PRB monitoring
▪ The en route 2024 actual unit cost of Greece was 20.31 €2017, -27% lower than the determined unit cost (27.98 €2017). The terminal 2024 actual unit cost was 138.07 €2017, -31% lower than the determined unit cost (198.95 €2017).
▪ The en route 2024 actual service units (7.7M) were +14% higher than the determined service units (6.8M).
▪ The en route 2024 actual total costs were -33M €2017, (-18%) lower than the determined, marking an underspend across all cost categories. The largest difference for HASP was in staff costs (-18M €2017, or -14%), followed by significantly lower depreciation costs (-13M€2017, or -92%), cost of capital (-4.3M€2017, or -97%), and other operating costs (-3.1M€2017, or -18%). The NSA did not provide sufficient explanations for these results. The PRB highlights that the actual number of ACC ATCOs in OPS FTEs for HASP were -39% below plan.
▪ HASP costs of investments were 2.3M €2017 in 2024 for both en route and terminal charging zones, -89% lower than determined (21M €2017), due to postponed investment projects. The NSA did not provide explanations for the non-implementation of the eight new major investments that were planned for RP3. As for the previous monitoring years, the discrepancies regarding costs of investments were significant.
▪ The en route actual unit cost incurred by users in 2024 was 26.80€ (-11% lower than the 2024 DUC), while the terminal actual unit cost incurred by users in 2024 was 147.25€ (-32% lower than the 2024 DUC). The difference between the AUCU and the DUC in the en route charging zone is primarily attributable to the difference between determined and actual costs in 2024, while for the terminal charging zone it is primarily attributed to the loss of revenue relating to the application of a lower unit rate, which amounted to -5.5M€.
▪ The en route regulatory result for HASP amounted to +25M€, or 14% of the 2024 revenue.
▪ Greece should take immediate, adequate, and proportionate action to implement the relevant ATCO and investment plans committed to in the RP3 performance plan and to provide the ANSP with the necessary means to implement the planned actions both in respect of decisional and budgetary procedures.
▪ Greece should ensure that any excessive regulatory result, including excess funds received by the ANSP due to the inflation mechanism, is either reinvested to improve the quality of services delivered to airspace users or reimbursed to them.
En route charging zone
| Actual and determined data |
| Total costs - nominal (M€) |
2020-2021 |
2022 |
2023 |
2024 |
| Actual costs |
257 |
165 |
177 |
182 |
| Determined costs |
277 |
172 |
189 |
204 |
| Difference costs |
-20 |
-8 |
-12 |
-22 |
| Inflation assumptions |
2020-2021 |
2022 |
2023 |
2024 |
| Determined inflation rate |
NA |
4.5% |
1.3% |
1.6% |
| Determined inflation index |
NA |
106.5 |
107.9 |
109.7 |
| Actual inflation rate |
NA |
9.3% |
4.2% |
3.0% |
| Actual inflation index |
NA |
111.4 |
116.1 |
119.6 |
| Difference inflation index (p.p.) |
NA |
+4.9 |
+8.2 |
+9.9 |
AUC vs. DUC
In 2024, the en route AUC was -27.4% (or -7.68 €2017) lower than the planned DUC. This results from the combination of significantly lower than planned en route costs in real terms (-17.6%, or -33.4 M€2017) and significantly higher than planned TSUs (+13.5%). It should be noted that the actual inflation index in 2024 was +9.9 p.p. higher than planned.
En route service units
The difference between 2024 actual and planned TSUs (+13.5%) falls outside the +10% threshold foreseen in the traffic risk sharing mechanism. The resulting gain of additional en route revenues is therefore shared between the ANSP and the airspace users (see the main ANSP gain in Box 11).
En route costs by entity
The 2024 actual real en route costs are -17.6% (-33.4 M€2017) lower than planned. This is the result of lower than planned costs for the main ANSP, HASP (-21.5%, or -34.6 M€2017) and higher than planned costs for the MET service provider (+2.1%, or +0.2 M€2017), the NSA/EUROCONTROL (+3.7%, or +0.5 M€2017).
En route costs for the main ANSP at charging zone level
Significantly lower than planned en route costs in real terms for HASP in 2024 (-21.5%, or -34.6 M€2017) result from:
- Significantly lower than planned staff costs (-13.9%),
- Significantly lower than planned other operating costs (-18.4%),
- Significantly lower than planned depreciation (-91.9%),
- Significantly lower than planned cost of capital (-96.9%),
- Exceptional costs which reflect a reporting of negative amount (-4.5 M€ in nominal terms) in 2024 determined costs for HASP to correct for the difference between planned and actual costs in 2021 resulting from resubmission of the RP3 PP.
- Significantly higher than planned deduction for VFR exempted flights (+8.7%).
No explanations on the differences between the 2024 determined and actual costs are available in the Additional information to the reporting tables or in the NSA Monitoring Report.
RP3 summary
When considering the whole of RP3 (2020-2024) for Greece en route charging zone, actual TSUs are +8.8% higher than planned, while actual costs in real terms are -11.1% lower than the determined costs (some -89.0 M€2017). As a result, the weighted average actual unit cost over RP3 (25.35 €2017) is -18.2% lower than planned in the PP (31.00 €2017).
Actual unit cost incurred by the users (AUCU) (PI#1)
| AUCU components (€/SU) – 2024 |
| Components of the AUCU in 2024 |
€/SU |
| DUC |
30.12 |
| Inflation adjustment |
1.93 |
| Cost exempt from cost-sharing |
-2.17 |
| Traffic risk sharing adjustment |
-2.07 |
| Traffic adj. (costs not TRS) |
-0.52 |
| Finantial incentives |
-0.45 |
| Modulation of charges |
0.00 |
| Cross-financing |
0.00 |
| Other revenues |
-0.04 |
| Application of lower unit rate |
0.00 |
| Total adjustments |
-3.33 |
| AUCU |
26.80 |
| AUCU vs. DUC |
-11.0% |
| Cost exempt from cost sharing by item - 2024 |
€'000 |
€/SU |
| New and existing investments |
-17,713.8 |
-2.30 |
| Competent authorities and qualified entities costs |
470.7 |
0.06 |
| Eurocontrol costs |
554.8 |
0.07 |
| Pension costs |
0.0 |
0.00 |
| Interest on loans |
0.0 |
0.00 |
| Changes in law |
0.0 |
0.00 |
| Total cost exempt from cost risk sharing |
-16,688.4 |
-2.17 |
The actual en route unit cost incurred by airspace users (AUCU) in respect of activities performed in 2024 (26.80 €) is -11.0% lower than the nominal DUC (30.12 €). The difference between these two figures (-3.33 €/SU) is due to:
- the positive inflation adjustment resulting from higher than planned inflation (+1.93 €/SU);
- the impact of adjustments resulting from the costs exempted from cost sharing mechanism (-2.17 €/SU);
- the deduction of the traffic risk sharing adjustments (-2.07 €/SU);
- the deduction of the traffic adjustment (-0.52 €/SU) for the costs not subject to traffic risk sharing;
- the financial incentives (-0.45 €/SU); and
- the deduction of other revenues (-0.04 €/SU).
The share of the regulatory result (see items 10 to 14) in the AUCU (before the deduction of other revenues) is 11.9%.
HASP net gain on activity in the Greece en route charging zone in the year 2024
HASP reported a net gain of +24.6 M€, as a combination of a gain of +20.4 M€ arising from the cost sharing mechanism, with a gain of +7.7 M€ arising from the traffic risk sharing mechanism and a loss of -3.5 M€ relating to financial incentives.
HASP overall regulatory result (RR) for the en route activity
Ex-post, the overall RR taking into account the net gain from the en route activity mentioned above (+24.6 M€) and the actual RoE (+0.1 M€) amounts to +24.8 M€ (14.1% of the en route revenues). The resulting ex-post rate of return on equity is 817.9%, which is higher than the 4.6% planned in the PP (see also Note 1 in Box 10 above).
RP3 summary
When considering the whole of RP3 (2020-2024), HASP generated a cumulative gain in respect of cost sharing of +67.2 M€, as actual total costs for RP3 were lower than planned. The traffic risk sharing mechanism generated a gain of +23.1 M€. Adding the loss of -6.7 M€ to be retained by the ATSP in respect of financial incentives and the actual RoE (+2.3 M€ over RP3) leads to an overall regulatory result of +86.0 M€, which corresponds to an average ex-post rate of return on equity of 196.7% (compared to 4.8% initially planned in the PP) (see also Note 1 in Box 10 above).
Note1: Ex-post RoE cannot be correctly calculated due to a very low total asset base, due to:1) the exclusion of net current assets from the calculation of the total asset base starting from 2021; 2) a very low net book value of fixed assets (as these are nearly fully depreciated).