Guidance for Assessing Implementation Progress in LSSIP Edition Year 2011
1 – Objective of this Guidance Material
This guidance material aims to ensure that “Implementation Progress” (further called “Progress”) of SLoAs, Stakeholders and States in relation to the ESSIP Objectives is determined in a common and consistent manner for all LSSIP documents. It facilitates the correct interpretation and verification of “Progress” reported by FPs, CP and Stakeholders, thus contributing to the quality and European-wide uniformity of the LSSIP documents.
The local implementation situation of any Objective must be explained in a concise and comprehensive manner; all relevant aspects that impact an Objective’s completion should be sufficiently explained. To this purpose, this guidance firstly addresses what information is expected from FPs/ Stakeholders in the Local Scope (LS)/ SLoA fields and what explanations should be added in the “State/ Stakeholders Comments”.
It is then explained how to interpret the reported info in order to determine the “Progress” for each SLoA/ Stakeholder and, finally, for the State. A list of “Progress” qualifications is used to this purpose (e.g. “Completed”, “No Plan” etc) and guidance is provided for their correct interpretation and use.
It is important that reported “Progress” is consistent and aligned with the local situation. The FPs, CPs and Advisors shall verify and challenge for higher accuracy and consistency whenever the reported information is deemed insufficient or ambiguous to determine or to justify a stated “Progress”.
2 – Implementation Progress and it’s importance
“Progress” is a statement that “measures” the extent to which the local implementation situation of a SLoA or Stakeholder or Objective meets the ESSIP objective scope, finalisation criteria and schedule.
It is important that all States and Stakeholders are “measured” with equal consistency and impartiality for all SLoAs and Objectives. This impacts on the overall quality of the LSSIP information, the LSSIP Map Tool and on the accuracy of analysis in the EIPR.
Implementation “Progress” may be interpreted and applied unevenly, with occasional inconsistency among the concerned stakeholders or from one LSSIP document to another. Consistency in this respect depends on whether the reported information by FPs/ Stakeholders is sufficiently comprehensive and accurate, and on how it is then translated into “Progress”.
Consequently, in order to ensure that the LSSIP mechanism continuously produces and uses planning, reporting & monitoring information of the highest quality, it is important that all the actors concerned - FPs, State Stakeholders, CPs and SIS Advisors etc - interpret and apply “Progress” definitions in a uniform and equally consistent manner.
3 – Reported Information on Local Implementation
3.1 What information should be reported and how it is organised
FP/ Stakeholders are expected to report on each particular local implementation by means of various descriptions and statements. This info is collected within a bottom-up approach, into five levels of the LSSIP Database, per each Objective/ Stakeholders/ SLoAs: the Local Actions (LA); the Local Scope (LS); the Stakeholder Lines of Action (SLoAs); the Stakeholder level; and finally the State level.
Each information level, from the LS until the State level, relies on the descriptions, explanations, dates etc reported and on the “Progress” determined for each of its lower levels. A particular statement of advanced implementation at State or Stakeholder level, e.g. that an Objective is partially completed, cannot be credible unless sufficient information explaining that “Progress” (descriptions/ statements) is reported in the lower levels of this info “pyramid” (the LAs, applicable LSs and SLoAs).
The reporting done through LSSIP (at national level) must be consistent with local and individual stakeholder plans, objectives or actions. How this is done is left to FP and its national environment: e.g. it could be done by properly labelling each individual LA to a specific item in the ANSP Business or Operating Plan. For that purpose, the “National Plan” field associated to each Line of Action in the Database can be used to capture the appropriate link, while any clarification and explanation can be reported in the LA description.
The SLoAs and Stakeholders for each Objective are defined within the ESSIP Objective. However, the way in which LAs are defined and organised, the definition of the LSs and the roles and participation of specific Stakeholders may vary from one LSSIP to another subject to the local conditions.
Some SLoAs may, in general, have more impact than others on the completion of implementation and on the other hand due to particular local circumstances, the impact of one or several SLoAs may be negligible when compared to the impact of the other SLoAs. A similar situation may occur with the Stakeholders: some Stakeholders may be less concerned than the others and, therefore, their “Progress” might have less relevance, or even be negligible for the overall State “Progress”. This aspect may be important in the overall context of the definition of the “Progress” of each SLoAs, Stakeholders and at State level.
This guidance, however, endeavours to propose a pragmatic approach for determining “Progress”. An iterative process is described, that can be applied for any Objective and associated information levels.
3.2 Use of the Stakeholder and State “Comment” fields
The purpose of the “Comment” fields is to allow for explanations of the “Progress” stated at Stakeholder and State levels. The “Comment” fields also appear in the LSSIP Level 1 document and not only in Level 2. The purpose is to facilitate Level 1 readers in understanding what has been achieved so far, the actions still pending, by when, by whom and if there are any relevant obstacles to completion.
Typically, a “Comment” field should contain:
· A concise description of the current status of implementation. The statement should be specific and add value to the reported “progress” (e.g. a comment “implementation late” does not add any value to a LSSIP Status ‘Late’);
· If implementation is not completed, the realistic expected date for completion must be specified (this is a mandatory entry in the LSSIP at SLoA and objective levels);
· If shortcomings/ obstacles are experienced, this must be explained, together with any identified tangible remedial or mitigation actions/plans at National or European level;
· Where the local implementation situation and its “Progress” are not in accordance with the ESSIP scope, criteria and/or schedule, a concise but clear explanation and information of the relevant plans, decisions or actions by that Stakeholder should be given. When “Late”, the main reasons and the impact of the delay must be explained (e.g.: no budget allocated, not a priority, no operational benefit at National level, technical difficulties, prerequisite not available, lack of skilled resources, lack of coordination with neighbouring countries, etc.)
· Where the “Progress” of a particular Stakeholder or at State level appears inconsistent with that of some of the SLoAs or the other Stakeholders, this must be explained. This may occur e.g. where low impact SLoAs/ Stakeholders are identified, having negligible influence on the overall implementation. In all such cases a concise explanation should be given, e.g. why a particular SLoA or a Stakeholder is of little or no impact at all to the higher level “Progress”; or, where the case, why a particular SLoA or a Stakeholder are “Key” to the completion of implementation;
· Additional specific info required for the EIPR:
- If significant changes, introduced in ESSIP in the previous cycle as endorsed by the PC, had a tangible impact on the implementation of the objective at State or Stakeholder level;
- Objective buy-in: if the FP and/or Stakeholder considers the objective as strongly needed, very useful, useful, desirable, premature, unnecessary or a waste of time or budget;
- Only for objectives progressing well: FP to specify the main reasons for implementation success, e.g. good buy-in by stakeholder(s) (to specify which of them), implementation mandated by EC law, clear objective description, etc.
- For MN objectives only, at which cycle the State joined the applicability area (optional);
- Needs/ requests expressed by the FP for modifying a specific objective or action (if any).
The State “Comment” field should also be used to complement, as necessary, the information provided at Stakeholder level, e.g. to explain inconsistencies, situation at national level, the absence of statements at Stakeholder level, etc.
4 – How to Assess and Determine “Progress”
In the same way as for the collection of relevant information from the FP/ Stakeholders, “Progress” must also be determined within a bottom-up approach:
4.1 SLoA “Progress”
First, an assessment of “Progress” must be made for each LS based on the information reported by the concerned Stakeholder, including the expected completion date. The assessment should verify that the reported LAs are consistent with the respective ESSIP detailed SLoA description, inter-alia with the criteria that must be checked to determine if that SLoA has been completed or not. This will result in a SLoA “Progress” for that LS.
When a SLoA “Progress” is inconsistent with the reported LAs, the expected completion date or with the ESSIP target finish date, the CP will challenge the FP to request that the Stakeholder reviews the SLoA and provides more info or explanations in accordance with the ESSIP SLoA description. In case this action fails, the CP may apply “Missing Data”, as another way of challenging for more information.
4.2 Stakeholder “Progress”
If a Stakeholder has several SLoAs, their “Progress” statements must be further grouped to determine the Stakeholder “Progress”. The simplest scenario is when all SLoAs have the same “Progress” – the Stakeholder’s “Progress” would then be the same.
However, most frequently, SLoA “Progresses” differ through the SLoAs of a Stakeholder, which may complicate the assessment of that Stakeholder’s “Progress” and also make it depend of other aspects, such as if any specific SLoAs are less necessary or important to the end Objective (low-Key SLoAs) in the general ESSIP implementation context or in that particular local context.
An SLoA should not be deemed as “low-Key” in comparison with other SLoAs if significant regulatory requirements or any of the important ESSIP objective criteria would thus be disconsidered.
4.3 State “Progress”
Stakeholder “Progresses” will determine State “Progress”. This assessment is similar to that for determining a Stakeholder’s “Progress”. The simplest scenario is: all Stakeholders have the same “Progress” – State “Progress” would then be identical to that of the Stakeholders.
However, most frequently, Stakeholder “Progresses” differ within the same Objective. The simplest solution in this case is when all Stakeholders are considered as being equally important; similarly as with SLoAs, the State “Progress” would be that of the least advanced Stakeholder.
In real life though, the “Progress” of Stakeholders may not be determined only by their effective achievements, but also by their specific roles in the completion of an Objective. Quite often, the participation required from Stakeholders is uneven, with one or two major ones bearing the majority of responsibilities and actions, while the other Stakeholders may have less important roles.
As an example, implementing an operational or technical development by ANSPs in absence of a common regulation supporting that development clearly gives a more significant role to the ANSP rather than to the REG. Another example is that of Objectives of lesser concern to MIL authorities, because either MIL involvement is optional or MIL ATS does not service GAT. In such cases, particularly when the end Objective has been confirmed as completed by the driving Stakeholder(s), the State “Progress should not be penalised because a less relevant stakeholder has not (yet) achieved the ESSIP criteria for completion.
The FP/Stakeholder should use the “Comment” field also to confirm that the “low-Key” SLoAs or Stakeholders do not prevent or prejudice operational capability and consistency with the ESSIP, and that compliance with regulations is in no way affected.
4.4 How to determine the “Implementation Progress”
A basic principle and simple iterative process that can be applied for any of the LSSIP information levels is the following: The overall “Progress” at any LSSIP information level will be given by the less advanced “Progress” of that level and which is not a low-Key (low impact) item.
Example 1: A Stakeholder has 5 SLoAs, out of which 2 are identified as not really important or relevant for full completion (low-Key SLoAs). That Stakeholder “Progress” will be determined by considering the less advanced “Progress” of the, only, 3 SLoA deemed necessary since that would most likely have the highest impact on the overall implementation of that particular Stakeholder.
Example 2: An Objective having 4 concerned Stakeholders according to ESSIP; however, REG is required to “approve” a reference advisory material which does not have any mandatory status; while MIL ATS does not provide services to GAT. State “Progress” in this case will be the less advanced “Progress” of the 2 driving Stakeholders, i.e. the ASP or APO “Progress”.
This simple principle generates a simple and generic process. Assuming that the impact of a few “items” on the implementation completion has been assessed as negligible, or less relevant than the other “items”, they will be treated as “low-Key” and therefore disregarded in determining “Progress”.
When all “items” are deemed important and necessary in the completion of the Objective, the “Progress” of each of them will be considered in determining the overall “Progress”.
Step 1 / Initially consider the item having the lowest “Progress” among (in this order): (1) Missing Data, (2) No Plan, (3) Late, (4) Planned, (5) Partially Completed and (6) Completed.Step 2 / If that item is deemed as “low-Key” (low impact), you may disregard it and move to the next of the remaining items having the lowest “Progress”. Each time that you are considering a low-Key item, ignore it and re-do Step 2.
Step 3 / When an item has the lowest progress and is not a Low-key (Low impact), the “Progress” at overall level should be the same as that item’s “Progress”. The iterative process may stop here, as the next items, if any are left, would be of either the same or of a higher “Progress”.
Step 4 / “Partially Completed” vs. “Planned”: In case implementation is on-going and the overall “Progress” revolves around “Partially Completed”, with a few “Completed” actions but also with some more “Planned” actions, CP/FP may opt to further differentiate between the relevance (“weight”) of the actions or Stakeholders. The decision of whether to apply “Partially Completed” or “Planned” may be taken by considering the “Progress” of the “Key items”. In other words, applying “Planned” or “Partially Completed” may be decided by considering how much has been achieved vs. what more remains to be achieved.