Trade Recommendations for
A2 Communications Outreach
The Critical Message:
Communicating ACE Is As Important As Building It
TSN Transition Committee
August, 2006
Executive Summary
On behalf of the TSN trade community, the Transition Committee wishes to express its concerns with regard to the current outreach efforts planned for the ACE project and specifically, for the transition from ACS to ACE with the coming A2 implementation. A successful build of ACE can be rendered unsuccessful by inadequate communication efforts. The purpose of this document is to formally document outreach concepts that we strongly believe should be rolled into existing CBP communication and outreach plans and not as separate activities. With our combined efforts, we can ensure that the transition from ACS to ACE will be a successful one.
The Impact of ACE
The actual impact of ACE on the trade community can neither be overstated nor fully anticipated. The current ACS system and related components such as ABI and AMS, represent an artery through which flows the blood of the U.S. economy. Nearly every significant enterprise in the U.S. relies on imported goods, and nearly all of this traffic is time-sensitive.
In addition to being the lifeline of commercial imports, the ACS/ACE realm is also the bread and butter of many other businesses. A clumsy implementation of ACE will cost money, clients, and jobs to those who are dependent on these systems to realize their work.
Impact of A1
Most of the functionality being built for A1 is “behind the scenes” and has little to no practical effect on the average member of the trade community. For this reason, combined with the fact that communications to some extent have already been underway, we offer no additional recommendations for A1 other than what has already been developed by CBP.
Impact of A2
The functionality being built for A2 has direct impact to many in the trade community. It represents substantive changes both in practice and in programming. The functionality in A2 and beyond will spur the need for a coherent, comprehensive plan to ensure the content specific messages are delivered in a timely manner to the trade community regarding ACE. The messages that need to be delivered are:
· If you are an importer, broker, or carrier, SIGN UP NOW!
· The transition to ACE from ACS will be no worse, but potentially as challenging, as the transition to ABI.
· Partnership between all parties (importers, brokers, CBP, Participating Government Agencies (PGAs), and transportation providers) is necessary.
These initial general messages to “sign up” must be coupled with concrete examples of the benefits of ACE usage. Such messages could be included in monthly “reminder” administrative messages. These messages should also include a request that ABI brokers get the word out to their customers. Also important is the fact that CBP must deliver these messages to both big and small companies; regardless of the size of the company, the impacts will be felt across the board. Early education regarding the advantages that can be expected by using ACE will further ensure participation. Additionally, detailed information regarding the system, how it works, and what trade users must do to cope with it, must be provided constantly, and as early as possible.
“Public Relations”
The history of ACE includes many missed deadlines, false starts, and other letdowns, dating back to 1994. While the program has been on track and making respectable progress for the last several years, the acronym, “ACE” likely remains tainted in the minds of many. This presents an impediment in gaining buy-in and enthusiasm from the trade community. In the commercial world, such situations often trigger the use of a professional public relations firm. However, the trade realizes that the current strain on financial resources allotted to ACE cannot permit such a luxury.
The ACE system now being built and implemented offers many new opportunities and benefits for its users. Unprecedented access to transactional data via the portal allows the importer to better analyze and correct problems. Periodic Monthly Statement offers simplicity and real financial savings over traditional practices. Multi-modal manifests and access to participating government agencies through ITDS will offer vast improvements in efficiency and uniformity. As these are all important milestones, it is important to sell them as benefits associated with the transition to ACE. While the transition to ACE will be difficult and costly in some areas, it is as necessary and helpful as the transition from kerosene lanterns to electric light.
CBP should consider “marketing” this type of information in the same manner a professional PR firm would. It is imperative that the CBP communication team not only “package” the information appropriately, but more importantly, effective communication must feature content tailored to specific audiences that is delivered effectively and efficiently throughout the stakeholder chain. It is vital to the success of ACE that we have a comprehensive outreach plan that includes consistent messages. A major media blitz could be undertaken, including a mass mailing of tri-fold brochures, with content tailored to the type of recipient.
A contingent of trade representatives could be helpful as a “sounding board” for the messages prior to general release.
ACE Message
The central theme of all ACE communications should be for affected parties, regardless of size, to “sign up now.” The transition will happen regardless of the readiness level of any particular entity, so it is incumbent on each member of the trade community to embrace the coming changes. Those who do will enjoy enhanced capabilities and cost savings. Those who do not will suffer increased cost, unmanageable cargo delays, and eventual irrelevance.
Although the specifics of the appropriate message may vary according to the target audience, a central theme should be that ACE is not a simple “reporting tool” nor should it be considered just a “system” change. A2 functionality will bring new business processes for both the trade and CBP and as such, there will be changes in the way that CBP and the trade will interact. The audience members will vary greatly, from large to small importers, large to small brokers, software vendors, transportation service providers, individual truck drivers, sureties, and many more.
Two things are important: First, an overall marketing message that explains what is happening, the need for the change, and that encourages participation, and second, dissemination of very detailed information on exactly how things will be done, and what changes will be needed inside the systems and procedures of those involved. This second component has not been promulgated to the extent that it should be. Particularly among software vendors and brokers, the “sales pitch” explaining why ACE will be so wonderful is at best unnecessary, and at worst, a little insulting. These groups have no choice but to participate. What these users are starved for is detailed systems requirements and alerts regarding changes they will need to make to the way they do business. While it is understood that many of the specifics are still under development, any details should get widespread distribution as they become available.
Trade Target Audience
In order of priority, those in most immediate need of detailed information are software vendors and those brokers and importers that self-program their IT systems. Next are those who interact directly with CBP on a technical level, such as customs brokers, self-filing importers, and those in the transportation industry. Finally, everyone else, such as all importers, and sureties will need information. Along the way, the information should be disseminated to trade associations of all types, as they serve as a conduit of information for their constituent members and the community at large.
Channels of Communication
External
In reaching the various parts of the trade community, there are many options. For larger importers and brokers, the obvious choices are direct communication and associations such as AAEI and NCBFAA, all of which are already being used. This should continue, and the full list of possible organizations should be fleshed out and used to maximum advantage.
Additional options that must be considered, particularly for smaller companies, are the following: seminars by CBP, including at the local port level, monthly ABI Administrative Messages, and direct mailings. CBP may want to consider creating an email list (listserv) composed of interested importers, brokers, carriers, software vendors, etc., who have proactively confirmed their interest in receiving direct emails from CBP regarding ACE Communications. Although it is recognized that the current ACE Accounts and current TSN members will do their part as “ambassadors” for ACE, CBP should not minimize the critical role that it must play in this outreach effort in order for the larger trade community to recognize the urgency of the information being delivered to them.
The trickier part of the picture is the transportation industry. While most of the air, sea, and rail carriers have been involved and are fairly well-informed, the trucking industry presents a unique problem in the form of individual drivers. These drivers are a critical part of the equation, will be among the first people affected by ACE, and have the least infrastructure in place dedicated to the communication of important details that pertain to them. Many options have been discussed in various forums, including:
· Billboards at border areas frequented by cross-border truckers
o Similarly, billboards should be strategically located both inside and outside each Customhouse
· Printed media strategically located in truck stop lounges
· Information kiosks (similar to those found in airports for travelers) in similar locations
· Communications to truckers’ groups, including local Teamster’s Unions
· Radio and other advertisements targeted to truckers
· Flyers inserted into transportation paperwork packages
Internal
CBP must do its utmost to educate its field employees on the details of ACE. Although we appreciate the challenges this presents for CBP, many in the trade will turn to their local Entry and Import Specialists as first-line resources. Unfortunately, as many in the trade have found, the current state of ACE-awareness among these individuals is almost nil.
As we move forward with ACE, CBP should conduct a review of recent implementations across relative ports and make “lessons learned” available to ALL CBP employees. For example, in the recent deployment of e-manifest at the port of Otay Mesa, there were many factors that caused delays. This information should have been made available to all CBP field employees. ACE related communications that are shared with both the local port level and/or expanded to the district level, will allow for sharing of experiences over various ports and eventually, will result in uniformity of standards across all of CBP.
Foreign Trade Associations and Governments
Additional outreach can be done through trade associations in Canada and Mexico, foreign consulates, and local chambers of commerce. The trade appreciates that outreach to Canadian and Mexican customs is politically sensitive and that initially, this should be approached internally. A recommendation may be to reach out to the Assistant Attaché, Trade Operations, in Ottawa (Eric Couture). Mr. Couture regularly meets with many government groups as well as the trade industry in Canada and might be a powerful proponent of these initiatives. Similarly, Mr. Couture’s counterpart in Mexico should be consulted.
As changes in import procedures in the U.S. directly impact export procedures in Canada and Mexico, the local ports across the border in Mexico and Canada should also considered. The trade is well aware that because of these relationships, local U.S. Customs ports and the corresponding Mexico or Canada Customs ports create local port practices that may require modifications with the implementation of ACE. Given that most of the land border ports have existing relationships with the Customs administrations just across the border, these communication channels should also be explored.
Eventually, as the relationships between CBP and the foreign governments become more established, the trade should be brought in so that ongoing discussions also take “commercial realities” into consideration. A three way dialogue, that is, U.S.-to-foreign government-to trade, will only help to strengthen communications and ensure success for ACE.
Post Deployment Communication
As functional ACE releases are deployed, some consideration should be given to post deployment communication between the trade and CBP. From a trade perspective, a “lesson learned” from past releases has been the fact that a mechanism is lacking to address feedback and problem resolution for the trade. Although it is recognized that there has been a current migration to “Great Idea Forms (GIFs) to address implementation issues, these GIFs are neither adequate nor realistic for actual implementation issues associated to a specific function. The lag time between the actual drafting of the GIF, the review of the GIF, and a final determination regarding the submitted GIF, can be staggering. Quicker validation of the problem at hand would be advantageous to both the trade and CBP
Materials Geared to Audience
The body of specific information should be developed for each segment of the industry. For example, the information relevant to brokers will not be identical to that required by truckers, importers, and other industry sectors.
A particularly helpful item would be “Checklists” for each industry segment. These would serve to guide users on important changes they should have made or should be planning on making with regard to their systems design, internal procedures regarding clearance of cargo, and the like. Content recommendations for these industry specific checklists could include “timelines” reflecting critical dates, internal system changes likely to be needed, etc. It is crucial however, that as these timelines are developed, CBP make allowances with regard to how one industry "check list" flows with another. The trade could then take these recommended check lists and modify them based on internal needs/processes/resources.
Procrastinators
Despite the best efforts of CBP and active members of the trade community to communicate the impending ACS/ACE Transition, there will be gaps. Some in the trade community tend to be like the proverbial ostrich, keeping their heads buried in the sand. This is common to smaller companies, but is not necessarily limited to them. It is important to go as far as possible to reach these players. These entities will, through ignorance and inadequate preparation, contribute greatly to glitches and delays in the use of the new system, the effects of which will be felt by the wider trade community.