Automation Letter to Sam Banks

March 17, 1998

Mr. Samuel H. Banks
Acting Commissioner
US Customs Service
1300 Pennsylvania Avenue, NW
Washington, DC 20229

Dear Acting Commissioner Banks:

The Joint Industry Group (JIG) Automation Committee was established one year ago under the principles outlined in the attached paper. The first meeting of our Automation Committee was attended by Commissioner George Weise, who agreed to cooperate with us in the development of Customs automation initiatives and outlined Customs ambitious plans for future automation. JIG remains committed to building "a coalition of its members and other industry groups concerned with automation" and "to utilize this coalition to provide a uniform industry position on trade needs and priorities for an automated import, export and trade compliance process."

For more than a decade, Customs has been a leader in developing automated systems to streamline the trade process. As the world’s largest trader, it is imperative that the United States remain a leader in trade automation and set the standard for trade automation worldwide. It is through automation and common international business practices that barriers to trade will be reduced and many inefficient and costly business practices eliminated. The biggest beneficiary of this streamlined international system of free trade is the United States. A standardized, streamlined, automated international trade process is the rising tide that lifts all boats and will be to the economic benefit of all governments and industries that choose to participate in the program. The JIG vision of this automated world is outlined in the attached paper (attachment) and briefing charts (attachment). For the reasons outlined above, JIG is in support of Customs and Treasury continued design and development and full funding of the following trade related systems provided that Customs and Treasury cooperate fully with industry in this endeavor:

The International Trade Data System (ITDS);
The North American Trade Automation Prototype (NATAP);
The US/UK Prototype;
The Automated Export System (AES); and,
The Automated Commercial Environment (ACE).

ITDS, NATAP, the US/UK Prototype, and AES are the key to continued and future leadership by the United States in automating the trade process worldwide. These systems provide the foundation and framework for integrating the export and import process into a seamless international system of trade and represent the long-term needs for trade automation. In spite of our inability to achieve Fast Track negotiating authority, the US remains the leader in global customs and trade issues and the development of these systems is an essential part of that leadership. The ACE system is essential as the logical extension of the highly successful Automated Commercial System upon which the United States system of trade is so dependent. In view of the importance of the Year 2000 conversion, it will be the subject of a separate letter. In regard to ACE, the JIG Automation Committee recommends full implementation of the entire system with emphasis for early implementation of the following modules:

NCBFAA recommendations for Enhanced Electronic Entry Program (EEEP);
Completion of Truck Pre-Arrival Processing System (formerly known as Buffalo Pilot);
AMS;
Remote Location Filing;
NCAP (Track 4 Processing, Reconciliation, Monthly Entry);
Periodic Payment; and,
Surety Interface.

By "early implementation" we mean that those projects should be implemented on a phased basis by the end of 1998. Design and implementation should be the responsibility of joint teams consisting of Customs personnel and exporters and importers and their agents with a stake in implementation. We would like to explore the possibility of establishing such joint teams for each of the projects outlined above as a partnership between key trade groups and Customs. This approach would incorporate mutual commitments and public accountability using established techniques for documentation and dialogue.

In all systems development efforts it is essential that the system that Customs develops represents the interests and needs of all Federal agencies. Any system that does not is a step backwards. Of course, this common system will require that other agencies adopt risk management, selectivity, post/pre-audit, and compliance measurement standards.

We believe that Customs and Treasury are on the right path in pursuing these various automation initiatives, however, we have not been pleased with the pace of implementation and the extent to which many of the projects reflect the concerns of the trade. We are also concerned that the early implementation initiatives have been slow in materializing. JIG will make every effort to build the industry coalition to ensure that Customs is adequately funded to achieve the goals summarized above provided that we can agree upon priorities and an implementation schedule with you. In view of the fact that industry is paying the Merchandise Processing Fee, the Harbor Maintenance Fee, Air Passenger Fees, border truck fees, and the importance of these systems to continued prosperity of our economy, it is essential that funding be provided to support these vital national and international systems development efforts. The JIG supports bold and expeditious development of these initiatives and will work cooperatively with you to secure early and sufficient funding for implementation.

These systems are of major importance to industry and the early workable implementation of these projects is long overdue. Perfect implementation is a time consuming illusion. Industry and Customs must jointly assume reasonable risks and proceed to implement.

Please give this matter your consideration and let me know how we can work together on these issues.

Sincerely,

Michael H. Lane
Chairman
JIG Automation Committee