APPENDIX 11
Memorandum by Birmingham International
Airport Limited
INQUIRY INTO PHYSICAL CONTROLS AT UK PORTS
OF ENTRY
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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