APPENDIX 6
Memorandum submitted by The Airport Operators Association (F9)
1. The Airport Operators Association (AOA) is the trade body that represents and speaks for Britain's airports and draws its membership from the nation's international hub airports, all of the major regional airports and a significant number of those providing facilities for business, training and leisure aviation. A full listing of AOA member airports is attached at Annex 1.
2. AOA fully supports the government's principal objective of seeking to prevent the illegal importation of meat and food products into the UK as a means of limiting the risk of disease. The government's action plan appears to offer a sound basis for implementation of the necessary controls, though it is important that the main action is focused onto those areas where the risk to public health is the greatest; this may not be at airports. However, we believe that the action plan could be improved by fundamentally addressing the key issue of the way in which UK border controls are organised.
3. The essential issue which the government is addressing in its action plan is one protecting public health through the implementation of effective border control. In this respect, AOA would reiterate the need for government to seriously consider the establishment of a single border control agency. This proposal was contained in AOA's evidence to the Home Affairs Committee's inquiry into Border Controls in 2000 and in its subsequent report the Committee recommended adoption of this general approach (Report HCP 163-I).
4. While the government's action plan proposes "more co-operation to achieve effective inter-agency enforcement" it would appear to stop some way short of advocating the creation of a single border control force. AOA believes that the creation of a single border control force encompassing HM Customs, Immigration, Special Branch, Port Health and possibly Transport Security could have significant advantages including:
— The development of an intelligence based approach to detection;
— Greater sharing of intelligence between agencies;
— Combination of operational databases across the various agencies;
— Greater co-ordination of operational activities;
— Improved border control.
5. In respect of the personal importation of illegal foodstuffs several of our members have questioned the practicability of "amnesty" or "sins" bins located in Customs Halls. While they recognise that the rationale behind these proposals is to encourage the surrender of unintended illegal imports, there are practical issues relating to the collection and disposal of goods surrendered. AOA does not support direct involvement of airports in these processes and it should be an issue for the appropriate border agency, Customs or Port Health, to make the necessary arrangements for collection and disposal.
6. AOA also notes that the government's proposals include provision for examining the potential benefits of using X-ray equipment to scan containers and personal baggage to detect illegal imports. Airports would be prepared to work with government in the development of such proposals but initial thoughts are that the introduction of X-ray equipment for baggage arriving in the UK could have implications for airport baggage arrival design assuming that such equipment was located at a point before baggage was reclaimed by the passenger and subsequently presented in the Customs Hall.
7. AOA believes that a more effective form of control might well come from adopting the approach taken by HM Customs, which relies largely on applying upstream intelligence to target the highest risks.
8. AOA trusts these views and observations will prove helpful.
Keith Jowett
Chief Executive
17 May 2002
Annex 1
AOA AIRPORT MEMBERS
BAA Plc
Glasgow International Airport
Belfast City Airport
Birmingham International Airport
Blackbushe Airport
Blackpool Airport
Bristol Filton Airfield
Bristol International Airport
Cambridge Airport
Carlisle Airport
Chester Hawarden Airport
Chichester Goodwood Aerodrome
City of Derry Airport
Coventry Airport
Denham Airport
Dundee Airport
Elstree Aerodrome
Exeter International Airport
Fairoaks Airport
Farnborough Airport
Glasgow Prestwick International Airport
Gloucestershire Airport
Guernsey Airport
Highlands & Islands
Isle of Man Airport
Jersey Airport
Leeds Bradford International Airport
London Battersea/Metro Heliport
London City Airport
London Manston Airport
Lydd Airport
Manchester Airport Group
Bournemouth Int'l Airport
Humberside International Airport
Manchester Barton Aerodrome
Newcastle Airport
North Denes Aerodrome Ltd
Norwich International Airport
Oxford Airport
Peel Airports Ltd
Liverpool John Lennon Airport
Peterborough Business Airport
Redhill Aerodrome
Regional Airports
London Biggin Hill Airport
Retford (Gamston) Airport
Scottish Airports Ltd
Shoreham Airport
Swansea Airport
Sywell Aerodrome
TBI Plc
Belfast International Airport
Cardiff International Airport
Teeside International Airport
Thruxton Aerodrome
Warton Aerodrome
Wolverhampton Business Airport
Wycombe Air Park
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