Preamble

a.  bmi welcomes the opportunity to submit comments with respect to the
    Notice of Proposed Rulemaking (NPRM) published on 14^th^ July 2006
    by the United States Customs and Border Protection (CBP) relating to
    the electronic manifest requirements relative to passengers, crew
    members and non-crew members travelling onboard international
    commercial flights and voyages.

b.  As a leading European carrier, bmi recognises the paramount
    importance of security & safety and endorses any initiatives
    designed to accomplish the necessary standards within the
    jurisdiction of our operating environment. bmi fully supports,
    therefore, the objectives and primary impetus of the proposal in
    attempting to respond to the continuing terrorist threat facing not
    only the United States, but the world as a whole. The benefit with
    respect to the prevention of boarding and apprehension of those
    individuals who seek to do harm are clearly recognised, providing
    the implementation and impact to commerce are proportional.

Introduction

III. Public Law 107-71 published on 19^th^ November 2001 makes mandatory
     the requirement for carriers operating international air services
     en route to the United States to transmit Advance Passenger
     Information (API) to the Bureau of Customs and Border Protection.
     In accordance with 19CFR122.49a, electronic manifest requirements
     for passengers onboard commercial aircraft arriving in the United
     States, and 19CFR122.75a, electronic manifest requirements for
     passengers onboard commercial aircraft departing from the United
     States, the time period for transmission is no later than 15
     minutes after departure and 15 minutes before departure
     respectively. The Department of Homeland Security (DHS) published
     in the Federal Register on Thursday 7^th^ April 2005 a Final Rule
     concerning the electronic transmission of Passenger and Crew
     manifests for Vessels and Aircraft which introduced, as well as
     other requirements, a mandatory provision to include additional
     data elements. Moreover, the Notice of Proposed Rulemaking (NPRM)
     published on 14^th^ July 2006 seeks to supplement the Final Rule
     and effectively implement the Intelligence Reform and Terrorism
     Prevention Act 2004[^1] by requesting that API data be provided to
     the Government in advance of departure of the aircraft. bmi is
     grateful for the flexible approach adopted by DHS in consideration
     of achieving compliance.

General Comments

IV. bmi welcomes the principle of 'APIS Quick Query' (AQQ) which
    generally reflects the approach suggested through earlier industry
    and government dialogue. In particular bmi considers the general
    direction of this proposal to be constructive which incorporates
    many of the features we require in order to maintain operational
    integrity, such as but not limited to:

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a.  Integration of current TSA No-Fly list checks into one streamlined
    process, eliminating the burden placed upon carriers to conduct the
    check independently. bmi does, however, seek clarification that
    carrier responsibility will be discontinued once the system is
    implemented.

b.  The introduction of a single government contact for the receipt and
    facilitation (distribution) of all data requirements to authorised
    agencies having legal right and purpose for the data

c.  Facilitating expedited clearance for legitimate travellers in
    advance, thus contributing to the reduction of primary line
    processing times whilst enhancing overall security.

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V.  bmi is keen, as are other carriers, to co-operate with DHS in order
    to satisfactorily establish a development and implementation
    programme that does not disrupt current operations, but one which
    seeks to improve both customer experience and security. Carriers are
    constantly required to respond to an increasing number of
    governments globally with respect to revised security procedures and
    the provision of passenger information. Indeed most recently the
    elevated security measures introduced in the United Kingdom,
    attributed to anticipated acts of terrorism, highlight the necessity
    for industry and government to work together. Specifically it
    demonstrates the need for governments to collaborate through
    intelligence sharing and thus generates the need to establish global
    standards. Indeed a significant amount of work in the area of API
    has already taken place in the international arena, notably in the
    International Civil Aviation Organisation (ICAO), the World Customs
    Organisation (WCO) and the International Air Transportation
    Association (IATA), including the IATA/Control Authorities Working
    Group (IATA/CAWG). International Standards and Recommended Practices
    contained in Chapters 3-47 to 3-47.3 of ICAO Annex 9 on Facilitation
    (12^th^ Edition, July 2005) provide the basis on which to achieve
    global harmonisation.

# Comments on the Proposed Rule

### Background & Purpose - Batch Manifest & AQQ timing

VI. The NPRM offers a choice to carriers with respect to the method by
    which carriers transmit API to the government, providing an option
    between a batch transmission no later than 60 minutes prior to
    departure (APIS-60) and the opportunity to participate in an
    interactive query/response arrangement, 'APIS Quick Query' (AQQ).
    Given that the nature of our flight operations comprises a
    substantial number of 'transfer' passengers travelling on flights
    both departing from and to the United States, the exclusive
    implementation of the APIS-60 option would give rise to significant
    operational difficulty. This was validated through our recent
    experience in which CBP enforced a mandatory APIS clearance process
    for all flights departing from the United Kingdom bound for the US,
    which clearly demonstrated that the APIS manifest is far from
    complete at this stage.

VII. Indeed the continuing enforcement of this policy is attaining an
     average clearance time of around 15 minutes. bmi urges CBP to
     exercise caution in mandating such a rigid 60 minute timescale and
     suggests that 30 minutes before departure is perhaps more
     achievable. Consideration should also be given to providing some
     flexibility to carriers to enable manifest updates beyond the time
     from which the initial manifest is transmitted.

VIII. The NPRM proposes that where carriers choose to engage AQQ
      procedures, passengers may check-in up to 15 minutes before the
      scheduled time of flight departure. It is anticipated that the
      'Query' triggered by carriers will receive an interactive response
      within seconds, providing sufficient time for CBP to conduct the
      necessary checks against internal data bases. Given that carriers
      will be required to commit to a refusal of travel in situations
      where AQQ is denied or not performed, a 15 minute restriction,
      therefore, would seem unnecessary.

IX. Moreover, the NPRM aims to implement the transmission of API data
    via AQQ at the point at which a passenger checks-in for a flight,
    the practicalities of doing so introduces considerable operational
    and technical challenges. The processing of transfer passengers is a
    prime consideration, where bmi, together with partner carriers, have
    already dedicated extensive technical resource and incurred
    considerable costs in developing 'through check-in' capability for
    certain continuous itineraries in order to enhance the passenger
    'smooth travel' experience.

> In such circumstances, whilst check-in is 'remotely' undertaken, AQQ
> may not be performed at the point of passenger acceptance but rather
> subsequently performed prior to boarding the US flight. Consequently
> passengers will be in possession of boarding cards, and whilst we
> recognise the requirement to ensure authority to travel is granted
> (AQQ), we believe that carriers should be afforded the opportunity to
> handle AQQ clearance procedurally rather than boarding card provision
> being subject to legislative enforcement.

X.  Whilst CBP offers the two transmission options 'at carrier
    discretion', bmi seeks clarification on whether either option or a
    combination of options could be used according to operational
    requirements. For example, carriers with scheduled operations
    to/from the United States may occasionally operate ad hoc charter
    flights perhaps from regional or remote, less well-equipped
    locations where an APIS-60 (or APIS-30) may be a more suitable
    approach to that normally adopted.

XI. Additionally, given that a significant proportion of passengers (but
    not all) will have checked-in for flights in advance of 60 minutes
    before departure, it is worthy of consideration that a combination
    of options be possible for a single flight subject to technical
    feasibility. This would provide CBP with the ability to vet those
    passengers in advance of travel upon receipt of the bulk manifest
    whilst affording carriers the opportunity to perform AQQ clearance
    for the others within the remaining time before departure.

**Change regarding definition of 'Departure' for aircraft**

XII. 19CFR122.49a(a) defines aircraft departure as being 'wheels up',
     whereas the NPRM seeks to modify this definition to mean 'Push Back
     from the departure gate'. bmi would like to draw CBP'S attention to
     a number of situations. Not all airfields have the luxury of
     departure stands or jetties, where aircraft may be parked in
     isolation from the terminal building or, due to airport congestion,
     are forced to park remotely, with passengers delivered by means of
     ground transportation. Of greater concern is, where due to lack of
     availability, carriers are required to surrender stands or jetties
     to make room for arriving aircraft at peak times. In consideration,
     therefore, bmi suggests that a more appropriate definition of
     departure time be 'Take Off' and seeks CBP'S further consideration.

**Proposed Options for Transmission of Manifest Data by Air Carriers**

XIII. It is stated that carriers will 'transmit required passenger data
      to CBP individually as each passenger checks in for the flight,
      from the beginning of the check-in process.' For bmi, as well as
      many other carriers, check-in may commence up to 48 hours before
      departure for transfer passengers who are 'accepted' by means of a
      through check-in (TCI) message generated by other carriers'
      systems. In these situations a high probability exists that up
      line carriers with whom we have concluded TCI arrangements will
      not have developed a capability to communicate with CBP
      electronically, for which an interactive AQQ dialogue may begin
      only once the US operating carrier has collected (and verified)
      the API data, but after check-in has been undertaken.

XIV. Both internet and SMS methods will provide for check-in well in
     advance of conventional airport times and for all situations bmi
     seeks clarity on where CBP considers the check-in process to begin.

XV. CBP anticipates that both batch and AQQ manifest options will be
    'interactive' in nature 'allowing the carrier to electronically
    receive return messages from CBP that can be sent within seconds or
    minutes'. During earlier discussions with CBP carriers had indicated
    that response times of within 4 seconds must be achieved in order to
    maintain operational integrity and which remain in line with current
    industry standards. Given that at a minimum the query/response (AQQ)
    is undertaken as part of the check-in process, it is important that
    this standard is maintained if carriers are to avoid a significant
    increase in check-in processing times. Perhaps CBP could define the
    distinction between AQQ and Batch response intervals more clearly.

XVI. The NPRM 'expects that the AQQ option would be selected by those
     carriers that have a pre-existing reservations control system'.
     Many European carriers, of which bmi is no exception, deploy
     separate, independent systems for the purpose of reservations[^2]
     and Departure Control Management[^3], and it should be noted that
     the data held in each differs including the time frame in which the
     electronic record is created. It is important that the two systems
     are not confused.

XVII. The NPRM advocates that the implementation of either option would
      'result in a higher success rate in keeping high-risk passengers
      from boarding aircraft than is possible under the current
      regulations'. bmi strives to ensure that both safety and security
      are never compromised, including the observance of regulatory
      obligations in this domain, about which we have maintained an
      exemplary record. Accordingly, whilst we embrace CBP'S intention
      to perform watch-list checks and thus remove the carrier
      obligation, it should be noted that our own internal standards and
      procedures have been undertaken to the highest degree,
      demonstrated by the fact that no instance of turn back or
      diversion has been recorded.

XVIII. The NPRM implies that by implementing the APIS 60 batch manifest
       method, all checked-in passengers would be considered
       provisionally accepted until the CBP vetting results are
       acknowledged by CBP through the provision of an electronic
       message which would include 'a not-cleared instruction to the
       carrier within minutes of CBP'S receipt of the manifest data'.
       Whilst we recognise that CBP attempts to distinguish matches of
       'incomplete or inadequate passenger records' from those where a
       match or close possible match exists to a terrorist watch list by
       instructing 'the carrier to retransmit complete/corrected data',
       bmi seeks assurance that the CBP electronic matching algorithms
       are sufficiently adequate to ensure that potential matches are
       manageable by the carrier at the airport as clearly the CBP
       response time will be a key factor in the success of the scheme.
       Further, it would be useful to clarify whether CBP intend to
       generate an 'all cleared' response in circumstances where no
       matches are found.

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XIX. We note that 'in some circumstances, during the further vetting
     process, either the carrier, CBP or other appropriate domestic or
     foreign government official would have to interview the passenger
     to complete the confirmation (or further vetting process)'. Bmi
     would like to understand in greater detail the procedural aspects
     with respect to the interview as we do not anticipate our agents
     becoming embroiled in protracted discussions of this nature.

XX. With the exception of an incomplete/inadequate data message
    requiring data re-submission, we suggest that that such dialogue
    pertaining to 'non-cleared' messages, the reason for which is likely
    to be sensitive, is undertaken by the passenger directly with CBP by
    telephone or referred to the local US Embassy. Under what
    circumstances will the intervention of foreign government officials
    be requested and we trust that such intervention has been committed
    by foreign governments?

XXI. Whilst in most cases CBP would complete additional vetting in
     sufficient time for the passenger to make the intended flights, we
     note that 'in some circumstances, further vetting could take longer
     than normally expected, resulting in the passenger having to be
     rebooked on a later flight (if ultimately cleared for flight by
     CBP)'. Given that this process is mostly electronically conducted,
     it would be useful for us to understand under which conditions
     these situations may arise. Although an exemption applies under
     Article 2(j) of Regulation (EC) 261/2004[^4] pertaining to
     passenger compensation for denied boarding, other passenger
     assistance, welfare and rebooking costs may ultimately apply. bmi
     would not wish to absorb any rebooking or associated costs as a
     result of a late clearance not directly attributed to bmi and
     wishes to note that such costs should be absorbed by CBP.

XXII. The NPRM makes procedural provision for 'a close-out message,
      consisting of a unique passenger identifier for each passenger who
      checked in for the flight but was not boarded for any reason' to
      be 'transmitted as soon as possible after departure and in no
      instance later than 30 minutes after departure'. bmi wishes to
      note that there is value in transmitting individual cancellation
      messages at the point at which a customer(s) is offloaded from the
      flight, should that become necessary, to avoid additional batch
      processing.

XXIII. In addition full consideration should be afforded to the
       development of a 'unique passenger identifier' to ensure
       consistency, but would caution against the use of current items
       such as DCS Security Sequence Number (Boarding Number), or PNR
       reference.

XXIV. Security Sequence Numbers or Boarding Numbers are not created for
      infants that do not occupy a seat and the same PNR reference may
      apply to up to 99 passengers for group reservations.

XXV. The NPRM states that 'under the AQQ procedure the carrier would be
     able to transmit data relative to a passenger as soon as passengers
     begin checking in for the flight, as early as two hours or more
     prior to departure', although later qualifies this statement by
     recognising an exception in respect of 'connecting passengers
     arriving by aircraft at the departure airport, for a flight en
     route to or departing from the United States'. In reality local
     check-in will normally commence much earlier than two hours before
     departure and transfer passengers 'who were issued boarding passes
     (for the flight to or from the United States)' may check in up to
     48 hours before departure.

XXVI. It is with respect to the latter group of passengers that raises
      cause for concern, given that this category frequently represents
      a significant proportion of the total passenger loading.
      Regardless of method, however, once check-in has been undertaken a
      boarding pass will be issued which is not considered
      'provisional'.

XXVII. We are able to identify through checked (TCI) passengers either
       through electronic transfer indicators or by the fact that such
       passengers will be in possession of boarding cards issued by
       partner carriers bearing bmi flight data. bmi suggests that the
       provision of boarding passes remains a carrier responsibility
       through existing processes on the understanding that 'not
       cleared' customers will be prevented from boarding.

XXVIII. Furthermore, bmi wishes to note that security and safety is of
        primary concern for European Governments, European Airports and
        European Airlines alike where standards are probably the highest
        globally. In view of this we are of the opinion that access to
        the secured zone should not be subject to CBP clearance.

XXIX. Naturally bmi is aware that 'CBP is developing user requirements
      for the programming necessary to implement the AQQ transmission
      procedure' and we are closely following progress in this matter in
      consultation with partner carriers and through membership of
      industry associations. bmi wishes to thank CBP in its willingness
      to consider carrier & industry observations and recommendations
      during development which is vital if we are to collectively
      achieve an efficient, robust and cost effective system.

XXX. The NPRM makes no specific reference to the technical or procedural
     detail of the '**APIS QUICK QUERY USER GUIDE**[^5]' initially
     published on 31^st^ December 2005 and subsequently revised in May
     2006 following initial industry views. Currently the proposed
     system appears far too complex and presents carriers with an
     enormous amount of development work. Accordingly, bmi would like to
     provide the following initial observations with respect to the
     revision prior to a more detailed review:-

XXXI. **3.2 Integrating into the carriers process**

> Carriers, incorporating AQQ into the remote check-in process, must
> verify the APIS data before the boarding pass is issued. Further, the
> NPRM denotes that '60 minutes prior to departure, most originating
> passengers' APIS data will have been collected and verified by the
> carriers and could thus be transmitted'.

XXXII. As is common amongst many of the leading carriers, for which bmi
       is no exception, internet and kiosk check-in are becoming not
       only fundamental but vital to our business process. Indeed the
       air carrier industry has devoted substantial resource and
       incurred considerable expenditure in the development and
       deployment of these facilities. bmi seeks clarity from CBP that
       verification does not mean that carriers will be required to
       implement additional procedures beyond those that are currently
       in force today as to do so will severely weaken the benefits of
       these services and undermine our investment. The very purpose of
       their existence is to streamline and improve carrier processes,
       reduce airport congestion and enhance the passengers' 'smooth
       travel experience', avoiding the need to report to conventional
       airport check-in desks. Any attempt to introduce additional
       verification procedures will serve not only to increase
       transaction times, but is also likely to cause flight delays.

XXXIII. **3.2.3 Storage of the vetting status indicator**

> Bmi would like to seek clarification with respect to statement 'The
> AQQ vetting result must be stored and maintained by the carrier for
> the life of the passenger's itinerary' which appears unnecessarily
> burdensome. We anticipate that AQQ action will be undertaken within
> the departure control system (DCS) as part of the check-in
> (acceptance) procedure and independent to the reservation record
> (PNR). As you may already be aware, the DCS record is created for each
> flight independently approx 48 hours before scheduled departure time
> and would pertain only to that flight, although may contain limited
> information about immediate connecting flights should they exist. The
> result of any AQQ query will be stored in the Departure Control System
> (DCS) only for the duration of the sector. If another leg of the
> journey or itinerary requires further AQQ clearance, a separate query
> would be submitted giving a new result. The DCS is unable to retain
> information relating to any previous or future sectors, and the
> ability to do so, either in DCS or in the reservation system would
> require significant development work. We would like to further
> understand the significance of retaining the vetting result and what,
> if any, relationship exists to flight sectors of later dates of an
> itinerary. Perhaps CBP could provide a further definition of
> 'itinerary', but we would perhaps suggest that this is defined, for
> the purpose of AQQ, as a journey which relates to immediately
> connecting sectors (continuous without stopover), and only in so far
> as is known by the carrier. Further, the vetting result should be
> stored only as part of the DCS record, and retention should not be
> required in the PNR as the AQQ User Guide implies.

XXXIV. **3.2.4 Unsolicited messages**

> bmi wishes to note a concern regarding the enormous complexity
> involved in a process pertaining to unsolicited messages that are
> 'sent to the carrier when the re-vetting process alters a passenger's
> previous vetting result' and would caution against any implementation
> in the absence of a thorough evaluation with respect to the impact on
> carrier processes. Clarity is sought as to which carrier would receive
> and action any change for those passengers in transit having been
> checked in through a partner airline system. Given that such status
> changes are likely to be rare, a manual rather than electronic
> exception procedure would be more appropriate. Further, the timely
> receipt of unsolicited messages must be clearly defined and
> manageable, as any necessary action close to departure time will
> undoubtedly compromise operational integrity.

XXXV. **3.2.6 Itineraries with domestic continuance**

> bmi assumes that 'domestic continuance' refers only to US domestic
> sectors and not domestic sectors undertaken outside the US, for
> example Frankfurt-Munich?

XXXVI. **7.6 System Outage**

> Today it is rare that sustained system outages occur, System outages
> are normally resolved within minutes, as our systems are vital
> business support. However, there may be occasions when the resolution
> of a technical problem may not be immediately found and on these
> occasions carriers will not have the means to collect and/or transmit
> APIS data or provide, as CBP mandates in 7.6.1 'at a minimum, a
> close-out message for all flights affected during a carrier outage'
> before flight arrival. Bmi respectfully requests that CBP engages
> fully with carriers in this respect in order to establish a realistic
> and manageable solution.

XIX. Bmi would also wish to note a further concern regarding the ever
     increasing electronic stress placed upon carrier systems in
     response to the plethora of requests from governments generally. In
     particular, we wish you to note that certain continuous
     (connecting) itineraries are likely to involve multiple interactive
     message sequences between multiple governments and airline systems
     simultaneously which may result in substantial detrimental impact
     causing system 'overload'. For example, if we consider a flight
     itinerary such as Los Angeles -- London -- Dubai, there would be
     not only a US AQQ interactive transaction in respect of the
     departure from the US, but also a UK ATC interactive transaction
     for clearance to travel to the UK, in addition to an additional
     APIS requirement for both departing the UK and arriving into Dubai.
     Carriers may soon be forced to reconsider the entire messaging
     concept.

**System Certification and Delayed Effective Date**

XX. 'CBP is proposing that the effective date of a Final Rule be delayed
    for 180 days from the date of its publication'. Regrettably our most
    recent experience in respect of the APIS+ Final Rule demonstrated
    that we were unable to meet a 180 day deadline for system
    development. In order to ensure system stability, any new or
    modified functionality is introduced into production only at
    pre-designated release intervals, 3 or 4 times per year which are
    not flexible. Scheduled releases, therefore, often fall beyond the
    180 day timescale. Given the likely development complexity of the
    'interactive' communication for both AQQ and batch transmission,
    additional time will be required. bmi suggests 300 days would be
    more realistic.

**Impact on Parties Affected by the Proposed Rule**

XXI. CBP recognises that 'if carriers exercise the APIS 60 option, it is
     anticipated that any adverse impact on passengers would fall
     disproportionately on connecting passengers'. bmi argues that
     regardless of the option chosen, and as stated earlier we would
     wish to explore the opportunity of combining both options, this
     group of passengers will be affected. The very nature of connecting
     flight operations and events which are often beyond the control of
     carriers, such as but not limited to air traffic control
     restrictions, airport congestion etc and in fact sheer volume,
     lends itself to flight delays.

XXII. The NPRM recognises 'that under the APIS 60 option, a small number
      of passengers may not make their flights, will be delayed, and
      will have to be rerouted' and that by implementing 'the AQQ
      option, delays to travellers will be minimized'. Inevitably the
      'interactive' development must be flexible enough to meet these
      challenges and thus avoid any unnecessary cost burden. CBP
      estimates that under APIS 60 implementation '2 per cent of
      passengers on large carriers' will miss connecting flights will
      need to be 'rerouted, with an average delay of 4 hours' and
      concludes that the AQQ procedure 'will significantly drive down
      even further the percentage of passengers requiring rerouting'.

XXIII. Current bmi flight operations both to and from the United States
       comprises either a single daily or thrice weekly schedule and any
       necessity to involuntarily reroute customers will be subject to
       at least a 24 hour delay if space re-protection is to take place
       on alternative bmi services. Even if customers are transferred to
       the services of other carriers, it is likely that the delay will
       be greater than 4 hours, although we would not wish and do not
       intend to surrender important revenue when the condition is not
       attributable to bmi.

XXIV. Moreover, irrespective of the percentage of customers, bmi seeks
      clarification as to why the need for rerouting should exist, given
      that watch-list procedures adopted today do not generate this
      requirement and that the introduction of an electronic system
      should streamline and make the procedure much quicker.

**Conclusion**

XXXIX. In conclusion, bmi considers the NPRM to portray a positive first
       move in realising an interactive APIS platform, but only where
       government, carrier and industry efforts are fully co-ordinated.
       Bmi respectfully requests that CBP gives full consideration to
       the aforementioned during the course of their deliberations and
       we look forward to working together in order to fulfil a
       satisfactory solution.

Yours faithfully,

Nigel R Little Peter McClymont

Ticketing, Interline & Immigration Affairs Manager, Industry &
Government Affairs

Administration Offices 6 Adam Street

Queens Building London

Heathrow Airport (London) WC2N 6AA

Middlesex

TW6 1DY

United Kingdom

Telephone: +44 (0) 20 8990 5365 +44 (0) 20 7379 8534

Facsimile: +44 (0) 20 8990 5419 +44 (0) 20 7836 4215

Email: <Nigel.little@flybmi.com> peter.mcclymont@flybmi.com

[^1]: Public Law 108-458, Section 4012 Advance Airline Passenger
    Screening

[^2]:
    > Amadeus is currently bmi's reservations system containing
    > electronic booking records commonly referred to as Passenger Name
    > Records (PNR) for the purpose of a passenger reservation or
    > journey. PNR'S pertaining to customers who are travelling on bmi
    > services as part of a code-sharing arrangement concluded with
    > partner carriers are subject to alternative booking criteria and
    > are, therefore, not included in this system

[^3]:
    > Departure Control Management, including check-in (passenger
    > acceptance), boarding control and certain passenger data
    > collection is an independent process to that undertaken in
    > Amadeus.

[^4]:
    > Regulation (EC) No 261/2004 of the European Parliament and the
    > Council of 11 February 2004 establishing common rules on
    > compensation and assistance to passengers in the event of denied
    > boarding, cancellation or delays.

[^5]: APIS -- Interactive User Guide; APIS Quick Query (AQQ) Document
    Number 2302001