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).
3. PREAMBLE
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.
4. PROJECT SEMAPHORE
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.
5. AUTHORITY
TO CARRY
(ATC)
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.
6. BIOMETRICS
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.
7. COSTS
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
| 
