appendix d: DESCRIPTION OF COORDINATION PROBLEMS AND ALTERNATIVES

TABLE OF CONTENTS

Planning [1](#__RefHeading___Toc26602407)

C-1. Inadequate Long-Term Planning Strategy for Border Crossings
[1](#__RefHeading___Toc26602408)

R-1. Inadequate Incentives for Participation in Pre-Clearance Programs
[2](#__RefHeading___Toc26602409)

C-2. Lack of Data Collection and Benchmarks
[4](#__RefHeading___Toc26602410)

C-3. Inconsistent Planning for Truck Safety Inspection Facilities
[5](#__RefHeading___Toc26602411)

Demand Management [7](#__RefHeading___Toc26602412)

C-4. Lack of Fee-Based Priority Shipment Lane
[7](#__RefHeading___Toc26602413)

R-2. Lack of Congestion Pricing [8](#__RefHeading___Toc26602414)

C-5. Commingling of Commercial Traffic Types
[10](#__RefHeading___Toc26602415)

Physical Layout and Truck Movement [12](#__RefHeading___Toc26602416)

C-6. POE Configuration -- New Inspection Technologies Cannot be
Accommodated [12](#__RefHeading___Toc26602417)

R-3. POE Configuration -- Outdated Facility Layouts
[13](#__RefHeading___Toc26602418)

C-7. POE Configuration -- Poor Internal POE Circulation
[13](#__RefHeading___Toc26602419)

R-4. Capacity -- Number of Primary Inspection Booths
[14](#__RefHeading___Toc26602420)

C-8. Capacity -- Inspection Sequencing [14](#__RefHeading___Toc26602421)

C-9. Capacity -- Uncoordinated Access Road Design and Limited Number of
Lanes [15](#__RefHeading___Toc26602422)

C-10. Lack of ITS Solutions to Streamline Truck Movements
[16](#__RefHeading___Toc26602423)

Staff Management [18](#__RefHeading___Toc26602424)

C-11. Personnel Turnover -- USCS Inspector Attrition Rates Are High
[18](#__RefHeading___Toc26602425)

R-5. Insufficient Customs Personnel [19](#__RefHeading___Toc26602426)

C-12. No Mechanism to Predict and Prevent Queue Development
[19](#__RefHeading___Toc26602427)

R-6. Personnel Turnover -- Mexican Customs' Rotation of Port Directors
[21](#__RefHeading___Toc26602428)

Stakeholder Coordination [21](#__RefHeading___Toc26602429)

C-13. Poorly Coordinated Stakeholder Schedules
[21](#__RefHeading___Toc26602430)

C-14. Inadequate Informal Stakeholder Coordination
[24](#__RefHeading___Toc26602431)

C-15. Untapped Opportunities to Enhance Broker Process
[26](#__RefHeading___Toc26602432)

Standards [26](#__RefHeading___Toc26602433)

C-16. Absence of Standardized Seal Notation Protocol
[26](#__RefHeading___Toc26602434)

C-17. Lack of Harmonized Truck Safety Standards
[27](#__RefHeading___Toc26602435)

Information Management [28](#__RefHeading___Toc26602436)

C-18. Information Systems -- Excessive Paperwork Preparation and
Handling [28](#__RefHeading___Toc26602437)

C-19. Information Systems -- Antiquated Technology
[29](#__RefHeading___Toc26602438)

C-20. No Advanced Threat Detection [31](#__RefHeading___Toc26602439)

References [32](#__RefHeading___Toc26602440)

APPENDIX D: DESCRIPTION OF COORDINATION PROBLEMS AND ALTERNATIVES

[]{#__RefHeading___Toc26602407 .anchor}Planning

[]{#__RefHeading___Toc26602408 .anchor}C-1. Inadequate Long-Term
Planning Strategy for Border Crossings

Description of Issue/Problem

Binational port planning is not coordinated to include all U.S. and
Mexican agency and private-sector requirements. There is no long-term
strategy for border system planning, or planning is dependent on the
inclinations of senior U.S. and Mexican officials. Trade practices and
new technologies may not be taken into consideration during the planning
process.

Alternative

Develop medium- and long-range plans for port of entry and binational
planning that involve all U.S. and Mexican public agency and
private-sector stakeholders.

Future Needs

Develop a border-wide planning handbook for use by public agencies in
Mexico and the United States. This handbook would provide detailed
profiles of all U.S. and Mexican commercial land ports. At minimum, each
profile should include U.S. and Mexican port layouts specifying traffic
flows, processing points, bottlenecks, and lane designations; detailed
data on two-way truck movements (by empty/bobtail and loaded trucks) and
average delay times; an inventory of NII equipment, ITS technology, DOT
installations, dock capacity (utilized and dormant), and other port
facilities; human resource capabilities of the various agencies working
at the port; and the operational schedules of those agencies and the
border bridge/roadway. This document would constitute a comprehensive,
updated compilation of strategic border planning information that is
currently fragmented among U.S. and Mexican Customs, the General
Services Administration, the Department of Transportation, and a myriad
of other public agencies in the United States and Mexico. The report
would build off previous efforts of a smaller scale such as the General
Service Administration's Summary of Existing and Proposed Border
Stations (1996) and the Texas Department of Transportation's Handbook,
International Bridges and Border Crossings Existing and Proposed (2001).

The operation of separate U.S. and Mexican land ports along their shared
border results in considerable duplication of systems, activities, and
infrastructure. The potential operational, financial, and security
benefits of developing joint border facilities is substantial. However,
special provisions would be necessary for the construction and operation
of binational border ports. Research aimed at defining the political and
operational requirements for development of joint border facilities at
remote, low-volume crossings between the United States and Mexico is
timely in light of current plans to expand the number of border
gateways.

[]{#__RefHeading___Toc26602409 .anchor}R-1. Inadequate Incentives for
Participation in Pre-Clearance Programs

Description of Issue/Problem

Inconvenient enrollment structures and lengthy U.S. pre-primary wait
times for pre-approved traffic have diminished private-sector
participation in pre-clearance programs and reduced program
effectiveness. The U.S. Customs Service has taken a leadership role in
the development or oversight of many incentive programs, which aim to
improve compliance, reduce smuggling and terrorism threats, and enhance
the speed and efficiency of the commercial border-crossing process.
Success of the Border Release Advanced Screening and Selectivity (BRASS)
program, the Carrier Initiative Program (CIP), the privately-run
Business Anti-Smuggling Coalition (BASC), and the Customs Trade
Partnership Against Terrorism (C-TPAT) is contingent upon their ability
to provide tangible benefits to participants.

BRASS is an anti-narcotics smuggling initiative developed to expedite
the release of compliant shipments into the United States from Mexico
and Canada. Certified shippers are not required to pre-file import
documentation or undergo U.S. secondary inspections in most instances.
Freed-up inspection resources focus on unknown shipments and those
requiring a closer examination. In order to qualify for enrollment in
BRASS, Mexican shippers are required to have a 90 percent (or higher)
Customs compliance record over the past year, export a minimum of 50
truckloads to the United States annually, and utilize security-certified
CIP carriers.

BASC is an industry-led program intended to deter the use of commercial
conveyances as a means of narcotics smuggling across international
borders. Participants agree to implement various security measures and
procedures in exchange for more lenient treatment by Customs in the
event that one of their shipment containers or trailers is utilized by
drug traffickers to import contraband into the United States.

C-TPAT is also designed to strengthen supply-chain and border security
by requiring participants to incorporate infrastructure, personnel, and
procedural security elements into their businesses. Like participants in
the BRASS and CIP programs, C-TPAT members receive fewer inspections at
the port of entry and are eligible for consolidated, account-based
processing. Despite an abundance of large shippers and highly repetitive
movements through U.S.-Mexico commercial gateways, BRASS enrollment in
Mexico is small vis-à-vis Canada.

According to the U.S. Customs Service, less than 10 percent of truck
entries on the southern border are BRASS, compared to 60 percent on the
northern border.[^1] Special BRASS lanes have been informally designated
upstream of some U.S. ports of entry to expedite these movements, but it
is still common for certified shipments to be forced behind
non-certified and low-priority traffic on access roads and in border
queues. This problem, combined with the lengthy BRASS certification
process, outweigh the benefits of participation in pre-clearance
initiatives for some firms.

Acknowledging private-sector demands for increased program incentives,
the U.S. government recently merged C-TPAT into a new program, FAST
(Free and Secure Trade program), at the U.S.-Canada border. This program
addresses private-sector demands for increased incentives by
incorporating features such as exclusive truck lanes for program
participants and barcoded ID cards for use by truck drivers.

Alternative

Organize comprehensive incentive programs that provide tangible benefits
to participants, such as queue bypass or expedited processing, thus
increasing the efficiency and security of the border-crossing process.
The requirements of incentive programs should not be so financially or
logistically onerous that they preclude participation by most
candidates. Initiatives must be marketed aggressively by public agencies
and supported with sufficient resources to ensure that program
objectives (including reasonable application processing times) are
achievable.

Creation of a lead agency at U.S. ports of entry would facilitate
coordination among the various stakeholders involved in the development
and launch of improvement initiatives. In the absence of a single lead
border agency, a binational, multi-agency planning structure would help.
Such a structure would foster the development of comprehensive and
worthwhile border initiatives as opposed to many overlapping programs.

Future Needs

First, the potential for reducing traffic congestion at the border
through higher private-sector participation in incentive programs is
significant. Further research could identify new options for inducing
private sector enrollment in these programs and to develop improved
strategies and action plans to achieve this goal.

Second, research to determine whether the remote border clearance and
"fast-lane" initiatives being tested at the U.S. - Canada border could
be implemented between the United States and Mexico and would provide a
basis for creating a more efficient and secure incentive program on the
southern border. Given the emphasis on drug interdiction and other
conditions at the southern border, development of a fast-lane program
may incorporate unique features.

[]{#__RefHeading___Toc26602410 .anchor}C-2. Lack of Data Collection and
Benchmarks

Description of Issue/Problem

One of the principal shortcomings of port of entry planning is the
absence of comprehensive traffic data and port performance monitoring.
Data deficiencies prevent operators, users, and oversight agencies from
understanding whether a given port of entry is functioning effectively
and efficiently. Likewise, the absence of benchmarks prevents the
development of coordinated inter-agency strategies to improve
border-crossing systems.

Numerous data collection efforts provide a better understanding of
truck-borne trade between the United States and Mexico. These efforts
focus on a variety of system characteristics including traffic patterns,
arrival rates, truck types (loaded vs. empty/bobtail), processing rates,
and delay times.

Manual data collection methods have limited many of these studies to
snapshots of select high-volume crossings. Because data collection
efforts normally last only a few days, the reliability of data is
sometimes questionable. The temporary presence of researchers at
border-crossing facilities may encourage border agencies to process
traffic more expeditiously than would otherwise be the case.

Some information on binational truck flows is automatically collected by
bridge operators, public agencies, and private-sector entities through
the scanning of documentation and other means. However, this information
is often not compiled, shared, or made available to the public. There is
currently no single, comprehensive source of data on trans-border truck
movements.

A consequence of the scarce availability of detailed, reliable data is
the lack of performance benchmarks. Problem identification in local
crossing systems is sometimes based on subjective analysis. U.S. port
directors report that the methodology for calculating pre-primary wait
times includes conversations with drivers and "eyeballing" the length of
the truck queue. Sources in the drayage industry dispute the pre-primary
wait times published on the U.S. Customs website, claiming that actual
delays are often much longer.

The underlying causes of border problems and their magnitude relative to
other problems experienced locally or border-wide may remain
undetermined due to data and benchmarking shortfalls.

Alternative

Coordinate public agency technology and resources in Mexico and the
United States to gather, compile, and disseminate data on traffic
characteristics and delay times. Develop a single source for binational
border planning data that can be utilized to establish where and why
border crossing problems exist, what their relative magnitudes are, and
what remedial policies can be introduced to mitigate them.

[]{#__RefHeading___Toc26602411 .anchor}C-3. Inconsistent Planning for
Truck Safety Inspection Facilities

Description of Issue/Problem

The 1993 North American Free Trade Agreement (NAFTA) required the United
States to allow Mexican trucks entry for deliveries and return loads,
first in border states by 1995, and then open entry into the United
States by January 1, 2000.[^2] Former President Clinton, sighting safety
concerns, imposed a moratorium on Mexican trucks beginning December
1995. But a NAFTA arbitration panel ruling in 2001 said the U.S.
moratorium violated the treaty, and President Bush said he would open
the border. Before Mexican trucks can cross into the U.S., the U.S.
Department of Transportation must satisfy that it is now safe for them
and that all safety procedures are in place. The Federal Motor Carrier
Safety Administration (FMCSA) reported that by June 30, 2002, inspection
facilities should meet new federal requirements at 23 of the 25 southern
border crossings.[^3] In a written comment on a recent Inspector
General's report on the safety issue, the Secretary of Transportation,
Norman Mineta, said that he fully expected that the U.S. would be in a
position to certify opening of the border by the summer of 2002.[^4]

Various strategies to maintain truck safety have been proposed at the
southern border. The overall commercial vehicle safety improvement
initiative at the border entailed the hiring and training of 214 new
inspectors and the construction or improvement of physical truck
inspection infrastructure. In Texas, eight truck inspection stations
have been (or are scheduled to be) constructed as close to the POE
facilities as possible. When these are operational, activities within
the federal compound by the FMCSA staff will cease. Other border states
have developed different systems to raise the level of truck inspections
at the border and ensure the safety of Mexican trucks entering the
U.S..[^5]

TransAnalysis, an engineering and planning company in Texas, has
undertaken a simulation of the safety inspection facilities at a number
of sites.[^6] The output of the simulation model includes system impacts
within the locale, the need for new traffic signals, modifying signal
coordination, evaluating geometry, and other related highway impacts.
However, the model does not address either the costs or benefits of
cooperation between those responsible for the safety inspection
facilities and related entities such as GSA, USCS, and the local city
planning entities. Planning and construction of U.S. state vehicle
inspection facilities at the border is being undertaken on a
state-by-state basis with little stakeholder coordination or system
integration within transportation corridors.

The absence of a consistent and far-reaching inspection facility
development and implementation plan has led each state to determine its
own direction and stakeholders to plan in isolation.

Alternative

Symmetry among truck safety inspection facilities is necessary to ensure
that commercial vehicles entering the United States are treated equally
regardless of the gateway through which they pass. A standardized
facility planning process would determine the location and operations of
permanent safety inspection sites along the border and promote greater
coordination with respect to the integration of those facilities into
border-crossing and international trade corridor systems.

There are clear benefits from enhanced stakeholder cooperation and
coordination in the construction and operation of border safety
inspection facilities on the U.S.-Mexico border. First, truck records
can be linked to USCS activities so that each may be aware of the other,
particularly when trucks first enter the USCS facilities. Developing the
records within the safety inspection facilities can lead to the creation
of trip records, which can be accessed after the vehicle has left the
facilities. This may assist police and safety inspection officers
throughout the border state and corridor states through which the truck
is traveling. Finally, there is an opportunity for these records to be
linked to the commercial vehicle operations (CVO) schemes that are
currently being developed by U.S. federal authorities along key trade
corridors. By credentialing these vehicles, it will be possible to hold
a record for the entire length of the trip and provide benefits for both
the users and those enforcing truck safety laws.

[]{#__RefHeading___Toc26602412 .anchor}Demand Management

[]{#__RefHeading___Toc26602413 .anchor}C-4. Lack of Fee-Based Priority
Shipment Lane

Description of Issue/Problem

Time-sensitive shipments are mingled with other traffic types creating a
"one-size-fits-all" border-crossing structure. High-priority, low-risk
cargo that is handled by certified carriers may be delayed in border
queues behind empties and low-priority shipments due to the lack of
expedited crossing alternatives. At some gateways, the organization of
infrastructure and processing systems tends to spread delay evenly among
vehicles regardless of whether they are carrying urgent shipments or
low-value, non-time-sensitive freight. The ability of border
infrastructure and processes to account for heterogeneous truck flows
with varying needs is an important aspect of a coordinated crossing
system.

Alternative

Resolution of one-size-fits-all traffic problems through implementation
of a fee-based priority shipment lane is referred to as "value pricing."
Value pricing differs from congestion pricing in that drivers have the
option to choose between regular facilities (lanes or roads) and
facilities that provide a premium level of service for an extra payment.
Unlike congestion pricing, value pricing does not seek to encourage the
off-peak movement; rather, it provides an opportunity for priority
shipments to circumvent peak-period congestion prior to inspection for a
fee that reflects the value of the premium service.

Although value pricing is usually proposed in connection with the
construction of new infrastructure (lanes, etc.), the main economic
rationale is its potential to improve the utilization of infrastructure.
Value pricing, therefore, takes infrastructure as given so that its
adoption entails the tolling of an existing facility that would
otherwise be unpriced. From this perspective, dedicating a lane for
value pricing means one less lane for regular use. The benefit of value
pricing arises not from a reduction in overall delay but from a more
efficient distribution of the burden of delay, shifting it from
relatively time-sensitive traffic to traffic that can bear delay at
lower cost. The more time-sensitive traffic opts for the fast lane and
experience shorter delays than it would in the absence of value pricing,
while traffic that sticks with the untolled lanes experiences longer
delays.

[]{#__RefHeading___Toc26602414 .anchor}R-2. Lack of Congestion Pricing

Description of Issue/Problem

Lack of congestion pricing may indirectly contribute to congestion and
delays during peak border-crossing periods. As discussed in C-13, a
significant coordination problem at the border is the lack of
complementary stakeholder schedules. For example, schedules in the
trading community may not match the schedules and processing capacity of
the POE inspection agencies. The typical consequence is a peak in the
demand across the day, usually in the afternoons. The processing
capacities of the border inspection agencies are relatively stable
because of constraints on infrastructure and staffing. As a result, the
processing capacity at many POEs is not able to accommodate the daily
peaks in demand and queues form.

Alternative

Collect additional data on traffic and delays to identify when and how
predictably peaks occur. Authorize an increase in fees during peak
periods to mitigate demand with a fee increase justified on the basis of
additional resources necessary to accommodate peak demand. Investigate
likely demand responses to peak-period tolls and, where warranted,
perform cost-benefit analysis of congestion pricing scenarios.

Congestion pricing is a potentially valuable tool to manage demand and
improve productivity and efficiency in the commercial border-crossing
process. Stakeholders that are currently able to disregard costs they
impose on others by crossing during peak periods, such as congestion and
subsequently higher levels of environmental pollution, would be forced
to internalize these costs. This, in turn, may bring about positive
changes in stakeholder procedures and scheduling. Stakeholders that
cross during congested afternoon periods may be enticed to reorganize
their activities to take advantage of cheaper, off-peak periods during
the morning. Drayage firms and independent drivers that frequently cross
empty or without a trailer, a common practice in unidirectional,
multi-shipment drayage contracts, will be encouraged to expend greater
effort in securing backhauls. This will enhance border system
productivity and efficiency. At border crossings that exhibit
particularly consistent hourly traffic patterns and delay times, charges
could be varied according to the level of congestion at a given time of
day. Revenue from congestion pricing could be allocated to initiatives
aimed at further reducing border congestion and delay.

Future Needs

To devise and evaluate a regime of congestion pricing would call for
more data. A clear and complete picture on when delays occur, their
length, and additional data on the predictability of peaks would be
necessary to undertake a congestion pricing feasibility analysis.
Information on the likely demand responses to peak-period tolls would
also aid in the development of appropriate congestion pricing
alternatives at U.S.-Mexico commercial truck crossings.

[]{#__RefHeading___Toc26602415 .anchor}C-5. Commingling of Commercial
Traffic Types

Description of Issue/Problem

Lack of commercial vehicle segregation by risk level, type, or time
sensitivity exacerbates traffic conflicts prior to the U.S. primary
inspection station. Trucks carrying time-sensitive BRASS, maquiladora,
or perishable freight may be funneled into the same queues as trucks
hauling traditional dry freight or empties/bobtails. The mixing of
commercial traffic types with different risk characteristics, priority
levels, and processing requirements is undesirable because it slows the
movement of priority trade and reduces the benefits of expedited
crossing programs for certified low-risk shippers and carriers.

At some ports of entry, the movement of laden vehicles is being choked
off by non-revenue movements. Nearly half of all northbound trucks
crossing the Mexico-U.S. border currently move empty or without a
trailer (Table D-1).

At Otay Mesa, the Laredo World Trade Bridge, and other ports of entry
that process large volumes of truck traffic, authorities have tried to
informally dedicate access lanes to specific truck types such as BRASS,
empties, or traditional trade. The segregation of truck traffic into
homogeneous groups reduces vehicle conflicts, facilitates Customs
processing, and speeds the crossing process for low-risk, priority
shipments. However, many of these arrangements have not achieved their
full potential on account of insufficient traffic monitoring and
enforcement of truck segregation. Drivers seeking the quickest route
across the border frequently enter the shortest queue regardless of
whether they are entitled to be in that lane or not. Other drivers
create traffic jams by using clear lanes to bypass traffic, cutting into
the correct lane immediately prior to the Primary Inspection Module.
Truck drivers working for the same firm allow this practice to continue.

Alternative

Segregate pre-cleared vehicles from traditional trade and
empties/bobtails. Monitor and enforce traffic-type segregation.
Implement latest pre-primary ITS technologies in combination with
driver, vehicle, and shipper databases to aid identification of
high-risk movements and expedite processing of low-risk movements. If
space constraints limit the use of physical barriers to segregate
traffic, compliance with informal lane designation schemes should be

Table D-1. Percent of Northbound Truck Crossings at U.S.-Mexico Border
that Were Loaded, Fiscal Year 2001.

  --------------------------- --------------- --------------- --------------
  **Port of Entry**           **Loaded Truck  **Total Truck   **Percent of
                              Crossings**     Crossings\***   Crossings
                                                              Loaded**

  Port of Laredo, TX¹         769,237         1,419,165       54%

  Port of Otay Mesa , CA      368,428         700,453         53%

  Port of El Paso, TX²        366,677         656,257         56%

  Port of Hidalgo/Pharr, TX³  227,749         367,991         62%

  Port of Calexico East, CA   113,837         259,174         44%

  Port of Brownsville, TX     122,223         255,231         48%

  Port of Nogales, AZ         189,438         251,474         75%

  Port of Eagle Pass, TX      55,567          100,983         55%

  Port of Tecate, CA          31,395          62,243          50%

  Port of Del Rio, TX         39,648          59,286          67%

  Port of San Luis, AZ        21,503          39,908          54%

  Port of Douglas, AZ         17,365          34,054          51%

  Port of Santa Teresa, NM    18,310          30,612          60%

  Port of Rio Grande City, TX 19,037          26,391          72%

  Port of Calexico, CA        4,765           Not Available   Not Available

  Port of Progreso, TX        3,644           16,649          22%

  Port of Roma, TX            6,718           12,141          55%

  Port of Naco, AZ            6,304           9,976           63%

  Port of Presidio, TX        4,526           7,562           60%

  Port of Lukeville, AZ       Not Available   4,271           Not Available

  Port of Columbus, NM        2,995           4,239           71%

  Port of Sasabe, AZ          1,110           2,215           50%

  Port of Andrade, CA         1,127           1,727           65%

  Port of Fabens, TX\*\*      Not Available   147             Not Available

  **Total**                   **2,391,603**   **4,322,149**   **55%**

  \* Loaded and empty/bobtail                 ** **           ** **
  trucks                                                      

  ¹ Includes Laredo World                                      
  Trade Bridge and Colombia                                   
  Solidarity Bridge                                           

  ² Includes Bridge of the                                     
  Americas and                                                
  Ysleta-Zaragoza Bridge                                      

  ³ Includes Veterans                                          
  International Bridge and                                    
  Los Indios Bridge                                           

  \*\* Light trucks only -                                     
  not a full-service                                          
  commercial crossing                                         
  --------------------------- --------------- --------------- --------------

Source: U.S. Customs Service

closely monitored and enforced by authorities. This will prevent
inspection delays that apply to certain traffic types from adversely
affecting entire commercial flows at the border. Where practicable,
bypass lanes through/around ports of entry should be provided for trucks
not selected for detailed inspections.

Future Needs

In order to determine the full magnitude of the empty/bobtail problem at
the U.S.-Mexico border, detailed data on southbound loaded and empty
movements must also be captured. Unfortunately, the Mexican agencies
that might collect such data (Customs - SHCP, the Federal Road and
Bridge Authority -- CAPUFE, and the National Institute of Statistics,
Geography and Informatics -- INEGI) do not archive this information or
are unwilling to share it with the public. An effort to combine data
collected by Mexican public agencies and private border bridge and
roadway operating authorities should be undertaken. This will enable a
much clearer understanding of traffic mixing problems and potential
solutions.

[]{#__RefHeading___Toc26602416 .anchor}Physical Layout and Truck
Movement

[]{#__RefHeading___Toc26602417 .anchor}C-6. POE Configuration -- New
Inspection Technologies Cannot be Accommodated

Description of Problem or Issue

Most border stations were built to accomplish specific missions and lack
flexibility and adaptability. New technologies and procedures have
changed the way inspections are performed. For instance, the advent NII
technology has rendered a significant portion of the loading dock
capacity at some U.S. land ports obsolete. Traditional layouts cannot
provide the space and symmetry needed for new inspection technologies
because there is not enough land to accommodate efficient linear
processes.

Alternative

Assess operational value of current POE design and evaluate options for
retrofitting and reconfiguring facilities to accommodate changes in
technological capabilities, POE demands, and updated processing
techniques. Discontinue initiatives, such as the construction of
additional secondary dock space, if more efficient non-intrusive
inspection options exist. Continue to acquire land adjacent to
extra-urban POE facilities to ensure future space availability for port
development and expansion.

[]{#__RefHeading___Toc26602418 .anchor}R-3. POE Configuration --
Outdated Facility Layouts

Description of Problem or Issue

The layouts of border stations have evolved over the life of the
facility, reflecting changing missions and practices. Most ports of
entry are inefficiently configured for optimum throughput, safety, and
security. Squeezing more activities into the limited confines of some
land ports on the U.S.-Mexico border has resulted in the creation of a
hazardous environment for inspection personnel. Tijuana-Otay Mesa is an
example of a border-crossing system with lane configurations that do not
provide sufficient room for inspectors to move safely around the
vehicles to perform pre-primary inspections. Other ports of entry lack
isolated and properly equipped areas to conduct hazardous materials
inspections.

Alternative

Restructure POE layouts to provide the flexibility necessary to properly
accommodate manual inspection activities and Customs processes. Widen
POE access lanes and provide adequate, isolated hazardous materials
inspection sites at designated ports of entry. Include all U.S. and
Mexican public-sector agencies in the planning and design of future
border crossings.

[]{#__RefHeading___Toc26602419 .anchor}C-7. POE Configuration -- Poor
Internal POE Circulation

Description of Issue/Problem

The combination of current processes and layouts produce internal POE
circulation problems that include traffic conflicts between cleared and
uncleared trucks. Some of these problems have arisen due to a larger
number of vehicles being inspected at secondary stations than was
previously possible. High-volume secondary inspection stations situated
close together have generated considerable traffic flow problems within
ports of entry.

Security concerns have also arisen due to inadequate regulation of
cleared and uncleared traffic circulation within U.S. ports of entry.
Anecdotal reports of forged inspector signatures and the illegal
exchange of documentation between cleared and uncleared vehicles at
secondary inspection waiting areas underscores the need for improved,
more tightly regulated POE traffic circulation schemes.

Alternative

Redesign POE circulation to prevent uncleared trucks from exiting POEs
unlawfully, and reduce traffic conflicts between cleared vehicles and
those awaiting inspection.

[]{#__RefHeading___Toc26602420 .anchor}R-4. Capacity -- Number of
Primary Inspection Booths

Description of Issue/Problem

Some POEs lack a sufficient number of primary inspection booths due to
severe space constraints. The Nogales, Arizona, port of entry is an
example of a facility that has insufficient physical capacity to handle
daily traffic volumes. Operation of all primary booths cannot
efficiently accommodate demand at this port throughout most of the day.
Demand for additional primary inspection booths could also increase
sharply at El Paso if plans to close the El Paso-BOTA facility to laden
truck traffic are implemented.

Alternative

Explore opportunities to expand the number of primary inspection booths
where required/feasible. Improvements to port layouts, operations and
vehicle tracking, and changes in peak arrival characteristics through
improved incentive planning may provide some relief to capacity
constraints. In some cases, acquiring land to expand the number of
primary booths may be the only option.

[]{#__RefHeading___Toc26602421 .anchor}C-8. Capacity -- Inspection
Sequencing

Description of Issue/Problem

There are untapped opportunities for border agencies to inspect vehicles
while they are in the queue for U.S. primary inspection. Peak-period
truck queues at U.S. Primary Inspection Modules are nearly ubiquitous at
major commercial ports of entry along the southern border. Normally, the
arrival rate of northbound trucks at the border steadily increases
throughout the morning. As vehicles exit the Mexican Export Compound,
they proceed onto the border roadway or bridge. The U.S. primary
inspection station is typically the greatest constraint in the crossing
system. Consequently, this is one of the first areas at which queues and
congestion form. Depending on the gateway and the time of crossing,
queues may be encountered immediately after the Mexican export facility
or as the truck approaches the U.S. primary inspection area. The time
spent by vehicles waiting in lines upstream of U.S. primary inspection
stations represents one of the largest segments of unproductive "dead
time" in the U.S.-Mexico border-crossing system.

Alternative

Various inspection activities typically carried out within the port of
entry could be conducted in advance of the Primary Inspection Module
where traffic and conditions permit. Assess the potential to reduce idle
wait time, alleviate congestion, and improve security in the border
crossing process through the transfer of canine drug inspections, driver
interviews, vehicle revisions, document reviews, and weigh-in-motion
screening activities to pre-primary vehicle queuing areas. Enable these
activities to be collapsed when congestion and queue length are
insufficient to justify them.

[]{#__RefHeading___Toc26602422 .anchor}C-9. Capacity -- Uncoordinated
Access Road Design and Limited Number of Lanes

Description of Problem/Issue

Uncoordinated access road design and a limited number of lanes cause
cross-border traffic to interfere with local vehicular movement on roads
near border crossings. Urban and geographical features confine the
number of access lanes leading to Nogales, El Paso-BOTA, and other U.S.
ports of entry. In the border cities of Tijuana, Ciudad Juárez, and
Reynosa, access roads to Mexican export facilities have been enveloped
by urban sprawl. The length and width of these roadways are insufficient
to handle present volumes of peak-period truck traffic. Access
bottlenecks in Mexico commonly produce truck queues that back up onto
adjacent roadways, disrupting traffic circulation in surrounding
communities.

Although a new highway leading to the Colombia-Laredo border crossing is
now complete, dangerous road conditions deterred carriers from utilizing
that uncongested crossing for years. Similarly, the absence of a
northern paved access route along the border from Ciudad Juárez to the
San Jerónimo-Santa Teresa border crossing has impeded a redistribution
of truck traffic from the congested BOTA and Ysleta facilities to that
gateway.

The length and width of the actual crossing infrastructure connecting
Mexican and U.S. commercial compounds is another access consideration
affecting border capacity. Delays at the U.S. Primary Inspection Module
occasionally produce queues that extend into Mexico. Where insufficient
queuing capacity exists, congestion clogs the Mexican export facility.
These problems are compounded by incongruent U.S. and Mexican border
facility layouts that require large commercial vehicles to negotiate
tight turns and steep grades.

Alternative

The extent to which access road design and capacity disrupt cross-border
trade flows depends on a combination of factors including the location
of the crossing, the volume of truck traffic, and the capacity of other
components in the system. Opportunities exist to better coordinate
access road and port designs binationally and within each nation. Use
the Metropolitan Planning Organization (MPO) planning processes to
integrate border station and city planning needs.

[]{#__RefHeading___Toc26602423 .anchor}C-10. Lack of ITS Solutions to
Streamline Truck Movements

Description of Issue/Problem

Existing processes at the border are time consuming, resource intensive,
and contribute to redundant information verification. The prevailing
crossing process at most commercial gateways between the United States
and Mexico requires a truck to stop several times within and around
border compounds. Delays are imposed for toll collection, Customs risk
assessment, inspections, document verification, vehicle weight checks,
and other reasons. The manual processes used to carry out these tasks
are time consuming and resource intensive.

Currently, trucks cross the border and normally stop behind other
vehicles waiting to be examined at the U.S. Primary Inspection Module.
As vehicles are processed at primary inspection (usually a 1-2 minute
procedure), the queue slowly advances, creating stop-start engine
cycles. If cleared at primary, the truck makes its way through the port
of entry, stopping again at the exit booth to ensure that all paperwork
has been checked and the vehicle is cleared to proceed into the United
States.

If a vehicle is sent to secondary, it may be required to stop a number
of times (for canine drug screening, a gamma ray or X-ray scan, vehicle
safety inspection, HazMat inspection, or manual cargo or conveyance
inspection at a loading dock). These steps are sequential in that a
vehicle can be cleared at any time and as it moves through the process.
The time taken at each step becomes successively longer, culminating
with a dock inspection if necessary. In an extreme case, it may take
several hours for a vehicle to be thoroughly checked and processed
through the U.S. port of entry.

New U.S. DOT regulations now require that vehicle safety inspections be
undertaken near the border. The U.S. congress has passed legislation
mandating that all trucks entering the United States meet state and
federal laws, and those whose trips are beyond the traditional
commercial zone receive even greater scrutiny. However, once
familiarization with Mexican companies and vehicles grows, vehicle
safety inspections should fall to meet those rates for all state
vehicles. Not to do this would be to follow a profiling policy, which is
prohibited under NAFTA.

Alternative

Develop ITS capabilities at the border that are interconnected with
Commercial Vehicle Operations (CVO) improvements and technology
initiatives along transportation corridors. ITS systems that minimize
delays for safe, legitimate trade should incorporate the electronic
transmission of pre-qualified information on the driver, tractor,
trailer, and cargo. Existing Dedicated Short-Range Communication (DSRC)
technology can be employed to transmit this information as the vehicle
approaches the border crossing, allowing sufficient time for public
agencies to determine which, if any, inspections are required. ITS
technologies, such as automated toll collection, variable messaging
signs, and weigh-in-motion scales, are additional traffic management
instruments that can be leveraged to streamline and expedite the
border-crossing process for legitimate trade.

The benefits to be gained from reducing multiple stops are three-fold.
First, fuel consumption will improve, which will lower vehicle operating
costs for truckers. Second, transit times through the facilities would
be improved, and this would impact both truck productivity and possibly
improve supply chain efficiency at the border. This may have associated
benefits in terms of production processes, just in time deliveries, and
the necessity to store or hold material in border warehouses. Finally,
reducing speed cycle changes at low-level engine revolutions will
improve emissions and promote a healthier environment for personnel
working in the facilities. As noted, further stops maybe necessary at
vehicle inspection stations adjacent to ports of entry.

Work to incorporate vehicle/trade links in ACE so that DPS data at
vehicle safety inspection stations can be developed as part of the new
POE systems. Coordination with the FHWA and U.S. State DOTs along NAFTA
transportation corridors should be undertaken to develop a credentialing
system that spans the entire supply chain.

In principle, inspection efficiency should remain the aim of all future
border crossings, and coordination should be structured to ensure that
all inspection duties can be carried out within expedited crossing
systems. In reality, some interim steps will need to be implemented at
border ports of entry to move from the current system to a one- or
no-stop system.

[]{#__RefHeading___Toc26602424 .anchor}Staff Management

[]{#__RefHeading___Toc26602425 .anchor}C-11. Personnel Turnover -- USCS
Inspector Attrition Rates Are High

Description of Issue/Problem

In the United States, voluntary attrition among public sector employees
has created human resource challenges for agencies such as U.S. Customs.
Customs inspectors are reportedly recruited from offices around the
country to work at the southern border. Senior officials report that
many new inspectors are unprepared to work the long hours and overtime
that are, today, common among Customs employees. Inspectors who are
trained to work as U.S. Customs agents quickly move on to more lucrative
jobs within the agency or elsewhere in government. Openings created as a
result of new government initiatives, such as the FAA's "Sky Marshall"
program, have drawn recently recruited agents away from the U.S. Customs
Service.

The extreme heat, vehicle exhaust, and difficult working conditions
prevalent at the U.S-Mexico border are additional factors cited as
contributors to inspector burn out. High rates of turnover among agents
at the USCS compromise agency resources, staff training levels, and
overall border planning and operations.

Alternative

Establish a long-term plan to equalize agency compensation and reduce
attrition rates due to unprepared trainees.

[]{#__RefHeading___Toc26602426 .anchor}R-5. Insufficient Customs
Personnel

Description of Issue/Problem

U.S. Customs staffing levels are often too low to take full advantage of
available NII technology. The two most common NII technologies currently
employed on the southern border are the gamma ray VACIS and the truck
X-ray. NII equipment scans the contents of tractors and trailers,
reducing the need for time-consuming and expensive manual inspections.
In the past, the National Guard has helped eased the staffing burden of
operating NII equipment, but this was never envisioned as a permanent
solution. Some U.S. port directors have indicated that they occasionally
have to shut down NII equipment on account of not having sufficient
staff to operate it. In other cases, trucks must wait in long queues at
NII stations or undergo alternate inspections that may be more time
consuming.

Alternative

NII-related deficiencies should be addressed through the provision of
specific funding for NII technology and equipment operators in
coordinated equipment/personnel implementation plans. Such plans will
require a reassessment of investment strategies and infrastructure
designs at U.S. ports of entry to ensure optimization of inspection
resources. Greater reliance on NII technologies in concert with the
deployment of advanced information systems will result in reduced
congestion and delay at U.S. ports of entry, lower levels of contraband
smuggling on commercial conveyances, and enhanced inspection efficiency,
capacity, and interdiction capability. In cases where physical space
limitations constrain the ability to add needed NII equipment, POE
retrofitting and reconfiguration should be considered.

[]{#__RefHeading___Toc26602427 .anchor}C-12. No Mechanism to Predict and
Prevent Queue Development

Description of Issue/Problem

Primary inspection capacity is partially determined by the availability
of personnel to perform required inspection activities. Fixed primary
inspection staffing schedules prevent the opening of additional primary
booths as soon as demand warrants. In some cases, a sufficient number of
primary inspection booths exist, but staffing is not sufficiently
responsive to preclude queue development. At large ports of entry,
primary staffing levels are normally tiered according to demand. For
example, a third of the available primary gates may be open during the
early morning hours, approximately two- thirds of the booths are staffed
throughout the mid morning, and all booths are generally operated during
the peak period from around noon until the evening hours.

However, regimented staffing schemes are unable to respond promptly to
variable traffic demands. Afternoon Customs shift changes are
particularly problematic because they can result in vehicles remaining
unattended within the port of entry for half an hour or longer. In other
instances, pre-primary queues have been observed to build to dozens of
vehicles before additional inspectors are assigned to primary
inspection. The lack of flexibility and responsiveness on behalf of
Customs in opening primary inspection booths and rapidly and seamlessly
executing shift changes contributes to delays for northbound commercial
vehicles. High truck arrival rates overwhelm constant (or temporarily
reduced) port capacity and promote the formation of queues that often
take significant periods of time to dissolve after additional personnel
have been added.

Alternative

Improving the responsiveness of primary booth staffing schemes and
reducing processing times during shift changes are two alternatives for
increasing capacity and lessening delays in the border-crossing process.
Implement an arrival-rate monitoring device upstream of primary
inspection to provide port authorities with advanced information on
impending queue development. This technology, coupled with enhanced
Customs staffing flexibility and responsiveness, would enable port
managers to make informed, real-time personnel decisions to speed the
crossing process.

Future Needs

In order to determine the extent of staffing responsiveness problems at
U.S. POEs, on-site observation or detailed POE operations records and
traffic data are required. Information currently available on primary
inspection wait times and staffing schedules is subjective, and
comprised of daily AM and PM snapshots of delay times rather than the
continuums that are necessary for meaningful analysis. Development of a
standardized wait-time monitoring system at southern border crossings
would facilitate and improve collection of this data. Maintenance of
U.S. Customs staffing records is also required to determine the level of
congestion generated by sub-optimal staffing transitions.

[]{#__RefHeading___Toc26602428 .anchor}R-6. Personnel Turnover --
Mexican Customs' Rotation of Port Directors

Description of Issue/Problem

There are frequent personnel changes within public agencies at the
U.S.-Mexico border. This disrupts domestic and binational planning,
operations, and coordination initiatives. The continual replacement of
Mexican port directors is a major component of this problem. Many port
directors have been fired or transferred after less than one year on the
job. This practice is likely associated with the Mexican federal
government's new anti-corruption initiative championed by President Fox.
In 2001, 44 of 47 Mexican Customs directors were dismissed along with 43
mid-level Customs officials and all 50 leaders of the Customs Police
Force.[^7]

U.S. port directors have indicated that the constant adjustment to new
port management in Mexico is complicated by changing rules and
regulations. Occasionally, new rules contradict effective agreements and
procedures that were developed over long periods and through extensive
consultation with previous administrators. Examples of such disruptions
include the discontinuation of extended evening hours at Mexican and
U.S. ports of entry, coordination problems regarding Mexican and U.S.
holiday schedules, and reduced or cancelled binational port initiatives.

Alternative

Establish a binational public-agency communication accord to minimize
conflicts caused by changes in Mexican Customs personnel.

[]{#__RefHeading___Toc26602429 .anchor}Stakeholder Coordination

[]{#__RefHeading___Toc26602430 .anchor}C-13. Poorly Coordinated
Stakeholder Schedules

Description of Issue/Problem

The differing schedules of public- and private-sector stakeholders in
the border-crossing process partially dictate daily commercial traffic
patterns at U.S.-Mexico border crossings. The differing operational
schedules of individual stakeholders and the time requirements for
completion of their activities result in a crossing window that is
substantially narrower than the daily hours of service offered at border
facilities. This is especially true at busy commercial crossings where
delays due to congestion can be lengthy or difficult to predict. Loaded
truck movements from Mexico to the United States are generally
concentrated between midday and the late afternoon-early evening hours.
Daily traffic peaks frequently result in the complete saturation of
border facilities during these periods and the availability of excess
capacity at other times. This demand pattern is a major contributor to
congestion at many ports of entry along the U.S. southern border.

By virtue of their role as an information conduit between Customs and
the privatesector, customs brokers exercise a large degree of control
over the timing of trans-border movements. The broker industry has been
criticized for contributing to peak-period congestion at the U.S.-Mexico
border by not beginning the documentation preparation and transmission
process earlier in the morning and, thereby, removing some of the
peak-period strain on public resources. The broker community contends
that the specific drayage information they require for completion of
their responsibilities is not available until the shipment is ready to
cross the border and that broker cycle times are generally too short to
justify pre-preparation of documentation.

The USDA's schedule for grading northbound produce at the port of
Nogales, Arizona, is an example of a public-sector scheduling practice
that contributes to a demand-capacity mismatch at the border.
Agricultural shipments that require grading to be sold on the U.S.
market are sent to special Mexican border facilities where they are
assessed and certified by USDA graders prior to importation into the
United States. Although the Nogales port of entry opens to commercial
traffic at 7 a.m., USDA employees do not typically reach the Mexican
grading facilities and begin grading activities until 9 a.m.. As a
result, many shipments are prevented from crossing the border during
early off-peak hours. By the time agricultural loads have been graded
and cleared, delays at the U.S. Primary Inspection Module are often
excessive. FDA staffing shortages at ports of entry along the southern
border are also reported to significantly constrain crossing windows for
shipments governed by that agency.

As the initiators of cross-border movements, shipper schedules play an
important role in determining when a load crosses the border. This is
especially true in the case of border zone maquiladoras operating
just-in-time inventory systems. Maquiladora factories in Ciudad Juárez,
Coahuila, and Tijuana, account for a sizeable portion of northbound
movements through commercial gateways in these regions. Maquiladora
plants normally load directly onto the truck to maintain low, inventory
carrying costs. Production runs initiated early in the day may not turn
out a finished product until midmorning. Additional delays associated
with loading the trailer and documenting the shipment prevent many
northbound loads from crossing the border until after 10 a.m.
Uncoordinated stakeholder schedules produce a peak demand trend that is
clearly visible in a random five-day sampling of laden truck movements
through the Otay Mesa port of entry (Figure D-1). By not coordinating
their activities, stakeholders in consecutive segments of the system
squander excess morning and late evening border capacity and aggravate
peak-period congestion.

![](media/image1.wmf)

Figure D-1. Hourly Arrival of Laden Trucks at the Otay Mesa POE
(02/11/02-02/15/02)

Source: Otay Mesa Port of Entry

Alternative

Organize public- and private-sector consultation to facilitate
identification of scheduling problems and enable adjustments that smooth
POE demand and reduced border congestion and delay. More broadly
distributed demand for port of entry services could be achieved if USDA
graders and customs brokers began their work earlier in the day and
shippers coordinated their production and shipping schedules to take
advantage of off-peak periods. Increased FDA funding would enable that
agency to bring its inspection schedules in line with those of other
agencies at major ports of entry.

[]{#__RefHeading___Toc26602431 .anchor}C-14. Inadequate Informal
Stakeholder Coordination

Description of Issue/Problem

Stakeholder practices are often carried out in isolation without regard
to their impacts on system efficiency. The physical movement of goods
across the U.S.-Mexico border is contingent upon the timely and accurate
transmission of information. Shipment data is exchanged among
private-sector supply chain partners via fax, email, Electronic Data
Interchange (EDI), or other means. Typically, the Mexican exporter
communicates cargo information to one or two parties (i.e., U.S.
consignee, Mexican customs broker, or U.S. customs broker) that
subsequently distribute it among other stakeholders on a need-to-know
basis. Some shippers rely on a customs broker in one country to arrange
broker services in the other. If these arrangements are not made in
advance and clearly communicated to the appropriate parties, delays will
result. Another common source of disruptions in U.S.-Mexico supply
chains is the transmission of incomplete or inaccurate information by
the shipper. If the customs broker does not receive the proper
information before the shipment arrives at the border, scheduled
crossings may have to be pushed back.

Most delays due to poor private-sector coordination occur with
infrequent shippers who lack established relationships with their
Mexican or U.S. customs brokers. These exporters may be unfamiliar with
the crossing process and transmit information that is incomplete,
incorrect, or late. In rare cases, documentation errors are not
discovered until the shipment reaches the U.S. port of entry, at which
time correction can be costly and potentially result in the impoundment
or confiscation of the conveyance and merchandise.

Broker delays may be the result of slow cycle times or infrequent
document delivery to the border. Two key documents prepared by customs
brokers are the Mexican Export Pedimento and U.S. Inward Cargo Manifest.
A driver and shipment may be forced to wait at the border if this
paperwork is not quickly processed and delivered. Some brokers
indirectly contribute to border delays by not providing precise
instructions or educating their clients with respect to required
documentation.

Poor broker-carrier coordination is another potential impediment to
crossing efficiency. Transfer of a trailer from a long-haul trucking
firm to a drayage carrier (and vice versa) may entail a short or long
delay, depending on the degree of communication and coordination that
exists between these stakeholders. If the long-haul carrier does not
expeditiously inform the broker of a shipment's arrival at the border,
the load may be forced to cross the border during the most congested
period. Similarly, the agility of the drayage carrier in responding to
service requests by brokers and long-haul firms is an important factor
in the timing and speed of the crossing process.

Poor communication between the public- and private-sector stakeholders
precludes border efficiency in some instances. Shippers using gateways
where traffic volumes vary on a daily basis complain that there is no
accurate source of real-time information on the length of truck queues
at U.S. primary inspection. Such information could be used by the
private sector to better match shipping schedules with available
capacity at the port of entry.

Alternative

Establish a forum for definition and resolution of stakeholder
coordination problems. Provide Web broadcasting of monthly U.S. customs
broker community meetings to facilitate dissemination of port operations
information among all interest groups. Provide Web broadcasting of truck
queue lengths to facilitate off-peak scheduling for discretionary
shippers.

The expansion of port meetings to all stakeholders in the supply chain
would increase awareness and accountability in the border-crossing
process and facilitate resolution of problems resulting from the lack of
informal stakeholder coordination. Port meetings address issues
affecting port operations and are held at large U.S. commercial ports of
entry on a monthly basis. Currently, these consultations are generally
limited to the U.S. Customs port director and the members of the customs
broker community. Utilization of Web broadcasting technology or other
communication resources could make these meetings available to other key
stakeholders such as shippers and carriers. Given that stakeholder
awareness and communication are major causes of border congestion and
delay, this alternative could potentially have a significant positive
impact on border operations. Real-time Web broadcasting of truck queue
lengths at ports of entry would also assist the trade community in
avoiding peak traffic periods at U.S.-Mexico gateways.

[]{#__RefHeading___Toc26602432 .anchor}C-15. Untapped Opportunities to
Enhance Broker Process

Description of Issue/Problem

Mexican law requires that a licensed Mexican Customs broker prepare and
submit all documentation for cargo entering or leaving that country. As
a result, Mexican Customs brokers have assumed a significant degree of
control over the border-crossing process. Many of these companies also
own border drayage firms, U.S. customs brokers, freight forwarding
agencies, and warehouses. Where modern technology and practices have not
been leveraged, the provision of services, such as freight
classification, stevedoring, drayage, and warehousing, may involve
delays and expense that are at cross-purposes with system efficiency. A
more streamlined crossing process may not be in the financial interest
of some brokers, especially for those whose clients are far-removed from
the border and do not view the status quo import/export system as
particularly problematic.

Alternative

Automated crossing programs and a shipper/consignee education campaign
on efficient crossing procedures would help familiarize supply-chain
partners with broker activities and services, and expedite shipments
across the border. Web broadcasting of monthly broker-port director
meetings could also enhance private-sector understanding of problems
contributing to crossing inefficiency.

[]{#__RefHeading___Toc26602433 .anchor}Standards

[]{#__RefHeading___Toc26602434 .anchor}C-16. Absence of Standardized
Seal Notation Protocol

Description of Issue/Problem

The lack of a standardized procedure for documenting trailer and
container seal numbers creates security vulnerabilities and delays in
the border-crossing process. In order to ensure that cargo is not
tampered with between the shipper's premises and the border crossing,
special seals are applied to the container or trailer door. Once the
seal has been applied, the door cannot be opened without breaking the
seal.

For northbound shipments that are subject to inspection by Mexican
Customs prior to proceeding to the U.S port of entry (Mexican Export
Inspections), original seals are replaced. There is no standardized
protocol for documenting the replacement of these seals. Inspector
signatures, stamps, or other forms of authorization may accompany the
new seal number. This regulatory gap often causes U.S. Customs agents at
primary inspection booths to view shipments that have had their seals
replaced in Mexico with skepticism. These shipments are frequently
directed to U.S. secondary inspections. In the absence of a binational
protocol governing the sealing and resealing of trailers and containers,
authorities cannot determine whether conveyances have been illegally
tampered with or opened for legitimate inspection purposes.

Alternative

Develop and implement a binational agreement on the procedure for
documenting container and trailer seal numbers for shipments moving
between Mexico and the United States. Such an agreement would enhance
border security and minimize delays due to the unnecessary examination
of shipments with replaced seals. Explore opportunities to incorporate
this initiative into the development of new regulations governing the
physical properties of trailer and container seals.

[]{#__RefHeading___Toc26602435 .anchor}C-17. Lack of Harmonized Truck
Safety Standards

Description of Issue/Problem

Different commercial vehicle size, weight, and safety standards in the
U.S., Canada, and Mexico complicate inspection and enforcement
activities at the border.

Alternative

An existing NAFTA mechanism--the Land Transportation Standards
Subcommittee (LTSS)--is charged with addressing the harmonization of
North American trucking standards. With the opening of the border, the
LTSS should revitalize its efforts to coordinate with transportation
authorities in Mexican, U.S., and Canadian jurisdictions to establish a
simplified NAFTA safety protocol for commercial vehicles.

[]{#__RefHeading___Toc26602436 .anchor}Information Management

[]{#__RefHeading___Toc26602437 .anchor}C-18. Information Systems --
Excessive Paperwork Preparation and Handling

Description of Issue/Problem

Some northbound border-crossing processes still rely on repetitive and
manual paperwork preparation and submission. Currently, the Mexican
Export Pedimento, U.S. Inward Cargo Manifest, and Mexican and U.S. bills
of lading must be produced in hard-copy format. Repetitive document
processing increases the potential for data entry errors, and adds cost,
time, and additional steps to the border-crossing process.

The pedimento is usually not prepared by the Mexican broker until the
shipment arrives at the border. Although shipment classification and
documentation preparation tasks are not normally problematic, hard
copies must be submitted to the truck that hauls the shipment across the
border. Many brokers employ "runners" to deliver documentation to trucks
waiting on roadsides at or near the Mexican export compound. Delays
attributable to the preparation and delivery of these documents force
some trucks to cross the border during peak, rather than off-peak,
periods.

Other inefficiencies associated with the continued use of paper
documents include the duplication of data entry activities by various
stakeholders. For example, preparation and submission of U.S. entry
information involves processes similar to what occurs in Mexico for
export movements (Harmonized Tariff Code classification numbers in the
U.S. are two digits longer). Each time data is re-entered to generate
required paperwork, the risk of information corruption increases. Public
and private-sector modernization has begun to alleviate this problem in
recent years, but port directors report that shipments are still
routinely detained at border crossings due to paperwork problems.

The USDA's and FDA's lack of connectivity to the Customs Service's
Automated Commercial System at some ports of entry is a critical
coordination shortfall that has exacerbated manual processes at these
locales. This is a critical problem for the USDA at the Nogales border
crossing where brokers must prepare and submit stacks of paper
documentation each morning in order to qualify for the expedited Border
Cargo Release (BCR) program. USDA agents must then sift through the
documentation manually to determine which shipments require inspection.
In spite of the increased use of electronic filing of U.S. entry
information, paperwork and document handling remains an important part
of the border-crossing process and a significant contributor to
congestion and delay.

Alternative

The use of a shared, internet-based information system accessible to
authorized stakeholders-as envisioned under the Automated Commercial
Environment (ACE) and International Trade Data System (ITDS)
programs--would reduce the time, cost and coordination requirements of
the border-crossing process. Implementation of a paperless Mexican
Export system (similar to the U.S. Export Declaration process),
harmonization of U.S. and Mexican Tariff Code reporting requirements,
and development of a joint documentation validation system would further
streamline the movement of international trade.

[]{#__RefHeading___Toc26602438 .anchor}C-19. Information Systems --
Antiquated Technology

Description of Issue/Problem

Information systems utilized by some public-sector agencies are outdated
and incompatible with one another and those used by the private sector.
This hampers efficient stakeholder communication and information-sharing
efforts and prolongs the use of duplicate and manual transaction
systems.

The main entry documentation system used by the U.S. Customs Service is
the Automated Commercial System (ACS). This system was developed in the
1970s to provide an electronic link between U.S. customs brokers and the
U.S. Customs Service via a link called the Automated Broker Interface
(ABI). The purpose of the ACS and ABI was to facilitate the transmission
of information to Customs so that agents could assess the need to
inspect a shipment before it arrived at the border. While originally
successful in achieving this goal, the systems have since become
outdated and plagued by intermittent failures. Sporadic "brown outs"
prevent Customs from electronically confirming receipt-of-entry
information which, in turn, disrupts the flow of commercial traffic from
Mexico to the United States.

Key U.S. agencies involved in the inspection of inbound freight do not
have access to these systems at some ports of entry. For example, the
USDA and the FDA still solicit hard-copy documents from the trade
community for lack of connectivity to the ABI and ACS. Public-sector
sources report that the USCS' ACS interface, the FDA's Operational and
Administrative System for Import Support (OASIS), and other public
agency information systems are outdated, incompatible, unstable, and are
not capable of handling additional user loads.

Mexican Customs has its own computer system, the SAAI (Sistema de
Automatización Aduanera Integral) that it uses to communicate with
Mexican Customs brokers. While this system is more advanced than those
employed by U.S. public agencies, it can only be accessed via the
Mexican Customs Broker Association and does not replace the need for
paper transactions. Several U.S. ports of entry are currently developing
stand-alone systems that provide basic information about the driver and
conveyance that is not currently available through other electronic
means. While these systems may prove valuable on an interim basis, a
more comprehensive, long-term solution to trade information management
is needed.

Toll collection is another segment of the border-crossing process
requiring modernization. With the exception of some gateways outside of
Texas, most major commercial border crossings are tolled. Diverse
charging mechanisms have been implemented to collect crossing fees.
These range from cash, tokens, and tickets to account payment. While a
transponder payment system similar to electronic toll collection on
freeways is now offered for commercial vehicles at Laredo and other
crossings, most trucks are still required to manually pay tolls before
proceeding across the border. Manual driver identification and visa
verification processes necessitate additional stops within the
commercial compound. While some of these delays do not presently create
bottlenecks in the system, removing or diminishing surrounding
constraints could result in their becoming points of congestion.

Alternative

A single, fully integrated information system such as that proposed
under ACE is needed to modernize and simplify the border-crossing
process and improve stakeholder coordination within the United States
and binationally. A system that ties together all stakeholders and
disseminates information on a need-to-know basis could drastically
reduce data input requirements and stakeholder transactions while
protecting information privacy and reducing data corruption. Promotion
of standardized trade data requirements and the development of
universally compatible technologies (i.e., interoperable transponders
and compatible processing systems) for use by stakeholders throughout
the supply chain will substantially diminish border delays stemming from
data preparation, submission, and analysis.

[]{#__RefHeading___Toc26602439 .anchor}C-20. No Advanced Threat
Detection

Description of Issue/Problem

Most border stations have limited ability to identify and contain
security threats at a safe distance from inspection personnel and
facilities. The lack of a binational threat detection/response
capability is a critical border security and coordination weakness.

Alternative

Explore opportunities to expand intelligence sharing among U.S. and
Mexican agencies. Deployment of detection equipment along approach roads
distant from the inspection facility could significantly reduce the
threats to personnel and facilities and speed the crossing process.
Develop a binational contingency plan to deal with threats or attacks at
U.S.-Mexico land border crossings.

[]{#__RefHeading___Toc26602440 .anchor}References

[^1]: "Border Release Advanced Screening and Selectivity" U.S. Customs
    Service presentation. Office of Trade Programs, Cargo Release
    Branch, U.S. Customs Service, March 4, 2002.

[^2]: "North American Free Trade Agreement." Washington D.C.: U.S.
    Government Printing Office, 1993.

[^3]: Federal Motor Carrier Safety Administration. *Implementation of
    Commercial Vehicle Safety Requirements at the U.S.-Mexico Border*.
    USDOT Report MH-2002-094. Washington DC: U.S. Department of
    Transportation, 25 June, 2002.

[^4]: Mineta, N. Written comments concerning USDOT Report MH-2002-094.

[^5]: Mineta, N. Testimony before joint Senate committee examining the
    opening of the southern border, U.S. Congress, Washington, D.C.,
    July 27, 2002.

[^6]: TransAnalysis. Simulation of Border Safety Inspection Facilities
    at TxDOT's Pharr District Bridges. San Antonio, Texas:
    TransAnalysis, January 2002.

[^7]: McCosh, D. "Mexican Customs cleans house again," *Journal of
    Commerce Online*, May 3, 2001.