9. Memorandum submitted by British
1. British Airways welcomes the opportunity
to submit evidence to the Home Affairs Committee inquiry into
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
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
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
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
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
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
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