The Aerospace and Defence Industries Association of Europe (ASD) welcomes the European Commission's proposal for a regulation, dated 23rd February 2021, establishing the Joint Undertakings under Horizon Europe (Single Basic Act). In particular, ASD supports the European Commission’s proposal as Europe needs to modernise its ATM infrastructure, whereby SESAR is key to actualising this, and a clear regulatory framework and sufficient funding are needed. Further, the SESAR Partnership will be a key element to reach the ambitions of the EU Green Deal and implement the EU civil aviation sector's own Destination 2050 Roadmap (see: www.destination2050.eu). ASD’s members have identified key concerns in the proposed legislation for the SESAR Partnership and propose the below high-level recommendations.
1. The Unconditional Commitment of Founding Members
The founding members' clause to unconditionally accede to the Partnership via a Letter of Commitment (LoC) raises a legal and financial risk for entities. The founding members will possibly be asked to sign an LoC when important rules (such as the funding rates or the United Kingdom’s public contribution) are not yet defined. Proposal:
- To remove ‘unconditional’ to get a balanced and legally acceptable risk.
- To limit each founding member’s contribution for administrative costs to a proportional part of the founding member’s In Kind Contribution to its rewarded Grants.
- To clarify that commitment on private investment will be dependent on granted calls.
2. Establishment of SESAR 3
Any public or private entity or body, including those from third-countries, that have concluded at least one agreement with the European Union in the field of air transport may be selected as associated SESAR 3 members. It must be confirmed whether any third-country based companies or any non-governmental organisation in the field of air transport can participate in SESAR 3. If yes, this list should be made available for full transparency and the rules must be aligned with wider EU objectives.
3. Finance and Funding
Connecting Europe Facility (CEF) funds are not mentioned in the SBA, although they are expected to be fundamental means to support SESAR 3 in the Digital Sky Demonstrators. An explicit reference, preferably with exact figures to be committed on those funds, should be included in the SBA. Further, it must be clarified whether third-countries can access to CEF funds as, for example, amount is earmarked in the SBA. Additionally, CEF funds are relevant for the actualisation of the ambitions in the Strategic Research and Innovation Agenda (SRIA), so the available funds must be compatible with the SRIA.
Clarification of the role of the State Representative group for SESAR 3 is required. From the initial 20 SESAR-JU founding members, SESAR 3 will grow to 40 founding members, whereby all will act in an open call process. There must be robust governance mechanism to ensure that SESAR 3’s actions will foster the innovation towards the ATM Master Plan with relevant deployable solutions in the European ATM ecosystem.
5. Programme Management
More details are required on the size of the expected projects (e.g. budget/partners). For example, will there be multiple awards (more consortia than one) to one call topic? If not, it may be the case that the winners are likely to also win the subsequent calls/waves. Clarifications should be provided on the open call contenders selection criteria, and how contenders capability to further industrialise and ensure a successful deployment of SESAR 3 solutions will be accounted for. Finally, more clarification is required on how members coordinated before calls.
LINK TO THE POSITION PAPER
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