Memorandum by easyJet Airline Co. Limited
(TS 15)
INTRODUCTION
easyJet welcomes the Transport Committee's inquiry
into steps taken to protect the travelling public from terrorist
violence. In particular, the Transport Committee has correctly
identified the importance of looking at the issue across the transport
modes. In easyJet's view, it is crucial to appreciate the distinction
between the nature of the threat to our transport systems and
the safety measures required to address the varying risks across
the transport modes. In easyJet's view, there is a lack of consistency
between threat assessment and risk assessment across the different
modes of transport.
In the aftermath of the 11 September 2001 attacks,
air transport is in a unique position to offer insight into the
issues at stake and the best way forward to protect the UK's transport
systems from violent attacks. Within the UK alone, easyJet has
10 bases (Belfast, Bristol, East Midlands Nottingham, Edinburgh,
Gatwick, Glasgow, Liverpool, Luton, Newcastle and Stansted airports)
and also operates services to and from Aberdeen, Bournemouth,
Doncaster and Inverness airports. With over 30 million passengers
per year, easyJet is fully supportive of any improvement to the
current regime governing transport security.
This paper sets out easyJet's written evidence
for this Inquiry.
THREAT ASSESSMENT
Requirement to clearly distinguish threat from
risk
The Government's assessment of the terrorist
threat to the UK's transport infrastructure is over-complicated.
In easyJet's view, this is explained by the Government's genuine
attempt to provide industry with specific information when communicating
the level of threat. The problem lies in the Government's efforts
to differentiate the threat for different transport modes. In
doing so, basic principles of threat and risk assessment become
confused.
Whilst the Security Service must rightly assess
the threat from terrorism to national interests, this should be
communicated as one clear national threat level for all transport
modes. Once the national threat has been identified, a separate
assessment is required for the residual risk(s) attached to it.
This is where the Transport Committee's inquiry should focus the
debate. There is no doubt that the threat to transport is well
understood and that combined with a relatively high threat, the
inherent risk is therefore also quite high. However, different
levels of countermeasures on the different transport modes result
in different levels of residual risk for each mode. This is the
key area of risk management on which the Department for Transport
should focus its efforts.
RISK ASSESSMENT
A consistent framework that can be applied across
all transport modes and at local level
This brings us to the heart of the matter and
where air transport offers a particular solution for all transport
modes. There needs to be a consistent framework for risk management
within which risks can be adequately addressed. The primary role
of the Department for Transport is to determine the baseline countermeasures
necessary to mitigate the inherent risk on each transport mode.
In air transport, the vehicle for risk management
is the National Aviation Security Committee and any measures are
communicated through the National Aviation Security Programme.
Local risk assessment is carried out at individual airports through
the process of a Multi Agency Threat and Risk Assessment (MATRA).
This process was created following the recommendation of Sir John
Wheeler in his review of airport security, which was commissioned
jointly by the Department of Transport and the Home Office after
the robberies at Heathrow in February 2002. MATRA provides an
opportunity to identify specific local vulnerabilities and to
tailor local counter measures to mitigate residual risk. It also
provides for the allocation of clear accountabilities for risk
mitigation, delivery of counter measures and quality control.
In easyJet's view, this is a successful process
which should be extended to other transport modes.
CLARITY OF
RESPONSIBILITY
Remove existing confusion between the Government,
Police and Industry
In easyJet's view, the main failing of the current
system for air transport relates to policing. Whilst the Government
will determine policy, industry is charged with the implementation
of such policy. However there is a lack of clarity over the responsibilities
entailed in practice, which stems from the confusion on national
threat and risk levels. This lack of clarity is particularly evident
in the policing responsibility as seen on 8 July 2005 with three
different threat levels within the boundaries of Gatwick Airport:
the lowest on aviation pertaining to the Restricted Zone, a higher
level for the public landside areas, and a critical level pertaining
to the railway platforms.
The Police have a role in developing contingency
strategies to cope with managing residual risks that cannot be
entirely eliminated. It is difficult to develop a cohesive risk
mitigation policy when there are 43 Chief Constables with autonomy.
Furthermore, there is reluctance on the part of the Police to
share their rationale for the airport policing plans. The result
is clear: the Police struggle with residual risk and therefore
have become risk averse. The police provide a response capability
rather than mitigation.
This situation could be improved by extending
the role of the British Transport Police to cover all modes of
transport, including aviation. This would have the benefit of
placing all the responsibility for risk management and contingency
plans under the Secretary of State for Transport. It would facilitate
clear accountabilities and allow a MATRA framework to work more
effectively as a collaborative effort to manage risk rather than
a competitive forum for obtaining funds and resources. easyJet
believes that the perennial arguments over funding would be eased
by this shift in responsibilities and by having a similar framework
for the different modes of transport there would be avoidance
of one form of transport receiving preferential subsidy over another..
All of this would result in one clear, cohesive security plan
for each individual airport, port, station and depot. Clearly
this is something that all stakeholders would welcome.
CONCLUSION
In conclusion, easyJet commends the Government
for its handling of and response to the events of 7 and 21 July
2005. Unlike the response of the US Administration to 9/11, there
was no knee-jerk reorganisation of Government and no panic introduction
of unreasonable and ill-considered counter measures. However,
easyJet believes that the time is right to consider in depth the
issues raised by the Inquiry and therefore urges the Committee
to consider the following proposals:
1. The publication of one national threat
level and different inherent risk levels for each mode of transport.
2. Adopt a MATRA framework across all modes
of transport to determine and manage local vulnerabilities and
residual risk.
3. Security policy, including policing,
to rest with the Secretary of State for Transport to mitigate
inherent risk on all modes of transport.
The issues raised by the Committee are fundamental
ones and any debate is greatly welcome. easyJet looks to the Committee
to make a recommendation to the Government along the lines mentioned
above. easyJet hopes this evidence proves informative and we remain
at the Committee's disposal to provide any further information
or oral evidence it may require.
December 2005
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