For the purpose of this study, in order to assess all the administrative costs, a specific evaluation approach was adopted consisting in the following main steps:
-
Identification of the actions required to implement each specific measure (identification of information obligations and the required actions);
-
Identification of relevant cost parameters: for the purpose of this study, it has been assumed that the main costs induced by the identified action plan are labour costs;
-
Identification of target groups (public, business), responsible to develop the actions and stakeholders affected by the implementation (the effects) of the actions;
-
Identification of two different types of administrative costs: one-off and recurrent administrative costs;
-
Identification of the frequency of recurring actions (starting from a case-by-case approach, considering an average value at EU level);
-
Identification of the timeframe;
-
Assessment the full administrative cost of a normally efficient entity (identification of the Full Time Equivalent -man-day- related to each action related to each measure);
-
Assessment of the number of entities concerned
-
Quantification of full administrative Cost: According to the commission requirement and Impact Assessment Guidelines, "administrative costs" are mainly assessed on the basis of the average cost per action (“P”) of total number of action performed per year, defined multiplying frequency (“F”) and number of entities concerned (“NE”)
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The average cost per action is estimated by multiplying a tariff (based on the average labour cost per hour including prorated overheads) by the time required per action.
2.General assumptions for administrative cost calculation
If an administrative action is required by law (directive, regulation, etc.) but corresponds to what an entity normally does in the absence of any legal obligation, it has not been regarded as administrative action and thus as administrative cost.
For the assessment of net administrative costs only additional/new costs imposed by a legislative framework in relation to the base line scenario (action/measures) have been considered;
One-off/recurrent administrative costs:
*one-off administrative costs, defined as start up-cost or costs incurred when re-designing the way administrative obligation or specific action are met;
*recurrent administrative costs, defined as annual costs (for instance) related to a specific reporting or auditing/controlling programme;
Cost timeframe: the one-off administrative costs have been distributed within a five year start up period. For all the measures, flat distributions of administrative costs within this start-up period have been assumed; moreover, the starting periods for the recurrent administrative costs have been assumed from 2012 onward.
For all the measures, specific levels of Full Time Equivalent (man-days) have been defined according to detailed assumptions and hypothesis developed measure-by-measure;
The following categories of cost parameters have been considered:
*cost parameters for actions developed by the targeted entity itself: number of hours spent to develop the specific action, multiplied by the hourly pay plus the overheads;
*cost parameters for the “outsourced activities”(administrative actions eventually outsourced to external providers): the service provider charges per activity could be calculated considering an “overall service provider” charge per action or by multiplying the hourly fee charged (the service providers “external” tariff) by number of hours spent on the specific actions.
3.Comparison of policy measures concerning approval systems
The policy measures are the following:
Policy measures
|
Description of the policy measure
|
Mutual recognition of approvals between the EU Member States with harmonised requirements
|
Harmonise the content of approvals and require Member States to recognize approvals delivered in another Member State. Definition of conditions for obtaining such approval, such as insurance, financial fitness, training, safety and environment.
|
Set-up an EU approval (delivered by the Commission)
|
Harmonise the content of approvals and centralise issuance of approvals at EU level.
|
These 2 measures are to be compared with the baseline scenario.
3.1.Presentation of the baseline scenario:
There has been no change so far (at the knowledge of the Commission) concerning the approval systems of each Member State. The baseline is therefore the current situation for approvals, which is reflected below for Member States for which this information is available:
|
Approvals systems
|
Airport authorisations/licences
|
Existence of an approval delivered by the State
|
Approval information to be transmitted to the authorities
|
Approval duration (frequency of delivery)
|
Inspections
|
Existence of airport authorisations
|
Information required by airports and inspections associated
|
Commercial registration
|
Good morality evidence
|
Financial stability /business plan/ annual accounts
|
personnel training/ experience
|
Operational manual/ organisation/equipment
|
Proof of insurance coverage
|
Compliance with Labour / Social law
|
Other
|
Existence of inspections
|
Number of inspections par year
|
AT
|
Yes
|
|
|
|
X
|
X
|
X
|
X
|
X
|
7 years
|
Yes
|
1
|
No
|
|
BG
|
yes
|
X
|
|
X
|
X
|
X
|
|
|
X
|
permanent
|
yes
|
1
|
No
|
|
CY
|
yes
|
|
|
X
|
X
|
X
|
X
|
X
|
X
|
permanent for landside services; 7 years for restricted services
|
yes
|
1
|
No
|
|
DE
|
No
|
|
|
|
|
|
|
|
|
|
|
|
No
|
Proof of insurance
|
DK
|
No
|
|
|
|
|
|
|
|
|
|
|
|
yes
|
compliance with local regulations for safety, security, working conditions, use of infrastructure, opening hours, insurance, etc.
|
ES
|
Yes
|
|
X
|
X
|
X
|
X
|
X
|
X
|
X
|
7 years
|
Yes
|
1/7
|
No
|
|
FI
|
No
|
|
|
|
|
|
|
|
|
|
|
|
?
|
?
|
FR
|
yes
|
|
|
X
|
|
|
X
|
X
|
|
5 years
|
yes
|
1/7
|
yes
|
Licence for use of public domain
|
GR
|
yes
|
|
|
X
|
X
|
X
|
X
|
X
|
|
For “baggage handling” and “ramp handling”: seven (7) years. For the rest, permanent.
|
yes
|
1
|
?
|
?
|
HU
|
Yes*
|
|
|
|
|
X
|
|
|
|
5 years
|
?
|
?
|
No*
|
|
IE
|
Yes
|
|
|
X
|
X
|
X
|
X
|
X
|
X
|
5 years
|
yes
|
1/5
|
yes
|
* vehicles / equipment to be used
* accident/ emergency plan,
* training details
*insurance
*processing fee
|
IT
|
yes
|
|
|
X
|
X
|
X
|
|
|
|
3 years
|
yes
|
1
|
No
|
|
LT
|
yes
|
|
|
X
|
X
|
X
|
X
|
|
|
permanent
|
yes
|
|
yes
|
Contracts with the airport containing "all conditions "
|
LV
|
yes
|
|
|
|
X
|
X
|
|
|
X
|
?
|
?
|
|
no
|
|
MT
|
Yes*
|
|
|
X
|
|
X
|
X
|
|
X
|
7 years
|
?
|
?
|
No*
|
|
NL
|
No
|
|
|
|
|
|
|
|
|
|
|
|
yes
|
*agreement of at least one airline
* Safety,
* working conditions *environmental management system .
*close surveillance by the airport
|
PL
|
yes
|
|
|
X
|
X
|
|
X
|
|
X
|
5-50 years (entity desired period). For restricted categories: 7 years.
|
yes
|
1
|
no
|
|
PT
|
yes
|
X
|
X
|
X
|
X
|
X
|
X
|
X
|
|
4- 7 years for restricted services. NA otherwise
|
yes
|
1
|
yes
|
licence for the use of public domain.
|
RO
|
yes
|
|
|
X
|
X
|
X
|
X
|
|
|
initial approval: 1 year ; following approvals : 3 years
|
yes
|
1/3
|
yes
|
?
|
SK
|
yes
|
NA
|
NA
|
NA
|
NA
|
X
|
NA
|
NA
|
NA
|
?
|
?
|
?
|
no
|
|
UK
|
No*
|
|
|
|
|
|
|
|
|
|
|
|
yes*
|
7 years authorisation ; requested information variable with some airports asking for experience and letter of intent to use the service of an airline
|
Source: Member States replies to EC questionnaire, end 2010 (for *: SDG report 2010, p.85-86)
From an administrative cost point of view, it can be seen that the situation is different between Member States. No models emerging amongst the Member States (information required are different and the frequency of the requests varies). It is therefore very difficult to calculate the "absolute" administrative costs borne by Member States and companies for the policy measures, for all the countries (it would additionally require to know the number of companies per countries and per airports, for each Member State, as well as the average number of approvals and stations for each company, in each Member States).
However, the objective being to compare the administrative costs between the policy measures, it is proposed to calculate in a simplified manner the administrative costs for the baseline and the policy measures to allow for a comparison between these options, as follows:
1. The number of approvals and authorisations requested/delivered in Europe will be estimated for the 3 cases.
2. The average cost of an approval (respectively an authorisation) for the businesses (groundhandling companies, airport operators in charge of delivering authorisations) and for public authorities (independent authority in charge of delivering approvals) will be calculated with the AB calculator (http://adminburden.sg.cec.eu.int/default.aspx).
Specific assumptions:
* 75% of Member States have an approval system, representing administrative costs for the Member States and the business entities (groundhandling companies), under the form of required information and inspections by the authorities. There is rarely additional information required by the airport operators, it is considered negligible in the baseline scenario.
*For the 25% of remaining Member States, there is no approval system but administrative costs for the business entities (groundhandling companies and airport operators) under the form of information requested by the local airport operators and associated inspections.
*It is considered when detailed information is unknown that airports are generally equally spread between approval and non-approval countries.
*It is assumed that 1 approval is valid for one State and one airport authorisation for 1 airport.
* In average, a groundhandling company operates in 3 Member States (2 Member States where an approval is needed and 1 Member State where an approval is not necessary) and more precisely at 4 airports (3 airports in 2 Member States where an approval is needed and 1 airport in a Member State where an approval is not necessary- but an airport authorisation is needed).
*For the policy measure about mutual recognition of approvals between Member States, the approval system is extended to all Member States, and approvals are mutually recognised. It is nevertheless assumed that 80% of information requested is mutually recognised, but that 20% of the information will remain State-related (i.e. checked as if was a national approval). In addition, we assume that 20% of airports previously requesting authorisations will continue to request information from the groundhandling companies, even if it is verified in the approval or by Member States.
*For the policy measure about setting up an approval delivery system at EU level, it is assumed that although the approvals are delivered in a centralised manner, 20% of the information will remain State-related. In addition, we assume that 20% of airports previously requesting authorisations will continue to request information from the groundhandling companies, even if it is verified in the approval or by Member States.
Estimate of the number of approvals and authorisations for each scenario
The number of approvals and authorisations delivered are the same for the policy measure consisting in setting up a mutual recognition of approvals between Member States and for the policy measure consisting in setting up an EU approval (except that in the first case, the approval is delivered by a Member State, while in the latter one, it is delivered by the Commission).
Only the first case is therefore presented in the following table:
|
Baseline
|
Policy measures consisting in delivering mutually recognised approvals between Member States
|
|
Number of airports covered by the Directive for third party handling (source: annex IV)33
|
Number of groundhandling companies in the EU (source: Booz study p.5634)
|
Number of approvals requested by groundhandling companies in each Member States35
|
Number of authorisations requested by ground-handling companies to airports in each Member States36
|
Number of approvals requested by groundhandling companies in each Member States37
|
Number of authorisations to airports requested by groundhandling companies in each Member States38
|
AT
|
1
|
9
|
9
|
0
|
|
|
BE
|
4
|
8
|
NA
|
NA
|
|
|
BG
|
1
|
4
|
4
|
0
|
|
|
CY
|
1
|
7
|
7
|
0
|
|
|
CZ
|
1
|
5
|
NA
|
NA
|
|
|
DK
|
6
|
5
|
0
|
6
|
|
|
EE
|
0
|
1
|
NA
|
NA
|
|
|
FI
|
1
|
5
|
0
|
5
|
|
|
FR
|
10
|
19
|
19
|
0
|
|
|
DE
|
14
|
46
|
0
|
0
|
|
|
GR
|
4
|
9
|
9
|
0
|
|
|
HU
|
1
|
3
|
3
|
0
|
|
|
IE
|
3
|
10
|
10
|
0
|
|
|
IT
|
15
|
23
|
23
|
0
|
|
|
LV
|
1
|
5
|
5
|
0
|
|
|
LT
|
0
|
3
|
0
|
0
|
|
|
LU*
|
1
|
1
|
NA
|
NA
|
|
|
MT
|
1
|
3
|
3
|
0
|
|
|
NL
|
2
|
10
|
0
|
10
|
|
|
PL
|
3
|
8
|
8
|
0
|
|
|
PT
|
4
|
5
|
5
|
0
|
|
|
RO
|
1
|
7
|
7
|
0
|
|
|
SK
|
0
|
2
|
0
|
0
|
|
|
SI
|
0
|
2
|
NA
|
NA
|
|
|
ES
|
16
|
18
|
18
|
0
|
|
|
SE
|
3,
|
8
|
NA
|
NA
|
|
|
UK
|
17
|
43
|
0
|
65
|
|
|
total
|
111
|
269
|
130
|
107
|
106
|
21
|
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