Back to basics for ACE

Delays and costs associated with the development of the Automated Commercial Environment next-generation trade processing system have forced U.S. Customs to scale back programming to meet the most essential needs of government and the import-export community, according to industry representatives collaborating on the project.

Customs and Border Protection officials have concluded that they need to prioritize the most important missions for ACE in order to get the massive computer system operating sooner after many years of planning and development.

That means getting rid of the bells and whistles many stakeholders kept layering on the project.

ACE is a $3.5 billion advanced information system designed to monitor, control and analyze commercial import and export transactions.

The agency revealed in late July that it plans to delay by at least six months deployment of an ACE electronic manifest function for ocean and rail carriers because of software glitches and extra testing requirements. Programming has taken longer too because of ever increasing security requirements for additional data fields to handle the pending 10+2 rulemaking and inadvertent releases of containers by marine terminals before they have been cleared by Customs. As a result of the manifest schedule slip, an additional four to six month delay is projected for the early 2009 deployment of initial ACE entry summary capabilities.

Kenneth Ritchhart, deputy assistant commissioner for information technology, delivered the news about the new ACE expectations at the mid-September meeting of the Trade Support Network (TSN) in Tysons Corner, Va., Cindy Allen, vice president customs for Argents Air Express in Detroit, told reporters on a conference call last week.

TSN is a large group from the international trade industry that regularly advises CBP on business, technical and policy considerations regarding the new system and other automation efforts.

Ritchhart has tasked the leaders of his internal team to identify core automated functions they need to handle cargo release, manifest collection, entry summary review and other duties. He pledged to then seek input on the trade industry's top priorities and jointly define the core processes for programmers to focus on in order to speed up the transition from the old Automated Commercial System to ACE, Allen said. How much time may be saved is unclear until CBP goes through its analysis, Allen added.

CBP's new approach has the dual purpose of expediting the rollout of ACE and saving money, she said. It costs CBP much more money to keep two systems running at the same time. Turning off ACS sooner also will allow the agency to focus resources on new program development in one system rather than making redundant changes to support both systems. Without the new direction CBP, for example, will have to program the upcoming 10+2 security filing in ACS and then reprogram it for ACE.

The trade community realizes that budget and time pressures may no longer allow it to shoot for the moon when it comes to choosing upgrades for ACE capabilities, Allen said.

The ACE project is like the development of a big mansion, Allen said. We and CBP are like the architects. Some people have focused on the bathroom, others on the fixtures or the kitchen. Anytime a new project manager comes on board, he takes a different view of things from those intimately involved in the project. So in the kitchen, do we really need that Viking range or will a Kenmore do?

Reality has come into this process more than we'd like. The main question is do we have the adequate cabinets and countertops, and as long as it has electricity, we're O.K., Allen said of the new mentality towards ACE. People always say they want to live in a mansion, but it costs a lot to maintain a mansion. Do we really want to hire the cleaning staff?

We were kids at Christmas. Now we're getting things we need and negotiating on everything else, she added.

TSN representatives on the conference call said they are pleased for the most part with the way ACE is moving forward and CBP's efforts to collaborate with the trade community.

ACE is meeting or exceeding expectations in terms of valuable reporting tools and various account types for importers, brokers and other parties, said Tom Gould, president of Tom Gould Customs Consulting.

We may not be getting everything on our original wish list, but we realize we need to look at things a bit differently. Maybe we didn't get everything, but it still accomplishes our original goal of better managing trade data and compliance, he said.

Industry professionals are excited about finally being able next year to file entries and manifests, and use new tools within ACE, he said.

Reaction from the TSN audience was generally positive because trade professionals agree with Ritchhart's private-sector approach to developing a more business-process-oriented model rather than standalone applications that function independently of each other and don't improve efficiency, Allen said.

ACE is such a huge project that CBP operations staff trying to solve their work requirements didn't have a good view about how every area impacts the rest of the organization. "They may have lost sight of the big picture as more operations people got involved" and are now correcting the situation, she explained.

In a follow-up interview, Allen noted that part of the new impetus for getting ACE off the ground is the increasing role of other agencies in regulating international trade, especially in the areas of food and consumer safety. Those bodies and Congress now are more interested in ACE as a tool to help them collect the data needed to monitor shipments.

CBP is developing the International Trade Data Systems in conjunction with ACE as a single government window for trade documentation and information sharing so that businesses can file information once instead of to multiple agencies. There are 45 agencies with some form of regulatory control over international trade that are participating in ITDS, but until recently adoption has been slow despite urging by the White House and Congress to invest in hardware and re-engineer their processes to interact with ACE. 

Agencies are at different levels of involvement, Scott, vice president of business development for TradeMerit U.S. and co-chair of TSN's ITDS Committee, said on the conference call. Many agencies have drafted but not submitted to CBP their concept of operations, and about a dozen have followed a recent Office of Management and Budget directive to identify a senior executive to oversee the automation transition. Thirty-six have high-level implementation plans to fully utilize ITDS in 2009 and there are 500 users among 27 agencies who are actively working with the data presented through the ACE portal, she said.

Tim Skud, deputy assistant secretary for tax, trade and tariff policy at the Treasury Department, told a separate industry advisory panel in August that the ACE delays will push back the ultimate availability of the single window and put more pressure on the ITDS development team. The delay combined with the churn among the ITDS staff puts a premium on documenting the development process to counteract the loss of institutional memory, he said. 

As for the manifest functions, CBP has tested more than 80 percent of roughly 2,400 scenarios and hopes to have a stable system in place by December so that the trade can start testing its internal systems that interface with ACE, Louis Samenfink, executive director of the cargo systems program office, said at the August meeting in Seattle. He expressed confidence that the agency will be able to hits its new timeline to have the capability in place in the April-to-June period because of the high pass rates during testing. 

Source: American Shipper