option C is considerably weaker than option B. 
The same applies for the economical impact
, where the key cost figur es among the different 
options follow the same vein but are based on the very different efficiency results of those 
options. Hence, the option to extend EASA is supported by its higher ove rall efficiency, so 
receives higher scores for the incurred effects both with regard to cost and to general market 
development factors emerging from the measure.  This comparison of qualitative nature, while 
already providing a clear result, reflects the fact that air safety is hardly measurable and 
especially an economic and social quantific ation attached loss of  lives is regarded 
inappropriate. Instead, the figures below, based on conservative a ssumptions and on the 
figures provided in section 2.2 above, reveal a potential development of European air safety 
related cost: Starting from the average of 920 Mio. € of accident related cost per year incurred 
at global level, the European damage is caref ully estimated to be at 10% of that figure.64 
Taking the duplication of traffi c until the year 2025 into acc ount, and leaving aside the 
exponential effect of related risk growth, the resulting accident figures should be multiplied 
by 2, arriving at 184 Mio. € of annual economic damage in Europe. The total contribution to 
that figure emerging from aerodrome and ATM/ANS safety is assumed to be in the area of at 
least 10% each, thus for each of those sector s an average annual economic damage of 9,2 
Mio. € (today) and 18,4 Mio. € (year 2025, followi ng the "Do nothing" option) is assumed. 
The estimated annual effort for option B in  the area of aerodromes (2,380 Mio. €) and 
ATM/ANS (2,240 Mio. €) i ndicates the minor nature of the e ffort compared to the potential 
saving of accident related damage.  
The same applies for option C; however, a justif ied quantification of the reduced efficiency 
incurred by this option must be taken into a ccount by 10% reduction of effects on the safety 
side and another 10% increas e of organisational effort. 
Following this very conservative comparison, only  a slight safety improvement created by the 
measure will lead to an economic "break ev en". Annex 1, figure 6 indicates a related 
sensitivity analysis. 
A key difference of the two opti ons appears for the social impact . While both options create 
positive effects due to the safety and economical impacts – again reduced in the case of option 
C – this EUROCONTROL option scores with the sole advantage of not  requiring any change 
                                                 
64 As the aviation accident statistics are based on low numbers hence are highly volatile, it is most 
appropriate to take the broadest level of numbers and "shrink" them to the level needed, based on valid and conservative assumptions. The numbers given do not include the significant contribution by non-
accident occurrences, especially by incidents involving taxi or other ground operation, ref. [7], page 
30f. 
EN 38   EN in the human resources aspect. However, as mitigating tools can be used in the 
implementation phase of the EASA option, this slightly non positive element is 
overcompensated by the other advantages of option B. 
As regards the issue of timeliness to reach operational cruising sp eed, both options have 
individual weaknesses and advantages: EASA will benefit from the integrated knowledge 
management and the existing, safety-oriente d structure, while EUROCONTROL benefits 
from having ATM/ANS expertise already in h ouse. The matter of civil-military interface, 
though certainly important, pertains to the technical implementation phase and does not 
indicate a preference for one of the option.  
In total, the above indicates th at option B is clearly the most  preferred option. Considering a 
weighing of the different fields of impact, and concluding that the imp act on safety matters 
are by and large the most importa nt effect as compared with economic and soci al ones, this 
result appears even more pronounced. Therefore, it is concluded that the very prominent 
option to meet the current and future safety challenges face by the European aviation is 
option B, extending the scope of competence of  EASA to the regulation of aerodromes as 
well as of ATM and ANS. This solution is also fully consistent with the Community 
policies in aviation safety and completes th e Single European Sky and SESAR initiatives 
by adding the required safety element. 
7 MONITORING AND EVALUATION 
This section highlights the tools and rationa le available for a continuous and systemic 
monitoring process as well as ev aluation of impacts and result s achieved, which are supposed 
to be compared with the intentions and especi ally with the related general, specific and 
operational objectives as listed in section 3. 
Regulation (EC) 216/2008 provides already an evaluation tool by its Art. 62. According to 
this provision, an external eval uation of the impact of the Re gulation, of the Agency and its 
working practices has to be perf ormed at periodic intervals. It is based on a broad stakeholder 
consultation and shall include an action pl an. Following an initial evaluation to be 
commissioned within three years after th e taking up of the new duties by EASA, this 
evaluation shall be performed every five years.  By applying the same rationale, it is intended 
to suggest reducing the initial evaluation peri od following the enactment of these extension 
measures to three years after the entry into  force of the selected Implementing Rules. 
Furthermore, Articles 10 and 24 on safety ove rsight and standardisation inspections of 
Member States and their undertakin g are adequate tools to assess if the measures  are correctly 
implemented, promote and enforce remedial acti ons if they are not a nd give the European 
Parliament, the Council and the Commission a system ic indication of the effectiveness of the 
adopted measure and of its Implementing Rules. 
For technical detail and expl anation on possible proposed indi cators balanced against the 
established objectives, it can be referred to the preliminary Impact Assessment, ref. [2], page 
67ff, on an exemplary basis. 
All in all, therefore a complete and satisfying set of monitoring and eval uation tools is put in 
place to ensure the correct path for implemen tation and achievement of the objectives listed 
under section 3. 
EN 39   EN Annex 1: Figures  
Figure 2.2.2.2: European Organisations 
European Organisations for aviation safety
EUROPEAN 
UNION
(27)GASR 
(28)ECAC & JAA
(42)
EUROPEAN COMMON AVIATION AREA (36)ICAO  EUR
(only a regional 
office; the 
Organisation is 
ICAO)
July  2007Algeria2
Andorra
Belarus
Kazakhstan
Kyrgyzstan
Morocco2
Russian Fed. +Kaliningrad FIR
San Marino
Tajikistan
TurkmenistanTunisia
2
Uzbekistan
LiechtensteinIceland
1Candidates to JAA
2Algeria, Morocco and Tunisia are situated in the ICAO 
AFI Region, but are served by the ICAO EUR/NAT 
Office
3ICAO Cairo Office (MID), in addition to EUR, is 
accredited in Cyprus
4United Nations Interim Administration Mission in 
Kosovo; Additional associated party of ECAAAzerbaijan1
Georgia1
Estonia
Latvia
Hungary
LuxembourgMoldova1
Portugal
RomaniaSlovak Rep.
Spain
Slovenia
Sweden
U.K.
Austria
Bulgaria
Cyprus3Belgium
Czech Rep.Denmark
Finland
France
Germany
GreeceNorway
EASA
(31)(55)
Albania 1Bosnia H.1Croatia    FYROM1Turkey
Ireland
ItalyLithuaniaMalta
Netherlands
PolandSwitzerland
UNMIK4Armenia 1Monaco    Ukraine1EUROCONTROL    (38)
Serbia
Montenegro
 
Figure 2.2.1: Western-built Jet Ai rcraft Accident Costs 1997-2006 ( ref. [11], page 13)  
 
EN 40   EN Figure 2.2.2: 2006 Runway Excursion Accidents (ref. [11], page 26) 
 
Figure 2.2.3: 2006 Ground damage Accidents (ref. [11], page 28) 
EN 41   EN 
 
EN 42   EN Figure 2.2.4: 2006 Approach & Landing Accidents (ref. [11], page 29) 
 
EN 43   EN Figure 2.3.1: Factors of safety threat 
European Aviation SafetyIncreasing Pressure
• Traffic Growth
• Technological ChangesExisting Regulatory framework
• Slow, consensus based
decision making
• Different and overlapping bodies• Lack of central coordination• different safety levels
Existing Rules
• Lack of enforcement and harmonization•E x i s t i n gg a p s• differences in certification and oversight
 
Figure 4.2.1: Aerodrom e characteristics 
Number Public use IFR Typical Infrastructure and use 
50 Yes Yes Major and hub airpor ts, more than 50 000 annual 
movements, long runways, intensely used by large aircraft 
650 Yes Yes 1. Same as above, but less actual movements 
2. Shorter runways, no or limited use by 
passenger aircraft, instrument procedures serving low end scale of commercial and corporate type use 
1445 Yes / No No Shorter, non-IFR runways not allowing (regular) 
use of commercial operation, partial grass runways, very high am ount of general and 
recreational operation 
3000 No No very short, mostly  grass runways,  recreational 
operation only 
EN 44   EN Figure 5.2.2: Relation of savings 
Hyp 1: 500 airports
2FTEs 4FTEs 6FTEs
DO NOTHING EASA EXTENSION
Hyp 1: 1000 airports
2FTEs 4FTEs 6FTEs
DO NOTHING EASA EXTENSION
EN 45   EN Figure 6: Cost sensitivity analysis 
Based on the conservative analysis provi ded in section 6, in Mio. € / year:  
   today 2025 
Global 
damage   920 1840  
European 
damage   92 184  
aerodrome 
contribution to damage   9,2 18,4  
ATM 
contribution to damage   9,2 18,4  
   share of cost (%) 
   today 2025 
Cost option B aerodrome 2,380 25,87 12,935 
 ATM 2,240 24,348 12,174 
Cost option C aerodrome 2,618* 28,457 14,228 
 ATM 2,464* 26,783 13,391 
* Cost of option B * 110 % due to reduced efficiency 
The sensitivity analysis reveals that the cost incurred by the measure is in the area of 25% 
today, with a decreasing sh are in the following years. 
EN 46   EN Annex 2 List of Abbreviations  
AFIS Aerodrome Flight Information Service 
AIB Accident Investigation Body AIM AIP AIS AMC ANS ANSP ATM ATS CFIT CRD  COM CS EAD EASA ECAC ERs ESARR EU FTE FUA GA GAP 
GASR 
IATA ICAO ICB IFR IRs IS-SG JAA JAR MET Aeronautical Information Management 
Aeronautical Information Publication Aeronautical Information Service Acceptable Means of Compliance Air Navigation Services Air Navigation Service Provider Air Traffic Management Air Traffic Services Controlled Flight Into Terrain Comment Response Document  Communication Certification Specification European Aeronautical Database (Eurocontrol) 
European Aviation Safety Agency European Civil Aviation Conference Essential Requirements EUROCONTROL Safety Regulatory requirements European Union Full Time Equivalent Flexible Use of Airspace (between civil and military) General Aviation Ground Accident Prevention programme 
Group of Aerodrome Safety Regulators 
International Air Transport Association International Civil Aviation Organisation Industry Consultation Body Instrument Flight Rules Implementing Rules Inter-Service Steering Group Joint Aviation Authorities Joint Aviation Requirements Meteorological services 
Mil MS MTOM NAA NAV NPA NPV NSA OPS PRC PRU RFFS RIA R&D Military 
Member States (EU) Maximum Take Off Mass National (or Civil) Aviation Authority Navigation Notice for Proposed Amendment Net Present Value National Supervisory Authorities Operations Performance Review Commission (Eurocontrol) Performance Review Unit (Eurocontrol) Rescue & Fire Fighting Services Regulatory Impact Assessment Research and Development 
EN 47   EN SAFA 
SARPS SES SESAR SESAR JU SMS SSC SUR Safety Assessment of Foreign Aircraft 
Standards And Recommended Practices Single European Sky Single European Sky ATM Research SESAR Joint Undertaking Safety Management System Single Sky Committee Surveillance 
 
Annex 3 References
 
[1] "Extending the tasks of the European Av iation Safety Agency: An agenda for 2010", 
Communication from the Commissi on to the Council, the European Parliament, the European 
Economic and Social Committee and the Committee of the Regions, COM(2005) 578 
[2] "Impact Assessment on the extension of EASA competences to ANS, ATM and 
airports", Final Report, Ecorys, 15 Sept ember 2005 (available at www.easa.eu.int) 
[3] " A framework for driving performance improvement", Report of the High Level 
Group for the future European Aviation Regulatory Framework, July 2007 
[4] "Towards A More Performing European Aviation System", Single Sky Conference, 
Brussels, 22 Jan 2008 
[5] "Opinion No. 3/2007 for amending Regulatio n (EC) 1592/2002 to ex tend its scope to 
the regulation of safety and interoperabi lity of aerodromes",  EASA, 06 December 2007 
(available at www.easa.eu.int) 
[6] "Essential Requirements", Attachment 1 to [5], EASA, December 2007 (available at 
www.easa.eu.int) 
[7] "Regulatory Impact Assessment", Att achment 2 to [5], EASA, December 2007 
(available at www.easa.eu.int) 
[8] "Extension of the EASA system to th e regulation of ATM and ANS", Notice of 
Proposed Amendment (NPA) No. 16/2007, EA SA, 30 November 2007 (available at 
www.easa.eu.int) 
[9] "Annual Safety Report 2007", Safety Regulation Commissi on, EUROCONTROL, 
2007 (available at www.easa.eu.int) 
[10] "Impact Assessment on 2nd extension of EASA's competencies: Preliminary 
Assessment of administrative costs", Dr aft Report, DG TREN F3, February 2007 
[11] "Safety Report 2006", IATA, April 2007 [12] "Opinion No. 1/2008, “Extension of the EASA  system to the regulation of Air Traffic 
Management and Air Navigation Services (A TM/ANS)”, EASA, 15 April 2008 (available at 
www.easa.eu.int) 
[13] Comment Response Document (CRD) to NPA 2007-16, "Extension of the EASA 
system to the regulation of Air Traffic Mana gement and Air Navigation Services, EASA, 18 
March 2008