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SydneyAirport~
15 Seotember 2017
Visa Simplification Consultation Department of Immigration and Border Protection PO Box 25 Belconnen ACT 2616
Dear Sir Madam
Re Visa Simplification Consultation Paper
Thank you for the opportunity to provide comment on the policy consultation paper Visa Simplification Transforming Australia s Visa System
Currently welcoming more than 42 million passengers a year and catering to 45 airlines Sydney Airport operates within a highly competitive global environment and strongly supports an Australian visa system that is responsive to our national economic social and security interests In particular we see the visa system as playing a crucial role in facilitating the economic benefits that occur as a result of increased visitation to Australia through competitive pricing quicker processing and a simplified application process
In 2016 education-related travel services was Australias third largest export with personal travel (excluding education) services our sixth largest export1 These two services were the only export items within Australias top nine not a part of the wider resources sector demonstrating the vital importance to Australias economy of international visitation Indeed the Productivity Commission found in 2015 that tourism spending by international visitors contributed almost three percent of Australias Gross Domestic Product (GDP)2
bull
In the year ending June 2017 approximately 85 million international visitors travelled to Australia spending A$398 billion With the Tourism 2020 target of $115 billion in overnight expenditure by both domestic and international visitors Australia is broadly on track to reach this goal with $1015 billion in overnight expenditure in the year ending March 2017 by domestic and international visitors However while Australia will likely meet the lower-range of the Tourism 2020 target we will fall well short of the upper range target of $140 billion in overnight expenditure by 2020 When looking at options to attract additional visitors visa reform should be a part of any solution
Australias competitors for tourist and other types of visitation have already started taking action to reform their visa facilitation policies and processes in order to attract additional visitors While Australia has implemented some positive reforms of our own we nevertheless risk losing competitiveness if we dont continually seek to improve the efficiency and cost of our visa application process This challenge is particularly relevant as Australia seeks to attract a larger share of the rapidly growing Chinese visitor market in a heavily contested marketplace
1 See httpdfatgov autraderesourcestrade-at-a-glancepagestop-goods-servicesaspx 2 See httpwwwpcqovauresearchcompletedinternational-tourisminternational-tourismpdf at p3
Sydney Airport Corporation Limited Central Terrace Building 10 Arrivals Court Locked Bag 5000 Sydney International Airport NSW 2020 Australia
ABN 62 082 578 809 T +61 2 9667 91 11 wwwsydneyairportcomau
This challenge particularly applies to short-term visas including those covering tourists visits to Australia (generally using visa subclass 600) Research conducted in 2012 by the World Tourism Organisation (UNWTO) and World Tourism and Travel Council (WTTC) looking at the impact of visa facilitation in G20 economies found that facilitative visa policy changes increased tourist arrivals in targeted markets by between 5 percent and 25 percent per year on average over a three-year period3 A subsequent study in 2014 focussing on the ASEAN (South East Asian) region found that improved visa facilitcition could yield a premium of visitor arrivals of between 85 percent and 13 7 percent4 What these studies demonstrate is that while the ease and cost of obtaining a visa is not the only factor in travel decisions they certainly can act as a deterrent to travelling to a particular destination when that countrys visa arrangements arent competitive with other countries being considered as possible destinations
Short Term Visitor Visas
Application fees
With some 12 billion tourists travelling internationally in 2015 the market to attract visitors is highly competitive and increasingly price-sensitive While other cost factors such as the price of long haul flights are beyond the reach of the Australian Government government nevertheless retains the ability to ensure visitor visas to Australia are price-competitive with other similar destinations
This point was recognised in the 2016-17 Federal Budget when the Commonwealth Government committed to maintaining visa fees at (then) current levels However in the May 2017 Budget this decision was overturned with the cost of visitor visas being indexed to inflation The first increase under this new arrangement occurred on 1 July 2017 with subclass 600 visitor visas increasing in cost from $135 to $140 While a singular $5 increase in visa charges is not a significant impost the cumulative impact of several price increases could mean that tourist visas to visit Australia become uncompetitive over a short period of time In combination with the Passenger Movement Charge (PMC) which was recently increased from A$55 to $60 these costs further reduce Australias competitiveness
By way of contrast a visitor visa to Canada costs CA$100 (approximately A$100) a singleshyentry visa to Japan costs yen3000 (approximately A$35) a single-entry visa to South Korea costs US$40 (A$50) for visitors of most nationalities Schengen Zone visas cost euro60 (A$90) and Singapore charges SG$30 (A$30) for all visitor visas including multiple entry visas valid for up to ten years Meanwhile in March 2016 Indonesia removed their fee requirement from an additional 90 countries bringing the total number of countries on their fee waiver list to 169
It is therefore vital that Australia regularly monitors the visa charges of competitor destinations and ensures that our fees are not a disincentive to travelling here
Processing Times
The time taken to process visa applications has improved greatly in recent years and the Department of Immigration and Border Protection (DIBP) is to be congratulated in this regard However there remains scope for further improvement to processing times
3 See httpzhwttcorg-mediafilesreportspolicy-researchvisa facilitation-g20pdf 4 See httpcfcdn unwtoorgsitesallfilesdocpdf2014impactofvisafacilitationinaseanmemberstateslowrespdf
page 2 of 6
The most recent DIBP figures covering July 2017 found that 75 percent of tourist (subclass 600) visas were processed in 17 days with 90 percent of applications processed in 28 days Processing times ranged from as little as 48 hours to more than 20 days depending on peak processing periods the location where an application was made and the deemed risk factors around an applicant While in reality most applications are processed within just a few working days the published processing time of two or more weeks is often a disincentive to potential visitors as they are concerned about not being able to obtain their visa in time to travel
By comparison the United Kingdom processes nearly all applications for general visits of up to six months from China within 10 days the Schengen visa is typically processed within 72 hours5
visas to Japan are generally processed within 5 working days6 and a visa to Singapore is typically processed within one working day7
The visa processing time to enter the United States is generally seven working days although may take longer8
There are however certain visa subclasses for short term visits to Australia with quicker processing times The subclass 651 eVisitor visa is available online for applicants holding a passport from one of 36 European nations with 75 percent of applications processed within one day and 90 percent within 2 days The Approved Destination subclass 600 visa available to Chinese tour group visitors processes 75 percent of applications in four days and 90 percent within five days9
As responses to this consultation paper are considered shortening processing times is a critical reform with the ability to make Australia a more attractive destination for tourists and other short-term visitors There are currently seven visa types within this broad category with five of them being subclass 600 visas Should the decision be taken to combine these different visas into a smaller number of visa subclasses it is vital that the quicker processing times that are a feature of some subclasses should cover all short-term visitor visas
An easier application process
Together with the price and length of processing time the other aspect of applying for a visa that can make Australia a more attractive destination is the process an applicant must go through to receive a visa Initiatives like online processing multiple-entry visas the language used on application forms and the ability to fast-track an application all make the visa system easier to use and ultimately enhance Australia as a destination The Department is to be commended in particular for its recent work making online applications available to passport holders from a wide range of nations The number of Indian visitors to Australia has increased 16 percent since the introduction of online visa applications demonstrating the benefit of making the application process easier
The amount of information required by an applicant can be complex and burdensome particularly for longer term visitors At present applicants for certain visa types need to prove their employment education bank balance property ownership and multiple forms of identification A better solution would be to tailor the required information to the type of applicant with wealthy applicants (for example) required to prove their bank account and one other asset class without also needing to prove their education which usually requires
5 See httpswwwschengenvisainfocomhow-to-apply-schengen-visa 6 See httpwwwmofagojpj infovisitvisaproceduredayhtml 7 See httpswwwicaqovsgvisitorvisitor entryvisa 8 See httpwwwustraveldocscoma uau-niv-waittimeinfoasp 9 See httpswwwborderqovauaboutaccess-accountabilityservice-standardsqlobal-visa-citizenship-processing-times
page 3 of 6
translation and notary office validation High risk applications should be identified and singled out in the process whilst others are streamlined
In December 2016 a trial of a ten year Frequent Traveller visitor visa to Australia for passport holders from China commenced allowing multiple entries of up to three months for tourist or business visits at a cost of $1000 While this initiative will make it easier for visitors from China to travel to Australia for tourism or business it is important that the Frequent Traveller visas be made available to visitors from other countries following a successful trial The other issue of note concerning the Frequent Traveller visa is the cost Canada New Zealand Singapore and the United States all charge the same fee for their ten-year multiple entry visas as they do for a single-entry visa Following the introduction of this visa type in the United States in 2014 a 70 percent increase in applications occurred demonstrating its role in increasing the attractiveness of the US as a destination10
Already three-year multiple entry visas are available for visitors from India Thailand Vietnam Chile and China at no extra cost This model should be expanded for visitors from other key markets to make the visa application process as easy as possible
The ability to fast-track a visa application for a premium fee has been available to passport holders from China India and the United Arab Emirates (UAE) on a trial basis since 2016 While ideally all applications should be processed quickly this is a useful initiative available to those who need to travel on short notice However it could be further strengthened by a reduction in the $1000 processing fee and being made available to passport holders from a wider range of counties By way of comparison the United Kingdoms fee for their priority visa service is pound184 (approximately A$300)
Consideration should also be given to expanding the ability of visa applicants to apply in their own language In June 2015 the Commonwealth Government announced a trial of online lodgement in simplified Chinese that commenced the following year However there have been no plans to expand lodgement options to include other languages This initiative would make applying for a visitor visa to Australia easier for a great many appl icants and also would demonstrate our readiness to engage with parts of the world for whom English is not widely spoken
Longer Term Entrant Visas
Longer term visas cover those seeking to come to Australia to live work and study In general the same issues that face short-term visa applications apply to longer term applicants as well with the need for reduced costs quicker processing and an easier application process
Indeed some of the issues faced with shorter-term visitor visas are exacerbated For example the subclass 100 partner visa attracts a fee of $6865 in Australia compared to significantly lower fees of $60 in Germany $575 in Canada $1000 for the United States and $1765 for New Zealand11
The importance of skilled migration programs
Skilled migration programs are of vital importance to the Austral ian economy ensuring that industries with skills gaps are able to fill key skilled positions These programs are available to
10 See httpwww ttf org a uwp-contenUuploads201609TIF-Election-Spotlight-1-Visa-Reform pdf 11 See httpwww s bs com autopicsI iferelationshipsarticle201 60914hidden-cost-australias-massive-partnership-visa-fees
page 4 of 6
people who work in an occupation specified in various legislative instruments published by the Department of Immigration and Border Protection Following reforms to the temporary skilled migration program (subclass 457 visas) that commenced in April 2017 this list contains 435 occupations although previously contained more than 650 occupations12 We note that further reforms to skilled migration that have already been announced will replace the subclass 457 visa with a Temporary Skills Shortage (TSS) visa in March 2018
Access to skilled migrants is of vital importance to the aviation sector For example as new airlines commence flying to Sydney and Australia they rely on establishing a local station staffed by an employee from the airlines home country It is essential that these positions are staffed by an existing employee generally from the airlines home country as they are familiar with the airlines operations and procedures and in many cases are able to speak the language of that country The broader tourism industry also relies on ready access to skilled labour from overseas for roles where there are ongoing skills shortages such as hospitality positions including chefs and hotel managers
While it is appropriate for the Australian Government to want to protect access to employment for Australians it is also vital to the Australian economy that industry is easily able to hire employees with skills that are in low supply within Australia Any reforms must ensure that applications are processed in a timely way visas are competitively priced and there are relatively simple application processes Furthermore the list of eligible occupations for shortshyterm and medium to long term visas should not be unduly changed to ensure certainty for businesses looking to operate in Australia If those businesses arent able to hire employees with the required skill-set or find the process of obtaining a visa for a staff member too complicated there is the risk that they will take their operation elsewhere
Supporting key industries - International education
International education is currently Australias third largest export industry valued at $19 7 billion and supporting more than 130700 full time equivalent employees in 2014-1513 Given the nature of tertiary education the value of international students studying in Australia flows through to a range of other sectors including transport and aviation With some 480000 international students enrolled in Australia 14 and approximately 280000 of these in higher education it can also be expected that a significant number of friends and relatives of international students will visit them during their time in Australia
At present obtaining a student visa to Australia requires evidence of sufficient funds to cover tuition and living costs (currently set at A$19830 per year) meeting the English proficiency requirement health requirements and character requirements (including a criminal history check) This process has already been simplified from the previous requirements following the 2011 Knight Review of the Student Visa Program The Knight Review streamlined processing applications and reduced the financial requirements on applicants with a view to supporting the international education sector As visa reform options are considered it is vital that this sector is not adversely impacted by future changes
12 See httpswwwbordergova uWorkinginAustral iaDocum entsabolition-replacem ent-457 pdf 13 See httpsinternationaleducationgovauresearchresearch-papersDocumentsNaluelnternationalEdpdf 14 See httpsinternationaleducationgovauresearchlnternational-StudentshyDataDocum entsMONT H L Y20SUMMARI ES2017 Mar20201720Monthlyl nfographic pdf
page 5 of 6
Conclusion
Thank you once again for the opportunity to comment on the pol icy consultation paper Visa Simplification Transforming Australias Visa System The objective of rationalising the number of visa subclass categories will be of benefit if it makes the process of applying for and obtaining a visa easier Ultimately however the success of the Australian visa system relies on the cost of applying for a visa being competitive with other destinations a visitor may be considering the processing of visas being timely and there being a simplified user friendly process for all applicants
As travellers make decisions around which country to visit as a tourist a student to work or live the ease of negotiating the visa process plays a role in determining their destination Given the global competitiveness for the lucrative and growing tourist market Australian visa policy should position us to capitalise on the economic and other benefits that international visitation brings
We would welcome the opportunity to discuss the issues contained in this submission For further information please contact Robin Schuck Manager Government Relations and Major Projects at Sydney Airport on (02) 9667 9288 or robin schucksydcomau
Yours sincerely
Kerrie Mather Managing Director and Chief Executive Officer
page 6 of 6
This challenge particularly applies to short-term visas including those covering tourists visits to Australia (generally using visa subclass 600) Research conducted in 2012 by the World Tourism Organisation (UNWTO) and World Tourism and Travel Council (WTTC) looking at the impact of visa facilitation in G20 economies found that facilitative visa policy changes increased tourist arrivals in targeted markets by between 5 percent and 25 percent per year on average over a three-year period3 A subsequent study in 2014 focussing on the ASEAN (South East Asian) region found that improved visa facilitcition could yield a premium of visitor arrivals of between 85 percent and 13 7 percent4 What these studies demonstrate is that while the ease and cost of obtaining a visa is not the only factor in travel decisions they certainly can act as a deterrent to travelling to a particular destination when that countrys visa arrangements arent competitive with other countries being considered as possible destinations
Short Term Visitor Visas
Application fees
With some 12 billion tourists travelling internationally in 2015 the market to attract visitors is highly competitive and increasingly price-sensitive While other cost factors such as the price of long haul flights are beyond the reach of the Australian Government government nevertheless retains the ability to ensure visitor visas to Australia are price-competitive with other similar destinations
This point was recognised in the 2016-17 Federal Budget when the Commonwealth Government committed to maintaining visa fees at (then) current levels However in the May 2017 Budget this decision was overturned with the cost of visitor visas being indexed to inflation The first increase under this new arrangement occurred on 1 July 2017 with subclass 600 visitor visas increasing in cost from $135 to $140 While a singular $5 increase in visa charges is not a significant impost the cumulative impact of several price increases could mean that tourist visas to visit Australia become uncompetitive over a short period of time In combination with the Passenger Movement Charge (PMC) which was recently increased from A$55 to $60 these costs further reduce Australias competitiveness
By way of contrast a visitor visa to Canada costs CA$100 (approximately A$100) a singleshyentry visa to Japan costs yen3000 (approximately A$35) a single-entry visa to South Korea costs US$40 (A$50) for visitors of most nationalities Schengen Zone visas cost euro60 (A$90) and Singapore charges SG$30 (A$30) for all visitor visas including multiple entry visas valid for up to ten years Meanwhile in March 2016 Indonesia removed their fee requirement from an additional 90 countries bringing the total number of countries on their fee waiver list to 169
It is therefore vital that Australia regularly monitors the visa charges of competitor destinations and ensures that our fees are not a disincentive to travelling here
Processing Times
The time taken to process visa applications has improved greatly in recent years and the Department of Immigration and Border Protection (DIBP) is to be congratulated in this regard However there remains scope for further improvement to processing times
3 See httpzhwttcorg-mediafilesreportspolicy-researchvisa facilitation-g20pdf 4 See httpcfcdn unwtoorgsitesallfilesdocpdf2014impactofvisafacilitationinaseanmemberstateslowrespdf
page 2 of 6
The most recent DIBP figures covering July 2017 found that 75 percent of tourist (subclass 600) visas were processed in 17 days with 90 percent of applications processed in 28 days Processing times ranged from as little as 48 hours to more than 20 days depending on peak processing periods the location where an application was made and the deemed risk factors around an applicant While in reality most applications are processed within just a few working days the published processing time of two or more weeks is often a disincentive to potential visitors as they are concerned about not being able to obtain their visa in time to travel
By comparison the United Kingdom processes nearly all applications for general visits of up to six months from China within 10 days the Schengen visa is typically processed within 72 hours5
visas to Japan are generally processed within 5 working days6 and a visa to Singapore is typically processed within one working day7
The visa processing time to enter the United States is generally seven working days although may take longer8
There are however certain visa subclasses for short term visits to Australia with quicker processing times The subclass 651 eVisitor visa is available online for applicants holding a passport from one of 36 European nations with 75 percent of applications processed within one day and 90 percent within 2 days The Approved Destination subclass 600 visa available to Chinese tour group visitors processes 75 percent of applications in four days and 90 percent within five days9
As responses to this consultation paper are considered shortening processing times is a critical reform with the ability to make Australia a more attractive destination for tourists and other short-term visitors There are currently seven visa types within this broad category with five of them being subclass 600 visas Should the decision be taken to combine these different visas into a smaller number of visa subclasses it is vital that the quicker processing times that are a feature of some subclasses should cover all short-term visitor visas
An easier application process
Together with the price and length of processing time the other aspect of applying for a visa that can make Australia a more attractive destination is the process an applicant must go through to receive a visa Initiatives like online processing multiple-entry visas the language used on application forms and the ability to fast-track an application all make the visa system easier to use and ultimately enhance Australia as a destination The Department is to be commended in particular for its recent work making online applications available to passport holders from a wide range of nations The number of Indian visitors to Australia has increased 16 percent since the introduction of online visa applications demonstrating the benefit of making the application process easier
The amount of information required by an applicant can be complex and burdensome particularly for longer term visitors At present applicants for certain visa types need to prove their employment education bank balance property ownership and multiple forms of identification A better solution would be to tailor the required information to the type of applicant with wealthy applicants (for example) required to prove their bank account and one other asset class without also needing to prove their education which usually requires
5 See httpswwwschengenvisainfocomhow-to-apply-schengen-visa 6 See httpwwwmofagojpj infovisitvisaproceduredayhtml 7 See httpswwwicaqovsgvisitorvisitor entryvisa 8 See httpwwwustraveldocscoma uau-niv-waittimeinfoasp 9 See httpswwwborderqovauaboutaccess-accountabilityservice-standardsqlobal-visa-citizenship-processing-times
page 3 of 6
translation and notary office validation High risk applications should be identified and singled out in the process whilst others are streamlined
In December 2016 a trial of a ten year Frequent Traveller visitor visa to Australia for passport holders from China commenced allowing multiple entries of up to three months for tourist or business visits at a cost of $1000 While this initiative will make it easier for visitors from China to travel to Australia for tourism or business it is important that the Frequent Traveller visas be made available to visitors from other countries following a successful trial The other issue of note concerning the Frequent Traveller visa is the cost Canada New Zealand Singapore and the United States all charge the same fee for their ten-year multiple entry visas as they do for a single-entry visa Following the introduction of this visa type in the United States in 2014 a 70 percent increase in applications occurred demonstrating its role in increasing the attractiveness of the US as a destination10
Already three-year multiple entry visas are available for visitors from India Thailand Vietnam Chile and China at no extra cost This model should be expanded for visitors from other key markets to make the visa application process as easy as possible
The ability to fast-track a visa application for a premium fee has been available to passport holders from China India and the United Arab Emirates (UAE) on a trial basis since 2016 While ideally all applications should be processed quickly this is a useful initiative available to those who need to travel on short notice However it could be further strengthened by a reduction in the $1000 processing fee and being made available to passport holders from a wider range of counties By way of comparison the United Kingdoms fee for their priority visa service is pound184 (approximately A$300)
Consideration should also be given to expanding the ability of visa applicants to apply in their own language In June 2015 the Commonwealth Government announced a trial of online lodgement in simplified Chinese that commenced the following year However there have been no plans to expand lodgement options to include other languages This initiative would make applying for a visitor visa to Australia easier for a great many appl icants and also would demonstrate our readiness to engage with parts of the world for whom English is not widely spoken
Longer Term Entrant Visas
Longer term visas cover those seeking to come to Australia to live work and study In general the same issues that face short-term visa applications apply to longer term applicants as well with the need for reduced costs quicker processing and an easier application process
Indeed some of the issues faced with shorter-term visitor visas are exacerbated For example the subclass 100 partner visa attracts a fee of $6865 in Australia compared to significantly lower fees of $60 in Germany $575 in Canada $1000 for the United States and $1765 for New Zealand11
The importance of skilled migration programs
Skilled migration programs are of vital importance to the Austral ian economy ensuring that industries with skills gaps are able to fill key skilled positions These programs are available to
10 See httpwww ttf org a uwp-contenUuploads201609TIF-Election-Spotlight-1-Visa-Reform pdf 11 See httpwww s bs com autopicsI iferelationshipsarticle201 60914hidden-cost-australias-massive-partnership-visa-fees
page 4 of 6
people who work in an occupation specified in various legislative instruments published by the Department of Immigration and Border Protection Following reforms to the temporary skilled migration program (subclass 457 visas) that commenced in April 2017 this list contains 435 occupations although previously contained more than 650 occupations12 We note that further reforms to skilled migration that have already been announced will replace the subclass 457 visa with a Temporary Skills Shortage (TSS) visa in March 2018
Access to skilled migrants is of vital importance to the aviation sector For example as new airlines commence flying to Sydney and Australia they rely on establishing a local station staffed by an employee from the airlines home country It is essential that these positions are staffed by an existing employee generally from the airlines home country as they are familiar with the airlines operations and procedures and in many cases are able to speak the language of that country The broader tourism industry also relies on ready access to skilled labour from overseas for roles where there are ongoing skills shortages such as hospitality positions including chefs and hotel managers
While it is appropriate for the Australian Government to want to protect access to employment for Australians it is also vital to the Australian economy that industry is easily able to hire employees with skills that are in low supply within Australia Any reforms must ensure that applications are processed in a timely way visas are competitively priced and there are relatively simple application processes Furthermore the list of eligible occupations for shortshyterm and medium to long term visas should not be unduly changed to ensure certainty for businesses looking to operate in Australia If those businesses arent able to hire employees with the required skill-set or find the process of obtaining a visa for a staff member too complicated there is the risk that they will take their operation elsewhere
Supporting key industries - International education
International education is currently Australias third largest export industry valued at $19 7 billion and supporting more than 130700 full time equivalent employees in 2014-1513 Given the nature of tertiary education the value of international students studying in Australia flows through to a range of other sectors including transport and aviation With some 480000 international students enrolled in Australia 14 and approximately 280000 of these in higher education it can also be expected that a significant number of friends and relatives of international students will visit them during their time in Australia
At present obtaining a student visa to Australia requires evidence of sufficient funds to cover tuition and living costs (currently set at A$19830 per year) meeting the English proficiency requirement health requirements and character requirements (including a criminal history check) This process has already been simplified from the previous requirements following the 2011 Knight Review of the Student Visa Program The Knight Review streamlined processing applications and reduced the financial requirements on applicants with a view to supporting the international education sector As visa reform options are considered it is vital that this sector is not adversely impacted by future changes
12 See httpswwwbordergova uWorkinginAustral iaDocum entsabolition-replacem ent-457 pdf 13 See httpsinternationaleducationgovauresearchresearch-papersDocumentsNaluelnternationalEdpdf 14 See httpsinternationaleducationgovauresearchlnternational-StudentshyDataDocum entsMONT H L Y20SUMMARI ES2017 Mar20201720Monthlyl nfographic pdf
page 5 of 6
Conclusion
Thank you once again for the opportunity to comment on the pol icy consultation paper Visa Simplification Transforming Australias Visa System The objective of rationalising the number of visa subclass categories will be of benefit if it makes the process of applying for and obtaining a visa easier Ultimately however the success of the Australian visa system relies on the cost of applying for a visa being competitive with other destinations a visitor may be considering the processing of visas being timely and there being a simplified user friendly process for all applicants
As travellers make decisions around which country to visit as a tourist a student to work or live the ease of negotiating the visa process plays a role in determining their destination Given the global competitiveness for the lucrative and growing tourist market Australian visa policy should position us to capitalise on the economic and other benefits that international visitation brings
We would welcome the opportunity to discuss the issues contained in this submission For further information please contact Robin Schuck Manager Government Relations and Major Projects at Sydney Airport on (02) 9667 9288 or robin schucksydcomau
Yours sincerely
Kerrie Mather Managing Director and Chief Executive Officer
page 6 of 6
The most recent DIBP figures covering July 2017 found that 75 percent of tourist (subclass 600) visas were processed in 17 days with 90 percent of applications processed in 28 days Processing times ranged from as little as 48 hours to more than 20 days depending on peak processing periods the location where an application was made and the deemed risk factors around an applicant While in reality most applications are processed within just a few working days the published processing time of two or more weeks is often a disincentive to potential visitors as they are concerned about not being able to obtain their visa in time to travel
By comparison the United Kingdom processes nearly all applications for general visits of up to six months from China within 10 days the Schengen visa is typically processed within 72 hours5
visas to Japan are generally processed within 5 working days6 and a visa to Singapore is typically processed within one working day7
The visa processing time to enter the United States is generally seven working days although may take longer8
There are however certain visa subclasses for short term visits to Australia with quicker processing times The subclass 651 eVisitor visa is available online for applicants holding a passport from one of 36 European nations with 75 percent of applications processed within one day and 90 percent within 2 days The Approved Destination subclass 600 visa available to Chinese tour group visitors processes 75 percent of applications in four days and 90 percent within five days9
As responses to this consultation paper are considered shortening processing times is a critical reform with the ability to make Australia a more attractive destination for tourists and other short-term visitors There are currently seven visa types within this broad category with five of them being subclass 600 visas Should the decision be taken to combine these different visas into a smaller number of visa subclasses it is vital that the quicker processing times that are a feature of some subclasses should cover all short-term visitor visas
An easier application process
Together with the price and length of processing time the other aspect of applying for a visa that can make Australia a more attractive destination is the process an applicant must go through to receive a visa Initiatives like online processing multiple-entry visas the language used on application forms and the ability to fast-track an application all make the visa system easier to use and ultimately enhance Australia as a destination The Department is to be commended in particular for its recent work making online applications available to passport holders from a wide range of nations The number of Indian visitors to Australia has increased 16 percent since the introduction of online visa applications demonstrating the benefit of making the application process easier
The amount of information required by an applicant can be complex and burdensome particularly for longer term visitors At present applicants for certain visa types need to prove their employment education bank balance property ownership and multiple forms of identification A better solution would be to tailor the required information to the type of applicant with wealthy applicants (for example) required to prove their bank account and one other asset class without also needing to prove their education which usually requires
5 See httpswwwschengenvisainfocomhow-to-apply-schengen-visa 6 See httpwwwmofagojpj infovisitvisaproceduredayhtml 7 See httpswwwicaqovsgvisitorvisitor entryvisa 8 See httpwwwustraveldocscoma uau-niv-waittimeinfoasp 9 See httpswwwborderqovauaboutaccess-accountabilityservice-standardsqlobal-visa-citizenship-processing-times
page 3 of 6
translation and notary office validation High risk applications should be identified and singled out in the process whilst others are streamlined
In December 2016 a trial of a ten year Frequent Traveller visitor visa to Australia for passport holders from China commenced allowing multiple entries of up to three months for tourist or business visits at a cost of $1000 While this initiative will make it easier for visitors from China to travel to Australia for tourism or business it is important that the Frequent Traveller visas be made available to visitors from other countries following a successful trial The other issue of note concerning the Frequent Traveller visa is the cost Canada New Zealand Singapore and the United States all charge the same fee for their ten-year multiple entry visas as they do for a single-entry visa Following the introduction of this visa type in the United States in 2014 a 70 percent increase in applications occurred demonstrating its role in increasing the attractiveness of the US as a destination10
Already three-year multiple entry visas are available for visitors from India Thailand Vietnam Chile and China at no extra cost This model should be expanded for visitors from other key markets to make the visa application process as easy as possible
The ability to fast-track a visa application for a premium fee has been available to passport holders from China India and the United Arab Emirates (UAE) on a trial basis since 2016 While ideally all applications should be processed quickly this is a useful initiative available to those who need to travel on short notice However it could be further strengthened by a reduction in the $1000 processing fee and being made available to passport holders from a wider range of counties By way of comparison the United Kingdoms fee for their priority visa service is pound184 (approximately A$300)
Consideration should also be given to expanding the ability of visa applicants to apply in their own language In June 2015 the Commonwealth Government announced a trial of online lodgement in simplified Chinese that commenced the following year However there have been no plans to expand lodgement options to include other languages This initiative would make applying for a visitor visa to Australia easier for a great many appl icants and also would demonstrate our readiness to engage with parts of the world for whom English is not widely spoken
Longer Term Entrant Visas
Longer term visas cover those seeking to come to Australia to live work and study In general the same issues that face short-term visa applications apply to longer term applicants as well with the need for reduced costs quicker processing and an easier application process
Indeed some of the issues faced with shorter-term visitor visas are exacerbated For example the subclass 100 partner visa attracts a fee of $6865 in Australia compared to significantly lower fees of $60 in Germany $575 in Canada $1000 for the United States and $1765 for New Zealand11
The importance of skilled migration programs
Skilled migration programs are of vital importance to the Austral ian economy ensuring that industries with skills gaps are able to fill key skilled positions These programs are available to
10 See httpwww ttf org a uwp-contenUuploads201609TIF-Election-Spotlight-1-Visa-Reform pdf 11 See httpwww s bs com autopicsI iferelationshipsarticle201 60914hidden-cost-australias-massive-partnership-visa-fees
page 4 of 6
people who work in an occupation specified in various legislative instruments published by the Department of Immigration and Border Protection Following reforms to the temporary skilled migration program (subclass 457 visas) that commenced in April 2017 this list contains 435 occupations although previously contained more than 650 occupations12 We note that further reforms to skilled migration that have already been announced will replace the subclass 457 visa with a Temporary Skills Shortage (TSS) visa in March 2018
Access to skilled migrants is of vital importance to the aviation sector For example as new airlines commence flying to Sydney and Australia they rely on establishing a local station staffed by an employee from the airlines home country It is essential that these positions are staffed by an existing employee generally from the airlines home country as they are familiar with the airlines operations and procedures and in many cases are able to speak the language of that country The broader tourism industry also relies on ready access to skilled labour from overseas for roles where there are ongoing skills shortages such as hospitality positions including chefs and hotel managers
While it is appropriate for the Australian Government to want to protect access to employment for Australians it is also vital to the Australian economy that industry is easily able to hire employees with skills that are in low supply within Australia Any reforms must ensure that applications are processed in a timely way visas are competitively priced and there are relatively simple application processes Furthermore the list of eligible occupations for shortshyterm and medium to long term visas should not be unduly changed to ensure certainty for businesses looking to operate in Australia If those businesses arent able to hire employees with the required skill-set or find the process of obtaining a visa for a staff member too complicated there is the risk that they will take their operation elsewhere
Supporting key industries - International education
International education is currently Australias third largest export industry valued at $19 7 billion and supporting more than 130700 full time equivalent employees in 2014-1513 Given the nature of tertiary education the value of international students studying in Australia flows through to a range of other sectors including transport and aviation With some 480000 international students enrolled in Australia 14 and approximately 280000 of these in higher education it can also be expected that a significant number of friends and relatives of international students will visit them during their time in Australia
At present obtaining a student visa to Australia requires evidence of sufficient funds to cover tuition and living costs (currently set at A$19830 per year) meeting the English proficiency requirement health requirements and character requirements (including a criminal history check) This process has already been simplified from the previous requirements following the 2011 Knight Review of the Student Visa Program The Knight Review streamlined processing applications and reduced the financial requirements on applicants with a view to supporting the international education sector As visa reform options are considered it is vital that this sector is not adversely impacted by future changes
12 See httpswwwbordergova uWorkinginAustral iaDocum entsabolition-replacem ent-457 pdf 13 See httpsinternationaleducationgovauresearchresearch-papersDocumentsNaluelnternationalEdpdf 14 See httpsinternationaleducationgovauresearchlnternational-StudentshyDataDocum entsMONT H L Y20SUMMARI ES2017 Mar20201720Monthlyl nfographic pdf
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Conclusion
Thank you once again for the opportunity to comment on the pol icy consultation paper Visa Simplification Transforming Australias Visa System The objective of rationalising the number of visa subclass categories will be of benefit if it makes the process of applying for and obtaining a visa easier Ultimately however the success of the Australian visa system relies on the cost of applying for a visa being competitive with other destinations a visitor may be considering the processing of visas being timely and there being a simplified user friendly process for all applicants
As travellers make decisions around which country to visit as a tourist a student to work or live the ease of negotiating the visa process plays a role in determining their destination Given the global competitiveness for the lucrative and growing tourist market Australian visa policy should position us to capitalise on the economic and other benefits that international visitation brings
We would welcome the opportunity to discuss the issues contained in this submission For further information please contact Robin Schuck Manager Government Relations and Major Projects at Sydney Airport on (02) 9667 9288 or robin schucksydcomau
Yours sincerely
Kerrie Mather Managing Director and Chief Executive Officer
page 6 of 6
translation and notary office validation High risk applications should be identified and singled out in the process whilst others are streamlined
In December 2016 a trial of a ten year Frequent Traveller visitor visa to Australia for passport holders from China commenced allowing multiple entries of up to three months for tourist or business visits at a cost of $1000 While this initiative will make it easier for visitors from China to travel to Australia for tourism or business it is important that the Frequent Traveller visas be made available to visitors from other countries following a successful trial The other issue of note concerning the Frequent Traveller visa is the cost Canada New Zealand Singapore and the United States all charge the same fee for their ten-year multiple entry visas as they do for a single-entry visa Following the introduction of this visa type in the United States in 2014 a 70 percent increase in applications occurred demonstrating its role in increasing the attractiveness of the US as a destination10
Already three-year multiple entry visas are available for visitors from India Thailand Vietnam Chile and China at no extra cost This model should be expanded for visitors from other key markets to make the visa application process as easy as possible
The ability to fast-track a visa application for a premium fee has been available to passport holders from China India and the United Arab Emirates (UAE) on a trial basis since 2016 While ideally all applications should be processed quickly this is a useful initiative available to those who need to travel on short notice However it could be further strengthened by a reduction in the $1000 processing fee and being made available to passport holders from a wider range of counties By way of comparison the United Kingdoms fee for their priority visa service is pound184 (approximately A$300)
Consideration should also be given to expanding the ability of visa applicants to apply in their own language In June 2015 the Commonwealth Government announced a trial of online lodgement in simplified Chinese that commenced the following year However there have been no plans to expand lodgement options to include other languages This initiative would make applying for a visitor visa to Australia easier for a great many appl icants and also would demonstrate our readiness to engage with parts of the world for whom English is not widely spoken
Longer Term Entrant Visas
Longer term visas cover those seeking to come to Australia to live work and study In general the same issues that face short-term visa applications apply to longer term applicants as well with the need for reduced costs quicker processing and an easier application process
Indeed some of the issues faced with shorter-term visitor visas are exacerbated For example the subclass 100 partner visa attracts a fee of $6865 in Australia compared to significantly lower fees of $60 in Germany $575 in Canada $1000 for the United States and $1765 for New Zealand11
The importance of skilled migration programs
Skilled migration programs are of vital importance to the Austral ian economy ensuring that industries with skills gaps are able to fill key skilled positions These programs are available to
10 See httpwww ttf org a uwp-contenUuploads201609TIF-Election-Spotlight-1-Visa-Reform pdf 11 See httpwww s bs com autopicsI iferelationshipsarticle201 60914hidden-cost-australias-massive-partnership-visa-fees
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people who work in an occupation specified in various legislative instruments published by the Department of Immigration and Border Protection Following reforms to the temporary skilled migration program (subclass 457 visas) that commenced in April 2017 this list contains 435 occupations although previously contained more than 650 occupations12 We note that further reforms to skilled migration that have already been announced will replace the subclass 457 visa with a Temporary Skills Shortage (TSS) visa in March 2018
Access to skilled migrants is of vital importance to the aviation sector For example as new airlines commence flying to Sydney and Australia they rely on establishing a local station staffed by an employee from the airlines home country It is essential that these positions are staffed by an existing employee generally from the airlines home country as they are familiar with the airlines operations and procedures and in many cases are able to speak the language of that country The broader tourism industry also relies on ready access to skilled labour from overseas for roles where there are ongoing skills shortages such as hospitality positions including chefs and hotel managers
While it is appropriate for the Australian Government to want to protect access to employment for Australians it is also vital to the Australian economy that industry is easily able to hire employees with skills that are in low supply within Australia Any reforms must ensure that applications are processed in a timely way visas are competitively priced and there are relatively simple application processes Furthermore the list of eligible occupations for shortshyterm and medium to long term visas should not be unduly changed to ensure certainty for businesses looking to operate in Australia If those businesses arent able to hire employees with the required skill-set or find the process of obtaining a visa for a staff member too complicated there is the risk that they will take their operation elsewhere
Supporting key industries - International education
International education is currently Australias third largest export industry valued at $19 7 billion and supporting more than 130700 full time equivalent employees in 2014-1513 Given the nature of tertiary education the value of international students studying in Australia flows through to a range of other sectors including transport and aviation With some 480000 international students enrolled in Australia 14 and approximately 280000 of these in higher education it can also be expected that a significant number of friends and relatives of international students will visit them during their time in Australia
At present obtaining a student visa to Australia requires evidence of sufficient funds to cover tuition and living costs (currently set at A$19830 per year) meeting the English proficiency requirement health requirements and character requirements (including a criminal history check) This process has already been simplified from the previous requirements following the 2011 Knight Review of the Student Visa Program The Knight Review streamlined processing applications and reduced the financial requirements on applicants with a view to supporting the international education sector As visa reform options are considered it is vital that this sector is not adversely impacted by future changes
12 See httpswwwbordergova uWorkinginAustral iaDocum entsabolition-replacem ent-457 pdf 13 See httpsinternationaleducationgovauresearchresearch-papersDocumentsNaluelnternationalEdpdf 14 See httpsinternationaleducationgovauresearchlnternational-StudentshyDataDocum entsMONT H L Y20SUMMARI ES2017 Mar20201720Monthlyl nfographic pdf
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Conclusion
Thank you once again for the opportunity to comment on the pol icy consultation paper Visa Simplification Transforming Australias Visa System The objective of rationalising the number of visa subclass categories will be of benefit if it makes the process of applying for and obtaining a visa easier Ultimately however the success of the Australian visa system relies on the cost of applying for a visa being competitive with other destinations a visitor may be considering the processing of visas being timely and there being a simplified user friendly process for all applicants
As travellers make decisions around which country to visit as a tourist a student to work or live the ease of negotiating the visa process plays a role in determining their destination Given the global competitiveness for the lucrative and growing tourist market Australian visa policy should position us to capitalise on the economic and other benefits that international visitation brings
We would welcome the opportunity to discuss the issues contained in this submission For further information please contact Robin Schuck Manager Government Relations and Major Projects at Sydney Airport on (02) 9667 9288 or robin schucksydcomau
Yours sincerely
Kerrie Mather Managing Director and Chief Executive Officer
page 6 of 6
people who work in an occupation specified in various legislative instruments published by the Department of Immigration and Border Protection Following reforms to the temporary skilled migration program (subclass 457 visas) that commenced in April 2017 this list contains 435 occupations although previously contained more than 650 occupations12 We note that further reforms to skilled migration that have already been announced will replace the subclass 457 visa with a Temporary Skills Shortage (TSS) visa in March 2018
Access to skilled migrants is of vital importance to the aviation sector For example as new airlines commence flying to Sydney and Australia they rely on establishing a local station staffed by an employee from the airlines home country It is essential that these positions are staffed by an existing employee generally from the airlines home country as they are familiar with the airlines operations and procedures and in many cases are able to speak the language of that country The broader tourism industry also relies on ready access to skilled labour from overseas for roles where there are ongoing skills shortages such as hospitality positions including chefs and hotel managers
While it is appropriate for the Australian Government to want to protect access to employment for Australians it is also vital to the Australian economy that industry is easily able to hire employees with skills that are in low supply within Australia Any reforms must ensure that applications are processed in a timely way visas are competitively priced and there are relatively simple application processes Furthermore the list of eligible occupations for shortshyterm and medium to long term visas should not be unduly changed to ensure certainty for businesses looking to operate in Australia If those businesses arent able to hire employees with the required skill-set or find the process of obtaining a visa for a staff member too complicated there is the risk that they will take their operation elsewhere
Supporting key industries - International education
International education is currently Australias third largest export industry valued at $19 7 billion and supporting more than 130700 full time equivalent employees in 2014-1513 Given the nature of tertiary education the value of international students studying in Australia flows through to a range of other sectors including transport and aviation With some 480000 international students enrolled in Australia 14 and approximately 280000 of these in higher education it can also be expected that a significant number of friends and relatives of international students will visit them during their time in Australia
At present obtaining a student visa to Australia requires evidence of sufficient funds to cover tuition and living costs (currently set at A$19830 per year) meeting the English proficiency requirement health requirements and character requirements (including a criminal history check) This process has already been simplified from the previous requirements following the 2011 Knight Review of the Student Visa Program The Knight Review streamlined processing applications and reduced the financial requirements on applicants with a view to supporting the international education sector As visa reform options are considered it is vital that this sector is not adversely impacted by future changes
12 See httpswwwbordergova uWorkinginAustral iaDocum entsabolition-replacem ent-457 pdf 13 See httpsinternationaleducationgovauresearchresearch-papersDocumentsNaluelnternationalEdpdf 14 See httpsinternationaleducationgovauresearchlnternational-StudentshyDataDocum entsMONT H L Y20SUMMARI ES2017 Mar20201720Monthlyl nfographic pdf
page 5 of 6
Conclusion
Thank you once again for the opportunity to comment on the pol icy consultation paper Visa Simplification Transforming Australias Visa System The objective of rationalising the number of visa subclass categories will be of benefit if it makes the process of applying for and obtaining a visa easier Ultimately however the success of the Australian visa system relies on the cost of applying for a visa being competitive with other destinations a visitor may be considering the processing of visas being timely and there being a simplified user friendly process for all applicants
As travellers make decisions around which country to visit as a tourist a student to work or live the ease of negotiating the visa process plays a role in determining their destination Given the global competitiveness for the lucrative and growing tourist market Australian visa policy should position us to capitalise on the economic and other benefits that international visitation brings
We would welcome the opportunity to discuss the issues contained in this submission For further information please contact Robin Schuck Manager Government Relations and Major Projects at Sydney Airport on (02) 9667 9288 or robin schucksydcomau
Yours sincerely
Kerrie Mather Managing Director and Chief Executive Officer
page 6 of 6
Conclusion
Thank you once again for the opportunity to comment on the pol icy consultation paper Visa Simplification Transforming Australias Visa System The objective of rationalising the number of visa subclass categories will be of benefit if it makes the process of applying for and obtaining a visa easier Ultimately however the success of the Australian visa system relies on the cost of applying for a visa being competitive with other destinations a visitor may be considering the processing of visas being timely and there being a simplified user friendly process for all applicants
As travellers make decisions around which country to visit as a tourist a student to work or live the ease of negotiating the visa process plays a role in determining their destination Given the global competitiveness for the lucrative and growing tourist market Australian visa policy should position us to capitalise on the economic and other benefits that international visitation brings
We would welcome the opportunity to discuss the issues contained in this submission For further information please contact Robin Schuck Manager Government Relations and Major Projects at Sydney Airport on (02) 9667 9288 or robin schucksydcomau
Yours sincerely
Kerrie Mather Managing Director and Chief Executive Officer
page 6 of 6