Select Committee on Home Affairs Written Evidence

5.  Memorandum submitted by bmi

  1.  bmi welcomes the opportunity to submit evidence to the Home Affairs Committee's enquiry into Immigration Control. Whilst the Committee seeks evidence on a wide range of topics, our content will be limited to e-borders including biometrics.

2.  BMI

  bmi is Heathrow's second largest operator. The airline operates a network of 2,400 flights a week, approximately 1,050 being at Heathrow. We serve 22 destinations on domestic, European, transatlantic, Indian and Arabian routes. The group has a fleet of 56 jet aircraft. In 2004 the bmi group carried over 10 million passengers.

  The bmi group comprises mainline operations (based at Heathrow), long haul services (transatlantic services based at Manchester, India and Saudi Arabia services based at Heathrow), bmi regional (serving the UK regions, based at Aberdeen) and bmibaby (low cost services, based at regional UK airports).


  bmi fully supports the objectives of the e-Borders project in its quest to enhance the security of the United Kingdom through more efficient border control management. The accrued benefit with respect to the prevention of boarding to those individuals who would not normally be granted entry clearance are recognised, providing the implementation costs of any proposed scheme are proportional. We maintain our view that border management remains a primary State responsibility the costs of which should not be borne by transportation carriers.

  bmi, like other British airlines, has a good day-to-day working relationship with UK border control agencies. We also value highly the recent establishment of high-level contact with those agencies. We look forward to making a positive contribution in maintaining secure UK borders.

  bmi is a member of the British Air Transport Association (BATA) and the Board of Airline Representative in the UK (BAR-UK). We associate ourselves with representations made by BATA and BAR-UK to the committee's deliberations.


  Within the explanatory phase of the e-Borders project, bmi is grateful for the opportunity to participate in Project Semaphore and to work in partnership with the project team. Whilst an intention exists to influence operational and technical development, we will be seeking reimbursement of our costs associated with the provision of passenger data. This we consider to be a reasonable request given that the Partial Regulatory Impact Assessment (RIA) of the Immigration and Nationality Bill concludes financial benefits of government agencies to be considerably greater than expenditure.


  An "interactive" authority to carry scheme is the long-term goal of the e-Borders programme that seeks to electronically screen passengers prior to boarding. We remain concerned about the practical implementation of this system.

  5a.  Given the emerging data requirements of various governments world wide, it is essential that a coherent and global standard is established if carriers are to avoid unnecessary and extremely costly system development. bmi urges the UK Government to promote the recognition of one global standard and to actively engage with other States in order to achieve consistency.

  5b.  It is our current understanding that ATC will be applied only to inbound services departing "to" the United Kingdom for which the practicalities of implementation require some consideration. Accordingly, the provision of facilities and communication networks to support the scheme could prove challenging in many overseas airport locations, and some UK airports, particularly those served infrequently. We believe it to be incumbent upon the government to recognise these difficulties when considering enforcement.

  5c.  Like many forward thinking, customer driven carriers, bmi is investing heavily in technology to facilitate various business processes for improved efficiency and to reduce airport congestion. The benefit of our investment in both kiosk and internet check-in will be severely reduced if the introduction of an ATC scheme results in referrals to conventional "manned" airport check-in desks.

  5d.  We understand that the government proposes a 24 hours, seven days per week telephone help line to handle passenger enquiries from those refused travel on a failed ATC. Whilst further discussion undoubtedly has to take place around the practicalities of its introduction, we remain concerned that such a facility will lack the capability to handle the anticipated volume. Given the time critical response time expected in some cases close to departure, delays could result in passengers missing their planned flight.

  5e.  It is not unreasonable to expect that tangible carrier and passenger benefits are commensurate with industry participation in e-Borders, for example an expedited clearance process upon arrival including separate automated biometric lanes.


  Considerable confusion remains about the introduction, nature and use of biometrics. For example with respect to interoperability of "coded" data and to what degree governments will permit carrier access and the method by which any biometric data may be collected for transmission within API/ATC messages. Until more information can be provided it is difficult to determine how biometric functionality can be incorporated into our business processes.


  The introduction of additional processes brings extended check-in transaction times and thus will certainly add to our operating costs. The deployment of new equipment to meet e-Borders requirements is a serious concern. According to paragraph 39 of the RIA dated 16 June 2005, the accrued quantified benefits to government over a 15-year period to year 2018 amount to £1,466 million, significantly greater than those attributed to carriers which are associated with a reduction in the carriage of "inadequately documented" passengers. Many carriers, including bmi, have invested resource, time and effort into achieving "Approved Gate Check" status that successfully mitigates the impact of certain charges imposed through the Carriers' Liability Act.

  7a.  Furthermore, the introduction of biometric requirements, including the collection of data, will place considerably more financial burden upon carriers in respect of the cost of equipment, additional processing times and increased data transmission costs.

  7b.  The financial benefit to Government of e-Borders should serve to reduce the charges imposed by Carriers' Liability, the cost of detention & of facilitating removal at carrier expense.

  7c.  Given, therefore, the disparity in benefits between government and carrier, we maintain that the e-Borders costs should be absorbed by the government.

Nigel Little

Ticketing and Immigration Affairs

Peter McClymont

Manager Industry and Government Affairs

1 December 2005

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