CBP Works to Make ACAS Air Cargo Pilot Permanent, Lists Filing Options, Phases
At the December 7, 2011 COAC meeting, COAC and CBP officials discussed the expansion and evolution of the Air Cargo Advance Screening (ACAS) pilot, including CBP's plans to make it a permanent program, the benefits of integrating ACAS and the ACE Simplified Entry pilot, and the EU's commitment to testing ACAS. In addition, COAC’s Air Cargo Subcommittee outlined the activities it plans to pursue during the next three months.
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(The ACAS pilot, which began after the October 2010 incidents with explosives being shipped via air out of Yemen, is a joint CBP-TSA targeting initiative that uses advanced shipment data to assess risk on air cargo transported into the U.S. High risk cargo is subjected to enhanced pre-departure physical screening or prevented from loading before a flight departs from an overseas airport.)
ACAS Pilot Running in over 70 Regions of Strategic Importance
While the initial scope of the ACAS pilot program began with 28 countries in the Middle East and North Africa, CBP has since expanded the pilot program to include over 70 regions of strategic importance.
ACAS Pilot is Being Implemented in Three Phases
According to an August 2011 TSA PowerPoint presentation, the ACAS pilot has three phases: (1) express cargo air carrier pilot (began in December 2010), (2) passenger air carriers and forwarders (began in September 2011), and (3) all-cargo carriers (yet to begin).
For the second phase, which began in September 2011, certain key freight forwarders and passenger carriers are transmitting test data and there are several additional freight forwarders and passenger carriers preparing to participate.
Details of Three ACAS Filing Options
According to a CBP PowerPoint presentation, the following are ACAS filing options:
| Filing Option #1 | Filing Option #2 | Filing Option #3 |
|---|---|---|
| (Carrier end-to-end) | (Carrier/FF shared) | (Carrier end-to-end) |
| Carrier transmits pre-lading security filing (7 data elements) | Forwarder transmits pre-lading MAWB/HAWB data to CBP on behalf of the carrier | Carrier to transmit pre-lading data |
| Carrier files full manifest (4 hrs/wheels up) | Carrier may amend | Carrier may amend |
| Carrier responsible to adjudicate ACAS holds | Forwarder responsible to adjudicate ACAS holds | Carrier responsible to adjudicate ACAS holds |
CBP/TSA Gives COAC Draft Plan to Make ACAS a Regulatory Program
Just prior to the December 7 COAC meeting, CBP and TSA provided COAC with their ACAS draft strategic plan. This plan lays out the ACAS pilot framework and lists milestones for how CBP and TSA plan to take ACAS from pilot phase into a regulatory program.
According to the Air Cargo Subcommittee, the trade community views the strategic plan as a prerequisite to subsequent activities, e.g., development of Concept of Operations for data transmission and communication protocols, resolution of associated pending policy issues and analysis of pilot results, protocol adjustments to accommodate lessons learned, identification of key regulatory changes, initiation of CBP’s proposed rule process, a target date for issuance of a final rule, and phased enforcement of new requirements.
CBP Says Integration with ACE Simplified Entry Pilot Would be Beneficial
During the meeting, CBP officials noted that being able to integrate ACAS with ACE Simplified Entry will incentivize the trade to participate in both pilots. CBP officials also noted that since the inception of ACAS, CBP has received advance data on nearly 5 million shipments and there have been no Do Not Loads.
EU Has Committed to Testing an ACAS System with U.S.
According to CBP officials, the European Union has committed to testing an ACAS system with the U.S. CBP was able to show the EU the benefits of an ACAS system as an alternative to the “hard and fast” rule they were developing.
Short-Term COAC Activities Include Monitoring Pilot, ID Possible Reg Changes
COAC’s Air Cargo Subcommittee has identified the following as the short-term activities it plans to work on during the December 2011 through February 2012 time period include information gathering & discussion, stakeholder outreach, monitor ACAS pilot, and identification of potential regulatory changes.
(See ITT's Online Archives 11121404 for summary of CBP notice of Deputy Commissioner's Aguilar's discussion of ACAS before a aviation security conference.)
COAC Air Cargo Subcommittee executive summary available here
CBP ACAS report available here
CBP August 2011 PowerPoint presentation on ACAS, including a discussion of the three ACAS filing options available here
TSA PowerPoint presentation on ACAS available here