Monitors saw no sign of problems
Officials had monitored the airport's progress as required and had no indication of problems before July 6, the submission said.
It rejected blame for the confusion and chaos, which it attributed to problems with the Airport Authority's management, and human error.
The Government, through its Airport Development Steering Committee, chaired by Chief Secretary for Administration Anson Chan Fang On-sang, 'did all it could do to satisfy itself that opening day was not at risk at any stage on the information made available to it'.
Government responsibility for air cargo problems was denied, while the difficulties of removing then authority chief executive Dr Hank Townsend were outlined.
'Neither the New Airport Projects Co-ordination Office or Adscom had any right to inquire into the credentials of any of the authority's employees and to make suggestions as to whether anyone was suitable for their job - to do so would be to unjustifiably inter-meddle with the internal administration of the authority.
'It was reasonable for the New Airport Projects Co-ordination Office to assume the authority would adequately monitor the progress of HACTL's works and in particular the testing and commissioning of its systems.' The Government's counsel, headed by Ronny Tong SC, said the airport was 'very nearly ready' on July 6 and passenger operations were 'back on track' from about the fourth day of operations.
'The fact that the airport quickly found its feet suggests very strongly there were no major deficiencies in its systems and supports the wide body of evidence which all testifies that the problems on opening day were more operational/management problems or human generated than anything else.'