Select Committee on Home Affairs Appendices to the Minutes of Evidence


Memorandum by Birmingham International Airport Limited


  1.  The Home Affairs Committee of the House of Commons is conducting an inquiry into the physical controls which operate at UK ports of entry. Birmingham International Airport Limited (BIA) is submitting this written memorandum to comment on some, but not all, of the issues identified in the Press Notice announcing the inquiry. BIA is a member of the Airport Operators Association which has also submitted a memorandum and which BIA fully endorses.

  2.  BIA welcomes the inquiry being undertaken by the Home Affairs Committee as it gives the opportunity to raise a number of concerns, which we have. In particular these relate to a consultation exercise recently undertaken by the Immigration Service Ports Directorate into the "Provision of facilities at ports and charging for additional services".

  3.  BIA is the UK's fifth largest airport and the second largest outside London. In 1999 the airport handled seven million passengers of which approximately 30 per cent or over two million were travelling for business. The balance were travelling for leisure reasons with a significant proportion of these leisure passengers being overseas visitors to the Midlands. The reason for including these statistics is to emphasise that the airport serves the whole region and that the economy of the region, and its citizens, benefits significantly from the airport's presence and growth. We believe that it is wrong to suggest that the only beneficiaries from growth in travel are the passengers, carriers and port operators and instead would contend that the greatest beneficiaries are the regions and economies that are served by the ports and airports concerned. We, therefore, believe that there is a fundamental principle which should apply in relation to the provision of border controls and that is that they are a proper function of the State in order to protect the State and its citizens from illegal entry. As such the cost of funding these controls should be borne by those who benefit from this protection, namely the State and its citizens.

  4.  The issue of the future funding of border controls stems from the White Paper "Fairer, Faster and Firmer—a Modern Approach to Immigration and Asylum", which raised the possibility that passengers, carriers and port operators would be asked to bear a greater proportion of the costs of the immigration control in the future, with a view to producing a better balance of costs shared as between taxpayer and commercial sector. One of our key concerns is that any moves to make the user pay for immigration services is that it will further impair the UK's competitive position in a number of major industries. Indeed industry as a whole is becoming increasingly global in nature with the ease and cost of accessibility to the rest of the world becoming more and more important. Air travel is a key component of this accessibility with access to comprehensive air services being a major factor in company location decisions. With the UK being essentially a trading nation the provision of high quality and cost-effective air services is essential to future economic prosperity. The introduction of any measures which have the impact of increasing the cost of air travel from the UK relative to the cost of air travel from countries with which the UK is competing for business can only have the effect of reducing the UK's competitive position. The impact of the proposals for the future funding of immigration facilities is to do exactly that.

  5.  The areas of the UK economy which we believe would be significantly affected by any proposals to make the user pay for the costs of immigration control would be key growth industries such as overseas tourism. There is already evidence that the UK is losing market share in overseas tourism to competing European countries with cost being an important factor. The current high value of sterling is likely to be an important causal factor but UK taxes on air travel to the UK are also likely to have an impact as well. The Air Passenger Duty is a prime example of such a tax but any future proposals for the funding of immigration control may well have a similar impact. Therefore, whilst getting users to pay for immigration control may assist in funding the immigration service the perceived benefits from doing this are likely to be significantly out-weighed by the cost of "lost" business to the UK due to resultant reduction in the UK's competitive position. The impact may well be most acutely felt in the tourism industry where the consumer bears the whole cost of any increase and who is often very sensitive to such increases.

  6.  Airport and port operators already provide extensive physical facilities to enable the proper functioning of immigration controls. However, the proposal is to add considerably to the list of facilities which port operators will be required to provide free of charge. We do not believe that the costs to port operators have been properly quantified or considered in any detail and, therefore, believe it is unreasonable to expect port operators to agree to such open ended commitments. Indeed we would suggest that any indications of the cost to port operators which may be given by the Immigration Service in terms of a Regulatory Impact Assessment may be fundamentally flawed and may have seriously under estimated the true costs.

  7.  The Consultation Paper referred to in paragraph 2 above contains a definition of the "Basic Service" which will be provided by the Immigration Service and above which the port operator would be required to fund. However, it has been impossible to offer any constructive comment on these proposals due to the totally inadequate definition of what constitutes the basic service. Despite this the Immigration Service claims that it has consulted with port operators and has taken account of their concerns.

  8.  It is evident from our response that we have focussed on only one particular aspect of the Home Affairs Committee's inquiry. However, this reflects the wide nature of the issues to be considered by the inquiry and BIA's ability to only be able to comment on a limited number of these issues.

May 2000

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