Memorandum by the Airport Operators Association
INQUIRY INTO CONTROLS AT UK PORTS OF ENTRY
1.1 The Airport Operators Association is
the trade body for British airports and has some 72 airports in
membership. These airports are listed in Annex 1 to this memorandum
and cover virtually all of those open to commercial air traffic
ranging from the international hub airports, to all major regional
airports and those dealing with business, leisure and general
1.2 AOA welcomes the Inquiry by the Home
Affairs Committee as it will cover issues which are of particular
concern to our members and which have been the subject of consultations
with HM Immigration at an industry level over the past 12 months.
We also believe that the Inquiry will offer the opportunity for
some radical re-thinking which could form the basis for an entirely
new structure for border controls within the UK.
1.3 AOA does not intend to submit evidence
to the Committee covering those aspects of the Immigration and
Asylum Act 1999 that deal with civil penalties on carriers of
illegal immigrants nor any associated issues relating to the procedures
for handling immigration and asylum cases or issues arising from
any consideration of the UN Convention on Refugees. Our focus
is to submit evidence relating to the provision of facilities
at ports of entry (specifically airports) and the arrangements
for providing border controls at these points.
1.4 Underpinning our evidence is the strongly
held view that one basic principle must apply in relation to the
provision of effective border controls, namely that the provision
of such controls is a proper function of the State implemented
for the protection of the State and its citizens from illegal
entry. As such, the cost of providing effective controls must
be borne by those for whom the protection is provided ie the State
and its citizens.
2.1 Air transport to and from the UK is
widely forecast to double in the next 15 years. Based on current
statistics, this would mean around an additional 170 million passengers
using UK airports by 2015 of which a substantial number will be
travelling internationally. This forecast growth represents a
significant challenge for all parties involved and will, amongst
other things, require radical reviews of operating procedures
and the means of handling passengers. These challenges will have
impacts for border control agencies as well as airports and airlines.
2.2 Airports are actively working to meet
the challenges that this growth will create. Some examples of
this can be found in the Terminal developments completed and/or
planned at Bristol, Birmingham, London Luton, Newcastle and Heathrow
Terminal 5 in addition to the commissioning of an additional runway
at Manchester later this year. Airports would expect control authorities
to similarly plan strategic development to accommodate these future
challenges by examining initiatives including the use of existing
or emerging technology or, in the case of HM Immigration, of advancing
the proposals for in-flight clearances based upon passenger information
contained on airline manifests.
3. COST OF
3.1 Generally, UK airports have provided
channels and facilities directly associated with the clearance
of passengers at no charge to the control authorities. This represents
a significant contribution by industry to the operating costs
of these authorities. However, HM Immigration are progressing
proposals which seek to transfer more of the cost of facilities
and equipment provided at ports of entry to port operators. These
proposals are extensive and the current HM Immigration position
is set out at Annex 2.
3.2 Airports have consistently argued that
as the rationale for immigration control is the protection of
the State and its citizens from illegal entry it must follow that
the costs associated with providing such controls should be met
by those for whom the protection is intended ie the State and
its citizens. This view has not been accepted to date by HM Immigration
who continue to progress their proposals which appear to be driven
by Treasury requirements to reduce costs rather than on a rational
examination of how real efficiencies could be obtained.
3.3 AOA is extremely concerned over the
proposals being progressed by HM Immigration as they:
3.3.1 Would increase costs for airport operators
which would have to be recovered through increased charges to
airlines and ultimately their passengers.
3.3.2 Would release HM Immigration from
any financial responsibility for these operating costs and we
believe an important internal discipline of financial efficiency
and review would thus be lost.
3.3.3 Would not encourage HM Immigration
to be prudent in requests for facilities and equipment in the
knowledge that airport operators would be required to foot the
3.3.4 May prevent airports from progressing
necessary development projects as quickly as planned due to these
additional financial requirements being placed on them and the
loss of income from facilities for which HM Immigration currently
3.3.5 Are not based on any consideration
of efficiency, either operational or financial, and merely seek
to move the cost burden to another party.
3.4 Air transport is an extremely competitive
industry and UK airports continue to lead the world in demonstrating
how a consistent high quality, customer focused and cost effective
service can be delivered. Air transport also makes a contribution
to UK GDP in excess of £10 billion each year and delivers
some £2.5 billion each to the UK Exchequer with around £850
million coming from Air Passenger Duty alone. With this level
of contribution to UK finances we are more than a little concerned
that a Government agency is trying to increase our contribution
still further by seeking to transfer the majority of its facility
operating costs to airport operators.
3.5 Air transport operates as an efficient
cost conscious industry. We would recommend that the border control
authorities are encouraged to operate under similar disciplines
and work with airport operators to seek real efficiencies and
4. FUTURE ARRANGEMENTS
4.1 AOA understands the Government's wish
to reduce the cost burden to providing Immigration Services at
ports of entry and no doubt similar cost savings will, in time,
be sought for the other control authorities. These however should
be true cost savings and not cost transfers.
4.2 AOA strongly believes that the experience
of airport operators in developing efficient and cost conscious
businesses could well be of benefit in this debate. We consider
that there is real potential to secure significant economies and
efficiency gains in the provision of border control arrangements
without the need to pass on costs to port operators.
4.3 The air transport sector has changed
significantly over the last 20 years through, amongst other things,
a process of internal review and rationalisation. AOA believe
that by using these experiences, industry could work with Government
with a view to examining the advantages offered through the creation
of a single border control agency encompassing the functions
of HM Immigration, HM Customs, Special Branch and Port Health,
and possibly TRANSEC. We believe that this proposal is worthy
of serious consideration and would, as a minimum, appear to offer
economies of scale through flexibility of manpower, shared accommodation
and co-ordination of activities.
4.4 AOA understands that this proposal presents
a very radical concept but believes that if Government is not
prepared to think "outside the box" no real progress
will be made and that historic demarcations will continue unchallenged.
This would not be to the benefit of the industries alongside which
the control authorities work, tax payers, or to the principle
of forward looking and cost efficient government.
5. AOA would be pleased to submit oral evidence
to the Committee if this would be considered to be helpful.