Cost base, cost allocation and charges

• Pages: 61-66

Revi ew of com pliance wit h t he Cha rgin g Sche me of t he Si ngle Eur opean Sky in Bulgar ia

2019 61/85

11 . Co st b ase , cost al loca tion and charg es

11 .1. Co st ba se

11.1 .1. Eligibil ity of the cost b ase

The st udy has r eviewed t he operations, systems, processes and hum an resources of

BULATSA and the cost base t hat arises from this. I nputs t o t his review have been

pr ovid ed b y BULATS A and CAA Bu lgar ia, as we ll as PRB an d Eur ocon tro l do cum ents and

dat abases. The sit e visit enabled the stud y team to gain a good insight into t he overall

operations an d activit ies and we did n ot discover any act iv ities that m ight be deemed

in eligi ble fo r t he p urp oses o f esta blish ing th e det erm ined cost base . We not e t hat ma ny

ANSPs conduct R&D that might be ex ploit ed com mer cially in the w ider aviat ion sector;

BULATSA’s R&D act iv ities ar e solely focused on ATC process im provement and

pr odu cti vit y t oo ls, such as the de velo pm ent of tCAT , a sect or pro duc tiv it y t ool . BULA TSA

answered our specific quest ions on cost s bu t as the st udy w as not a financial audit , we

did no t rev iew BULATSA’s ma nage men t accou nt s. W e al so n ote th at th e r elat ive bu dget s

app lied to the different fu nctions a nd operation s app eared propor tion ate.

Und er Art icle 20 of Regul ati on (EC) No 3 91 /2 01 3, CAA Bul gar ia h as a ccess to BULATSA’s

financial record s. CAA Bulgaria has also con duct ed quarterly review s and has h ad

in form al me etin gs w it h BULATSA sin ce 20 17 and as a re sult ar e con fid ent th at the re a re

no inelig ib le cost s wit hin t h e determin ed cost s. We est ablished t hrough discussion of

th eir m onit or in g proced ures and access t o inform ation t hat CAA Bu lgar ia are aware of

and hav e pr ocesses to monit or com plian ce of det erm ined costs.

Fina lly we n ote th at r eim bur seme nt of t he cost of V FR fl ight s is don e usin g t he mar gina l

cost met hodolog y, as pr ovid ed und er art icle 8.4 of Regu lati on ( EC) No 391/2013.

11.1 .2. Wh at ar e the j u st ificat ions for enr out e cost s increases w hile t erm inal air

navigati on serv ices cost s rem ain const ant?

At t he tim e of th e revision, th e term in al services part of the performance was n ot

re vised . Th is w as dec ided on t he basis of sever al f acto rs: th e la ck of Union-w ide t ar gets

on determ in ed cost s for t erm inal ser vices; the adm inistrative burden; and that t he

increase in ar riv als and depar t ures was not significant enoug h. Whilst t his m ay have

sim plif ied the process at t he tim e, it also led t o a divergen ce of plann in g assum ptions

bet w een the two plan s, su ch as inflat ion.

It does not appear t hat t here is a m ater ial diff er en ce between t he ch an ges in enr ou t e

and terminal costs (Table 11- 1 ) . BULATSA adv ises that t he revenu es collect ed f rom

Terminal Navigation Char ges ar e sufficient t o cover t he cost of providing Term in al

servi ces, t hus t here wou ld be no ne ed for cr oss su bsidisat ion.