CBP Planning Simplified Entry Pilot with PGAs for Lacey Act Filings

CBP is moving toward testing Simplified Entry for Lacey Act filings, said Vincent Annunziato, director of cargo control and release at CBP, speaking at the CBP East Coast Trade Symposium Nov. 28. CBP recently wrapped up its Phase 1 of Simplified Entry testing when it expanded the pilot to numerous ports, said Annunziato. (See ITT's Online Archives 12081319 for summary of CBP's plans to expand the simplified entry pilot. Simplified Entry allows for filing of shipment information earlier in the import process and is now being tested within air cargo.)

Progress toward interaction with participating government agencies (PGAs) through Simplified Entry is among the priorities following the September transition to ACE M1, said Annunziato. 'We're going to run a pilot, there will be two agencies and were going to take the Lacey Act into that mode," he said. "We may even be able to take that from anywhere the Lacey Act is submitted. But the big key piece on that is that for the first time there will be bidirectional communication with other agencies. Right now it is just one way. Were just sending data out, its being reviewed and everything is operational from there."

(CBP sought volunteers in August for a Cut Flower Pilot Project, a proposal developed by CBP, the Department of Agriculture (USDA) and the Association of Floral Importers of Florida that will be conducted at Miami International Airport in 2013 in conjunction with the CBP Simplified Entry Pilot. See ITT's Online Archives 12082126 for a summary of the CBP Federal Register notice.)

Also important in Simplified Entry will be automated corrections and deletions, a complicated but "foundational" piece, said Annunziato. That will mean brokers won't need to send paper any more and CBP can do a side-by-side review of prior versions and what is coming in, he said. One complication, though, is that it remains unclear if suspension of the release is necessary once a correction is sent to CBP or PGA or both, he said. The policy will have to be integrated on that, he said. Also unclear is holds and whether CBP must set the hold or if a PGA will be able to, he said. Remote location filing is another important piece and is being looked at for inclusion within Simplified Entry, he said. Simplified Entry for Ocean transportation is hoped to be available by 2014, he said.

Report Capabilities for SE Still Being Figured Out

One area that will have to take a back seat within Simplified Entry is the sending out of reports, Annunziato said. CBP is waiting for another piece to be added to Simplified Entry system and once that's done CBP will consider adding that to the schedule, he said. The agency will be working hard on adding that capability, said Monica Crockett, director-entry summary in the Office of International Trade at CBP. "Going into next year, I just want you to know that we will focus on some of the reports that you’ve been looking for," said Crockett. "I know that [the] AM 100, courtesy notice of liquidation to brokers, is high on your list. We’re just waiting for some software upgrades to our reports functionality. Once we get that, we will start hitting some of those enhancements and fixes that are sorely needed for reports. So it’s still very high on our list, we have not forgotten. And we’ll deliver those just as soon as we can. "

Smith Addresses Funding Questions

Many questions remain for progress in ACE, considering the difficult budget environment and uncertainty of future funding for the program. "We have been doing a lot of work to figure out how the money that we currently have on hand will support our goal of getting a complete trade process built within ACE," said Brenda Smith, head of the ACE business office. "We think we are in reasonable shape but we do have a gap. Currently, CBP is allocated about $140 million a year for ACE maintenance and operations and enhancements. We also have approximately $70 million in carry over funds from previous years. "The agency is "working really hard, though, to figure out how we can spend the carry over dollars most wisely and make sure we're using our operations and maintenance funding most efficiently. We believe we have enough funding to carry us through about 18 months of new development but we are also exploring ways to find the additional funding that we believe we need while at the same time figuring out how we can be more efficient with our operations and maintenance funding."

(Since the September transition to M1, the agency has taken on a new stance of "agile" development for ACE, allowing for smaller, incremental additions to the program that will give the CBP better flexibility. See 12082729 for summary of CBP's revised ACE development strategy.)