Select Committee on Home Affairs Written Evidence

40.  Memorandum submitted by Virgin Atlantic Airways


  1.1  Virgin Atlantic believes that the Home Office and Border Agencies must work closely with airlines on immigration control. The working relationship has improved but more still needs to be done. The e-Borders project represents a major opportunity to modernise the UK's border control and to set global standards. Virgin Atlantic supports the e-Borders initiative and we are content to work with the Border Agencies to implement it. However, it is clear that the vast majority of benefits accrue to the Government and consequently, we strongly believe that the Home Office should pay for the costs that would be incurred in modifying IT systems to collect data and in transmitting the data in the required format to the Border Agencies.


  2.1  Virgin Atlantic welcomes the opportunity to submit evidence to the Home Affairs Committee's inquiry into Immigration Control. Virgin Atlantic is the UK's second largest scheduled airline and brings over 2.5 million passengers into the UK each year. As such, we recognise that we have a major role to play in immigration control at the UK's borders. Virgin Atlantic works closely in partnership with the Border Agencies and we fully realise that we have important responsibilities to assist them in maintaining a secure border.

  2.2  The Committee's inquiry into Immigration Control is timely given the number of initiatives that the Home Office and Border Agencies have recently put forward in this area.


  3.1  The Home Office and Border Agencies have greatly improved their consultation and liaison with aviation industry stakeholders over the past couple of years. Lessons seem to have been learnt from the nadir of the Asylum and Immigration Bill in 2003 which was so heavily criticised by the Social Market Foundation in its August 2004 Report on Accountable Government. In this instance, a clause was inserted at the last minute and airlines were given six days to estimate the cost of compliance and no regulatory impact assessment had been published when MPs debated the bill.

  3.2  However, despite increased consultation at lower levels, doubts remain as to the extent to which there is Ministerial recognition about the impact of Home Office initiatives on airlines and how these initiatives support the Government's vision for future of border control. On this particular issue, Virgin Atlantic welcomes the Home Secretary's decision to establish on Air Industry Stakeholder Forum where Home Office Ministers and senior officials from the Border Agencies will meet regularly with senior airline and airport managers.


  4.1  Recent Home Office initiatives aimed at improving border control that impact directly on airlines include: Border Management Programme, Project Semaphore, e-Borders and Travel Document copying. Given the increase in the number of people travelling by air and using UK airports, Virgin Atlantic is concerned whether the Home Office has considered whether these initiatives and the way in which they use available technology will alleviate some of the problems caused by the growth in passenger numbers and the overcrowding at the UK's major airports or simply maintain current inadequate levels of passenger service. In our view, the Home Office should be working with the aviation industry to develop systems and processes that will not only make the border more secure, but will also improve the passenger experience. Virgin Atlantic believes that the lack of an obvious passenger service dimension to the Home Office border control strategy is a notable omission. After all, it should never be overlooked that over 99% of passengers pose no threat to the Border Agencies. Virgin Atlantic wants to improve the passenger experience and hence increase UK competitiveness and believes that passenger benefits such as immigration pre-clearance and automated biometric lanes will assist this.

  4.2  Virgin Atlantic is also concerned that when new immigration processes and requirements are introduced, there does not seem to be any review of existing ones to assess whether they are now redundant. Instead, layer upon layer of regulation is added resulting in unnecessary duplication of processes adding costs to airlines. Virgin Atlantic encourages the Home Office and Border Agencies to introduce new initiatives and utilise new technologies but to recognise that when doing so, previous systems and processes should be reviewed to see whether they can be stopped.

  4.3  It is also important that new initiatives are introduced and phased in at an appropriate pace so that airline operations are not adversely affected. This will require close co-operation and consultation between the Border Agencies and airlines. It should also be noted that many airlines, including Virgin Atlantic, are changing how they do business and are increasingly encouraging passengers to check-in on-line or to use self-service check-in kiosks at airports and other locations. This obviously has a significant impact on the contact that airlines have with passengers and with the timing and method by which passenger information can be obtained. In Virgin Atlantic's view, it is imperative that future initiatives are compatible with this trend if millions of pounds of investment in improving the passenger service experience are not to be wasted.


  5.1  Virgin Atlantic welcomes the "single window" concept for the provision of data by air carriers to the UK Government that is an integral part of the e-Borders project. Previously there has been a lack of co-ordination between Border Agencies when making requests for information and Virgin Atlantic has been asked for the same information by different agencies which is costly and time-consuming.

  5.2  The "authority to carry" (ATC) element within e-Borders has the potential to greatly assist the Border Agencies. However, Virgin Atlantic is concerned that a different system will be used to that of other countries that will add significantly to both costs and time needed to collect data. A global standard should be adopted.

  5.3  In discussions thus far in the IAN Bill Air Carriers' Consultation meetings, the Home Office have been unable to specify what the benefits, such as possible expedited passenger clearance of Immigration, might be. Virgin Atlantic believes that it is important that these are identified as soon as possible.


  6.1  In July this year, the charge for a UK visa was increased significantly, a multiple visit six month visa increased by 39% from £32 to £50. It is Virgin Atlantic's view that this increase represents a major economic disincentive to visit the UK. Although it is difficult to separate the effect of this visa fee increase from the effect of the London bombings in July, it is our view that this increase has had a significant and adverse impact on the applications for UK visas and thus the contribution of overseas visitors to the UK economy.

  6.2  Transit passengers are very important to most UK airlines including Virgin Atlantic. The requirement for Direct Airside Transit Visas (DATVs) for the nationals of many countries transiting at UK airports has an adverse effect on the attractiveness of using UK airlines and airports for indirect routes. We recognise that in certain cases a DATV regime is important but given its potential impact on UK airlines, we would encourage the Home Office to impose a requirement for DATVs with caution and only with good reason, and to periodically review the need for its continued imposition.


  7.1  All airlines, including Virgin Atlantic, have a heavy financial burden in respect of border control issues. These include the development of systems and processes to collect data required and to check documentation, carriers' liability fines, detention costs, presentation costs, repatriation costs and others. While Virgin Atlantic appreciates that it has responsibilities to assist with immigration control, we strongly believe that immigration control is essentially a function of government and that as such, the presumption should be that the costs of maintaining a secure UK border should fall to the UK Government. The Home Office have agreed to meet certain costs of recent initiatives, for example the scanners required to copy documents and the data transmission costs in Project Semaphore. These are welcome developments. Virgin Atlantic is content to provide the necessary staff and to incorporate the necessary data collection in our current processes provided it does not interfere with our operations, but we believe that in cases where new IT systems or significant investment in hardware are required, the Home Office should meet the costs.

  7.2  Virgin Atlantic welcomes the statement in the Regulatory Impact Assessment (RIA) provided for the Immigration, Asylum and Nationality Bill 2005 that "e-Borders will initially be funded mainly from the Home Office/IND budget and ongoing costs will be incorporated in the planned expenditure of the relevant agencies." We also note that "it is forecast that the financial benefits for all the Agencies involved will significantly outweigh expenditure" (emphasis added). Despite these clear statements, it is also stated that "additional work is underway to establish the practicality of charging passengers a small fee to cover costs." Virgin Atlantic has two fundamental issues with this last statement. Firstly, if the two earlier statements were true, why would there be any need to charge passengers. The Home Office believes, and Virgin Atlantic agrees, that e-Borders will achieve significant and substantial savings to the Border Agencies. Secondly, even if the costs of e-Borders was not to be exceeded by savings, we do not believe that the passengers, who already pay an Airport Departure Duty, passport fees and visa fees, should be further charged to pay for e-Borders. Aviation is a price sensitive and competitive industry and the introduction of such a charge would harm carriers who are working in partnership with the Home Office to assist them in delivering e-Borders. In addition it is likely that the administrative costs of any system of collection would outweigh the actual amounts collected.

  7.3  The RIA identifies savings to central Government of £1.46 billion over the next 15 years. Over the same period, the savings to Virgin Atlantic are approximately £3 million through the removal of the requirement to provide passengers with landing cards, the removal of carriers' liability fines and the removal of detention/repatriation costs. It is Virgin Atlantic's strongly held contention that the significantly greater savings to the UK Government should be used to offset the infrastructure and transmission costs.


  8.1  Virgin Atlantic is concerned about the lack of relevant and appropriate fora available to develop a proper dialogue with foreign Governments on a global approach to many immigration issues. This is particularly the case with regard to the use of biometrics. Neither airlines nor passengers want to have to use different documents or procedures depending on which country they are travelling to. It is our view that the UK Government should take a lead in developing globally accepted standards.

Nigel Milton

Manager, Government & External Affairs

5 December 2005

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