The trade community has been hearing that the Advanced Commuting Environment is coming, or “ACE is coming,” for 22 years now and it seems ACE will become a reality on November 1, 2015, regardless of whether system is ready to perform or not.
    A Feb. 2014 Executive Order has mandated the use of ACE and the government agencies are scrambling to make that deadline.
     Within the past few years, CBP has begun the use of agile development to drop functionality sections of the ACE programming into production and software vendors have been making constant updates, changes, and procedures to their systems to meet the new requirements.
     The average importer has no idea what struggles the logistics and software firms have had trying to adapt to a fluid program in just a few months, sometimes weeks. And lest we forget, the government agencies themselves are struggling to learn new programs, processes, and procedures.
     In the past year we have seen some significant drops in ACE and some significant debacles, too. For example, May 1, 2015, was the mandatory date for filing all manifest in ACE. Ocean (ACE M1) dropped with little disruption sometime back. However, when the Air ACE manifest was released in June, there was major disruption in the trade community. Some brokers reported, “With the crash of the ACE Air Manifest system, we have a number of air shipments that were not released for more than 3 days. Where should we tell our clients to submit their claim for storage charges incurred because of the ACE Air Manifest failure?” CBP had tested for months but did not anticipate the numerous filings that would be received after the pilot ended (with, by the way, only 9 participants allowed in an initial pilot). Individual U.S. Customs Ports were issuing Port Pipelines on how to handle the releases and brokers were caught up in the need to contact individual ports for how to handle release of cargo, as well as having to negotiate with each carrier for the storage incurred.
     The November 1, 2015, mandate for processing all entries in ACE seems virtually unreal considering the over 20 entry types that can be filed; ACE currently only accepts types 01, 03, 11, 51, and 52. Currently there are 5 PGA’s (Participating Government Agencies) underway in ACE—keep in mind there are approximately 48 agencies that have regulatory authority in international trade matters.
     Just last week, CBP sent this message:

CSMS# 15-000622 - ACE Cargo Release Processing Errors
ACE Cargo Release experienced processing errors affecting Cargo Release Status Notifications (SO messaging) and release postings to manifest from Friday afternoon, August 21, 2015, through Tuesday morning, August 25, 2015. CBP is working to resolve all of these transactions.

     That amounts to 5 days… can you say storage?  And who pays?  You and me, the consumer—that’s who will absorb these costs.
     One broker wrote:
    “West Coast was having issues too. We have tried Bill of lading updates, Queries and now we are running into storage, so will be forced to cancel the entries and try again!
    “And remember when I said they would blow up the Entry Docs required on RLF entries? Well, we are 50-50. Half of all RLF entries we have filed have gone entry docs required and are taking 1-2 days (instead of 1-2 hours) to release! (and we previously had 100 percent paperless releases since we submitted AII with the RLF entry).
     “But wait, there’s more. How about these PGA guidelines (450 pages for FDA, 100 pages for NHTSA)—who is reading all of that? Scary!
    “No way I can see the November deadline staying in place.
    “OK, I’m done!”
     Letters have been written from COAC, TSN, and others to CBP Commissioner Kerlikowske with copy to White House representatives Christine Turner, director, Global Supply Chain Security, National Security Council; Jeff Weiss, chairman, Border Interagency Executive Council (BIEC); Alan Bersin, assistant secretary (Acting), Department of Homeland Security; Alejandro Mayorkas, deputy secretary, Department of Homeland Security; Timothy Skud, deputy assistant secretary for Tax, Trade and Tariff Policy), U.S. Department of the Treasury; Christa Brzozowski, counselor to the Deputy Secretary, Department of Homeland Security stating in part “the TLC is convinced that the plan for mandatory use of ACE/ITDS for all entry summaries and cargo release transactions, including the new PGA message sets, on November 1, 2015, is premature. Adherence to this deadline threatens to compromise the investments made by the government and the private sector and to disrupt commerce between the United States and the rest of the world. A misstep by the United States with respect to the implementation of a single window will set back similar efforts in other areas of the world. We are concerned that proceeding with the November 1, 2015, deadline will result in unwarranted expense and disruption for both the Trade and the U.S. Government and will harm future and ongoing efforts to continue the development of ACE/ITDS.”
     ACE has tremendous abilities, but needs to be implemented in a way that will not disrupt U.S. trade or result in enormous additional costs associated with it during the implementation stages.
     Stay tuned… there is a Race for ACE in our future and includes ACE export requirements. We’ll see.
Donna M. Mullins

    Editors Note: Donna Mullins is president of Alpha Sun International, based in Atlanta, Georgia, USA.
    Donna, who by any measure is both professional and concerned, serves the community in the air cargo business as a stalwart member of The Atlanta Air Cargo Association at Hartsfield – Jackson International Airport.
    The great thing about this wonderful lady is that making extra efforts for clients and community are all part of a day’s work for her.
    But rather than put the spotlight on herself and her company, she gladly advances everybody.
     “Too often in the air cargo business we don’t realize what is required to bring items, including animals, into the U.S. and that you can be as large as a Delta or Lufthansa, or you can be as small as an Alpha Sun International or New Vision Transportation and play an integral part in the supply chain,” Donna once told me.
    We often forget how far down the trail dedicated and decent air cargo people like Donna have brought our business.
    Thanks.
Geoffrey