40. Memorandum submitted by Virgin
Atlantic Airways
1. SUMMARY
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. INTRODUCTION
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. WORKING RELATIONSHIP
WITH THE
HOME OFFICE
AND BORDER
AGENCIES
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. HOME OFFICE
INITIATIVES
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. E-BORDERS
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. UK VISA REGIME
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. COSTS
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. GLOBAL STANDARDS
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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