CBP Reports to Congress on ACE (Cargo, ESAR, Edit-Lite, Etc.)

This is Part I of a multi-part series of summaries on this report, and highlights CBP's assessment of ACE Secure Cargo Management capabilities (e.g., e-Manifest, ESAR), Edit-Lite, and related ACE milestones.

ACE Cargo Management

ACE secure cargo management capabilities discussed in the report include:

e-Manifest: Truck. CBP completed the deployment of ACE truck processing capabilities on November 7, 2007, with the deployment to Piegan, Montana. Truck e-Manifests for advance cargo information purposes can now be processed at all 99 U.S. land border ports of entry. Implementation of the mandatory e-Manifest policy in Alaska on February 11, 2008 marked the full operational maturity of ACE truck processing capabilities.

ESAR A1. Following the September 9, 2007 deployment of Entry Summary, Accounts, and Revenue (ESAR): Master Data and Enhanced Accounts (A1), account-related problems ranging from missing data to difficulty accessing the ACE Secure Data Portal were reported.

CBP states that problems having the most impact on users were declared high priority and have been resolved. These problems ranged from data reliability to system access problems for both CBP and trade community users. Resolutions for problems determined to be of less impact to users continue to be prioritized and implemented.

Customer service, outreach. As part of its efforts to enhance ACE customer service and trade outreach efforts, CBP recently:

implemented a streamlined application process that allows electronic signature and submission of ACE applications;

increased the number of second-tier help desk support from 7 to 22 staff members;

began plans to increase the number of client representatives and open three new offices;

began development of a new messaging service that will allow CBP to instantaneously provide information regarding all CBP cargo systems to subscribers via e-mail; and

assembled a new working group to evaluate and improve the ACE user-interface.

ITDS. The International Trade Data System interagency coordination efforts continue to focus on deepening existing relationships with the 40 ITDS participating government agencies (PGAs), identifying the business requirements of these PGAs, and integrating these requirements with the ACE development process.

ACE fully operational in 2012. CBP completed the annual update to the ACE program plan following a comprehensive analysis and validation of the cost and schedule for future releases. The updated program plan calls for ACE to be fully operational by August 2012 at a cost of $3.3 billion. CBP had previously estimated completing ACE sooner (July 2011) and at less cost; however, CBP notes that extending the ACE schedule until August 2012 will enable ACE to be completed within current annual funding levels.

M2 and A2 releases. As part of efforts to update the ACE program plan, reduce dependencies between releases, and deliver new capabilities to the field faster, CBP states that capabilities previously included in e-Manifest: Air Manifest and Cargo Release (M2) and ESAR A2 have been divided into smaller sub-releases, or "drops."

CBP states that e-Manifest: Sea and Rail (M1) and M1 Reference Data (A2.1), which will incorporate sea and rail manifest processing into ACE, are scheduled for deployment in late 2008.

Four ACE A2 and M2 "drops" are scheduled for delivery during calendar year 2009:

ESAR A2.2 Initial Entry Summary Types - entry types 01 (consumption) and 11 (informal);

ESAR A2.3 - Remaining Entry Types;

e-Manifest M2.1 - Air and Conveyance Management System; and

e-Manifest M2.2 - Full Multi-Modal Database.

CBP acknowledges that delivery of these four significant groups of capabilities in a relatively short time period creates a risk of schedule delays. To mitigate this risk of delays, CBP is in the process of evaluating options for increasing the competition for development work, including use of a more economical off-site development facility, use of improved business process modeling, and maximizing the efficient use of resources, such as system server capacity.

Edit Modification (aka Edit-Lite)

CBP's updated ACE program plan also includes the results of an in-depth examination of Automated Commercial System entry summary processing capabilities, which began as part of efforts to address delays in the "decomposition" of legacy system "edits," or checks that essentially re-validate the entry summary at the time of filing, and ultimately resulted in a larger discussion of how these capabilities would satisfy the Modernization Act requirements of shared responsibility and informed compliance.

CBP believes it can and should rely on the accuracy of initial entry summary declarations and, for this reason, is proceeding with "Edit Modification¹," the plan to reduce the number of existing entry summary automated system edits in ACE that CBP states largely duplicate the efforts of entry summary filers.

CBP states that edit modification will reinforce the need for importers and their agents to ensure the quality of entry summary data. CBP planned to meet with trade community representatives in January 2008 to discuss its plans for Edit Modification

A2.2 will involve voluntary participants. CBP states that it continues efforts to develop ACE entry summary processing capabilities. With the first phase of ACE entry summary capabilities (A2.2), an initial group of voluntary trade partners will be able to submit entry summaries via ACE for the most common entry types (entry types 01 and 11).

Remaining entry types constitute A2.3. Remaining entry summary types constitute drop A2.3, and will be implemented in ACE incrementally throughout 2009.

Trade participation will remain voluntary until all entry summary capabilities are available in ACE.

ACE Milestones for Second Quarter FY 2008

The report identifies the following as ACE milestones that were scheduled for the second quarter of FY 2008 (January 1, 2008 - March 30, 2008):

February 2008:

Critical Design Review completion for A2.2, which would signal that design work has been completed and that construction could begin.

Preliminary Design Review completion for M2.2, which would signal that preliminary design work has been completed and that detailed design work could begin.

March 2008:

Reactivation of the system interface between ACE and the Federal Motor Carrier Safety Administration (FMCSA) Query Central. This interface would facilitate the transmission of truck e-Manifest data from ACE to FMCSA. FMCSA uses this data to conduct pre-arrival screening of truck manifest information. This would represent the first full-time system-to-system use of ACE by an ITDS PGA and a step toward the realization of the ITDS vision of a "single window" for the filing of trade data.

ACE reports instructor-led training for CBP officers, port management, import and entry specialists, broker management offices, financial operations, analysts, and national account managers.

¹Commonly referred to as "Edit-Lite," it is CBP's proposal to have a minimal number of edits and validations in ACE. (See ITT's Online Archives or 02/26/08 news, 08022605, for most recent BP summary on Edit-Lite. See future issue for further information)

CBP's ACE quarterly report (including Appendices A-F) available at http://www.cbp.gov/linkhandler/cgov/trade/automated/modernization/ace/quarterly_reports/ace_rpt_dec_07/report_2008_q1.ctt/report_2008_q1.pdf.

Appendix G of quarterly report available at http://www.cbp.gov/linkhandler/cgov/trade/automated/modernization/ace/quarterly_reports/ace_rpt_dec_07/appendix_g.ctt/appendix_g.pdf.