Memorandum from Virgin Atlantic Airways
(TS 21)
1. Virgin Atlantic welcomes the opportunity
to submit evidence to the Transport Committee's inquiry into Travelling
without Fear. Ensuring the safety and security of our passengers
and crew is our number one priority and we fully recognise that
we have important responsibilities to assist the Government to
counter the terrorist threat.
2. Virgin Atlantic submitted evidence to
the Transport Committee's Preliminary Report on UK Transport Security.
The concerns raised in this submission remain valid, with the
exception of our position on the scrambling of military aircraft
on which significant progress has been made, and are repeated
below. We are pleased that the Committee identified some of these
as "Matters for further investigation" in its First
Report of Session 2005-06. Virgin Atlantic has also contributed
to the submission to the Committee from the National Aviation
Security Committee (NASC), of which we are an active member. Virgin
Atlantic fully endorses the NASC submission.
3. The UK Government has introduced a number
of measures to counter the terrorist threat and it is Virgin Atlantic's
view that any such measures should satisfy a number of requirements
before they are imposed. In summary, Virgin Atlantic believes
that any measure introduced to improve security should be proportionate
to the threat, practicable, capable of cost-effective implementation
and, whenever possible, utilise latest technology. It is important
that the measure does not unnecessarily hinder travel by air and
encourage modal shift. A thorough assessment of the risk being
countered and of the effect of the measure should be carried out
before implementation. Once a measure has been introduced there
should be a review of the measure at periodic intervals so ascertain
whether its continued imposition is necessary.
4. Virgin Atlantic has been particularly
disappointed with the lack of adequate Regulatory Impact Assessments
(RIA) being carried out prior to the imposition of many measures.
We understand that in certain circumstances, emergency security
measures may be required without an RIA, but it is our view that
a full RIA should be produced before such a measure is made permanent.
5. Finally, Virgin Atlantic would like to
re-iterate the point made in our initial submission about the
burden of costs. Virgin Atlantic is content to fund security measures
sufficient to meet the international base-line standards set by
the EU and ICAO. But additional measures that are necessary because
of the greater threat to the UK which results from UK Government
policy over which we have no say, should be paid for by the UK
Government itself. We believe that this is an important principle
with which we hope the Committee will agree.
G&EA
VAA
December 2005
ISSUES RAISED
IN SUBMISSION
OF 28 OCTOBER
2005
Lack of co-ordination across government departments
We remain concerned about the lack of co-ordination
across government on security issues and would urge government,
as a minimum, to expand the role of the Department for Transport's
Transport Security Division (TRANSEC) to include responsibility
for all initiatives relating to aviation security.
Lack of cross-border co-ordination
Virgin Atlantic, along with other airlines,
remains concerned at the role of the Safety Regulation Group of
the UK Civil Aviation Authority in relation to the European Air
Safety Authority (EASA). There is already considerable duplication
between the powers and responsibilities of SRG and EASA. Terrorism
does not respect borders—there is an urgent need for national
authorities to co-ordinate with international organisations to
work effectively together to establish global standards of airline
security.
Burden of costs
It should be borne in mind that terrorist action
is aimed at governments and not the airline industry. Virgin Atlantic,
in common with other airlines, reacted swiftly and effectively
to the need for increased vigilance and security following the
tragic effects of 11 September 2001. However, the burden of increased
security measures has been considerable, with European airlines
and airports paying out €3 billion for additional anti-terrorist
security measures imposed by EU governments. This can be contrasted
with the US, where the US Government has made an estimated US$32
billion available to US airlines in the form of financial aid
and loan guarantees.
Lack of review of security requirements
Layer upon layer of security measures are imposed
on airlines but no review seems to take place to go back and verify
the validity of previous measures when new ones are introduced.
A good example of this was the continuing ban on metal cutlery
despite the subsequent requirement to keep cockpit doors locked
throughout a flight. Amendments to the rules on cutlery were only
introduced after sustained lobbying from the airline industry.
Virgin Atlantic believes that the Government should undertake
a regular review of the validity of security regulations and measures.
December 2005
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