Select Committee on Home Affairs Appendices to the Minutes of Evidence


Memorandum by the Airport Operators Association



  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 aviation.

  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.


  3.1  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 bill.

  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 pay.

  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 productivity gains.


  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.

April 2000

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