Mr. Donal Moriarty:

I thank the committee for having the opportunity to speak before it again. Aer Lingus has previously outlined, both in July at the Oireachtas Special Committee on Covid-19 Response and again at our appearance before this committee on 7 October, the catastrophic effects that the Covid-19 pandemic continues to have on the global aviation sector.

The committee is aware of how important aviation is for the Irish economy and its prospects for future recovery. The members all know that the international businesses that headquarter in Ireland, that manufacture in Ireland, that carry out critical research and development in Ireland, and that secure investment from their boards for Ireland do so because Ireland is a connected, progressive, business-friendly country. Connectivity is key. We are an island nation, and that connectivity can never be taken for granted. It is a key element of foreign inward investment and in helping our domestic businesses to grow and develop.

Now is the time to put a framework in place so that all businesses can plan for 2021. Fortunately, there are elements of that framework already in existence. Crucially, we know that air travel is safe. Aer Lingus and other airlines have put in place measures in line with European Union Aviation Safety Agency, EASA, and ECDC guidelines that very effectively mitigate the risk of transmission during travel. Indeed, a recent study by the International Air Transport Association, IATA, indicated that risk of transmission on board an aircraft is as low as one in 27 million. Second, the traffic light system introduced by the European Council recently is an important step towards ensuring greater harmonisation for safer travel across Europe, and I will address that in more detail later. Third, new and more effective means of testing are being used globally, and their introduction into this country can increase the level of safe international travel.

I now turn to the decision of the European Council on the traffic light system. The decision at the European Council on 13 October aims to co-ordinate the approach to free movement in response to the Covid-19 pandemic. The wider aviation sector has been somewhat critical of the ultimate decision that emerged from the European Council. The Council recommended a co-ordinated approach to free movement and set out some guidance for member states, but it falls considerably short of what was originally proposed by the European Commission on 4 September, which was to encourage a restart of travel through effective co-ordination and proportionate, predictable and non-discriminatory measures.

Despite this assessment of the European Council decision, Aer Lingus has constructively shared an implementation approach with Department of Transport that could support safely increasing international travel. Although it has not yet been published, Aer Lingus understands that the Government approach to implementing the European traffic light system will involve a number of elements. First, persons arriving from green list locations can enter the State without the requirement to restrict movement or undergo testing. Second, people arriving from orange-listed locations should have the option to disapply the requirement to restrict movements if they have negative test result of an appropriate standard done pre-departure. Third, people coming from red-listed countries should have the option to disapply the requirement to restrict movements following a negative test result taken five days after arrival. We understand that that is the Government's proposal, although it has not been published yet.

We would describe the proposed approach as a fairly tentative and moderately positive step forward, but it urgently needs to evolve and move to something quite different. Aer Lingus is actively engaging with the Government and will seek to influence the implementation of an appropriate solution before 8 November 2020, which I understand is the date the Government has in mind.

Aer Lingus notes that the intention is to allow travel from orange-coded countries and areas without a requirement to restrict movements on arrival if a pre-departure test is taken. In our view, it is critical that if pre-departure tests are required for passengers travelling from orange-coded countries, it has to be based on a rapid, affordable antigen testing solution. Only a rapid antigen testing solution will facilitate a meaningful increase in safe international travel. For passengers coming from high-risk or red countries, the European Council decision specifically enables the replacement of quarantine and movement restrictions by the introduction of a testing regime.

Aer Lingus also welcomes the exemption in the European Council decision for passengers with an essential function from the requirement to undertake restricted movement or testing while exercising this essential function, and this includes those in critical occupations, students and persons travelling for imperative family or business reasons. This exemption will allow passengers with an essential function to travel without restriction, be that a test or a movement restriction.

Aer Lingus believes that following the initial implementation of the measures, the fortnightly review process, which we understand the Government intends to apply, should quickly lead to a streamlining of the processes to allow a meaningful increase in safe international travel. This streamlining should look like a limited form of random rapid testing for passengers arriving from higher risk orange-coded countries, and a pre-departure testing for countries classified as red.

Aer Lingus believes that through the adoption of a co-ordinated and multilayered risk mitigation approach the level of safe international travel can be increased. The multiple layers involve pre-travel health declarations; mandatory use of face masks; enhanced cleaning on aircraft and in the airport environment; the use of state-of-the-art air filtration technology on board the aircraft; the use of the e-passenger locator forms, ePLF; the use of the Covid tracker app and its integration with similar apps in other countries; and agreed international travel protocols such as the European traffic light system. It is based on this range of risk mitigation measures, which is already in place, that we believe aviation requires a screening standard of testing, not a diagnostic standard of testing. In summary, Ireland must implement the European Council’s decision in such a way that the traffic light system delivers a meaningful contribution to increasing safe international travel.

I will turn briefly to testing and rapid testing. First, I draw the committee's attention to the International Air Transport Association, IATA, study which indicates that the risk of on-board transmission is one in 27 million. So far in 2020, 1.2 billion passengers have travelled by air and IATA says there are only 44 cases of Covid-19 being transmitted on board an aircraft in that period of time. Second, the European Centre for Disease Prevention and Control, ECDC, notes that in the current epidemiological situation it does not recommend that passengers should be systematically tested when crossing internal or external administrative borders. I also point to the recent data released by the Health Protection Surveillance Centre, HPSC, on 21 October, which highlighted that four cases were reported in the previous 14 days that were travel related. There were 80,000 passengers in that period of time, which represents 0.05% of cases in that period. The evidence, therefore, is that international travel is simply not a vector of transmission for Covid-19. Interestingly, the HPSC report published on 21 October has not been published since. We believe the continued publication of the report would be a helpful statistic and it should continue. I do not understand why it has been discontinued.

All this highlights the effectiveness of the measures introduced by the-----