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Review of the Transport Security Amendment Bill 2024 - Public Hearing 20/02/25

Via APH YouTube channel:

Australian Airports Association (AAA)

Submission link: https://www.aph.gov.au/DocumentStore.ash...bId=776488

Opening statement:

Mr Westaway : Thank you for this opportunity to appear today. The Australian Airports Association represents over 340 airports across Australia. This includes our major international hubs and regional and small aerodromes. We also have 150-plus corporate members which support aviation nationwide. Our members are essential in connecting communities, facilitating trade and tourism and supporting livelihoods. Today, 40 per cent of Australians interface with a local airport annually, which we think is an important point.

The AAA supports strength in our aviation security. However, we have genuine concerns about the Transport Security Amendment Bill 2024 which remain unaddressed, and we detailed these in our considered submission. The AAA notes the inadequate consultation process by the Cyber and Infrastructure Security Centre, or CISC. Whilst we appreciate the pre-election cycle that we now all feel like we're in, only two formal consultation phases with industry have actually occurred. The first allowed for minor feedback, and legitimate concerns were overlooked. The second, a first-pass impact analysis, was a rushed process. There was just a week for stakeholder response before the bill came before parliament.

Regulatory duplication caused by CISC's proposed all-hazards security framework remains a significant issue. Contrary to CISC's claims, comparable international frameworks do not adopt such a model for aviation security. Examples from the UK, the USA and the EU that the CISC used in their submission touched on natural hazards in passing or were focused on critical infrastructure but not aviation security. Australian airports already manage natural hazards under the Civil Aviation Safety Authority. CASA's manual of standards, MOS, part 139 requires aerodrome emergency management plans to align with the International Civil Aviation Organization's, ICAO, annex 14. Meanwhile, ICAO's annex 17 governs aviation security and does not integrate natural hazards. This is a further example of unnecessary regulatory duplication, a disappointing constant across Australian aviation today.

Compliance costs are a major concern for us. By the CISC's own estimates, implementation costs could cost our sector nearly $1 billion over the next decade. This is an additional expense for airports across Australia, particularly for our small regional airports, who will find it very difficult to absorb these costs. In 2023-24, our major airports had over 97 million passenger throughputs while our regional and rural airports had a little over 18 million passenger throughput movements. These costs will inevitably be passed on to the flying public. Further increasing travel expenses in a disproportionate way will impact regional and rural aviation harder.

Finally, while security is paramount, pushing legislation without due consideration is problematic, and we believe it's actually bad public policy. The AAA recommends a minimum 24-month compliance timeline, rather than the proposed one year. This is to ensure effective implementation without the unintended consequences.

In conclusion, the AAA urges the committee to refine this bill to eliminate regulatory duplication, ensure a proportionate risk based approach and mitigate the cost burdens.

Qantas | Virgin Airlines | Airlines for ANZ

ANZ submission link: https://www.aph.gov.au/DocumentStore.ash...bId=776498

Department of Home Affairs

DoHA submission link: https://www.aph.gov.au/DocumentStore.ash...bId=776480

Hansard link: https://www.aph.gov.au/Parliamentary_Bus.../&sid=0000


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