My answer with respect to question 13:
13. Do you have any views on the operation of the twelve-hour notification period under paragraph 12 of Schedule 7 to the Terrorism Act 2000?
It is outdated and is a fundamentally problematic limitation of liberty that is not compatible with a democratic and free society in peacetime. The Good Friday agreement, ending that Civil War, was a quarter century ago, a normalisation of travel by plane within the CTA is long overdue.
It is also a trap for foreign pilots, which cannot imagine that a free and democratic state would have such requirements for travel within the same country or group of countries having established a common travel area. While they will assume that a flight entering or exiting the CTA needs notification to the appropriate authorities, and will look up their obligations in this regard, tit will likely be unfathomable to them that a flight from Cardiff to Edinburgh doesn’t need any notification, but Glasgow to Belfast does.
I put a similar comment on Q13, “scrap the whole thing or just align it with GAR”…if you ever call Police on short notice for trip to Jersey they will tell you, they don’t deal with it and they are ok if UKBF is ok
I always wondered who was pushing to keep 12h PN after the last revision of GAR in 2021? institutional inertia?
It will be interesting to know who is pushing behind this consultation? and what is the ultimate goal? the GAR is great system that works well, it has all the data for API with click of a button
Let’s hope it’s not Farnbrough airport & handlers who are pushing for it…
The 2 hour notification prior to departure is particularly irritating, vs the current 4 hours prior to arrival. I suppose it’s better than the situation almost everywhere in France though.
Particularly surprising is that GAR compliance is only 90%, and that people are submitting GARs by post!
Firstly, remember that the UK GAR makes every runway an “international airport”. This is a huge advantage. Mainland Europe never had that, and it was eventually addressed by EU+schengen which created a tight club which works to exclude everyone outside the club. Whether you think this is right is of course entirely political, and according to self-interest (those inside the club probably like it, regardless of any wider impact).
The UK has always been outside this club, being non-schengen. Brexit itself has had only limited impact on this; it reduced the options via the loss of the German+Italian “immigration on PN almost everywhere” concession, but almost nobody knew about that anyway 
Unless I missed something, this proposal is a “2hr GAR” for everything except N Ireland.
The proposal intro shoots itself in the foot with Ordinarily there are approximately 124,000[footnote 1] international GA flights in and out of the UK and then listing six cases over 5 years of the police having prevented somebody from travelling! One of these was January 2018: Border Force officers found 500kg of cocaine in suitcases on a private jet that arrived at Farnborough Airport from Colombia. Four individuals on board were convicted of importing class A drugs and imprisoned for between 20 and 24 years. Well, Farnborough has permanent police presence, so I don’t think a GAR (or no GAR) was of relevance! The police interception rate is 100% at many locations and the claimed intelligence value of the GAR is of course nil in those cases, which further confirms that the GAR is principally a police job protection system. An estimated fully costed cost of two officers meeting an aircraft is around £2000 so this is a very expensive police job protection system!
So what is this proposition seeking to achieve?
Firstly, the Terrorism Act stuff will remain, at 12hrs, and this is for flights to N Ireland
Terrorism Act 2000
The existing requirement under Paragraph 12 of Schedule 7 to the Terrorism Act 2000[footnote 10] provides that GA pilots must provide 12 hours’ notice in writing to a police constable of an intention to arrive at or depart from a non-designated airfield in the UK when making a flight between Great Britain and Northern Ireland or a flight to or from Great Britain or Northern Ireland made within the CTA. The notification enables counter-terrorism police officers to identify and respond to the movement of private aircraft which may be of national security concern. The proposed regulations will not amend this requirement. However, views are invited on its practical impact as part of this consultation.
There is something relating to the CTA:
Common Travel Area
The CTA is a travel zone (for people, not goods) between the UK, Ireland and the Crown Dependencies (Jersey, Guernsey and the Isle of Man) which facilitates the principle of free movement for British and Irish citizens and the reciprocal enjoyment of rights in one another’s state. The operation of the CTA will not change as a result of these proposals – there will be no routine immigration controls on journeys to the UK from within the CTA, and none whatsoever on the land border…
The proposal is merely a smaller set of data on Brit and Irish people aboard, which is irrelevant since a standard form is used anyway! The above incidentally appears to be bogus because journeys between Shoreham and say Alderney are 100% met by the police at Shoreham.
This appears to be a key point: a 2hr GAR PN before a departure from the UK and a 2hr PN before a departure to the UK.
The proposed regulations will require responsible persons to provide information no earlier than 24 hours prior to departure and no later than 2 hours in advance of departure, online, about flights to and from the UK and about the persons on board.
These are the points they want input on:
Questionnaire
We would welcome responses to the following questions set out in this consultation paper.
Do you consider the proposed regulations to be necessary and proportionate for border security and law enforcement purposes?
A: No.
What are your views on the information that would be required in respect of each person on board as set out on page 12?
A: It merely gives the police something to check when they turn up at the airport.
What are your views on the proposal to require notification no earlier than twenty-four hours and no later than 2 hours before departure to or from the UK?
A: no change to present unless it applies to Channel Islands IOM and Ireland, in which case it is a welcome improvement, but really the GAR does nothing useful since the police seem to turn up almost 100% of the time.
What are your views on the information that would be required in respect of the flight (including in respect of the aircraft) as set out on page 13?
A: It merely gives the police something to check when they turn up at the airport.
What are your views on the proposal for information about flights and persons onboard to be submitted only online using portals or apps?
A: It merely gives the police something to check when they turn up at the airport.
What are your views on the gov.uk online service that allows for the online submission of data (s-GAR)? Does it meet your needs as a user of the portal? If not, please explain why?
A: it is a horrible website, designed for blind and stupid people, but you would fail your aviation medical in such a case.
If you are a pilot, captain or operator, what would be the practical implications for you of providing advance information online? Please state whether you are answering this as a pilot, captain or operator.
A: It is a hassle extracting the information from passengers, who often make personal arrangements at a short notice, and it involves endless SMS messages getting it all together.
If you are an operator of commercial GA flights what do you consider the impact of the proposals would be on your business operations?
A: as above but worse
If you are an operator of commercial GA flights what are your views on the practicality of complying with a requirement to provide PNR data?
A: N/A
Do you think that a civil penalty will provide an effective incentive to comply with the advance reporting requirement? Why do you think this?
A: because nobody wants to get fined 10k
What is your view of the implications of operating the Authority to Carry Scheme in respect of international GA flights?
A: N/A
Do you have any views on how the reporting requirement should operate in exceptional circumstances, such as weather disruption or technical problems?
A: usually the decision is short notice so no opportunity exists to transmit updated data, plus the police a) get flight plans b) watch the flight in FR24 c) usually turn up anyway
Do you have any views on the operation of the twelve-hour notification period under paragraph 12 of Schedule 7 to the Terrorism Act 2000?
A: completely and totally superfluous, since the IRA has been out of business for around 30 years
Do you have a view on alternative approaches, whether regulatory or not, to securing the border and managing vulnerabilities relating to GA flights?
A: as the Intro proves with the six cases over five years (and some being bogus examples), the problem is statistically insignificant. It is purely an emotional thing. Zero immigration is impossible.
Do you have any views on the impact of these proposals on the operation of the Common Travel Area?
A: as above
Are there any further comments you would like to make relating to the proposed regulations?
A: improve the govt website for data submission, in a way appropriate to users who can use a smartphone, a tablet or a laptop
I put a similar comment on Q13, “scrap the whole thing or just align it with GAR”…if you ever call Police on short notice for trip to Jersey they will tell you, they don’t deal with it and they are ok if UKBF is ok
I don’t understand…
The 2 hour notification prior to departure is particularly irritating, vs the current 4 hours prior to arrival.
It is already thus. Since 2021
Particularly surprising is that GAR compliance is only 90%
I think that is BS
and that people are submitting GARs by post!
and fax! Who wrote this?? A civil servant with an arts degree from oxford or cambridge but was quite good ar rugby 
Peter wrote:
It is already thus. Isn’t it?
No – you can set off from say Cannes LFMD and file the GAR on the runway as it’s over 4 hours from arrival in most SEP aircraft. Now you will have to file 2 hours before departure
Thanks for posting this Alioth. Is there a way to find out about these kinds of things? (EuroGA is my sole source for all news )
I completed the survey at the same time but was a bit kinder than Peter. Admittedly, I’ve never been met by the police or Border Force.
The ‘crime prevention’ examples given are pathetic or not the whole story. That’s a 0.0008% crime rate! 10% estimate for GAR non-compliance is pretty staggering too.
Is this a post-Brexit ‘make Britain Great again’ thing by tightening borders? The sailing community has a pleasurecraft report since 2022 which is very similar to the GAR. Or is it just the way things are going, big data and big government, and passing responsibility for data entry from the state to the individual? Handling others’ passport information is a data protection problem too.
I recommended a larger window to submit: 72 hours prior to 1 hour prior. Not as good as zero, but a bit more flexible than the proposal. In line with flight plan filing times is another option.
The CTA notice period badly needs to be in line with the rest.
Edit: Just to compare, I’ve just looked the crime rate for up a random year (July 2021- June 2022) on gov.uk and it’s 10.8%.
Capitaine wrote:
Admittedly, I’ve never been met by the police or Border Force.
This very much depends on where you are based. As someone who flies into various UK airports, I see different things happening in different areas.
Some airports, you are guaranteed a meeting, and some you are pretty much guaranteed not to be met. Some are more ‘random’ (probably intelligence based).
You, like most UK based pilots, probably arrive to into the UK in the same airport all the time, so only see one area’s policy.
Is this about the fact that (I think) you are only required to notify the flight and must of the passenger information (if not all of it) isn’t actually mandatory on the GAR? I think you can submit a GAR without the passenger information. So now they are looking for that information to be made compulsory?
I’m not sure why there should be a maximum pre-submission window? Certainly it’s much more convenient to submit a GAR from home, before departing on a trip, than it is to submit while travelling. And why should the police care if you give them 5 days notice instead of 5 hours? It gives them more time to plan their resources!
10% estimate for GAR non-compliance is pretty staggering too
I would love to see how DfT come up with that number? Count of (FPL – GAR)?
There is lot of “lost GAR stuff” due to different systems (new Govt website, no NCU email, third party tools) and different organisations (“well NCU got it by email but not Team Sierra, please send again”), I am even impressed some people send GAR by post?
Lot of pilots are not even aware they need an outbound one, they did weak up after 3 years break of covid and go…it will be good for Home Office to get “5000 missing” in the exit stats of people leaving the country, they look great in the press when doing net inbound vs outbound
I gather reconciling FPL, GAR and API in different systems will be a nightmare?
I had one fun story of FPL, GAR and Passenger Locator Forms…they only turn up because GAR 3×PAX != 4×PLF (one pax was 1 year old and exempt from submitting his own PLF, it was very obvious in GAR data but some Sherlock Holmes was on the case)
The ‘crime prevention’ examples given are pathetic or not the whole story. That’s a 0.0008% crime rate!
Yes – miniscule, and it reflects the practical difficulty with using GA for transporting illegals I’d use a boat every time, and while at it, load it up with a few tons of hash
10% estimate for GAR non-compliance is pretty staggering too.
I am surprised it is that high, but they may be counting “lost” forms (which are quite common regardless of which system is used to file them). Remember we are dealing with oxbridge arts graduates who played rugby all day. Gosh – just googled on Jenrick and he is indeed an ex cambridge toff
the crime rate for up a random year (July 2021- June 2022) on gov.uk and it’s 10.8%.
That seems high. Does it include speeding tickets? I can see you could get that if you counted the number of “Irish Gypsy” occurrences on FB
Is this a post-Brexit ‘make Britain Great again’ thing by tightening borders?
Could be. It’s a politically hot topic and GA is getting caught up in the nonsense. I suspect it is partly that, and partly trying to push electronic submission. But all the time the police is resisting any workload reduction meeting up nearly all flights this isn’t going to go far. The govt website (remember this is the one whose IT expert devs emailed the list of all their users to … all their users) is not used by all that many pilots.
The sailing community has a pleasurecraft report since 2022 which is very similar to the GAR.
I did wonder what will happen there. They had no GAR, nothing, since for ever.
Or is it just the way things are going, big data and big government, and passing responsibility for data entry from the state to the individual?
The govt website has been there for years…
Handling others’ passport information is a data protection problem too.
They don’t want to get into that one. Same with airports; they are not allowed to see GAR data unless GDPR registered. The obvious workaround would be for your passengers to enter the data themselves but that will just make practically every potential passenger drop out.
To re-iterate: we want the GAR. It’s a brilliant system. I know it gets ritually slagged off on the UK GA chat sites but that’s only by 5hr/year pilots whose “foreign trip” is the Isle of Wight. It just needs to work a bit better.
