NCADF Regulatory Working Group

IRELAND’S AVIATION RESTART PLAN 2021

APRIL 14, 2021

NCADF Regulatory Working Group 1

Contents

Page

1. Executive summary 2

2. Economic importance of aviation 10

3. Epidemiological situation 10

4. Variants of concern 5. Airline and Airport planning processes

12 14

6. Aviation protocol 7. Risk mitigation

16 17

8. Restarting air travel 18

A. Lifting ban on international travel and metrics B. Narrative on international travel C. EU traffic light system D. UK E. USA F. Other countries G. Vaccines

18 20 20 24 25 27 28

H. Testing 30

I. Proof of recovery 32

J. Passenger Locator Form K. Travel Apps L. Operational readiness

33 33 34

9. Financial Support 10. Summary recommendations

35 37

Appendices: Appendix A: International experience Appendix B: Antigen Testing Appendix C: Protocol for the management of air passengers

40 43 44

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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.

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• 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/

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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

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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

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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

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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

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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

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Jan-Mar Apr-May Jun

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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

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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

USA By April 19, every adult will be eligible to be vaccinated / Sufficient supplies for all

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 15https://www.zerohedge.com/markets/goldman-now-sees-most-advanced-economies-reaching-herd-

immunity-3-months

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There 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

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The 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:

22https://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

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- 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

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viability 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/

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Covid 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

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The 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.

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/

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%

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8. 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/

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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

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b) 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.

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On 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/

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ECDC 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.

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The 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

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Recommendations:

- 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.

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e) 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

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Track and Trace: We understand the US is planning to introduce contact tracing capability

for international passengers in the coming weeks which will replicate the objectives of the

Passenger Locator Form system in Ireland.

Contact Tracing: The US Government is also implementing a contact tracing program

applicable to all passengers flying to the United States. This will be almost identical to the

contact tracing program considered in 2020 but which was put on hold by the US

Government. This includes 1) Collection of data elements; 2) Transmission to CBP via APIS,

JSON and, for the short term (100 days) PNRGOV.

At this point, the US Government proposes to issue the Order with a short-term effective

date which will include language which will provide airlines with 90-100 days to be in full

compliance.

Recommended Approach:

Recognising the strong business and cultural 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.

There is a requirement for effective risk mitigation measures that would enable the aviation

industry to safely open up operations in line with wider international experience.

The following proposed approach recognises Ireland’s alignment (albeit currently

suspended) with the European guidance (currently reflected by the European Council

Decision approved on 13th October and as amended in January 2021 which aims to

enhance coordination and harmonisation among EU countries for intra EU/EEA/UK travel).

The principles of this approach should also be applied reciprocally for travel between Ireland

and the US and a regional approach should be adopted at state level.

Epidemiological progress, developments in respect of vaccination programmes and the

potential introduction of digital passports with health information create further opportunities

to relax the entry ban into the US.

In relation to the US, Ireland does not apply the travel restrictions applied at a European

level but currently maintains a mandatory quarantine for travellers who arrive from US with

the ability to test out after 5 days.

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.

The European Council decision also states that passengers with an essential function or

need and persons travelling for imperative business or family reason should not be required

to undergo quarantine or restrict their movements. This should be applied for travel between

US and Ireland.

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There is an opportunity to strengthen the Ireland/US relationship under the current US

administration including exploring the possibility of piloting safe travel corridor arrangements

for Irish citizens.

There is therefore a strong case for urgent bilateral engagement between US and Ireland.

Pilot

Pending the lifting of the entry ban which prohibits entry to the US for Irish citizens40

engagement between the US and Ireland is required to consider a more graduated approach

for Irish citizens that leverages the presence of US CBP facilities in Dublin and Shannon

Airports.

This could consider a segmented approach to the lifting of the ban or exempting categories

of passengers to enable travel on a piloted basis. This could include enabling travel for a)

verifiable business purposes; b) for passengers with documentary evidence of vaccination;

c) for passengers with stays less than 72 hours by way of example.

Engagement of US / Ireland stakeholders to promote this opportunity is therefore a key

priority.

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

f) Other Countries

There is an opportunity to use the mechanics of the EU Traffic Light system to enable

reciprocal access for Irish and other third country citizens and thus enable the resumption of

travel between Ireland and other strategically important third countries.

Recommendations:

- Government to engage bilaterally with other country Governments to agree a reciprocal basis in which to enable restoration of travel

- Government to explore opportunities to pilot schemes that may enable earlier relaxation of entry bans for Irish citizens to other key countries

40 https://www.whitehouse.gov/briefing-room/presidential-actions/2021/01/25/proclamation-on-the-suspension-of-entry-as-immigrants-and-non-immigrants-of-certain-additional-persons-who-pose-a-risk-of-transmitting-coronavirus-disease/

NCADF Regulatory Working Group 28

g) Vaccines:

The World Health Organization (WHO) supports the use of vaccination on the principle that

when a substantial proportion of a population is vaccinated, this lowers the overall amount of

virus spreading in the whole population.41 WHO’s position is based on the encouraging

preliminary results of some large, Phase III clinical trials of COVID-19 vaccine candidates, as

well as available data suggesting that most people who recover from COVID-19 develop an

immune response that provides at least some period of protection against reinfection.42

Besides its key role in bringing the pandemic under control, vaccination will also play an

important role in aviation recovery as the proportion of the global population that is

vaccinated increases over time. The study by Cambridge University Hospitals NHS

Foundation Trust (CUH) and the University of Cambridge analysed data from thousands of

Covid-19 tests carried out each week on hospital staff who showed no signs of infection.

Two weeks after a single dose of the Pfizer Covid-19 vaccine, hospital staff became four

times less likely to become infected with Coronavirus.43

The International Civil Aviation Organization (ICAO) supports WHO’s position on not

requiring vaccination as a precondition for travel. While vaccination should not be a pre-

requisite for travel, measures applied to vaccinated persons should be proportionate to the

level of risk which they present. Vaccinated persons would have reduced risk of acquiring

infection outside the home country and reintroducing infection upon return to home

country44.

A scientific report45 jointly prepared by Israel's health ministry and Pfizer claims that the

company’s covid-19 vaccine is stopping nine out of 10 infections and the country could

approach herd immunity by next month. The study, based on the health records of hundreds

of thousands of Israelis, finds that the vaccine may sharply curtail transmission of the

coronavirus. “High vaccine uptake can meaningfully stem the pandemic and offers hope for

eventual control of the pandemic as vaccination programs ramp up across the rest of the

world,” according to the authors.

As such, a coordinated, time-limited, risk-based, and evidence-based approach to health

measures, including vaccination, in relation to international travel should be encouraged.46

41 WHO, Coronavirus disease (COVID-19): Herd Immunity, Lockdowns and COVID-19, updated 31 December 2020. https://www.who.int/news-room/q-a-detail/herd-immunity-lockdowns-and-covid-19 42 WHO, Coronavirus disease (COVID-19): Vaccines. 12 December 2020. [website] 43 https://www.authorea.com/users/332778/articles/509881-single-dose-bnt162b2-vaccine-protects-against-asymptomatic-sars-cov-2-infection?access_token=-hDTQsMUXcCPSpdZV_Lmpg 44 WHO SAGE Roadmap for Prioritising Uses of COVID-19 Vaccines in the context of limited supply, p.18 45 https://www.technologyreview.com/2021/02/19/1019264/a-leaked-report-pfizers-vaccine-conquering-

covid-19-in-its-largest-real-world-test/

46 WHO, Statement on the sixth meeting of the International Health Regulations (IHR) (2005) Emergency

Committee regarding the coronavirus disease (COVID-19) pandemic (15 January 2021)

NCADF Regulatory Working Group 29

Whilst vaccines will be important in reducing the risk of infection among the general

population of a country and therefore enabling a phased removal of travel restrictions, the

pace of rollout in other countries will differ and as a result, vaccines should not be mandated

as the only means of enabling travel.

Governments, the EU Commission and IATA/ICAO must work together to produce a

standard international vaccination certificate that will enable travel without the need to

comply with any other testing or quarantine requirements that may be imposed on those who

have not received a vaccine..

The European Commission’s plans for a Digital Green Pass to facilitate European citizens'

lives and in particular to gradually enable them to move safely in the European Union or

abroad - for work or tourism is an important development which should be welcomed.

Also of note in this regard is the statement by Dr Michael Ryan, director of the WHO’s

emergencies programme, that the agency was now “looking at different options around

vaccine passports so that governments can at some point verify the vaccination status of

individuals as they potentially move around the world”47.

There are many countries who are allowing or planning to allow vaccinated travellers to be

exempt from measures like quarantine or testing. These include Greece, Cyprus, Portugal,

Iceland, Estonia, Seychelles, Romania, Georgia, Poland, Spain.

In Massachusetts, from 18th March travellers who are fully vaccinated (i.e. who have

received two doses of either the Moderna or Pfizer COVID-19 vaccines OR who have

received a single dose of the Johnson & Johnson vaccine, 14 days or more ago and who do

not have symptoms) will not be required to show evidence of a negative test or quarantine

on arrival into the State.48

Based on the clear evidence about the effectiveness of vaccines from countries with high

levels of vaccinations as outlined above, 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. Vaccination of the population is therefore key to restarting

travel and reopening Ireland and travel restrictions should be eased once the vulnerable and

healthcare workers have been vaccinated. The Aviation Restart Plan therefore recommends

that those who have received the requisite doses of a vaccine approved by European

Medicine Agency (EMA)49 should be exempt from testing and quarantine requirements. It is

for the governments to determine the point at which vaccine rollout in their own population is

at a level that allows travel restrictions to be eased and this should be communicated

transparently.

47 https://www.dailymail.co.uk/news/article-9319293/Foreign-holidays-hopes-boosted-appears-warming-

Covid-vaccine-passports-plan.html

48 https://www.nbcboston.com/news/local/massachusetts-covid-19-travel-order-be-replaced-with-advisory/2332616/ 49 https://www.ema.europa.eu/en/human-regulatory/overview/public-health-threats/coronavirus-disease-covid-19/treatments-vaccines/vaccines-covid-19/covid-19-vaccines-authorised#authorised-covid-19-vaccines-section

NCADF Regulatory Working Group 30

Airline crew or aviation personnel should be prioritised for vaccination in accordance with WHO guidance and in recognition of the importance of maintaining air connectivity50.

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) should be exempt from testing and quarantine requirements

- Ireland to produce a standard vaccination certificate in line with the proposed EU Digital Green Pass that will enable international travel in UK, Europe and US without the need to comply with any other testing or quarantine requirements

- Government to support an evolution of the EU Traffic Light System such that vaccinated travellers be exempted from testing and quarantine requirements

h) 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. The industry does not believe that testing should be considered a

permanent travel requirement and should be removed as soon as the Government’s

assessments of risk allow.

Mandatory pre-departure testing should be maintained as the ongoing primary measure to

provide consistency for travellers from high risk countries and support Government scrutiny

of travel and should be used instead of quarantine as part of the phased removal of

restrictions.

Any requirements to test should be for pre-departure tests to reassure customers, staff and

authorities that flights are virus free.

The March ‘Report of the Covid-19 Rapid testing Group’ established by the Irish Government

noted that rapid antigen tests are sensitive for detection of infectious cases.51 This is key to

enabling travel and is the reason antigen tests enables travel to many of Irelands key

markets including UK, US and several European states.

The report also calls for the Department of Enterprise, Trade and Employment and wider

employers to establish programmes of repeated rapid testing of essential workers who travel

into the country. This approach has much wider applicability to enable travel

Irish aviation urges governments to support affordable rapid tests including antigen as an

enabler to remove restrictions. These tests will be key to supporting travel once demand

returns and passenger numbers increase. As travel related testing should be considered as

a screening rather than a diagnostic device, we do not believe that the very high sensitivity

and specificity levels appropriate in a diagnostic setting should be applied to tests used to

permit travel provided that sufficiently high accuracy levels can be demonstrated.

50 https://a4e.eu/publications/1338/ 51 https://www.gov.ie/en/publication/f50f0-report-of-the-covid-19-rapid-testing-group/

NCADF Regulatory Working Group 31

In addition, the ‘Report of the Covid-19 Rapid testing Group’ calls for the launch of major

testing programmes including the use of Rapid Antigen tests to support “Test to release- to

reduce harms from unnecessary quarantines e.g. international travellers”. As the ECDC has

noted, rapid antigen “should be able to rule out the most infectious cases. Using them to

screen travellers prior to departure would therefore specifically prevent transmission during

travel and directly upon arrival, as it would stop highly infectious individuals from travelling.

RADTs may miss individuals with low viral loads, for example during the pre-symptomatic

phase and/or towards the end of the active infection”52

Effective criteria for testing protocols

• Rapid: Testing should be able to be performed at speed, particularly if testing is to take place at the airport (results within an hour)

• Scalable: Testing needs to be scalable to respond to increasing traffic levels

• Accuracy: Testing should demonstrate high sensitivity and specificity

• Recognised: Testing should be supported by a system of mutual recognition across the EU/EEA/Switzerland and the UK and US regulators.

• Affordable: Testing should be at an affordable cost for passengers

The Lancet journal has stated that: “For those who test positive in low prevalence settings,

the high false positive rate means that mitigation strategies, such as PCR testing to confirm

positive results, are needed. Antigen Tests when used appropriately, are promising tools for

scaling up testing and ensuring that patient management and public health measures can be

implemented without delay”.53

The European Council agreed in January on strengthening the use of rapid antigen tests

and on the mutual recognition of COVID-19 test results. Member states (including Ireland)

unanimously agreed on a Council recommendation setting a common framework for the use

of rapid antigen tests and the mutual recognition of COVID-19 test results across the EU.54

The Council stated that: “This is a central tool to help mitigate the spread of the virus and

contribute to the smooth functioning of the internal market; the mutual recognition of test

results is essential in order to facilitate cross-border movement, cross-border contact

tracing and treatment”55

The HIQA report56 published in October 2020 specifically states that rapid antigen test

“screening may be feasible in some open settings, such as airports if adequate measures

are taken to address challenges such as follow up, estimating testing volumes, safety and

quality assurance processes and variable prevalence”.

The challenges associated with international travel should be addressed through greater

investment in track and trace capability and greater use of the COVID-19 Tracker app by

arriving passengers.

52 https://www.ecdc.europa.eu/en/publications-data/guidance-covid-19-quarantine-and-testing-travellers 53 https://www.thelancet.com/journals/laninf/article/PIIS1473-3099(21)00048-7/fulltext 54 COUNCIL RECOMMENDATION on a common framework for the use and validation of rapid antigen tests and the mutual recognition of COVID-19 test results in the EU 55 https://www.consilium.europa.eu/en/press/press-releases/2021/01/21/council-agrees-on-strengthening-the-use-of-rapid-antigen-tests-and-on-the-mutual-recognition-of-covid-19-test-results/ 56 HIQA report https://www.hiqa.ie/sites/default/files/2020-10/Rapid-HTA-of-alternative-diagnostic-tests.pdf

NCADF Regulatory Working Group 32

Antigen testing as a pre-departure test is currently being used to enable travel across the majority of Ireland’s key markets including UK, US, Germany, Italy.

In respect of affordability, the Government should support the access of passengers to affordable testing options to ensure that cost is not a barrier to travel from Ireland.

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 - Testing should not be considered a permanent travel requirement and should be

reduced over time - Government to support access to affordable rapid tests including antigen

i) 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.57

Like the arrangements in effect in the US, travel should be enabled for passengers who have

recovered from Covid following a previous infection and being cleared for travel by a

licensed heath care provider or public health official. For reference, currently the US CDC

states the recovery from COVID-19 follows having tested positive in the last 3 months (90

days).

The CDC in the US states that accumulating evidence supports the recommendation that

people who have recovered from laboratory-confirmed COVID-19 do not need to undergo

repeat testing or quarantine in the case of another SARS-CoV-2 exposure within 90 days of

their initial diagnosis. 58

Recommendations:

- Government to enable passengers with documented proof of recovery from Covid-19 within 6 months to travel exempt from testing and quarantine requirements

- Government to support evolution of EU Traffic Light System to include proof of recovery as means to avoiding travel restrictions

57 https://www.hiqa.ie/reports-and-publications/health-technology-assessment/duration-protective-immunity-protection 58 https://www.cdc.gov/coronavirus/2019-ncov/hcp/duration-isolation.html?CDC_AA_refVal=https%3A%2F%2Fwww.cdc.gov%2Fcoronavirus%2F2019-ncov%2Fcommunity%2Fstrategy-discontinue-isolation.html#Annex

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j) Passenger Locator Form:

As with other measures governments have taken to tackle the pandemic, requirements to

provide passenger tracking data such as in 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, the Government should require the

Passenger Locator Forms to be exclusively in electronic format.

A more efficient use of the online PLF to streamline the document check process for airlines

is recommended by expanding the existing ePLF to provide for passenger confirmation of

compliance with all requirements and capture all data (e.g., vaccine, negative test). The legal

obligation on all passengers entering Ireland to complete the PLF should incentivise

compliance by passengers.

The form should be as concise and straightforward as possible and available in major

languages other than English and should be integrated with the emerging travel apps.

The requirement to check for a completed ePLF or similar should not be the responsibility of

airlines, and they should not be liable for penalties. It is for the passenger to ensure they

have completed a PLF prior to travel.

Governments should work together and in collaboration with ICAO, IATA, the EU

Commission and industry associations to ensure as much commonality as possible and

ideally a global PLF standard.

The electronic PLF should therefore be amended to include all applicable entry 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.

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

k) Travel Apps:

President von der Leyen announced on 17th March 2021 a legislative proposal for EU Digital

Green pass. The aim of this will be to provide: 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.

President von der Leyen stated that “The Digital Green Pass should facilitate Europeans’

lives. The aim is to gradually enable Europeans to move safely in the European Union or

abroad - for work or tourism”.

NCADF Regulatory Working Group 34

The European Commission’s plans for a Digital Green Pass are encouraging and it is critical

that Ireland fully supports European efforts in this area. 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.

The use of travel apps is supported to simplify the end to end customer journey by capturing

and storing required information such as passenger data and providing proof of vaccination

certificates or test results and this document urges government agencies to recognise this

technology at the border.

It is important to emphasise that the reason these apps are becoming prevalent is the

complex burden of pre-departure checks that have been placed on passengers and airlines

by different government regulations. Priority needs to be given to removing as much of this

complexity as soon as possible, streamlining processes for airlines, passengers and

authorities.

To progress and validate the use of such applications, the Plan recommends that airlines

implement trials of the new technology. The Plan recommends that the Government

encourage test and vaccination centres to engage in such trials to deliver digitally verifiable

health certificates.

This will demonstrate the benefits of remote verification, limit unnecessary congestion at

airport check-in and border inspection posts and support contactless customer journey

capability.

Recommendations:

- 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 does not result in delays to airline capacity restoration in Ireland

- Use of travel apps by airlines should be supported - Airlines should actively implement trials of Travel App technology - Testing and Vaccination centres to enable digitally verifiable health certificates

l) Operational Readiness

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.

Focus is also required on wider operational readiness to ensure resumption of aviation is

supported by appropriate enablers.

NCADF Regulatory Working Group 35

This Plan requires 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.59

Border management resourcing and processing should also be reviewed to ensure that

congestion experienced at airports in other jurisdictions is not replicated in Ireland’s airports.

In terms of the airports, the suite of mitigations in place should negate need for any

measures that would reduce airport capacity thereby impeding the restoration of airline

capacity and/or negatively impacting the passenger experience.

The EC proposal to introduce Digital Green Pass by the summer is very welcome as

coordination of national initiatives is urgently needed to avoid having 27 different certificates

covering testing, vaccination and/or immunity. National Governments, including Ireland must

move quickly to support, evaluate and adopt digital approach and support digital verification

through digital apps that facilitates faster border processing upon arrival and reduced

congestion and thereby minimising queues.

The objective is to avoid the experience of Heathrow Airport which saw significant issues in

early February due to new UK regulations requiring PCR checks for arriving passengers.

The additional check resulted in a 2.5 hr queues at immigration on a day where there were

only 5,000 arriving passengers.

All those who have a role in facilitating the passenger journey (airports, airlines, state

services etc.) should continue to engage to ensure restart of aviation is supported and

enabled by robust processes e.g. testing, check-in, bag drop, security, boarding,

disembarkation, passport control, baggage collection etc.

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

- All relevant industry players should work together to ensure restart of aviation is

supported and enabled by robust processes

9. 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

59 https://www.irishtimes.com/news/consumer/passport-service-suspends-almost-all-operations-due-to-covid-19-1.4489923

NCADF Regulatory Working Group 36

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

NCADF Regulatory Working Group 37

10. Summary table of detailed recommendations

Summary table of recommendations

Lifting of ban on international travel and metrics

- 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

Develop supportive narrative on international travel

- 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 and support evolution

- 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

UK - 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

US - Government to engage 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

Other Countries - Government to engage bilaterally with other country

NCADF Regulatory Working Group 38

Governments to agree a reciprocal basis in which to enable restoration of travel

- Government to explore opportunities to pilot schemes that may enable earlier relaxation of entry bans for Irish citizens to other key countries

Implement Clear Policies on Vaccines and Exemptions

- 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) should be exempt from testing and quarantine requirements

- Ireland to produce a standard vaccination certificate in line with the proposed EU Digital Green Pass that will enable international travel in UK, Europe and US without the need to comply with any other testing or quarantine requirements Government to support an evolution of the EU Traffic Light System such that vaccinated travellers be exempted from testing and quarantine requirements

Endorse the use of Antigen Testing for Travel and invest in track and trace

- 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

- Testing should not be considered a permanent travel requirement and should be reduced over time

- Government to support access to affordable rapid tests including antigen

Enable restriction free travel for those with proof of recovery

- Government to enable passengers with documented proof of recovery from Covid-19 within 6 months to travel exempt from testing and quarantine requirements

- Government to support evolution of EU Traffic Light System to include proof of recovery as means to avoiding travel restrictions

Passenger Locator form

- 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 - 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 does not

NCADF Regulatory Working Group 39

result in delays to airline capacity restoration in Ireland - Use of travel apps by airlines should be supported - Airlines should actively implement trials of Travel App

technology Testing and Vaccination centres to enable digitally verifiable health certificates

Operational readiness

- 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

- All relevant industry players should work together to ensure

restart of aviation is supported and enabled by robust

processes

Financial support 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

Variants of concern (VOC)

- 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

Timeline

Jan-Mar Apr-May Jun

NCADF Regulatory Working Group 40

Appendix A: International Experience

List of EU Countries Planning for Vaccination Certificates at March 2021

Country Comment

Cyprus Cyprus has announced that it will welcome tourists starting May 1 as long

as they have had two doses of any vaccine approved by the European

Medicines Agency (EMA)60.

Czech

Republic

Looking into the possibility of allowing restriction-free travel for vaccinated

persons, though it is not planning to make the vaccine a requirement for

travel61.

Denmark It will soon introduce COVID-19 vaccine passports for its citizens who

receive the vaccine against the virus so that they can use those certificates

to travel restriction-free to countries that ask for them. The Danish

government has now decided to offer digital vaccination passports even for

those planning to travel to Denmark62.

Estonia Estonia working on creating a yellow vaccination card which will enable a

reliable and transparent cross-border exchange of vaccination data63.

Greece A mutual recognition of an ‘electronic Covid-19 vaccination certificate’ for

travel between Greece and Serbia in place. Greece and Cyprus have

already signed a bi-lateral travel deal with Israel, vaccine certificates are in

use there64.

Iceland Iceland is the first European country that started granting COVID-19

certificates to its citizens vaccinated against COVID-19 and to permit

restriction-free entry for other EU and Schengen Area citizens holding proof

they have been vaccinated against COVID-19 (this benefit only to those

who have been vaccinated with one of the vaccines authorized by the

European Medicines Agency or the World Health Organization)65.

60 https://www.bbc.com/news/uk-56289054 61 https://www.forbes.com/sites/ceciliarodriguez/2021/03/07/covid-passport-the-15-best-european-

destinations-ready-for-vaccinated-travelers/

62 https://www.schengenvisainfo.com/news/list-of-eu-countries-issuing-asking-for-vaccination-certificates/

63 https://www.schengenvisainfo.com/news/list-of-eu-countries-issuing-asking-for-vaccination-certificates/

64 https://www.schengenvisainfo.com/news/list-of-eu-countries-issuing-asking-for-vaccination-certificates/

65 https://www.schengenvisainfo.com/news/only-those-vaccinated-with-covid-19-vaccines-approved-by-ema-

or-who-can-enter-iceland-restriction-free/

NCADF Regulatory Working Group 41

Country Comment

Italy While the Italian government has not indicated of any plans regarding

vaccination certificates, Italy’s National Federation of Travel and Tourism

Industry has called on the Italian government to speed up the national

vaccination rollout, and issue certificates to those who take the vaccine

against the virus66.

Kosovo Kosovo will join the list of countries issuing vaccination passports to those

who get the vaccine against COVID-19, which would make the travel

process for these persons easier when travelling to countries that ask for

such a document67.

Poland Poland has also revealed plans to introduce vaccine passports, in order to

permit those who have taken the COVID-19 vaccine greater freedoms than

those who have not. The document will be issued in the form of a QR code,

downloadable only at the citizens’ public health system account. Another

alternative printed version will be issued to those who do not have

smartphones68.

Portugal Portugal’s Minister of the Interior Eduardo Cabrita, a vaccination certificate

should prove safety and abolish some requirements at the European

Union’s internal borders.

Rita Marques, Portugal's secretary of state for tourism, told the BBC: "I do

believe that Portugal will soon allow restriction-free travel, not only for

vaccinated people, but those who are immune or who test negative. We

hope to welcome British tourists from 17 May69".

Slovakia Slovakia is among the EU countries that has shown its support towards the

introduction of the COVID-19 certificate, which the Slovak government

believes would allow the highest possible level of free movement in the EU

while maintaining the necessary security70.

Spain Spain’s Tourism Minister, Reyes Maroto has announced that the country’s

government is working to introduce a ‘vaccination certificate’, which will

have the same functions the ones that are set to be launched by Denmark,

Greece, Iceland, and backed by the European Union Commission

President, Ursula von der Leyen71.

66 https://www.schengenvisainfo.com/news/list-of-eu-countries-issuing-asking-for-vaccination-certificates/ 67 https://www.schengenvisainfo.com/news/kosovo-plans-to-issue-covid-19-vaccine-passports/ 68 https://www.schengenvisainfo.com/news/list-of-eu-countries-issuing-asking-for-vaccination-certificates/ 69 https://www.bbc.com/news/uk-56289054 70 https://www.schengenvisainfo.com/news/list-of-eu-countries-issuing-asking-for-vaccination-certificates/

71 https://www.schengenvisainfo.com/news/list-of-eu-countries-issuing-asking-for-vaccination-certificates/

NCADF Regulatory Working Group 42

Country Comment

Sweden Sweden is one of the most recent countries revealing plans for a digital

coronavirus passport by summer in order to identify people who have been

vaccinated against COVID-1972.

72 https://www.schengenvisainfo.com/news/list-of-eu-countries-issuing-asking-for-vaccination-certificates/

NCADF Regulatory Working Group 43

Appendix B: Antigen Testing

In an analysis on the use of rapid testing technologies for covid-19, the BMJ 2021; 37273 the

following table outlines how antigen testing is being used in asymptomatic testing:

Countries accepting antigen tests for entry

Austria Netherlands

Canary Islands Poland

Czechia United Kingdom

Germany United States

Italy Slovakia

In a paper published on New England Medical Journal entitled Rethinking Covid-19 Test

Sensitivity — A Strategy for Containment- the authors from the Harvard T.H. Chan School of

Public Health, Boston (M.J.M.); and the University of Colorado, Boulder (R.P., D.B.L.).

highlight the following graphic which shows the importance of antigen testing – low analytic

sensitivity when identifying infectious cases of covid-19.74

A person’s infection trajectory (blue line) is shown in the context of two surveillance

regimens (circles) with different analytic sensitivity. The low-analytic-sensitivity assay is

administered frequently and the high-analytic-sensitivity assay infrequently. Both testing

regimens detect the infection (orange circles), but only the high-frequency test detects it

during the transmission window (shading), in spite of its lower analytic sensitivity, which

makes it a more effective filter. The window during which polymerase chain reaction (PCR)

detects infections before infectivity (green) is short, whereas the corresponding

postinfectious but PCR-detectable window (purple) is long.

73 https://doi.org/10.1136/bmj.n208 74 https://www.nejm.org/doi/full/10.1056/NEJMp2025631

NCADF Regulatory Working Group 44

Appendix C: Protocol for the Management of Air Passengers in light of COVID-19-

December 2020 (Issue 3)

Attached separately.