IRELAND'S AVIATION RESTART PLAN 2021 - APRIL 14, 2021 - Aer Lingus ...
←
→
Page content transcription
If your browser does not render page correctly, please read the page content below
IRELAND’S AVIATION
RESTART PLAN 2021
APRIL 14, 2021
NCADF Regulatory Working Group
Contents
Page
1. Executive summary 2
2. Economic importance of aviation 10
3. Epidemiological situation 10
4. Variants of concern 12
5. Airline and Airport planning processes 14
6. Aviation protocol 16
7. Risk mitigation 17
8. Restarting air travel 18
A. Lifting ban on international travel and metrics 18
B. Narrative on international travel 20
C. EU traffic light system 20
D. UK 24
E. USA 25
F. Other countries 27
G. Vaccines 28
H. Testing 30
I. Proof of recovery 32
J. Passenger Locator Form 33
K. Travel Apps 33
L. Operational readiness 34
9. Financial Support 35
10. Summary recommendations 37
Appendices:
Appendix A: International experience 40
Appendix B: Antigen Testing 43
Appendix C: Protocol for the management of air passengers 44
NCADF Regulatory Working Group 1
1. Executive summary
On 5th March, the Steering Committee of the National Civil Aviation Development Forum
(NCADF) and wider industry stakeholders met with Minister for Transport, Eamon Ryan, and
Minister of State for International and Road Transport and Logistics, Hildegarde Naughton,
where it was agreed that the industry and the Government needed to urgently develop an
exit strategy from the current Covid-19 restrictions in order to enable recovery for the
aviation sector.
Air travel has always been a driver of economic growth not least given our island economy
and the fact that over 90% of all travel into Ireland is by air. A pathway to restoring Ireland’s
international connectivity is essential for the economic and social recovery of the country,
and for the jobs that depend on it. For the industry to be able to meaningfully contribute to
the economic recovery in 2021 and minimise the permanent damage of a partially closed
economy, restoration of Ireland’s international connectivity needs to happen this summer.
To enable industry to plan for the resumption of operations, aviation stakeholders require a
clear roadmap with key measurable metrics and target timeframes based on current
assumptions. The roadmap must be proportionate having regard to risk profile in Ireland
and its key markets with the goal of restarting aviation in line with vaccination of the most
vulnerable and the improving health situation.
The aviation sector has made significant investment in implementing protocols for the safe
management of passengers that were developed in consultation with Government and the
public health authorities. These protocols set out the expectations and requirements on
industry to ensure public health safety of passengers, staff and crew and cover the end-to
end passenger journey. The industry is also focussed on the development of operational
plans to scale up operations in the context of appropriate continued application of these
protocols.
The attached ‘Aviation Restart Plan’ has been prepared by industry members of the
Regulatory Working Group of the NCADF and sets out a balanced and evidence-based
approach to enable the recommencement of aviation and the restoration of Ireland’s
connectivity. The Plan contains a comprehensive set of recommendations which, if
implemented, would facilitate restoration of connectivity whilst continuing to protect public
health.
In addition, a broad package of robust, financial incentives and supports for aviation in line
with EU state aid rules will be required to assist recovery and to ensure that Ireland restores
its connectivity.
The ‘Aviation Restart Plan’ recognises that improving public health outcomes, reducing risk
levels and the rollout of vaccination programmes in Ireland and the countries linked to
Ireland by air should facilitate the reopening of international aviation on which economic
recovery depends. The ‘Aviation Restart Plan’ acknowledges the potential risks associated
with variants of concern but also notes the emerging international evidence in respect of
vaccine efficacy against such known variants of concern.
Aviation planning has long lead-times, and it is therefore imperative that a clear exit plan
from the current restrictions is urgently developed to facilitate a restart of aviation this
summer. In this context, airlines and airports will require an ‘extensive return to normal
operations plan’ including:
• The management of returning aircraft which have been in storage back into service,
which in some cases may require significant maintenance checks.
NCADF Regulatory Working Group 2
• Ensuring that flight and cabin crew qualifications are up to date as many will not have
flown throughout the pandemic.
• Ensuring that support personnel (operations control, engineering, ground handling etc.)
are appropriately trained, checked and ready for return to normal operations.
• Ensuring that third party providers are ready for return to normal operations.
Developing a roadmap as an immediate priority to enable the restart of aviation is therefore
critical to enable effective airline and airport planning processes in time for a restart of
aviation this summer.
Risk mitigation associated with travel is based on a multi layered approach which has
consistently resulted in very low numbers of imported cases into Ireland.1 The aviation
industry will not recover if quarantine and travel restrictions remain in place causing
significant job losses and irreparable harm to the Irish economy. The path for safe
international travel is through adherence to the Irish Protocol for the management of air
passengers in light of Covid-19 (October 2020 – Issue 2) and appropriate screening
protocols that do not increase the risk to Ireland and such protocols should be used instead
as part of the phased removal of restrictions
As the Aviation Recovery Taskforce report concluded in July 2020: “Ireland cannot
function as a closed economy without permanent damage being done”. The various
recommendations set out in the attached ‘Aviation Restart Plan’ are for a coordinated, risk-
based approach that is developed in collaboration with stakeholders and in which
Government explicitly recognises that current restrictions are temporary and will be removed
as soon as reasonably possible.
The key recommendations of the Plan are summarised below, and the NCADF Steering
Committee should reconvene before the end of April to review the planned progress and
state of preparedness of stakeholders.
Lifting of Ban on International Travel and Metrics
The aviation sector cannot begin to recover from the current crisis until the ban on non-
essential international travel is removed. A key deliverable is therefore for Government
to identify and confirm the metrics that will enable the removal of this ban and the
restoration of international travel for those markets which meet the specified metrics.
In addition to infection rates, metrics that should also be considered include increasing
vaccination rates and reducing number of hospitalisations.
The extension of mandatory hotel quarantine to additional countries (including certain EU
countries and the US) gives rise to significant concerns about the serious and potentially
long-term impact which such measures would have on travel between Ireland and these
countries. Measures of this nature go far beyond those imposed by other EU Member States
and would be contrary to the principles set out in the EU Traffic Light System. Having due
regard to the relevance of proof of vaccination, existing testing requirements and EU rules
on free movement of persons, any requirement for quarantine should be proportionate and
based on transparent and objective criteria. In particular, clarity is required on the criteria
used to determine what constitutes a variant of concern, and a high incidence thereof. Such
criteria should be published, together with a regular review process.
1
https://www.hpsc.ie/a-z/respiratory/coronavirus/novelcoronavirus/surveillance/covid-1914-
dayepidemiologyreports/
NCADF Regulatory Working Group 3
Key Recommendations:
- Government to identify and confirm the metrics that will justify the removal of the
ban on all non-essential international travel for summer operations together with
target dates based on these metrics and current assumptions
- Having due regard to the relevance of proof of vaccination, existing testing
requirements and EU rules on free movement of persons, any requirement for
quarantine should be proportionate and based on transparent and objective
criteria.
- Government to identify and publish these criteria and review on a regular basis
Narrative on international travel
The removal of restrictions on international travel is not in itself sufficient to facilitate a
recovery in the sector. In conjunction with lifting the ban on non-essential international
travel, the Government has a key role to play in ensuring the evolution of the current
relentlessly negative commentary on international travel to a more positive narrative having
regard to the improving epidemiological situation and progress on vaccine rollout.
Key Recommendations:
- Government and industry stakeholders to develop an evidence-based
communications plan in order to support consumer sentiment and endorse the safe
resumption of air travel when the specified metrics have been met.
Resume application of the EU Traffic Light System
A cornerstone of the Plan is the resumption of the application of the EU Traffic Light System
to enable international travel. The European Council updated its recommendation on a
coordinated approach to travel measures on 1st February 2021 to address the risks
associated with very high levels of Covid-19 circulation and variants of concern.
On this basis the following measures associated with each colour coding within the Traffic
Light System are recommended:
Key Recommendations:
- Persons arriving from Green list locations can enter the State without the
requirement to restrict movement or undergo testing for Covid-19
- Persons arriving from Orange coded areas subject to pre-departure test based on
a rapid antigen test or PCR test
- Persons arriving from Red areas subject to a pre-departure test based on PCR and
14-day restricted movement (with test to release after 5 days)
- Persons arriving from Dark Red areas are subject to pre-departure test based on
PCR and 14-day home quarantine with test to release after 5 days
- Non-essential travel from Dark Red areas should continue to be discouraged
- Government to support evolution of EU Traffic Light System to waive testing
requirement and restriction requirement for vaccinated travellers and those with
proof of recovery
NCADF Regulatory Working Group 4
UK
The Government should give due consideration to opening up travel between Ireland and
the UK at the earliest opportunity having regard to the 300 mile open land border together
with the implications of the Common Travel Area (CTA) and the Brexit Protocol on freedom
of movement within the island of Ireland and between Ireland and the United Kingdom. It
should be recognised that the UK Government has at all times during the current pandemic
allowed for unrestricted travel from Ireland to the United Kingdom. In addition, the UK has
the highest vaccination levels in Europe and travel from the UK represents a minimal risk
and should be facilitated without delay.
Having regard to the level of traffic across the open border to/from Northern Ireland, the
current broad alignment between Ireland and the UK with regard to countries considered
high risk due to variants of concern, and the improving epidemiological situation on both
islands, together with the very high levels of vaccination in the UK, there is no public health
rationale for restrictions in travel between Ireland and the UK.
The unilateral restrictions on travel from the UK are disproportionate and should therefore be
removed as an immediate priority to ensure that the benefits of the CTA and the Brexit
Protocol can be resumed at the earliest juncture
Recommendations:
- Government should, as an immediate priority, seek to restore the full operation of
the CTA for Irish and UK citizens
- Government should align its approach to international travel with that of the UK
while respecting the principles of the EU Traffic Light System.
USA
Recognising the strong business and social links between Ireland and the US, it is now
critical that there is focus on planning to safely open up travel between Ireland and the US in
summer 2021. The US CDC is currently developing a road map with criteria to be used to
determine when/if to establish travel corridors with certain countries.
Ireland is unique in Europe in terms of having US Customs Border Protection (CBP) facilities
based in Dublin and Shannon Airports –and this presents an opportunity for the US to
remotely validate pre-departure testing. The introduction of appropriate COVID-19 screening
regimes should enable the US to dis-apply the current entry ban on Irish citizens.
Recommendations:
- Government to engage with the US government with respect to planning reciprocal
arrangements on travel that lifts the current ban on Irish citizens entering the US
- Pending full lifting of the entry ban on Irish citizens, Government to engage with
relevant US authorities with a view to enabling a pilot scheme for reciprocal travel
Vaccines
Based on clear evidence from countries with high levels of vaccinations, the ongoing rollout
of vaccines should allow for a progressive lifting of restrictions as Covid becomes less
impactful and less of a risk to the population and health services. High levels of vaccination
NCADF Regulatory Working Group 5
of the most vulnerable and healthcare workers is therefore key to restarting travel and
reopening Ireland, and travel restrictions should be eased once the most vulnerable and
healthcare workers have been vaccinated.
While vaccination should not be a precondition for travel, vaccinated travellers should not be
subject to any travel restrictions as evidence indicates that vaccines significantly reduce the
risk of transmission.
Airline crew or aviation personnel should be prioritised for vaccination in accordance with
WHO guidance and in recognition of the importance of maintaining air connectivity.2
Key Recommendations:
- Government to confirm that vaccination should not be a pre-requisite for travel
- Government to confirm that those who have received the requisite doses of a
vaccine approved by European Medicine Agency (EMA) will be exempt from
testing and quarantine requirements
Testing
As the roll-out of vaccines gathers pace and some countries vaccinate their populations
more quickly than others, testing will continue to be a key part of the travel process even as
restrictions are eased.
As both the ECDC and Ireland’s recent ‘Report of the Covid-19 Rapid testing Group’ have
noted, rapid antigen tests are sensitive for detection of infectious cases.34 Such tests are
also in use in many of Irelands key markets including UK, US and several European states.
Key Recommendations:
- Government to update pre-departure testing protocols to allow use of rapid antigen
testing as an alternative to PCR for inbound passengers
- Government to agree to mutual recognition of antigen testing
- Government to enable rapid antigen tests for “test to release” from quarantine
Proof of recovery
Anyone with documented proof of recovery from Covid-19 within a defined timeframe should
be exempt from testing and isolation requirements. Guidance from Ireland’s Health
Information and Quality Authority (HIQA) on presumptive immunity is 6 months.5
Key Recommendations:
-
Government to enable passengers with documented proof of recovery from Covid-
19 within 6 months to travel exempt from testing and quarantine requirements
2
https://a4e.eu/publications/1338/
3
https://www.ecdc.europa.eu/en/publications-data/guidance-covid-19-quarantine-and-testing-travellers
4
https://www.gov.ie/en/publication/f50f0-report-of-the-covid-19-rapid-testing-group/
5
https://www.hiqa.ie/reports-and-publications/health-technology-assessment/duration-protective-immunity-
protection
NCADF Regulatory Working Group 6
Passenger Locator Form:
The Electronic Passenger Locator Form (ePLF) should not become a fixed part of the
aviation industry but should be recognised as a temporary measure. During this temporary
period of use, Passenger Locator Forms should be exclusively in electronic format,
harmonised at EU level, and allow passengers to confirm their compliance with all
requirements and capture all data (e.g. vaccine, negative test).
The electronic PLF should therefore be amended to include all applicable requirements and,
upon completion, passengers should be provided with confirmation of compliance which they
must present before boarding a flight to Ireland. This process has worked well for other
Governments including Greece and Spain.
Key Recommendation:
- Government to immediately mandate use of electronic PLF (ePLF) only (i.e. paper
based PLFs should no longer be acceptable).
- Government to use ePLF to minimise operational impact or demands on airlines to
validate paperwork on behalf of Government.
- Government to actively pursue and support harmonisation of ePLF at EU level
- PLF only to be in use on temporary basis and should be suspended at earliest
opportunity
Travel Apps
The use of travel apps should be supported to simplify the end to end customer journey by
capturing and storing required information such as passenger data and providing 1) Proof
that a person has been vaccinated; 2) Results of tests for those who have not yet been
vaccinated; and 3) Information on Covid recovery.
The European Commission’s plans for a Digital Green Pass for this purpose is encouraging
and it is critical that Ireland fully supports its efforts in this area. The objective of the Digital
Green Pass is to gradually enable Europeans to move safely in the European Union or
abroad - for work or tourism. In parallel, Ireland should progress the development of digital
certificates at national level to ensure that any potential delays at European level do not
result in delays to airline capacity restoration in Ireland.
Key Recommendation:
- Government to fully support and engage with EU Digital Green Pass
- In parallel, Government to progress certification at national level to ensure that any
delays at European level do not result in delays to airline capacity restoration in
Ireland.
- Use of travel apps by airlines should be supported
- Testing and Vaccination centres to enable digitally verifiable health certificates
Operational Readiness
NCADF Regulatory Working Group 7
The industry is focussed on the development of operational plans to scale up operations in
the context of appropriate continued application of the protocols set out in Appendix C
(Protocol for the management of air passengers as issued by Department of Transport).
Additional focus is required on wider operational readiness to ensure resumption of aviation
is supported by appropriate enablers.
This Plan calls on the Government to ensure that the Passport Office can function as normal
to ensure that the current backlog in passport processing does not create a further
impediment to any recovery.6
Key Recommendations:
- Industry to finalise operational plans to scale up operations in the context of
appropriate continued application of the protocols set out in Appendix C.
- Government to recognise the Passport Service as essential function and to enable
the Passport Office to function as normal whilst restrictions are in place
- Border management to ensure that they are ready as required for the restart of
aviation this summer
Financial Support
While the financial support which has been provided to the sector to date (including the
support package provided to airport operators as approved by the European Commission) is
welcome, a comprehensive plan to stimulate traffic and tourism will be required. The Plan
supports the recommendations in this regard made by the Aviation Recovery Task Force
which issued its report last July and which included the rebate of airport charges for three
years, extension of wage subsidy schemes etc. The NCADF will continue to work through
the Regulatory Working Group to formulate specific proposals in this regard.
Key Recommendations:
- Implement comprehensive financial incentives and support schemes in line with the
recommendations of the Aviation Recovery Task Force and in accordance with EU
state aid rules to stimulate the recovery of air travel
Timeline
If the Government adopts the above recommendations, Ireland’s connectivity can begin to
be restored by June in line with the below timeline. It is imperative that the Government
acts now, and without any further delay. A failure to do so will irreversibly damage Ireland’s
world-leading aviation sector which is so important to the country.
6
https://www.irishtimes.com/news/consumer/passport-service-suspends-almost-all-operations-due-to-covid-
19-1.4489923
NCADF Regulatory Working Group 8Jan-Mar Apr-May Jun NCADF Regulatory Working Group 9
2. Economic importance of aviation to Ireland The Aviation Recovery Taskforce established by the Minister for Transport in 2020 highlighted the importance of aviation to Ireland including supporting 140,000 jobs and contributing €8.9bn to GDP. The taskforce also noted that: “Ireland has had a leadership position in global aviation. While two highly regarded international carriers are the anchors of the national industry, Ireland also controls over 60% of the entire global leasing market for aircraft, and has a significant international position in maintenance, repair and overhaul (MRO). The airports have been strategic enablers of this business growth and economic development. As a result, Ireland has been one of the most highly connected island nations, with both extensive short-haul and increasingly pervasive long-haul route networks. Dublin Airport had over 50 airlines operating in the summer of 2019. These routes not only have given strategic advantage to the entire economy but also have been viewed enviously by some other jurisdictions”.7 IATA’s latest forecast for 2021 predicts that traffic will only be 13 percent higher than in 2020 if severe travel restrictions are not lowered. This would leave the industry at only 38 percent of its 2019 level. Ireland as an island is likely to have greater exposure and without an upturn in fortunes in 2021, the situation will only get worse, putting more jobs at risk, diminishing Ireland’s international connectivity, and holding back Ireland’s economic recovery.8 3. Epidemiological situation International aviation is all but grounded due to the global prevalence of Covid-19. Eurocontrol reported that half of the top 30 airlines had reduced their capacity by over 90% in January 20219. The emergence of new variants of concern has resulted in governments imposing a range of travel restrictions, and Ireland, the UK and EU countries are all in various stages of lockdown with citizens unable to travel except for emergency reasons. Travel restrictions in Ireland have been and remain among the most stringent in Europe whilst the US continues to enforce an entry ban on all EU and UK citizens. A complex and mainly uncoordinated patchwork of restrictions and information is in place across the globe, incorporating a combination of travel bans, quarantine, passenger declarations and Covid testing requirements. Increasing levels of vaccination and immunity from infection are likely to assist in the decline in incidences of new cases and resulting in a significant reduction in prevalence, hospitalisations and mortality by summer. 7 Final Report Aviation Task Force https://assets.gov.ie/79443/d218cf7a-2c0b-42bc-80f1-b66058822bda.pdf 8 https://www.iata.org/en/pressroom/pr/2021-02-03-02/ 9 https://www.eurocontrol.int/sites/default/files/2021-01/covid19-eurocontrol-comprehensive-air-traffic- assessment-2112021.pdf NCADF Regulatory Working Group 10
The first dose of the Pfizer vaccine was associated with a vaccine effect of 85% for COVID-
19 related hospitalisation at 28-34 days post-vaccination. Vaccine effect at the same time
interval for the Oxford/AZ vaccine was 94%10.
Country Forecast
Ireland 82% of adults to have received first dose in H1, 55-60% to be fully vaccinated11
UK All adults to have received first dose by end of July12
Europe 70% of adults to be vaccinated in H113
By April 19, every adult will be eligible to be vaccinated / Sufficient supplies for all
USA adults by end of May14
The following chart indicates how Goldman Sachs expects most advanced economies to
reach herd immunity by early Q3.15
The following chart outlines the expected vaccination rollout in Ireland based on Government
announcements but remains subject to change given dependency on vaccine supply
levels.16
10
https://www.ed.ac.uk/files/atoms/files/scotland_firstvaccinedata_preprint.pdf
11
Statement by An Taoiseach, 23rd February https://www.gov.ie/en/speech/147f5-speech-by-an-taoiseach-
micheal-martin-covid-19-resilience-recovery-2021-the-path-ahead/
12
https://www.independent.co.uk/news/uk/politics/covid-vaccine-uk-adults-july-b1805091.html
13
https://www.bloomberg.com/news/articles/2021-04-06/eu-will-near-virus-immunity-by-end-june-internal-
memo-shows
14
Statement by Joe Biden, 1st March
15
https://www.zerohedge.com/markets/goldman-now-sees-most-advanced-economies-reaching-herd-
immunity-3-months
NCADF Regulatory Working Group 11There is now increasing body of evidence from countries with high levels of vaccination that
significantly reduced transmission levels ranging from 75%-94% following vaccinations is
being achieved as follows:
• Health care workers in England were found to have 86% reduction in asymptomatic
transmission17
• Health care workers in Israel were found to have 75% reduction in asymptomatic
transmission18
• Israel general population were found to have 90% reduction in asymptomatic
transmission19
• Patients in Mayo Clinic health system were found to have 89% reduction in
asymptomatic transmission20
4. Variants of concern (VOC)
The ECDC, in the most recently published Rapid Risk Assessment21 states that since 21st
January 2021, EU/EEA countries have observed a substantial increase in the number and
proportion of SARS-CoV-2 cases of the B.1.1.7 variant, first reported in the United Kingdom.
Ireland reports B.1.1.7 to be the dominant circulating SARS-CoV-2 strain and, based on
growth trajectories observed, several other countries are expecting a similar situation.
The variant B.1.351 (South Africa variant) has also been increasingly reported in EU/EEA
countries, often, but not only, linked to travel, and it has also been associated with
outbreaks.
16
https://www.rte.ie/news/coronavirus/2021/0223/1198716-living-with-covid/
17
https://papers.ssrn.com/sol3/papers.cfm?abstract_id=3790399
18
https://www.thelancet.com/journals/lancet/article/PIIS0140-6736(21)00448-7/fulltext
19
https://www.nejm.org/doi/full/10.1056/NEJMoa2101765
20
https://www.medrxiv.org/content/10.1101/2021.02.15.21251623v3
21
https://www.ecdc.europa.eu/en/publications-data/covid-19-risk-assessment-variants-vaccine-fourteenth-
update-february-2021
NCADF Regulatory Working Group 12The variant P.1 is so far being reported at lower levels, possibly because it is mainly linked
to travel exchange with Brazil, where it appears to be spreading.
Test and trace approaches, including strong surveillance and sequencing, remain the
cornerstones of the response. ECDC also confirms that targeted and robust vaccination
programmes will enable the easing of Non-Pharmaceutical Interventions (NPI’s).
The following table outlines the efficacy and effectiveness of Covid-19 Vaccine authorised
for use in the EU against Covid-19 and variants of concern as published in February.
.
Since the publication of this report, it is notable that media reports are now indicating that
studies are showing that Oxford/AZ is also effective against Brazil P1 variant (Fiocruz
Biomedical Institute)22. In addition, there are also studies showing that the Pfizer/BioNTech
is effective vs. Brazil P1 variant23.
On 25th March a further paper was published showing Pfizer/BioNTech vaccine likely to work
against variants with a single shot vaccine working very well in those with prior infection
(including the South African variant.)24
The ECDC, in its technical report25 published on 12th March on guidance for quarantine and
testing notes the following summary findings:
22
https://www.reuters.com/article/us-health-coronavirus-pfizer-brazil/pfizer-biontech-covid-19-vaccine-
neutralizes-brazil-variant-in-lab-study-idUSKBN2B02JC
23
https://www.nejm.org/doi/full/10.1056/NEJMc2102017?query=featured_home
24
https://science.sciencemag.org/content/early/2021/03/24/science.abg9175
NCADF Regulatory Working Group 13- At this stage of the pandemic, travel measures can be considered for travellers
coming from areas with a high level of viral community transmission with the
presence of one or more VOCs (or with an unknown understanding of the extent of
VOCs) in order to delay their importation and spread in an area where these VOCs
are not widely circulating.
- To respond to the emergence of VOCs , ECDC recommends the strengthening of all
public health measures, including those relevant to travel, taking into account the
epidemiological situation in both the points of departure and arrival, until very high
vaccination coverages of high risk groups and healthcare workers are reached, and
until sufficient sequencing capacity is in place for Member States to rapidly detect
and take appropriate response action to reduce the risk of a further spread of VOCs.
- For individuals that have recovered from a laboratory-confirmed SARS-CoV-2
infection within 180 days prior to travel, it can be considered to ease quarantine and
testing requirements.
On 3rd March 2021, the Minister for Health Stephen Donnelly said that there had already
been a “significant increase” in genome sequencing of positive Covid-19 tests from 1 per
cent of positive tests being genome sequenced to 15 per cent.26
The EU Traffic Light System was amended on 1 February 2021 and under the updated
recommendation, a new colour coding (Dark Red) was added to the existing categories. This
colour coding applies to areas where the virus is circulating at very high levels, including
because of variants of concern. A specific set of recommendations in relation to travel for
this coded area is outlined in the EC Recommendation and considered later in this paper.
Recommendations:
- Government to confirm expected timeline to complete vaccination of Health Care
workers and high-risk groups
- Government to continue to meet the recommendation set by the European
Commission of having a Genome sequencing rate of 5–10% of positive test results
to identify VOC’s
5. Airline and Airport planning process
Aviation planning has long lead-times, and it is therefore imperative that a clear exit plan
from the current restrictions is developed and agreed by the relevant stakeholders to enable
airlines and airports to develop an ‘extensive return to normal operations plan’ in order to
facilitate a restart of aviation this coming summer.
Airline planning processes must consider aspects such as fleet planning, route evaluation,
schedule development, and revenue and inventory management27 to ensure the commercial
25
https://www.ecdc.europa.eu/sites/default/files/documents/Guidance-for-COVID-19-quarantine-and-
testing-for%20travellers.pdf
26
https://www.irishtimes.com/news/health/nphet-considers-asking-all-arrivals-to-give-samples-for-covid-19-
genomic-sequencing-1.4500081
NCADF Regulatory Working Group 14viability of operations. In the context of Covid-19, airlines are also tasked with the
management of returning aircraft which have been placed in storage, back into service and
ensuring that flight and cabin crew qualifications are up to date as many will not have flown
throughout the pandemic. These challenges will require an appropriate lead-in time as
outlined further below:
Maintenance: Given the very low levels of flying activity over the last 12 months, a
sizeable proportion of the airline fleets will have been placed in parking / storage
programmes at locations across Europe. Furthermore, to save costs, various
maintenance events which would have been due to be carried out had the aircraft
been flying have been deferred. Returning the full fleet to service will require a
unique set of rectifying actions for each aircraft which in some cases may require
significant maintenance checks, consuming significant engineering resources
estimated to take up to 12-14 weeks to complete.
Crewing: Airline crew resources have also been heavily underutilised over the last 12
months. Due to a lack of recent flying experience, many pilots are out of ‘currency’,
and are required by aviation regulation to complete a training programme before
being able to resume commercial flying. Training itself cannot be conducted in flight
simulators alone but also requires ‘real world’ flying, which is currently only occurring
at very minimal levels, exacerbating the problem. Training capacity, in terms of
instructor resources, is a further constraint. In summary, restoring the entire pilot
population to being ‘current’ is a sequential process which is anticipated to take up to
2-3 months, assuming maximum utilisation of airlines training capacity and increased
availability of operational (revenue generating) flight routes to/from Ireland.
Rostering: Although not the most limiting factor in a resumption of normal operations,
it is important that airline and airport staff are given advance notice of their work
requirements, especially where there is a training element incorporated into this.
Rosters are typically published for 4-week periods 7-14 days in advance of the first
day of the roster period but this also requires earlier confirmation of the operating
schedule.
Ground staff: Requirement to ensure that support personnel (e.g. operations control,
engineering, ground handling etc.) are appropriately trained, checked and ready for
return to normal operations and that third-party service providers and suppliers are
also ready for return to normal operations.
In the airport context, advance planning is required to understand how the passenger
journey can be facilitated through a range of airport and third-party operated processes at
various volumes. All airport stakeholders (airport operators, ground handlers, airlines, state
services etc.) will need to engage in that work if we are to avoid bottlenecks and delays. This
will be even more important given the scope for different regimes to apply depending on the
origin/destination of the flight. Some processes or operating practices may also require
specific legislation and/or regulatory approvals in advance of being put in place. Government
27
https://www.iata.org/en/iata-repository/publications/economic-reports/airlines-have-little-visibility-of-
demand/
NCADF Regulatory Working Group 15Covid planning exemptions should continue for any temporary facilities that may be required
to deal with the initial recovery at the airports.
Developing a roadmap to enable the restart of aviation will enable airlines and airports to
recommence operations, restore Ireland’s connectivity and ensure that the economy is
supported to deliver the recovery that will be vital for the country. Government should
therefore engage proactively and as a matter of urgency with all the relevant stakeholders to
facilitate the finalisation and speedy implementation of this plan.
6. Aviation Protocol
The Irish Government’s Protocol for the Management of Air Passengers in light of COVID-19
(December 2020 - Issue 3) provides guidance for coordinated implementation of
EASA/ECDC - “COVID-19 Aviation Health Safety Protocol -Operational Guidelines for the
management of airline passengers in relation to the COVID-19 pandemic” as set out in
Appendix C.28
This protocol to coordinate public health safety measures in air passenger transport was
developed in consultation with the National Air Transport Facilitation Committee which
includes representatives of the aviation industry, regulators, border control and public health
authorities in Ireland.
Inputs were also considered from the NCADF concerning operational implementation of
measures by airports and air carriers, and, the National Civil Aviation Security Committee
concerning risk assessment for possible aviation security impacts.
The EASA/ECDC Guidelines are evaluated on a continuous basis by EASA in conjunction
with the Member State competent authorities.
The objectives of the Protocol include the following:29
• to ensure the health and safety of passengers, as well as the staff and crew who service
them, by reducing the risk of COVID-19 transmission during the journey upon entering
the airport
• to maintain safe and secure operations whilst minimising the risk of COVID-19
transmission during the journey upon entering the airport
• to complement the advice of public health authorities and help employers in their duties
under the relevant legislation on protection of workers’ health and safety’
• to achieve effective risk mitigation and ensure compliance with national public health
requirements
• to ensure preventative measures are implemented in such a way as to consider both the
actual risk factors and practical need for mitigation measures in different circumstances
• to reduce the risk of COVID-19 transmission at the airport and on board the aircraft as
much as practicable
28
https://www.ecdc.europa.eu/en/publications-data/guidelines-covid-19-testing-and-quarantine-air-travellers
29
https://assets.gov.ie/81165/7e6d6df2-c350-4256-a2fd-535f9ae66195.pdf
NCADF Regulatory Working Group 16The above objectives are achieved by the deployment of a range of measures both at the
airport and onboard the aircraft - this includes passenger information; pre-departure health
declarations; hand hygiene and respiratory etiquette signage; mandatory wearing of face
masks; promotion of online/self-check-in and bag drop facilities to promote touchless
customer journeys; use of High-Efficiency Particulate Air (HEPA) filters in jet aircraft which
provides a higher level of health safety assurance than other public transport modes;
reduced inflight services; changes to embarkation and disembarkation processes.
The implementation of the protocols ensures that the risk of transmission of COVID-19 in
airports or onboard aircraft is minimised to a negligible level. This provides passenger
confidence in the steps that the aviation industry continues to take to protect public health.
7. Risk mitigation
Risk mitigation associated with travel is based on a multi layered approach which results in
the low numbers of imported cases into Ireland. Health Protection Surveillance Centre
defines records imported cases in their 14-day epidemiology reports30 and defines within its
technical notes that imported cases only indicates locations where all cases have been
acquired outside the location of reporting i.e. Republic of Ireland.
08-Sep 22-Sep 06-Oct 20-Oct 03-Nov 17-Nov 01-Dec 15-Dec 29-Dec 12-Jan 26-Jan 09-Feb 23-Feb 09-Mar 23-Mar 06-Apr
Total Cases 1,888 3,369 5,543 13,299 10,855 5,778 4,144 4,032 11,967 67,157 34,336 15,189 11,448 7,683 7538 7482
Imported 37 22 19 4 Not Stated 18 2 20 15 Not stated 9 7 11 17 58 23
Share 1.96% 0.65% 0.34% 0.03% n/a 0.31% 0.05% 0.50% 0.13% n/a 0.03% 0.05% 0.10% 0.22% 0.77% 0.31%
The significant reduction in the risk of importation of new COVID-19 cases is achieved
through the multiple risk mitigation in place.
30
https://www.hpsc.ie/a-z/respiratory/coronavirus/novelcoronavirus/surveillance/covid-1914-
dayepidemiologyreports/
NCADF Regulatory Working Group 178. Restarting air travel The combination of a continued improvement in the epidemiological situation, Covid testing and increased vaccination levels is acknowledged as the key enabler to re-opening societies and to removing layers of travel restrictions. Based on clear evidence from countries with high levels of vaccinations31, the ongoing rollout of vaccines should allow for a progressive lifting of restrictions as Covid becomes less impactful and less of a risk to the population and health services. The following recommendations are for a coordinated, risk-based approach that is developed by Government in collaboration with stakeholders and in which it is recognised that current restrictions are temporary and will be removed as soon as reasonably possible. These recommendations also recognise the need for an improved degree of certainty around re-opening dates, restrictions and other requirements which will influence both airline and passengers’ decisions. Such a strategy would enable Irish airlines to develop operational and business plans with a reasonable level of certainty that will allow them to trade their way out of the current crisis and allow passengers to make decisions to plan or book travel with an improved level of certainty. Markets should initially be opened on a phased basis supported by vaccine verification and pre departure testing. Governments should provide clarity about the levels of risk to health that are appropriate to allow travel restrictions to be eased and the relevant metrics for doing so. The aviation industry will not recover if quarantine restrictions continue to be required at a time of rapidly diminishing risk. In addition, this will lead to significant job losses and result in lasting economic and societal harm. The path for safe international travel is through appropriate screening protocols that mitigate the diminishing risks to Ireland. These protocols should be relied upon as part of the phased removal of restrictions. a) Lifting of ban on international travel and metrics Ireland’s connectivity cannot begin to recover from the current crisis until the ban on non- essential international travel is removed. A key deliverable for any Restart Plan is to identify and confirm the metrics that will enable the removal of the current ban on non-essential international travel and the restoration of international travel to key markets including UK, Europe and US once those metrics are met. These metrics should be achievable, balancing public health risk with the requirement for planning certainty. 31 https://www.timesofisrael.com/with-most-israelis-now-fully-vaccinated-virus-spread-continues-sharp-drop- off/ NCADF Regulatory Working Group 18
In a recent IATA survey, 85% of those surveyed believe that governments should set
COVID-19 targets (such as testing capacity or vaccine distribution) to re-open borders.32
For example, the ECDC recommends certain travel restrictions until very high vaccination
coverages of high-risk groups and healthcare workers are reached.33 For Ireland, this could
equate to the start of May 2021 when Health Care Workers and vulnerable groups will have
been fully vaccinated based on current vaccine rollout estimates.
In addition to infection rates, metrics that should also be considered include increasing
vaccination rates and reducing numbers of hospitalisations. Mandatory quarantine legislation
has a sunset clause which requires both Houses of Oireachtas to approve any extension
within three months from the date of enactment (i.e. 8th March 2021).
The extension of mandatory hotel quarantine to additional countries (including certain EU
countries and the US) give rise to significant concerns about the serious and potentially long-
term impact which such measures would have on travel between Ireland and these countries
all of which are close trading partners and key markets for international travel. Measures of
this nature go far beyond those imposed by other EU Member States and would be contrary
to the principles set out in the EU Traffic Light System which establishes a coordinated
approach on the application of common criteria and thresholds to be applied when
introducing restrictions to free movement and on the measures which may appropriately be
applied depending on the level of risk of transmission.
Having due regard to the relevance of proof of vaccination, existing testing requirements and
EU rules on free movement of persons, any requirement for quarantine should be
proportionate and based on transparent and objective criteria. In particular, clarity is required
on the criteria used to determine what constitutes a variant of concern, and a high incidence
thereof. Such criteria should be published, together with a regular review process.
This Plan therefore recommends that transparent and objective criteria be published to
support the inclusion of any country to the Category 2 designated state list of countries
subject to mandatory quarantine together with a regular review process to ensure any
country added to the list is removed at the earliest possible date once these criteria no
longer apply.
Recommendations:
- Government to identify and confirm the metrics that will justify the removal of the
ban on all non-essential international travel) for summer operations together with
target dates based on these metrics and current assumptions
- Having due regard to the relevance of proof of vaccination, existing testing
requirements and EU rules on free movement of persons, any requirement for
quarantine should be proportionate and based on transparent and objective
criteria.
- Government to identify and publish these criteria and review on a regular basis
32
https://www.iata.org/en/pressroom/pr/2021-03-09-01/
33
https://www.ecdc.europa.eu/sites/default/files/documents/Guidance-for-COVID-19-quarantine-and-
testing-for%20travellers.pdf
NCADF Regulatory Working Group 19b) Narrative on international travel
The removal of legal restrictions on international travel is not in itself sufficient to facilitate a
recovery in the sector.
The Government has a key role to play in ensuring the evolution of the current relentlessly
negative commentary on international travel to a more positive narrative having regard to the
improving epidemiological situation and progress on vaccine rollout.
The current ban on non-essential travel has been accompanied by a concerted policy
(including criminal sanctions) to deter people from travelling. In advance of the lifting of the
current ban once the identified metrics have been met, this narrative must be changed and
updated to support and enable international travel as part of this plan.
A comprehensive communications plan supported by Government and stakeholders will be
required to rebuild consumer sentiment in Ireland with respect to international travel. This is
required well in advance of the resumption of air travel and should focus on public
endorsement of the safe resumption of air travel for inbound and outbound travellers.
The narrative therefore needs to shift to indicate that:
• Ireland is one of the most open economies in the world and is re-opening for
business, FDI, trade and tourism all of which are central to the economy. There is an
economic and social need for travel and open borders,
• The combination of vaccines and other measures to manage the virus will reduce the
risk and so there is no reason to continue to overly restrict or discourage travel
• Citizens and businesses require a resumption of more normalised international travel
• The current bans and restrictions on non-essential international travel will be
reconsidered and relaxed as soon as the identified metrics have been met
• International visitors from territories with similar epidemiological situations to Ireland,
and/or who have been vaccinated / tested and/or have proven immunity are welcome
in Ireland.
Recommendations:
- Government and industry stakeholders to develop an evidence-based
communications plan in order to support consumer sentiment and endorse the
safe resumption of air travel when the specified metrics have been met
c) Resume application of the EU Traffic Light System
A cornerstone of the Plan is the resumption of the application of the EU Traffic Light System
to enable international travel.
NCADF Regulatory Working Group 20On 13 October 2020, the EU Council adopted Council Recommendation (EU) 2020/1475 on
a coordinated approach to the restriction of free movement in response to the COVID-19
pandemic. 34
The Recommendation established a coordinated approach on the following key points:
- the application of common criteria and thresholds when deciding whether to
introduce restrictions to free movement,
- a mapping of the risk of COVID-19 transmission based on agreed colour codes,
- a coordinated approach as to the measures which may appropriately be applied to
persons moving between areas, depending on the level of risk of transmission in
those areas.
On 1 February 2021, the Council adopted an updated recommendation on a coordinated
approach to COVID-19 travel measures within the EU in response to the COVID-19
pandemic.35
- Under the updated recommendation, a new colour (Dark Red) is added to the
existing categories. This colour would apply to areas where the virus is circulating at
very high levels, including because of variants of concern.
- Member states should strongly discourage all non-essential travel to red and dark red
areas and require persons travelling from an area classified as dark red to:
1. undergo a test for COVID-19 infection prior to arrival
2. undergo quarantine/self-isolation
Restrictions on non-essential travel to the EU - On 2 February 2021, EU countries
agreed on an updated recommendation on temporary restrictions on non-essential travel into
the EU and the possible lifting of such restrictions.
- The new rules include additional criteria to determine the countries for which the
restrictions should be lifted, such as COVID-19 testing positivity rate and the
presence of virus variants of concern. Transport and frontier workers should be
exempted from certain travel measures.
Common framework for Covid-19 travel measures36
34
See Footnote 1 above and https://www.consilium.europa.eu/media/48122/st05716-en21-public.pdf
35
https://www.consilium.europa.eu/en/press/press-releases/2021/02/01/covid-19-council-updates-
recommendation-on-measures-affecting-free-movement/
36
https://www.consilium.europa.eu/en/infographics/a-common-approach-on-covid-19-measures/
NCADF Regulatory Working Group 21ECDC Maps
Using the criteria and thresholds established in that Recommendation, the ECDC has been
publishing a weekly map of Member States, broken down by regions, in order to support
Member States’ decision-making:
• Green if the 14-day notification rate is lower than 25 cases per 100 000 and the test
positivity rate below 4%;
• Orange if the 14-day notification rate is lower than 50 cases per 100 000 but the test
positivity rate is 4% or higher or, if the 14-day notification rate is between 25 and 150
cases per 100 000 and the test positivity rate is below 4%;
• Red, if the 14-day cumulative COVID-19 case notification rate ranges from 50 to 150
and the test positivity rate of tests for COVID-19 infection is 4% or more, or if the 14-
day cumulative COVID-19 case notification rate is more than 150 but less than 500;
• Dark Red, if the 14-day cumulative COVID-19 case notification rate is 500 or more;
• Grey if there is insufficient information or if the testing rate is lower than 300 cases
per 100 000.
NCADF Regulatory Working Group 22The below maps37 are published by ECDC every Thursday pursuant to the European
Council Recommendation on a coordinated approach to the restriction of free movement in
response to the COVID-19 pandemic, which was adopted by EU Member States on 13
October 2020 and amended on 28 January 2021. The maps are based on data reported by
EU Member States to The European Surveillance System (TESSy) database by 23:59 every
Tuesday. Below chart was published on 8th April:
As the vaccine rollout gathers pace across the EU with reduced rates of hospitalisations and
mortality, the EU Traffic Light System should evolve so that it no longer solely relies on case
numbers to determine the risk profile of particular countries. However, pending such revised
metrics, the following table sets out the recommendations for the ‘Aviation Restart Plan’ for
the resumed use by Ireland of the EU Traffic Light System.
ECDC Colour Recommended measures for resumed EU /traffic light system
Persons arriving from green list locations can enter the State without the
requirement to restrict movement or undergo testing for Covid-19
Pre-departure test based on a rapid antigen test or PCR
Pre-departure test based on PCR test AND 14-day restricted movement
from test (with test to release after 5 days)
Pre-departure test based on PCR AND 14-day home quarantine (with test
to release after 5 days)
Passengers with evidence of vaccinations/ proof of recovery to be exempt from restrictions
37
https://www.ecdc.europa.eu/en/covid-19/situation-updates/weekly-maps-coordinated-restriction-free-
movement
NCADF Regulatory Working Group 23Recommendations:
- Resumption of the EU Traffic Light System
- Persons arriving from Green list locations can enter the State without the
requirement to restrict movement or undergo testing for Covid-19
- Persons arriving from Orange coded areas subject to pre-departure test based on
a rapid antigen test or PCR
- Persons arriving from Red areas subject to a pre-departure test based on PCR test
and 14-day restricted movement (with test to release after 5 days)
- Persons arriving from Dark Red areas are subject to pre-departure test based on
PCR AND 14-day home quarantine with test to release after 5 days
- Non-essential travel from Dark Red areas should continue to be discouraged
- Government to support evolution of EU Traffic Light System to waive testing
requirement and restriction requirement for vaccinated travellers and those with
proof of recovery
d) UK
The Government should also give due consideration to opening up travel between Ireland
and the UK at the earliest opportunity having regard to the 300 mile open land border
together with the implications of the Common Travel Area (CTA) and the Brexit Protocol on
freedom of movement within the island of Ireland and between Ireland and the United
Kingdom. It should be recognised that the UK Government has at all times during the current
pandemic allowed for unrestricted travel from Ireland to the United Kingdom. . In addition,
the UK has the highest vaccination levels in Europe and travel from the UK represents a
minimal risk and should be facilitated without delay.
Recognising the level of traffic across the open border to/from Northern Ireland, the current
broad alignment with regards to countries considered high risk due to variants of concern,
and the improving epidemiological situation on both islands, together with the very high
levels of vaccination in the UK, there is no public health rationale for restrictions in travel
between Ireland and the UK. There exists therefore an opportunity for the Government to
remove unilateral restrictions on travel from the UK as an immediate priority to ensure that
the benefits of the CTA and the Brexit Protocol can be resumed at the earliest juncture.
It is also noted that the UK has established a Global Travel Task Force which has recently
issued its initial report to the UK Government with recommendations on a restart of
international travel potentially as early as 17th May. Having regard to the impact that this
Report will have on international travel to/from the UK (including Northern Ireland) and the
high volume of traffic between Northern Ireland and the Republic of Ireland, there will no
longer be any rationale for continued restrictions on travel from the UK. The Government
should as far as possible seek to align its policy on international travel with that of the United
Kingdom where appropriate.
Recommendations:
- Government should, as an immediate priority, seek to restore the full operation of
the CTA for Irish and UK citizens and remove restrictions on travel from the United
Kingdom.
- Government should seek to align its approach to international travel with that of the
UK while respecting the principles of the EU Traffic Light System.
NCADF Regulatory Working Group 24e) USA
The vaccine outlook for the US has improved following President Biden’s announcement on
2nd March that there would be enough doses of the coronavirus vaccine available for the
entire adult population in the United States by the end of May (noting that it will take longer
to inoculate everyone). This is an improvement of the previous July estimate.38
The US Centre for Disease Control (CDC) has recently updated its travel guidance for fully
vaccinated people.39
Key points include:
- Fully vaccinated people can travel in the US without the need for COVID-19 testing
or self-quarantine as long as they continue to follow COVID precautions while
travelling (mask, social distance etc)
- Fully vaccinated people can travel internationally without getting a COVID-19 test
before travel unless it is required by the international destination
- Fully vaccinated people do not need to self-quarantine after returning to the US,
unless required by a state or local jurisdiction
- Fully vaccinated people must still have a negative COVID-19 test result before they
board a flight to the US and get a COVID-19 test 3-5 days after returning from
international travel
Pre-departure testing/ Proof of recovery: Effective January 26, the US CDC requires all
air passengers entering the United States (including U.S. citizens and Legal Permanent
Residents) to present a negative COVID-19 test, taken within three calendar days of
departure or proof of recovery from the virus within the last 90 days. Airlines must confirm
the negative test result or proof of recovery for all passengers two years of age and over,
prior to boarding. Airlines must deny boarding of passengers who do not provide
documentation of a negative test or recovery.
Entry ban: Currently a US proclamation applying to citizens of the United Kingdom and
Ireland that restricts entry in the US, was made effective on 16th March 2020. This followed
the proclamation relating to Schengen countries on 11th March 2020. Neither proclamations
apply to US citizens.
The US Government has not yet made any formal announcements of changes to their
existing “212f” restrictions on travel to the US by non-US nationals who have in the past 14
days been in the Schengen Area, Brazil, Ireland, the United Kingdom, China and
Iran. However, on 2nd April it was reported to IATA that the CDC is developing a road map
with criteria to be used to determine when/if to establish travel corridors with certain
countries.
38
https://www.nytimes.com/live/2021/03/02/world/covid-19-coronavirus/biden-says-there-will-be-enough-
vaccine-available-for-all-adults-by-the-end-of-may-as-johnson-johnson-makes-a-deal-to-boost-supp
39
: https://www.cdc.gov/media/releases/2021/p0402-travel-guidance-vaccinated-
people.html?ACSTrackingID=USCDC_1_3-
DM53881&ACSTrackingLabel=CDC%20Newsroom%3A%20Week%20In%20Review%20-
%2003%2F29%2F21&deliveryName=USCDC_1_3-DM53881
NCADF Regulatory Working Group 25You can also read
