COAC Comments on DHS' Draft Supply Chain Security Strategy at May 15, 2007 COAC Meeting
During the May 15, 2007 meeting of the Departmental Advisory Committee on Commercial Operations of Customs and Border Protection and Related Homeland Security Functions (COAC), DHS officials discussed, among other things, DHS' draft report entitled "Security to Enhance International Supply Chain Security."
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On March 29, 2007, DHS provided COAC with a draft of its report which is intended to meet the requirements of the Security and Accountability for Every (SAFE) Port Act of 2006 for the development of a strategic plan to enhance the security of the international supply chain specific to containerized cargo.
This report was developed by DHS with representatives from U.S. Customs and Border Protection (CBP), the Coast Guard, and the Transportation Security Administration (TSA).
COAC Expresses Concerns About DHS' Draft Strategy
In response to DHS' draft supply chain security strategy, COAC expressed concerns, highlights of which include:
Plan is not actionable. COAC does not believe that the plan is actionable. The plan as written is very general and until the detail is populated, COAC does not believe that the plan is useful.
Plan focuses too much on maritime environment. The plan is almost entirely focused on the maritime environment and does not recognize the interdependency of the international supply chain environment as to modalities of transportation and the supporting industries.
Plan does not specify who is in charge at each level. DHS' plan does not specify exactly who is in charge at each level or how the authority cascades.
Plan does not address agencies' interlocking relationships. While the plan describes at a high level the relationship between departments of the government, it does not specify what interlocking agencies are expected to do in detail sufficient to enable coordinated guidance.
Plan does not provide for 24/7 communication with trade. A major weakness of the plan is that it does not include 24/7 communication with the trade nor does it provide that any agency is charged with this responsibility.
Plan does not provide trade with intelligence on port conditions. The plan does not provide for intelligence to the trade on port conditions as previously recommended by COAC.
Plan does not provide benchmarks for goals, etc. The SAFE Port Act requires that the government set measurable goals, objectives, and timetables to implement a national strategy, but DHS' plan does not provide these important benchmarks.
Plan does not address incremental benefits for programs such as C-TPAT, etc. A key to the layered approach to national security has been voluntary participation in the Customs-Trade Partnership Against Terrorism (C-TPAT). DHS's report does not address the SAFE Port Act's calls for incremental benefits for participation in voluntary programs.
Plan does not provide for cost-benefit analysis. DHS' plan does not speak to the costs versus benefits or even how analysis of marginal costs/benefits can be approached. Programs such as the "advanced data initiative" will require re-engineering of the global business process. However, there is no requirement that the program be demonstrated to achieve significant benefit.
COAC requests continued consultations with DHS, final report due late 2009. COAC also asks that DHS continue to consult with COAC as subsequent iterations of the strategy and tactical plans are developed, up through and including the final strategy that is not due to Congress until late 2009.
(See ITT's Online Archives or 05/31/07, 05/21/07, and 05/17/07 news, 07053105, 07052105, and 07051705, for previous BP summaries on the May 15, 2007 COAC meeting. See future issues of International Trade Today for additional summaries.)
COAC comments (dated May 15, 2007) available at http://www.cbp.gov/linkhandler/cgov/import/communications_to_trade/coac/meetings/05152007_mtg/05152007_comment.ctt/05152007_comment.doc.