Select Committee on Home Affairs Written Evidence

9.  Memorandum submitted by British Airways


  1.  British Airways welcomes the opportunity to submit evidence to the Home Affairs Committee inquiry into Immigration Control.

  1.1  The airline's main base is London Heathrow Airport, the UK's primary international hub airport and one of the busiest airports in the world. British Airways also operates from 11 other airports in the UK, and worldwide, to 153 destinations in 70 countries. Its franchise partners take the airline's colours to an additional 85 destinations in a further 17 countries.

  1.2  In 2004-05, British Airways carried 35 million passengers across its network, 30 million of those on international journeys. Passport and immigration checks are carried out at all the airports we serve, and training of customer service representatives is done by the airline itself.

  1.3  British Airways is the fifth largest airline in the world, measured in terms of passenger kilometres travelled, and the largest outside the United States on this measure. BA employs around 47,000 employees worldwide, 80% of whom are based in the UK, and generates annual revenues of £7.8 billion (2004-05).


  2.  The evidence submitted in this memorandum focuses on e-Border operations, including biometrics.

  2.1  British Airways welcomes the "single window" concept associated with the e-Borders project, which allows for all data to be captured at a single source. The "single window" is an improvement on the current costly and complex method of sharing data across a number of different agencies.

  2.2  British Airways is currently participating in the on-going "Project Semaphore", the name given to the trial of the e-Borders scheme. Arrangements are in place whereby certain costs that are associated with the transfer of passenger information as required by the project are met by the Immigration and Nationality Directorate (IND). It is the airline's intention to recharge the costs of providing such passenger information to IND when the eBorders project is launched.

  2.3  e-Borders features an "Authority to Carry" (ATC) scheme. To be effective, it is essential that a common and global standard be established for the exchange of data between airlines and government. If different ATC schemes are introduced by individual countries which vary from others, it will result in duplication, complexity, unnecessary cost, and delays and inconvenience to passengers.

  2.4  It is vital that ATC processes allow for the continued use of emerging online check-in procedures for customers. British Airways has invested heavily is automating its processes in recent years in line with customer expectations. Such investment would be wasted should large numbers of customers be forced to report to manned airport check-in desks. This would also cause serious congestion at airports that are already over-crowded.

  2.5  e-Borders will extend check-in transaction times for our customers and the additional resources required will add to operating costs in an industry that has slender margins.

  2.6  However, we do anticipate benefits for passengers on their arrival in the UK, for example, pre-clearance and automated biometric lanes. Moreover, e-Borders can facilitate measures that could reduce other charges imposed on carriers by IND, for example, Carriers Liability charges and related detention costs.


  3.  British Airways provides passenger information to the Immigration and Nationality Directorate (IND), Her Majesty's Revenue and Customs (HMRC) and the Police by various methods. This has created additional cost and complexity for all parties concerned. We therefore welcome the principle associated with e-Borders where information provided to the border control agencies is delivered by means of the "single window" concept.

  3.1  British Airways is privileged to have participated in the early phase of Project Semaphore, the test bed for e-Borders. At present, we provide Advance Passenger Information (API), by means of our Departure Control System (DCS) and Passenger Name Record (PNR) information from our reservations system, on nine routes to and from the UK, namely: Bangkok, Beijing, Shanghai, Dubai, Islamabad, Johannesburg, Kingston, Miami and Washington. We have been asked by the IND to provide data on a further 10 routes, and we expect to be able to meet this request by early 2006.

  3.2  Amadeus, a third party computer reservations system, is contracted to operate the British Airways reservations and DCS systems. Currently, Amadeus charges British Airways for the extraction of PNR data. Furthermore, it may levy additional transaction fees in the future for the extraction and transmission of API data.

  3.3  Project Semaphore has created additional cost for British Airways through the collection and transmission of passenger information. We are grateful that the IND recognises this and has agreed to cover the costs of providing PNR data during the life of the project.

  3.4  It is our intention to recharge the costs of providing PNR and API data to IND when e-Borders is launched. We plan to employ transmission procedures that minimise costs, which nevertheless are still expected to be in the region of £2.5 million per annum. We seek an assurance from Government that these costs will be met by the control authorities. This is not an unreasonable expectation in light of paragraph 38 of the Immigration and Nationality Bill Regulatory Impact Assessment, as follows:

    e-Borders will initially be funded mainly from the Home Office/IND budget allocation and ongoing costs will be incorporated in the planned expenditure of the relevant agencies. In the medium to long-term it is forecast that the financial benefits for all the agencies involved will significantly outweigh expenditure. In addition work is underway to establish the practicality of charging passengers a small fee to cover costs.

  3.5  British Airways does not agree with the premise that airline passengers should be charged "a small fee to cover costs", in addition to other taxes, fees and charges required worldwide, including Air Passenger Duty. The contribution of e-borders in reducing crime, terrorism and illegal immigration in the UK will benefit the population as a whole. It is therefore logical that the same population should meet the costs through general taxation.

  3.6  The "Authority to Carry" (ATC) scheme is expected to replace current API procedures. The ATC scheme involves airlines sending electronic messages from overseas check-in and boarding points to the Joint Border Operations Centre (JBOC) as passengers check-in for their flights. The JBOC, based in the UK, responds immediately to the airline with an appropriate "board" or "no-board" response.

  3.7  Other governments are developing similar concepts: Australia already operates Advance Passenger Processing (APP) and the USA has plans for a similar scheme, APIS Quick Query (AQQ). It is essential that a common global standard be established for the exchange of data between airlines and governments. As outlined above, unnecessary cost and complexity will be introduced if different ATC schemes are implemented. British Airways calls on the UK government to press for an international standard.

  3.8  British Airways has invested substantially in enhanced customer service processes to minimise delays at airports. It has introduced self-service and on-line check-in facilities that enable customers to check-in for their flights either remotely using the internet or by self-service machines at airports. Both of these methods greatly reduce the time customers spend waiting to check-in, and they will gradually supersede conventional manual processes. It is vital that ATC processes allow for their continued use, for both customers, airlines an airports.

  3.9  In 2008, British Airways will move its operations at London Heathrow Airport to Terminal 5. To safeguard the operation and ensure a seamless transfer, we will embargo any systems developments and major process changes affecting Heathrow for a period of approximately two years commencing in 2007. As the major carrier of travellers to and from the UK, we would ask that the e-Borders implementation plan respects this limitation on development.

  3.10  We are concerned that ATC operations will extend check-in transaction times for customers and increase operating costs. For passengers in possession of machine-readable documents, we recognise that the additional time to check-in will be minimal. However, for those with non-machine readable documents, which include nationals from a wide range of countries, the additional time required could be more than one minute per passenger.

  3.11  Airlines expect to see a direct customer benefit as a result of the ATC scheme. Special clearance facilities (Fast Track Immigration lanes) at airports of arrival should be available as a basic outcome, and automatic clearance facilities must be the goal. British Airways hopes that the number of passengers using the IRIS biometric lanes at UK airports will increase. Furthermore, we wish to see those passengers whose biometric fingerprints are taken when visas are issued to them at British consular offices overseas using automated biometric booths on their arrival in the UK.

  3.12  British Airways acknowledges that the e-Borders scheme may have advantages for the UK in general, but it is difficult to identify any real benefits for the airline industry or travellers. However, it is possible that there may be a reduction in charges currently imposed on British Airways by the IND, namely in respect of Carriers' Liability and detention costs.

  3.13  We propose that charges should not be imposed if the JBOC grants an "Authority to Carry" notice for a passenger who is then deemed to have incorrect documentation on arrival in the UK. For example, the JBOC checks carried out following submission of the required API data by the airline could include a check of the UKvisas database. The response to the airlines' API submission would be "board" if the check proved positive. Where such "ATC" is approved, the carrier should not then be liable for a Carriers' Liability charge or any related detention cost.


  4.  British Airways recognises the requirement for improved immigration controls to the UK. It understands the pressures imposed on the UK authorities to upgrade and improve the procedures to deal with immigration issues. The airline believes the IND is genuine in seeking to co-operate with the travel and transport industry to achieve a workable solution to the challenge it faces, and commends the directorate for its inclusive approach. There is no ideal solution to the problem that meets the requirements of all parties, but it is hoped that co-operation and practicality will result in a better and more efficient immigration control system to meet the needs of the UK in the 21st Century.

2 December 2005

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