ACE Cannot Reach Planned Operability in 2012 on $3.3 Billion (3rd Quarter FY 2009 ACE Report to Congress)

CBP's report provides a program assessment and describes the challenges, fiscal status, accomplishments, and future program milestones for ACE. Highlights from the report include the following:

ACE Program Assessment

CBP's ACE program assessment for the third quarter of FY 2009 includes (partial list):

Independent Review Says ACE Contracting Needs to be Reevaluated, Etc.

To increase efficiencies in ACE, an independent management review was conducted in late 2008. The findings that resulted from this review included: (1) the need to improve requirements management and ensure better business engagement; (2) the need to reevaluate the ACE contracting and acquisition strategy; and (3) the need to improve the testing process and the technical architecture. Activities to address the findings are ongoing.

M1 Placed Under Increased Scrutiny, M2.1 Placed on Hold

In light of the findings from the independent management review, CBP placed M1 (e-Manifest: Ocean and Rail) under increased scrutiny, and in June 2009 development and testing for M1 was placed on temporary hold pending a full requirements review and validation. As testing progressed, CBP encountered software defects at a rate that exceeded the ability to fix them.

(CBP initiated a comprehensive review of M1 code to determine if work should proceed on course or if other actions should be taken. It was determined that some requirements for ocean and rail manifest processing had not been accurately defined, which resulted in the errors found during software testing. CBP placed the development and testing of M1 on hold so that the requirements can be thoroughly reevaluated and finalized. Upon completion of this process, CBP will conduct an internal Critical Design Review (CDR) review and renegotiate a contract for completion of M1 development.)

Work has been put on hold for M2.1 (e-Manifest: Air) capabilities because this drop depends on the code being developed in M1; M2.1 will not resume until CBP is satisfied that the foundational M1 drop is working as intended.

ACE Cannot Reach Planned Operability in 2012 on $3.3 Billion

The cost overruns and schedule delays associated with the M1 project have further impacted the cost and schedule performance of the overall ACE program. CBP began investigating the extent of that impact as part of annual updates to the ACE program plan.

As those efforts progressed, it became evident that ACE, as originally defined, could not be completed within the program's $3.0 billion total budget constraint. Although the ACE Acquisition Program Baseline (APB) calls for ACE to reach full operational capability (FOC) in FY 2012 at a cost of $3.3 billion, CBP has determined that the current project scope cannot be completed within these APB thresholds. (See ITT's Online Archives or 05/01/08 news, 08050105, for BP summary announcing that CBP extended the ACE schedule to 2012 (from 2011), and increased the cost to $3.3 billion.)

Meetings with DHS May Result in Changes to Overall ACE Program Plan

Changes to the overall ACE program plan may result from two separate meetings with the DHS Acquisition Review Board (ARB) held in June 2009. As a result of those meetings, CBP was directed to evaluate the business requirements and priorities of the remaining ACE projects.

Baldwin Named as Executive Business Owner for ACE Program

To improve the governance structure and ensure better business engagement, CBP has named Assistant Commissioner for the Office of International Trade Daniel Baldwin as the senior Executive Business Owner (EBO) for the ACE program. The ACE EBO is responsible for establishing a clear and transparent vision for the deployment of an environment that meets the needs of both the agency and the trade community. Baldwin will coordinate and recommend business decisions, including business requirements, prioritization, implementation, and communications.

Selected ACE Accomplishments

ACE accomplishments for the third quarter of FY 2009 include (partial list):

Completed ITDS Data MOU

The Data Memorandum of Understanding (MOU) template and instructions were completed and submitted to 31 participating government agencies (PGAs) on May 7, 2009.

This document lists each ACE data element that the PGA has the legal authority to receive. The ITDS data harmonization team tabulated the data elements currently available in the ACE Data Warehouse and the data elements that will be available in the M1 release, creating the contents of the MOU for 31 PGAs. Each of the 31 PGAs will review the template, make any necessary changes to reflect their legal authority, and incorporate it into their Data MOU.

(See ITT's Online Archives or 11/10/09 news, 09111010, for BP summary of Treasury's ITDS list of data elements required by government agencies.)

Completed Critical Design Review for ACE AD/CVD Functionality, Etc.

In June 2009, CBP conducted a successful CDR for the first sub-drop of A2.3 functionality, called A2.3.1a, which will allow users to file type 03 (Anti-Dumping/Countervailing Duty (AD/CVD)) entry summaries via ACE.

This sub-drop will also include an integrated AD/CVD case management system. The case management system will provide the U.S. with a more accurate tool to help comply with AD legislation, streamline the processing of entries subject to AD/CVD, and enable much better communication between the Department of Commerce, CBP, and the trade community.

ACE release A2.3 will also result in the use of the Automated Targeting System (ATS) for all entry summaries (both ACE and the legacy Automated Commercial System) submitted to CBP.

(See ITT's Online Archives or 11/09/09 news, 09110940 1, for BP summary announcing the availability of this report.

See ITT's Online Archives or 11/04/09 news, 09110405, for BP summary announcing that CBP would be deploying ACE AD/CVD testing to the Certification environment on November 9th.

See ITT's Online Archives or 08/27/09 news 09082705, for BP summary of CBP, other government agencies, and COAC members discussion of ACE's status at the August 5th COAC meeting.)

ACE quarterly report (posted 11/05/09, dated 10/26/09) available at http://www.cbp.gov/linkhandler/cgov/trade/automated/modernization/ace/quarterly_reports/ace_rpt_09_3qtr.ctt/ace_rpt_09_3qtr.pdf