Memorandum from Airports Council International
(ACI) (TS 53)
1. INTRODUCTION
1.1 ACI is the voice of airports worldwide.
It has 567 members operating over 1650 airports in 176 countries
and territories. In 2005, ACI members handled 4.2 billion passengers,
81.8 million metric tonnes of freight, and 71.6 million aircraft
movements. There are 32 ACI member airports in the United Kingdom.
1.2 ACI advances the interests of the world's
airports and promotes professional excellence in airport management
and operations. ACI is committed to maintaining a safe, secure,
environmentally compatible, efficient and prospering air transport
system.
1.3 ACI has its World Headquarters in Geneva
and has regional offices in Washington D.C, Brussels, Hong Kong,
Merida, Casablanca and a liaison office in Montreal. Through its
Geneva and Montreal offices, ACI interfaces with the International
Civil Aviation Organization (ICAO), other U.N. agencies and aviation
industry related associations. The other offices have a regional
focus, representing the interests of airports at a regional level
while providing a range of support services. The ACI Europe office
interfaces with the European Commission and the European Civil
Aviation Conference.
1.4 Airports Council International (ACI)
thanks the Transport Select Committee for this invitation. Having
reviewed the Committee's Terms of Reference, ACI would like to
raise three principles which it considers pertinent to the scope
of the study. These are:
— States have an unequivocal responsibility
to protect their citizens.
— Aviation security measures should
be risk-based, proportional and balanced with the needs of facilitation[6].
— Security measures should be harmonized
internationally.
2. STATES HAVE
AN UNEQUIVOCAL
RESPONSIBILITY TO
PROTECT THEIR
CITIZENS
2.1 Over the years, acts of terrorism have
been committed against civil aviation at airports and on aircraft.
However, the real target of the attack is the State. Terrorism
is the pursuance of political aims through violent and criminal
means. States have an unequivocal responsibility to protect their
citizens and the citizens of other states travelling through or
over their sovereign territory.
2.2 After the terrorist attacks in the US
on 11 September 2001, we have seen in many countries greater recognition
of this responsibility through the reorganisation of governmental
agencies under a new banner of "homeland security".
However, in most cases, airports continue to carry the responsibility
and burden of implementing or facilitating aviation security measures.
Even in places where governmental agencies do provide the security
measures, airports have incurred huge infrastructural costs in
facilitating such measures, invariably without an adequate or
appropriate means of recovery.
2.3 Funding aviation security measures,
as with other facets of national security, should be a State's
responsibility. In the years following "9/11" aviation
security measures and their costs have increased substantially.
All too often we have seen administrations cite the "user
pays" principle to justify passing this cost onto airports,
airlines and the travelling public. However, it is anomalous that
the cost of safeguarding other sectors of public transportation
systems has often remained on the public account. This has raised
the cost of air travel and reduced its competitiveness.
2.4 Civil aviation will remain a target
for terrorists. Airports, airlines and the public (both those
working in the industry and those travelling) remain at risk.
Security measures are also likely to increase in response to the
new threats. The current situation where airports, airlines and
the travelling public are bearing the cost of this facet of national
security is neither fair nor sustainable.
3. AVIATION SECURITY
MEASURES SHOULD
BE RISK-BASED,
PROPORTIONAL AND
BALANCED WITH
THE NEEDS
OF FACILITATION
3.1 Good facilitation at airports relies
on the expeditious, safe and efficient flow of aircraft, people
(principally passengers), baggage, cargo, information and goods.
Airport facilities and processes are designed with this objective.
Efficiency is critical if the civil aviation system is to optimize
the use of air space, runways, terminal and ground facilities.
Airports are under increasing pressure to cope with continuing
growth in aircraft, passenger and cargo movements.
3.2 Against this back drop, security measures
have to be implemented to secure aerodromes, to prevent unauthorized
access and to safeguard the aircraft and travelling public. Aviation
security has traditionally relied on a layered or ringed approach
to security, to eliminate single points of failure. With time,
therefore, we have seen regulatory authorities prescribe more
and more preventive measures. Invariably these measures have some
impact on the facilitation process and it has been the perennial
challenge for airport managers to reconcile the facilitation needs
with the aviation security requirements.
3.3 Security measures need to be risk-based,
proportional and continuously reviewed in the light of the changing
risk profile. In reviewing their requirements, regulators should
take a holistic view of the level of protection provided rather
that viewing measures in a piecemeal fashion. There is often reluctance
on the part of regulatory authorities to critically review and
remove a requirement once it has been introduced, even though
the risk may have been adequately addressed through another, more
recent measure. As a result, airports are finding it increasingly
more difficult to maintain acceptable levels of facilitation.
Indeed, additional security requirements are causing delays, airport
system problems and levels of inconvenience to passengers on an
unprecedented scale.
3.4 Airports and airlines are harnessing
technological advances to increase the efficiency of their processes,
reduce operating costs and improve services to their customers.
Many of these require the reengineering of existing processes
that have aviation security controls placed on them. There is
a need for regulators to work actively with industry partners
to find ways in which such advances can be facilitated while still
achieving the security requirements.
3.5 Security and safety will always remain
paramount. However, authorities must give greater recognition
to the facilitation needs of the industry and its customers, when
making security regulations.
4. SECURITY MEASURES
SHOULD BE
HARMONIZED INTERNATIONALLY
4.1 Civil aviation is a global industry.
While States have signed up to common international standards,
through the Convention on International Civil Aviation, the lack
of harmonization on the application of these standards remains
one of the most challenging problems facing the industry. It creates
duplication of security measures, which burden airports operationally
and financially. Passengers and baggage which were deemed safe
for transportation from the airport of origin are subsequently
deemed sufficient risk at the airport of transfer to warrant re-screening.
4.2 The tendency of regulatory authorities
to think nationally and to act unilaterally exacerbates the problem.
In some cases this may be unavoidable, particularly if there is
an imminent threat. However, regulatory authorities need to work
together to resolve their differences and to establish bi-lateral
and multi-lateral agreements, leading to mutual acceptance of
security measures. In this respect, the EU has made considerable
progress in this direction but there remain problems with flights
into and out of the region.
5. CONCLUSION
5.1 It is fitting that the Committee has
used the caption "Travelling Without Fear" for its study.
Air travel, whether business or leisure related, is so important
to what has now become a global economy. It is essential, therefore,
that we maintain public confidence in air travel. However, we
need to do it a way that is sustainable in the long term.
5.2 The threat to civil aviation is unlikely
to disappear in our life time. Terrorism will likely remain an
issue of national security at the top of most governments' agenda.
Accordingly, governments should give adequate recognition to this
responsibility in their policies, regulations and funding arrangements.
They should not continue to burden airports and airlines with
the responsibility and cost of this aspect of national security.
Similarly, they should not over burden the industry with layer
upon layer of security regulation but rather follow a disciplined,
risk-based approach which ensures that the level of regulation
is adjusted, commensurate with the risk and is balanced with the
needs of facilitation. And finally, governments should work actively
to ensure greater harmonization of security measures between States,
so that duplication of measures can be avoided and the transfer
of passengers and baggage can be facilitated in an efficient and
"hassle-free" manner.
5.3 ACI thanks the Committee for taking
these issues and views into consideration and is happy to provide
further clarification, if needed.
October 2006
6 The term "Facilitation" is used as per
ICAO Annex 9 and includes the arrangements at airports covering
the entry and departure of aircraft, persons, baggage, cargo and
other articles. Back
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