APPENDIX
Memorandum to All Engaged Carriers
FURTHER CLARIFICATION—PER
PASSENGER MESSAGING
Introduction
A memorandum on per passenger messaging was
issued to Carriers engaged with the e-Borders Programme on 22
May 2009. In response to Carrier enquiries, this memorandum updates
and provides further clarification of the requirements and intentions
of the UK Border Agency (UKBA) in this area. In the interests
of clarity, the note incorporates and restates content from the
original memorandum.
Transitional Arrangements Period
During 2009, to ease the burden of implementing
e-Borders, the Programme has allowed Carriers to seek Transitional
Arrangements. Such arrangements represent a concession against
the Programme s full requirements and have been granted on
a case by case basis. In each case, the granting of Transitional
Arrangements has been conditional upon plans and commitment from
the Carrier to meet the Programme s full requirements by
an agreed date.
For some Carriers, the transition to full compliance
is dependent upon the availability of an additional message format
and/or transport mechanism. Specifically:
(1) e-Borders PAXLST US Option—Some Carriers
await an alternative version of the UN/EDIFACT PAXLST message
format, closer to the format used for the US AQQ system. The PAXLST
Interface Control Document has been updated to include this option
and the interface is on track to be available before the end of
this year.
(2) MATIP Type B—Some Carriers await the
ability to submit messages directly to e-Borders using MATIP Type
B (BATAP protocol) as the transport mechanism. The Programme is
committed to offering MATIP Type B from the end of November 2009.
MATIP Type A—Some Carriers have indicated
a desire to submit messages directly to e-Borders using MATIP
Type A as the transport mechanism. In most cases, the demand for
MATIP Type A appears to reflect future support for real time per
passenger messaging. In more limited cases, the demand may reflect
existing implementations and infrastructure. The e-Borders programme
had previously not offered MATIP Type A as a transport mechanism
but following further consideration this will now be made available
in early 2010. Carriers will be offered reasonable time to implement
this mechanism before full compliance is sought on affected routes.
Full Requirements—Post Transitional Arrangements
By the agreed end date for any Transitional
Arrangements, Carriers are expected to comply with the full e-Borders
requirements. These are considered below.
Current legislation allows for batch or individual
messaging but does not make per passenger messaging compulsory.
The Agencies' preference is for real time individual messaging
for all passengers. This is the best solution to meeting the Agencies
business requirements and minimises the risk to Carriers of operational
impact from late interventions by Agencies on outbound flights
from the UK. It also positions Carriers well for supporting any
Authority To Carry scheme which may be introduced in the future
(see Future Requirements and Authority To Carry below).
Carriers are also permitted to employ batched
solutions. Where this approach is taken, all check in data that
is available must be submitted no later than 30 minutes before
scheduled departure.
It is accepted that some passengers may join
a flight later than 30 minutes before scheduled departure, especially
where Flight Close does not take place until much closer to departure
time (or Push Back where a delay has been experienced). Where
this applies, pre-departure data is also required for the late
arriving passengers. It is the strong preference of the Agencies
for Carriers to configure their systems so that details for the
late passengers are sent in real time as soon as these become
known. However, Carriers are also permitted to store up late arrivals
and submit them in a single, second pre-departure data batch at
flight close. Clearly, under either scenario, the later the data
is submitted, the greater the risk of operational impact from
late interventions by Agencies on outbound flights from the UK.
Historically, the programme has indicated that
Carriers accepting passengers less than 30 minutes before scheduled
departure must implement real time messaging for those passengers.
This revised guidance relaxes that constraint following widespread
requests from Carriers and careful consideration by the Agencies,
much of this driven by the recent Transitional Arrangements process.
Note that this concession does not change the Agencies' strong
preference for real time messaging in these circumstances or in
any way reduce the operational risks to Carriers who send passenger
details late.
Finally, Carriers that check-in passengers prior
to 24 hours before scheduled departure will still be required
to submit information for these passengers no earlier than 24
hours before scheduled departure. Neither per passenger messaging
nor batch messaging will be accepted prior to 24 hours before
scheduled departure.
Future Requirements and Authority To Carry
The UKBA plans a voluntary proof of concept
trial for an Authority To Carry (ATC) scheme with one or more
Carriers and Ports later this year. This trial will inform the
thinking and planning around any future ATC scheme which would
only be used for immigration purposes (ie inbound travel to the
UK) and would link in with the UK Visa process.
Whilst UKBA may wish to implement an automated
ATC scheme in the future, there are no plans to do this until
after the London 2012 Olympics. The details, timing and funding
for such a scheme have not been confirmed and any proposals would
be subject to consultation with Carriers and the public and require
Parliamentary and European Commission approval before implementation.
The working assumption for automated ATC to
date has been that it would operate in a similar fashion to the
US AQQ system. Carriers would provide passenger details in real
time as they become known and the e-Borders system would provide
a response within seconds, indicating whether the passenger is
permitted to travel. This model provides the maximum notice to
Carriers and allows Carriers to accommodate ATC into their business
processes, ensuring consistent enforcement of travel denials.
On this basis, the programme has previously reported the Agencies
intent to move towards a compulsory passenger by passenger method
of data transfer.
Recent consideration of ATC suggests that alternative
models of operation may be acceptable. The industry is changing
rapidly, with increasing emphasis on on-line check-in, often many
hours before passengers present for baggage drop or boarding.
Where a Carrier routinely closes flights significantly in advance
of the scheduled departure time, it might be possible to support
ATC while continuing to supply pre-departure passenger details
in one or more batches (and later batches could include all previously
submitted passengers). ATC responses would be provided for the
passengers in each batch on a similar basis to individual messages,
although response times might be slightly slower. Under this scenario,
the onus would remain with the Carrier not to carry any passenger
for which ATC is denied.
The Programme believes that real time per passenger
messaging is the most suitable solution for an ATC environment,
particularly for any Carrier who regularly accepts passengers
near to the scheduled departure time. However, it is envisaged
that a batched solution would also be acceptable, providing Carriers
are able to support this procedurally and ensure that all ATC
denials are consistently acted upon.
Conclusions
The Programme is committed to offering Carriers
a controlled and manageable path from Transitional Arrangements
to compliance with the full e-Borders requirements. Per passenger
messaging and batched solutions are both acceptable on the basis
set out by the programme.
Carriers will not be required to implement an
automated ATC solution before 2013 at the earliest. If automated
ATC is implemented after this date, the options open to Carriers
may not require per passenger messaging. However, the programme
believes that per passenger solutions will be the most satisfactory
for Carriers in an automated ATC environment, particularly for
Carriers who accept frequent late passengers.
It is recognised that Carriers and their systems
suppliers will need adequate notice of ATC introduction together
with input to the development and trialling of the scheme.
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