12.5.2022
EN
Official Journal of the European Union
L 135/13
(70)
Greece indicates in the draft performance plan that a significant increase in the number of air traffic controllers in operations at the Athens area control centre is foreseen in the course of RP3, resulting in a total of 71 additional full-time equivalents in 2024 as compared to 2019.
Furthermore, several major investments regarding ATM and surveillance systems are planned to be realised towards the end of the reference period, with a significant cost impact from year 2022 onwards.
Greece states in the draft performance plan that the related depreciation cost have been netted of amounts that were overcharged in RP2 in respect of delayed investments in fixed assets.
(71)
The Commission notes that the advice received from the performance review body points to ambiguities and inconsistencies as to the overall set of measures presented by Greece in respect of the implementation of its local capacity targets, leading the performance review body to question whether those measures will effectively be implemented and hence will have the expected impact.
It should also be noted that Greece has neither detailed nor quantified, in its draft performance plan, the additional costs related to the training and recruitment of new air traffic controllers.
In the absence of any substantiated information concerning those costs, the Commission estimates that both of the deviations referred to in recital 69 are too significant to justify that they could be exclusively attributed to measures for achieving the local capacity targets.
(72)
In addition, it should be noted that the draft capacity targets set by Greece have been found, for the reasons stated in recitals 53 to 59 of this Decision, to be inconsistent with the corresponding Union-wide targets.
In the absence of capacity targets assessed as consistent, the Commission considers that at this stage it is not possible to conclude the assessment of the criterion set out in point 1.4(d)(i) of Annex IV to Implementing Regulation (EU) 2019/317 in respect of Greece, as the planned measures required to achieve capacity targets may have to be amended in connection with the required revision of capacity targets.
(73)
Therefore, the criterion set out in point 1.4(d)(i) of Annex IV to Implementing Regulation (EU) 2019/317 is not fulfilled in respect of Greece.
(74)
In respect of the criterion set out in point 1.4(d)(ii) of Annex IV to Implementing Regulation (EU) 2019/317, it suffices to mention that Greece has not presented in its draft performance plan any restructuring measures which would justify a deviation from the Union-wide determined unit cost trend or from the Union-wide long-term determined unit cost trend.
Therefore, the criterion set out in point 1.4(d)(ii) is not fulfilled in respect of Greece.
(75)
In addition, the review of key factors and parameters referred to in point 2.1.(d) of Annex IV to Implementing Regulation (EU) 2019/317 underpinning the draft performance targets in the key performance area of costefficiency has resulted in the following findings regarding the proposed RP3 cost base of Greece.
(76)
The Commission notes that determined costs related to search and rescue have been added for the first time in the en route cost base of Greece in RP3.
Those costs lead to a sizeable increase of the en route determined costs, and amount to approximately 9 % of the 2020 en route cost base and approximately 5 % of the 2024 total en route cost base.
Greece should provide further justifications in its revised draft performance plan as to the eligibility and proportionality of the related determined costs and on their allocation between en route and terminal air navigation services, as well as between air navigation services and other relevant sectors.
(77)
Furthermore, the Commission takes note of the establishment of a new national supervisory authority organisationally separated from the air navigation service provider, which is associated with an increase of the supervision costs.
Taking into account the magnitude of the related additional costs, Greece should further explain the underlying cost drivers and assumptions in its revised draft performance plan.
(78)
On the basis of the findings set out in recitals 64 to 77, the proposed targets included in the draft performance plan of Greece should be assessed as inconsistent with the Union-wide performance targets in the key performance area of cost-efficiency.