Briefing
Implementation of pre-departure testing for all air passenger arrivals
from Australia
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Date due to MO: 09/07/2021
Action required by:
For information
Commissioned
Act
Security level:
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BEB Report:
21/029
[agency] Report:
To:
Hon Chris Hipkins, Minister for COVID-19 Response
Copy to:
QFT Ministers
Information
Contact for telephone discussion Official
Name
Position
Telephone
the
Christine Stevenson
Chair of the Border Executive Board
s 9(2)(a) OIA
under
Minister’s office to complete:
☐ Approved
☐ Decline
☐ Noted
Released
☐ Needs change
☐ Seen
☐ Overtaken by events
☐ See Minister’s Notes
☐ Withdrawn
Comment:
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Implementation of PDT for all air
passenger arrivals from Australia
Security level:
IN CONFIDENCE
Date:
09/07/2021
To:
Hon Chris Hipkins, Minister for COVID-19 Response
Purpose and key points
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1.
This report meets your request for a briefing on the resourcing and other operational
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implications across agencies of making pre-departure testing (PDT) mandatory for all air
passenger arrivals into New Zealand under Quarantine Free Travel (QFT) arrangements
with Australia.
2.
Making PDT a standard condition of travel under QFT arrangements with Australia
requires agencies and airlines to consider longer term assurance arrangements. This is
different from the time-limited “surge capacity” that agencies have applied recently to
flights from Melbourne requiring PDT.
Information
3.
Officials have engaged further with airlines to explore what might be possible. Airlines’
advice continues to be that they are severely constrained in their ability to upscale
compliance checks on a regular basis and that existing QFT requirements are already
putting significant pressure on resources.
Official
4.
Agencies and airlines could work together to maximise coverage of pre-departure
checks across airports within existing ALO and airline resources – drawing primarily on
the
the flexibility of ALOs to be deployed to areas of highest risk.
5.
If Ministers would like to pursue a higher level of pre-departure checks, the option of
outsourcing pre-departure compliance checks to a third-party security provider could
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be considered. This would require funding options to be identified.
6.
Immigration NZ advise that it would cost an additional $2.6-2.8 million on a full year
basis for 15 Airline Liaison Officers (ALO) in total to be deployed. ALOs are Crown funded.
This would give enough ALO capability to establish an airport presence for 100% of QFT
flights departing the top five Australian airports by passenger number, and provide
sufficient capacity to service the minor airports. It would not enable the checking all
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passengers’ PDT compliance pre-departure unless airlines up their efforts or other
external contractors are employed.
7.
On arrival in NZ, Customs can sustain for the short-term PDT spot-checks of up to 30
percent of all arriving passengers from Australia, and conduct short-term “surges” to
spot-check up to 50% of arriving passengers without impacting on other areas of
Customs’ business. To sustain PDT check–rates at this level as “business as usual” would
require an estimated 13 additional staff at a cost of about $1.2 million per annum. This
could be implemented fairly quickly.
BEB Report: 21-029
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8.
For Customs to check the PDT of all arriving passengers from Australia as a standard
condition of travel would require an estimated 67 additional staff at an annual cost of
$6.1-7.1 million. Passenger processing would take on average 1-4 minutes longer for
each passenger as passengers would have to be processed manually and e-Gates would
not operate.
9.
The additional costs of a higher level of PDT compliance checking by Customs could be
met completely or in part by fees charged on passengers. This would depend on the
outcome of consultation being conducted by the Ministers of Customs and Primary
Industries on cost recovery policy for passenger processing.
10.
Officials are working on a Government online pre-departure declaration (i.e. Travel Health
Pass) which would enable agencies to undertake digital assurance checks for all
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passengers.
11.
Officials will provide further advice if Ministers wish to explore any of the options
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discussed in this paper.
Information
Official
the
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Recommendations
We recommend you:
a)
Note that making pre-departure testing a standard condition of travel under
Yes / No
Quarantine Free Travel arrangements with Australia requires agencies and
airlines to consider longer term assurance arrangements which have different
resourcing implications from the time-limited “surge capacity” that agencies
have applied recently to flights from Melbourne requiring PDT.
b)
Note that pre-departure checks on eligibility to travel, including PDT, are
Yes/ No
preferable as it means risk is kept off-shore, and current options for pre-
departure checking are spot-checks by Airline Liaison Officers (ALOs) and
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airlines.
c)
Note that Immigration NZ advise that the deployment of nine additional ALOs
Yes/ No
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(15 deployed in total) would establish coverage for 100% of QFT flights
departing the top five Australian airports by passenger number, and provide
sufficient capacity to service the minor airports but that it would not enable
checking of all passengers’ PDT compliance pre-departure unless airlines up
their efforts or other external contractors are employed. This would cost an
additional $2.6-2.8 million on a full year basis.
d)
Agree that Immigration New Zealand submit a funding request to deploy an
Yes/ No
Information
additional nine ALOs based at airports in Australia to assist with PDT
compliance.
e)
Note that airlines have continued to advise that they do not have the
Yes/ No
resources to sustain a higher level of pre-departure checks; and check-in staff
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are not well-placed to review lab reports and make compliance judgements.
f)
Direct the Border Executive Board to report back by the end of July 2021 on
Yes/ No
the
the feasibility of using a third party service provider arrangement for pre-
departure PDT checks, including estimated costs, funding options and a
stand-up timeframe. under
g)
Note that Customs advises that for travel from Australia:
Yes/ No
to check 30% of all arriving passengers for compliance with PDT
requirements, with periodic surges of up to a 50% check-rate would
require an estimated 13 additional staff at a cost of about $1.2 million
per annum
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to check 50% of all arriving passengers for compliance with PDT
requirements would require an estimated 41 additional staff at an
annual cost of $3.7-4.2 million
to check all arriving passengers for compliance with PDT requirements
would require an estimated 67 additional staff at an annual cost of
$6.1-7.1 million.
BEB Report: 21-029
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Act
Information
Official
the
under
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Implementation of PDT for all air
passenger arrivals from Australia
Background
12.
This briefing provides advice on the resourcing and other operational implications across
agencies of making pre-departure testing (PDT) mandatory for all air passenger arrivals
into New Zealand under Quarantine Free Travel (QFT) arrangements with Australia.
13.
The primary onus is on the passenger to comply with QFT requirements. Currently when
PDT is applied within the QFT passengers must return a negative COVID-19 RT-PCR test
within 72 hours prior to departure from Australia. Travellers are required to hold evidence
(including lab results) throughout their journey. Layered assurance processes are
designed to manage the risk to New Zealand.
14.
Monitoring compliance and enforcement are primarily the responsibility of government
agencies. Airlines, however, play an important supporting role.
15.
There are two places where physical checks can take place:
Pre-boarding: checks on eligibility to travel, including PDT, are preferable as it means
risk is kept off-shore. Pre-boarding checks comprise a combination of airlines’ pre-
boarding checks and spot-checking by Airline Liaison Officers (ALOs). However, the
Government’s presence is limited offshore and airlines have limited resources to support
compliance activity.
On arrival: Assurance checking is supported as passengers arrive in New Zealand by
eGate questions that identify (by self-reporting) any travellers who have been in locations
of interest and by random sampling of PDT by New Zealand Customs Service (Customs)
officers with enforcement action taken against any non-complying passengers.
Ensuring compliance with PDT – current arrangements, capabilities and constraints
under the Official Information Act 1982
Airlines
16.
Airline systems, particularly at big airports, are set up in a way where in-person contact
with airline staff at check-in is minimised. For Melbourne, airlines were asked to
undertake spot checks of up to approximately 10% of passengers (the limit of what
airlines had advised they could accommodate). Checks took place either before
electronic check-
Released in, or at the check-in counter where counter check-in was available. s9(2)(b)(ii) OIA
17.
s9(2)(b)(ii) OIA
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s9(2)(b)(ii) OIA
18.
s9(2)(b)(ii) OIA
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Airline Liaison Officers (ALOs)
19.
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As of 5 July 2021 there are six ALOs deployed to Australian airports: one in Sydney, two
in Brisbane and three in Melbourne. Whilst the Airline Liaison Officers are posted to a
home port they are a flexible resource that can be transferred between ports as the
demand requires. Traditionally the three busiest airports for QFT flight volumes are
Sydney, Melbourne and Brisbane followed by Gold Coast and Perth. Hobart, Adelaide,
Sunshine Coast, Cairns and Norfolk Island also operate QFT flights but at much lower
volumes.
Information
20.
ALOs are not capable of undertaking 100% of pre-departure PDT checks. ALOs are
undertaking PDT spot checks of passengers as well as checking for completion of Nau
Mai Ra, but their primary role is to support airlines to meet their obligations and ensure
that QFT border controls are in place and operating effectively. ALOs provide valuable
on the ground reporting that enables NZ agencies to respond quickly to problem solve
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emerging issues. Initial feedback from Melbourne Airport indicates that ALOs are
capable of undertaking PDT checks on approximately 10% of passengers.
the
21.
The following measures are also being taken to support passenger compliance with PDT:
clear and consistent communications to passengers, including test type and evidence
requirements under
information/number to call for information on testing sites in each location
a notice for airlines/ALOs to provide to passengers who do not meet PDT eligibility
requirements.
Compliance checks upon arrival in New Zealand – NZ Customs Service
22.
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Air services from Australia arrive at Auckland, Wellington, Christchurch and
Queenstown airports.
23.
With its existing staff resources at each airport, and without impacting on other areas of
Customs’ business, Customs can sustain for the short-term PDT spot-checks of up to 30
percent of all arriving passengers from Australia. Customs can also conduct short-term
“surges” to spot-check up to 50% of arriving passengers depending on staff availability,
and flight loadings and scheduling at each airport. At this level of PDT checking,
eGates remain in operation to support efficient passenger processing.
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24.
To sustain PDT check–rates at the above level or higher on a permanent or “business as
usual” basis would require additional staff and funding.
25.
s 6(c) OIA
Resourcing and operational implications of requiring all passengers to NZ
from Australia to undergo PDT
Airlines
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26.
s9(2)(b)(ii) OIA
Act
27.
In the immediate term, we consider that agencies and airlines could work together to
understand the best way of maximising coverage of pre-departure checks across
Information
airports within existing ALO and airline resources. This would take into account the
operating conditions at each airport and what could be achieved, taking into account
factors such as flight frequency, whether check-in was primarily by electronic kiosk or
face-to-face at the counter, airport space – and importantly the public health risk level.
Official
This would not achieve 100% pre-departure compliance checks, but would give
flexibility to direct ALO resources to areas of highest risk.
the
Third-party personnel
28.
An option raised by airlines for increasing the level of pre-departure checks is the
option of outsourcing to a third-party provider. Security personnel would likely be the
most appropriate – and readi
under ly available – sector to provide this service.1 There is a
precedent for this – security personnel were used for vetting last year when the first
wave of COVID restrictions was introduced. Funding would need to be identified to
enable this. Officials could report-back further on the feasibility of using a third party
service provider arrangement for pre-departure PDT checks, including estimated costs,
funding options and a stand-up timeframe by the end of July 2021.
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Airline Liaison Officers (ALOs)
29.
Immigration NZ advise that it would cost an additional $2.6-2.8 million on a full year
basis for 15 ALOs in total to be deployed. ALOs are Crown funded. This would give
1
The option of outsourcing to e.g. a nursing provider, as is done elsewhere, was raised but is not considered
appropriate as it’s an expensive, in-demand, over-qualified resource.
BEB Report: 21-029
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enough ALO capability to establish an airport presence for 100% of QFT flights departing
the top five Australian airports by passenger number, and provide sufficient capacity to
service the minor airports (ie outside the top five) on a fly in – fly out basis as the situation
required e.g. to train the airline staff and confirm correct QFT assurance processes were
operating.
30.
While this level of capability would enable ALO support to be provided over all trans-
Tasman flights, it would not in itself enable the checking all passengers’ PDT compliance
pre-departure unless airlines up their efforts or other third party personnel are employed.
Increase compliance checks on arrival in New Zealand – NZ Customs Service 31.
For Customs to sustain a compliance check-rate of 30% of all passengers, with periodic
surges of up to a 50% check-rate, as business as usual would require an estimated 13
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additional staff at a cost of about $1.2 million per annum. This could be implemented
fairly quickly as Customs is currently in a recruitment round and some of those staff could
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be allocated to airport PDT work and the additional funding used to add to the
recruitment pool to replace those officers.
32.
Customs officers currently conduct the PDT spot-checks in NZ. The proposal above is to
add to the pool of officers doing such checks. Customs believes this is the appropriate
response (in comparison, for example, to a temporary workforce recruited specifically for
the task) if PDT checking on arrival in NZ is to become long-term feature of COVID-19
risk management as NZ reconnects with the world. Looking to the future there are likely
Information
be a range of risk management activities required at the border and which will also
require enforcement and sanction capability that fully trained Customs officers are best
placed to provide.
33.
Any lifting of the level of compliance checking on arrival in NZ to above 50% of arriving
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passengers requires eGates to close which would add between 1-4 minutes to processing
times per passenger for manual processing. This would have impacts on the end-to-end
the
passenger processing of other border agencies and airports and airlines, especially when
multiple flights arrive at the same time.
34.
The 50% threshold to close e-Gates has been selected as the most viable threshold to
facilitate travellers who self-declare their eligibility, and to enable selection and
under
processing of passengers to undertake a manual compliance check (having been
initially processed by the eGate). When assurance thresholds are above 50%, it is more
efficient to conduct PDT compliance checks at one point in conjunction with identify
verification in comparison to the alternative of passengers first queuing at eGates for
identity verification and then subsequently joining another queue for PDT compliance
checking.
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35.
The cost and staffing implications of maintaining PDT compliance checks over arriving
passengers from Australia on an ongoing basis are:
for Customs to check
50% of all arriving passengers would require an estimated 41
additional staff at an annual cost of $3.7-4.2 million.
for Customs to check
75% of all arriving passengers would require an estimated 59
additional staff at an annual cost of $5.3-6.3 million.
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for Customs to check
all arriving passengers would require an estimated 67
additional staff at an annual cost of $6.1-7.1 million.
36.
It would take 3-4 months for the staff to be recruited, trained and fully deployed for
any of the above options. Some or all of the cost of the additional officers required for
PDT compliance could be met by cost recovery fees. The Ministers of Customs and
Primary Industries are currently consulting over options to recover the costs of
passenger processing. If as an outcome of this consultation it is decided to recover all
or a proportion of passenger processing costs by way of fees on passengers, then the
costs of PDT compliance checks by Customs would be included in the passenger
processing costs to be recovered.
37.
The staff estimates are based on assumptions about passenger volumes and flight arrival
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patterns at each airport, and expected non-compliance levels. These assumptions, while
based on past data from immediately prior to travel pauses being applied, are quite
uncertain going forward given the recent experience of traveller and airline responses to
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the travel pauses and changed requirements on travel from Australia. However, the
additional staff capability would also allow flexibility to apply on-arrival PDT checking for
travel other than from Australia should this be required.
Application of technology to PDT in the future
38.
Officials are working on a Government online pre-departure declaration (i.e. Travel Health
Pass) which would enable agencies to undertake digital assuranc
Information e checks for all
passengers. This project is the subject of separate advice to Ministers.
Next steps
39.
Official
If Ministers wish to further explore any of the options set out in this brief officials will
provide advice as directed. the
ENDS.
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