Written evidence submitted by Kent County Council (EEE0002)

1. The EU first proposed an entry/exit system for the Schengen Area in February 2008. How have proposals for its introduction developed over the last 15 years?
2. Are there currently any other domestic or transnational systems either planned or in operation that are similar to EES?
3. The EU’s Entry/Exit System was initially due to be introduced in 2022. What challenges do the EU and its Member States face in ensuring the full introduction and effective operation of EES?
4. What challenges will ‘third country’ (non-EU Member State) ports and operators face servicing destinations in the Schengen Area when EES becomes fully operational?
5. How will EES affect the travel experience of third country nationals?

The international rail link and the stations within Kent are the result of multi-billion-pound UK state investment to enable fast, convenient and seamless travel between the UK and its largest trading partner. As late as 2019, UK government funding has been directed into the international rail link, with investment at Ashford International station to ensure that power and signalling upgrades for route between the station platforms and the international high-speed track can continue to allow modern international train fleets to stop at the platforms for the benefit of passengers. This investment and the wider investment represented a recognition of the substantial journey time benefits and environmental credentials of international rail. A single international rail journey on the link via the Channel Tunnel emits around 20 times less carbon that the equivalent journey by plane. The form of the EES in terms of the technology used, the infrastructure needed and the process that travellers have to follow, all pose risks to ensuring that the international rail link and its stations for accessing services (given the juxtaposed border arrangements) remain a go-to choose for the millions of passengers who already do and could further use the link in the future. For Kent County Council, this carries further importance as the existing stations at Ashford International and Ebbsfleet International remain unserved by international services since 2020 due to the Covid pandemic, with the risks of EES now cited by Eurostar International as a further factor weighing against the prospect of future services. Potential new operators on the line provide an opportunity, but for any operator the ease of conducting convenient and efficient station operations and quality of journey experience will be a vital factor in determining operating models using the stations available to serve the southeast region’s market. Given this, as with non-rail juxtaposed border points, Kent County Council strongly urges the Committee to use the inquiry evidence to recommend extensive effort by the Government to work with operators and infrastructure owners and managers, such as High Speed Limited (HS1 Ltd), and with the French Government and all services involved in frontier control, to ensure the EES is conducive to maintaining the benefits of international rail, and places no new barriers for customers to use the international rail link. Furthermore Kent County Council urges the Committee to use the evidence from the inquiry to recommend to the government that the Kent stations of Ebbsfleet International and Ashford International can continue to provide benefits following the substantial sunk UK public investment in these stations, by ensuring that any remaining infrastructure needed to facilitate passenger service operations is provided in the public interest and not at the mercy of solely commercial decisions by operators and HS1 Ltd.

The Port of Dover has very limited space in the buffer zone between the Eastern Docks roundabout and the French Customs booths. Currently, the buffer zone is the only area that EES Registration can be carried out. This will mean lengthy delays for all tourist traffic entering the port. Any queuing tourist traffic outside the Port may then in turn impact the outbound freight (85% of which is from Schengen areas) causing lengthy delays for good supplies between UK and Europe. Queues for tourists have been quoted as a reasonable worst case of up to 14 hours. Such queues will create welfare concerns for passengers as well as having a significant effect on the local communities, specifically the town of Dover. Whilst Eurotunnel has more space to manage the flow of tourist traffic, lengthy delays at the Port of Dover is likely to see queues back along the A20 and M20, which in turn has a significant impact on Eurotunnel, blocking access for staff and ultimately blocking access for tourist traffic. In the summer of 2022, delays on the approaches to both portals in Kent caused long delays with tourists stuck in queues for over 15 hours – the impact of EES on tourist traffic crossing the short straits is expected to be much worse.

6. The EU is not planning to allow registration for EES remotely—e.g. via a dedicated website or mobile phone application—or physically at a location away from London St Pancras, Dover or Folkestone (such as an EU or Member State facility in a major UK city).
1. Is this approach justified?
2. Would remote registration be justifiable for nationals of countries with comparable immigration and security standards to the EU?

Further to our answer to question 5, we understand from operators and infrastructure owners of the high-speed international rail link and the stations on that route, that a lack of front-ending of registration remotely risks adding processing time and queueing time and delay to international rail travellers. We understand from these rail industry actors that are both UK-based and EU-based that remote registration should be technologically possible and viable whilst preserving the planned integrity of the EES and the checks it entails. We are concerned, as stated in answer to question 5, that EES implementation could erode the benefits of the international rail link and the public sector investment in that. We therefore recommend that the Committee urge Government to continue to work with operators, infrastructure owners, EU member state governments, the European Commission and its agencies to explore all technological capabilities and legislative possibilities to enable remote registration and consequently to reduce the prospect of delays at the border points.

By allowing remote registration, the expected delays to tourist traffic to the Port of Dover and Eurotunnel would be greatly reduced. This would reduce welfare concerns for passengers, ensure the continued through flow of freight and reduce the impact on residents and businesses in Kent.

7. Juxtaposed UK/France(Schengen) border controls are in operation at London St Pancras International, Folkestone and Dover.    1. introduced in its current form, what challenges will EES present UK sites facilitating juxtaposed border controls?    2. Should special dispensation for remote registration or remote pre-registration for EES be provided for at these sites?

Kent County Council wishes to bring the Committee’s attention to the prospect and opportunity that, additional to those locations listed, Ashford International and Ebbsfleet International stations are two further locations in the UK where juxtaposed control bureaux are required by legislation, and where border controls have operated until Eurostar suspended services during the pandemic in March 2020. These important locations for providing access to the southeast region via the convenient motorway network connections and their capacious vehicle parking provisions, as well as providing arrival points for international visitors to enjoy the wealth of visitor attractions across the southeast, must not be overlooked. We urge the Committee not to lose focus on these important international transport assets and to ensure that in their recommendations to government, whatever provisions are promoted and undertaken for St Pancras, Folkestone and Dover and similarly undertaken for Ashford and Ebbsfleet International stations as this is in the public interest.

8. In addition to EES, the EU plans to introduce a ‘European Travel Information and Authorisation System’ (ETIAS) in 2024. The UK’s ‘Electronic Travel Authorisation’ scheme will go live in November 2023.   1. What challenges does the introduction of new EU and UK electronic travel systems present for operators and travellers?   2. Should the UK EU and international partners prioritise interoperability between their respective systems?
9. What steps should the UK Government be taking to mitigate potential disruption stemming from the introduction of EES for UK ports, operators, and passengers travelling to the Schengen Area?

Whatever is needed for St Pancras International should similarly be provided for Ebbsfleet and Ashford International stations.

If there is no facility for prior registration, as mentioned previously there will be lengthy queues of tourists at the Port of Dover and Eurotunnel. Freight will be delayed, Operation Brock could become a permanent feature, rather than at peak times. Increased facilities for holding EU bound freight is essential so that the Strategic Road Network through Kent does not become a permanent lorry park. As previously stated, welfare for tourists will be a major issue. UK government must enable the Local Resilience Forum to be funded accordingly to enable provision of adequate welfare. In addition, the UK Government must recognise that the Short Straits is the most important entry to Europe for the whole of the UK and Kent County Council must be supported with managing the expected impact on the county.

January 2024