The Canada Border Services Agency (CBSA) is responsible for border management that contributes to the safety and security of Canada and facilitates the flow of persons and goods. The Agency exercises a risk-based approach to border management to detect and intercept dangerous travellers and goods, and to facilitate the movement of low-risk persons and goods.
The purpose of this evaluation is to review the pre-arrival targeting activities the Agency uses to identify potential high-risk [ 1 ] travellers and goods in the marine, rail and air modes of transportation and to propose recommendations for improvement. This evaluation addresses four key areas: relevance, design and delivery, success in preventing the entry of and intercepting dangerous persons and goods, and associated costs.
This evaluation looked at pre-arrival information on travellers [ 2 ] en route to Canada by air, sea and rail. Airlines provide the data collected in their reservation and departure systems directly to the CBSA. The PAXIS system risk-assesses this passenger and crew information. The National Risk Assessment Centre (NRAC), regional Passenger Targeting Units (PTUs) and Passenger Analysis Units (PAUs) share responsibility for targeting air travellers. NRAC reviews incoming air travellers whom PAXIS identifies as reaching at least one national security threat threshold. PTUs/PAUs review flight manifests for contraband and other threats. Marine Passenger Analysis Units and/or Vessel Targeting Units assess travellers arriving by cruise ship and/or commercial vessel. Regional targeters and border services officers (BSOs) use the information provided by carriers to assess travellers arriving by passenger train.
If someone is identified as a potential threat, the targeter issues a "lookout [ 3 ] " in one of the CBSA systems indicating that the person should be intercepted upon arrival and referred to secondary processing for further examination by a BSO.
On the goods side, the CBSA receives advance commercial information (ACI) for all marine vessels and aircraft destined to arrive at a port in Canada. Preliminary systems process the data before TITAN risk-scores and transmits them to targeters for review. Like the targeting of air travellers, marine targeting is divided by risk level. NRAC looks for threats to national security (e.g. weapons of mass destruction, radioactive materials), while regional targeters focus on contraband, environmental contaminants (e.g. pine beetles, chemicals) and other threats. Joint Targeting Initiative officers risk-assess marine containers arriving in the United States and destined for Canada (by rail or truck). In the air mode of transportation, the regional Air Cargo Targeting Unit reviews all goods arriving in the Greater Toronto Area for potential threats, while NRAC is responsible for air cargo arriving at all remaining airports. The Winfall project handles the targeting of goods arriving by rail.
If a suspicious shipment is identified, a "lookout" is issued in a CBSA or other system and the item is examined either prior to loading or upon arrival depending on the mode and nature of the threat.
The CBSA's Evaluation Division conducted this evaluation as per the CBSA Risk-Based Multi-Year Evaluation Plan, 2006-2007. The then-Internal Audit and Evaluation Committee approved the terms of reference for this evaluation in June 2006. The research for this evaluation was conducted between September 2006 and August 2007. The evaluation used the following methodologies:
Overall, this evaluation found that the CBSA has a number of pre-arrival targeting components in place (e.g. NRAC regional targeting units, supporting systems), and that the major systems developed for pre-arrival targeting are sound and reliable. However, there are specific systems whose efficiency and user-friendliness could be improved.
Over the past few years, the Agency has received more advance information for people and goods arriving by the air and marine modes of transportation. This report found that the use of Administrative Monetary Penalties (AMPs) for the non-submission of data, as well as other outreach activities with clients resulted in a significant increase in compliance by air carriers, and similar approaches in other modes could be beneficial to the CBSA.
There are specific areas in which improvements to data collection, analysis and monitoring could be made, such as the better documentation of referrals and results of all secondary examinations, and the institution of a system to randomly select goods for examination. These measures, among others, would help the effectiveness of targeting by identifying and intercepting high-risk travellers and goods.
The CBSA continues to work toward fully integrating the operations and staff of its legacy agencies. [ 4 ] This evaluation found that many targeters bring with them a wealth of experience from the front line and other assignments. With time and effort, improvements to the overall leadership of the targeting function and the communication of standard protocols, procedures and training will strengthen the efficacy and efficiency of pre-arrival targeting.
Pre-arrival targeting is a critical component of the CBSA's risk-management approach. The CBSA spends approximately $62 million annually on these activities. [ 5 ] Without pre-arrival targeting to identify high-risk goods and travellers, the movement of people and goods would be greatly delayed by more intensive scrutiny at primary inspection lines, and would incur an enormous cost to the Agency and its clients (e.g. importers, exporters, airlines). It is the opinion of the evaluators that the pre-arrival targeting function is well positioned to achieve its expected results, but that it has not yet realized its full potential.
Recommendation 1: Consider creating a cohesive targeting program, with appropriate resources, coordinated by a single functional authority.
Recommendation 2: Strengthen an integrated approach for pre-arrival targeting that includes both centralized and regionalized components.
Recommendation 3: Take steps to improve the advance data provided by commercial stakeholders on both travellers and goods.
Recommendation 4: Develop and implement approaches to move further toward the 100% pre-arrival risk assessment of marine and air commercial shipments, and travellers to Canada, against cost-benefit considerations.
Recommendation 5: Continue to refine aspects of the automated targeting systems to improve the accuracy and efficiency of pre-arrival targeting.
Recommendation 6: Transition the risk assessment activities of the Winfall project and the Joint Targeting Initiative to the next phase of the ACI initiative (the eManifest initiative).
Ensuring the security of Canadian citizens and fostering a healthy economy are ongoing concerns. The mission of the Canada Border Services Agency (CBSA) [ 6 ] is to "ensure the security and prosperity of Canada by managing the access of people and goods to and from Canada." [ 7 ] The CBSA attempts to balance intercepting potential risks without excessively impinging on the movements of bona fide travellers and trade crossing the border by land, air and sea.
In fiscal year 2006-2007, the CBSA processed more than 95 million travellers arriving by highway, air, sea and rail--or 260,300 travellers entering Canada per day. [ 8 ] The CBSA admitted more than 2 million marine containers (twenty-foot equivalent units, or TEUs) in fiscal year 2005-2006. More than two million air cargo manifests were risk-assessed in 2006-2007.
The CBSA has approximately 13,000 employees, including 7,200 uniformed border services officers (BSOs). The Agency manages 119 land border crossings and 13 international airports. CBSA officers carry out marine operations at
24 ports of entry, marinas and reporting stations. CBSA officers also carry out rail operations at 3 international crossings for passenger rail and 24 crossings for goods arriving by train. [ 9 ] In 2006-2007, officers cleared 351,080 passenger planes, 5,525 cargo planes and 186,192 marine vessels. [ 10 ]
Targeting is an approach for identifying potentially high-risk travellers and goods for examination. The CBSA's targeting activities are multi-faceted, multi-dimensional and embedded in virtually every area of the organization. They involve the scrutiny of goods, people, food, plants and animals entering and exiting the country by different modes of transportation. They take place in land, air, marine, postal and courier environments. Goods and people can be targeted before they come to Canada, upon arrival, and in some cases, post-arrival.
Targeting is an approach for identifying threats that are both known and unknown. Known threats are identified when there is a match against an enforcement database. Unknown threats are identified using knowledge of previous patterns and related indicators to uncover illicit activities.
The CBSA's Evaluation Division conducted this evaluation as per the CBSA Risk-Based Multi-Year Evaluation Plan, 2006-2007. The then-Internal Audit and Evaluation Committee approved the terms of reference for this evaluation in June 2006. The evaluation was conducted between September 2006 and August 2007.
This evaluation addresses four key areas of the CBSA's pre-arrival targeting activities: relevance, design and delivery, success in preventing the entry of and intercepting dangerous persons and goods, and associated costs.
In preparation for this evaluation, the evaluation team, in consultation with key stakeholders, developed a logic model for the pre-arrival targeting function, around which the evaluation plan was developed. The immediate objectives of pre-arrival targeting are the following:
The intermediate objectives of pre-arrival targeting are the following:
This evaluation focused on targeting activities involving the use of pre-arrival or advance information. Table 1 shows what areas are included in and excluded from this evaluation.
|Included in the Evaluation||Excluded from the Evaluation|
The evaluation used the following qualitative and quantitative lines of evidence to investigate pre-arrival targeting activities:
Table 2 provides a summary of the key evaluation questions pursued.
|Evaluation Issue||Evaluation Question|
|Program design and delivery||To what extent is the structure for managing, coordinating and delivering the pre-arrival targeting function effective?|
|To what extent is the CBSA developing and maintaining a sufficient pre-arrival targeting capacity?|
|To what extent are effective performance measurement systems in place for the pre-arrival targeting function?|
|How effective are the channels of communication for managing and delivering the pre-arrival targeting function?|
|How effective is the CBSA in collaborating and partnering with U.S. CBP?|
|Success||To what extent is the advance information provided by private sector partners complete, accurate, useful and timely?|
|To what extent are the API/PNR, ACI and supporting systems in place and reliable?|
|To what extent do the API/PNR, ACI and supporting systems contribute to the effectiveness of pre-arrival targeting?|
|How effective are the PAXIS and TITAN algorithms?|
|How effective are the targeting activities for the identification of high-risk travellers and goods?|
|What is the impact of pre-arrival targeting activities on the deterrence of terrorism and border criminality?|
|How do the results achieved through targeting using advance information compare with the results achieved through other means?|
|How do the CBSA's targeting results compare with those of other countries? Are there more effective alternative methods?|
|Were there unexpected results? What impact(s) did these results have on the targeting function?|
|Relevance||To what extent are the targeting activities consistent with CBSA and government-wide priorities?|
|Are there new or other threats against which targeting using advance information should/could be used?|
|Cost-effectiveness and efficiency||To what extent do the targeting activities make the best use of resources?|
CBSA targeting activities are circumscribed by a number of laws, regulations and guidelines. [ 11 ]
Immigration and Refugee Protection Act (IRPA) regulations state that commercial transporters must provide advance passenger information for each person carried. [ 12 ] These regulations apply to the air, marine and rail modes of transportation.
The API/PNR program for air travellers was implemented in October 2002 [ 13 ] to protect Canadians by identifying high-risk air travellers before they reach Canada's border. Airlines collect API/PNR information when a traveller books a flight and upon check-in. [ 14 ] API data include full name, date of birth, gender, citizenship or nationality, travel document type and number (e.g. passport, visa), and country of issue. PNR data consist of travel reservation and departure (check-in) information (such as ticketing information, baggage information and seat number). There are 25 PNR fields approved for use in Canada. [ 15 ] By law, airlines must submit all of the API and PNR data they collect.
Implemented in 2002, the PAXIS system collates and assigns a risk score to arriving passenger and crew based on API/PNR information. In 2006, PAXIS risk-assessed approximately 96% of air travellers. The targeting of air travellers is shared between NRAC and regional units.
Initiated in January 2004, NRAC operates 24/7 primarily to conduct pre-arrival assessments of air travellers, and air and marine cargo. NRAC is also the primary point of contact with U.S. CBP for the Canada/U.S. Smart Border High-Risk Traveller Identification (HRTI) initiative. NRAC targeters review air travellers that PAXIS flags as reaching or exceeding one or more of the "national security" risk thresholds to determine if they pose a threat.
Implemented in 2004, [ 16 ] PTU/PAUs assess entire flight manifests for Canada's eight largest international airports. [ 17 ] PTU targeters specialize in customs-related targeting, looking for individuals smuggling drugs or other contraband. PAU targeters review the same flights to detect immigration-related infractions, such as people smuggling and the production and use of counterfeit documents.
"From a PAU point of view, officers must know their region's particular clientele, and be able to communicate and work fast with the specialty BSO teams. Officers must know how to interpret the systems they use and have a very good knowledge of trends regarding illegal migration, human smuggling, which travel docs are the tools "of choice" for smugglers…must be on top of intelligence information... must have an excellent relationship with airline personnel, front-line experience, and daily exchange with those working PIL." - Targeter surveyed
Targeters review the passenger and/or crew manifest and match the information against customs, immigration or law enforcement databases, and/or other information sources. If someone is identified as a potential threat, the targeter issues a "lookout" in one of the CBSA systems indicating that the person should be referred to secondary processing for further examination by a BSO.
Ports can request API on the passengers and crew of incoming commercial vessels and cruise ships. Targeting is handled by VTUs or by MPAUs in large ports (such as Halifax and Vancouver). [ 18 ] In smaller ports, BSOs carry out this function.
Cross-border rail carriers submit API to the CBSA. All three ports of arrival pre-screen passenger manifests. In two locations, if a passenger warrants further review, the officers conduct a secondary examination on-board the train. In the third location, there is a separate area for secondary examinations off the train.
Table 3 summarizes the type and timing of information submitted to the CBSA relating to travellers by mode of transportation.
|Air - crew and passengers||API/PNR||Data must be provided upon takeoff or within 15 minutes of arrival in Canada. (Mandatory)|
|Marine - crew of commercial vessels||API from the crew manifest||As far in advance as possible, a minimum of 7 days prior to arrival (updated at the last port of departure before Canada). (Mandatory)|
|Marine - crew and passengers of cruise ships||API from passenger and crew manifests||As far in advance as possible, a minimum of 96 hours prior to arrival (updated at the last port of departure before Canada). (Upon request)|
|Rail - crew||Rail crew report||At least 2 hours prior to arrival at the port of entry. (Upon request)|
|Rail - passengers||API from passenger manifest||Information provided upon departure from the last station prior to arrival in Canada. (Upon request)|
|Bus||API||If requested, information provided upon departure from the last station prior to arrival in Canada. (Upon request)|
Under ACI, [ 19 ] marine and air carriers must transmit marine/air conveyance reports and marine/air cargo reports (including supplementary cargo reports) for all vessels and aircraft loaded with commercial goods destined for Canada. This applies to all import, in-transit and freight remaining on board shipments. Targeters use these data to search for health, safety and security threats before the vessels or aircraft arrive in Canada.
ACI passes through two system validations. First, the Customs Electronic Commerce Platform (CECP), which allows importers, brokers, carriers, freight forwarders and warehouse operators to exchange information electronically with the CBSA and scans the reports to ensure that the mandatory fields are filled out. Once complete, the reports are transmitted to the Accelerated Commercial Release Operations Support System (ACROSS), which scans the reports for errors and sends out acknowledgement messages to carriers. If there is a problem with a report, carriers receive a rejection notice and must provide additional information. ACROSS then transmits the data to TITAN, the Agency's automated risk-scoring mechanism for goods arriving by air or sea.
NRAC and MCTUs (located in Halifax, Montréal and Vancouver) share the targeting of commercial goods arriving by marine vessel. NRAC targeters review the risk scores and ACI of each shipment, and conduct an in-depth assessment of the shipments identified by TITAN as posing a potential national security threat. If they identify a suspicious shipment, they may issue a "do not load" or "do not unload" order and the cargo is examined (either in a foreign port or upon arrival depending on the nature of the threat).
MCTUs review cargo manifests against law enforcement, customs and other databases, local trade chain traffic patterns and other sources, looking for potential Tier II threats, such as contraband smuggling, forged goods and weapons. If they identify a potential threat, they refer the shipment for examination by BSOs upon arrival.
As part of the Canada/U.S. Smart Border Declaration, [ 20 ] JTI targeters located in the ports of Newark, NJ, and Seattle, WA, review marine containers arriving at U.S. ports destined for Canada (by rail or truck). U.S. CBP assesses all shipments for national security threats, while JTI targeters concentrate on identifying contraband smuggling. If JTI targeters wish to refer a container for examination, they submit a formal request to U.S. authorities to conduct the examination at the port of entry. NRAC assumed management of day-to-day JTI operations in November 2005.
Under the current air cargo [ 21 ] pilot project, the ACTU assesses goods arriving at Toronto Pearson International Airport destined for the GTA, while NRAC reviews all air cargo arriving at all other Canadian airports. Both units operate 24/7. Targeters cross-reference suspicious cargo against TITAN, ACROSS and other databases and sources. If they find a suspicious shipment, they issue a target in TITAN and ACROSS, and a BSO examines the shipment upon arrival.
Carriers provide data on their vessels directly to the CBSA (electronically or by fax). There are vessel targeters in Vancouver, Halifax, Montréal, Quebec City and the GTA, which summarize and cross-reference information on all inbound vessels to their ports against Canadian and international marine databases. Vessel referrals are printed out and faxed to the appropriate dock teams for action. The Marine Automated Vessel Information System [ 22 ] , or equivalent systems, house all action reports in which BSOs input examination details. This information can be reviewed later for analytical purposes or for assessing a vessel again in the future.
Winfall targeters focus on inbound rail shipments originating in the United States and Mexico. Billing information is rich and available to targeters as soon as a booking is confirmed, which can be as much as two weeks prior to transport. The targeting team also has access to information on empty cars, and can track containers anywhere in North America on all major railroads. If targeters identify a potential threat, they issue a target and contact the closest marine examination facility to examine it.
Table 4 provides a summary of the type and timing of data available for the pre-arrival assessment of incoming goods in the air, marine and rail modes of transportation.
|Air cargo||ACI||4 hours prior to departure at a foreign port or after "wheels up" if the flight is shorter than 4 hours in duration|
|Marine - vessel and cargo (landing in Canada)||ACI [ 23 ]||Vessel - 24 to 96 hours prior to arrival
Cargo - 24 hours prior to loading cargo at a foreign port
|Marine - cargo destined for Canada landing in the United States (JTI)||ACI||Cargo - 24 hours prior to loading cargo at a foreign port (submitted to U.S. CBP)|
|Rail - Winfall||Rail data||Upon arrival, although it can be available up to two weeks in advance.|
Pre-arrival targeting is part of the expanding worldwide security net.
The pre-arrival targeting of travellers and goods by the CBSA fits within the larger global security continuum of systems and processes to deter, detect, intercept and detain dangerous goods and persons while facilitating the movement of legitimate travellers and trade. Ports around the globe are busy. According to the World Tourism Organization, there were 846 million tourist arrivals worldwide in 2006, up 43 million from the previous year. Also, on any given day around the world, more than 15 million containers are moving by vessel, truck or train. [ 24 ]
The measure of a port's success is its ability to move cargo and travellers in and out as quickly as possible. As such, in addition to Canada and the United States, other countries use risk-management systems and processes to screen and release people and goods rapidly while ensuring safety and security.
Targeting contributes to fulfilling Canada's international agreements and obligations.
Canada is party to a number of trade, prosperity and security initiatives. As a member of the World Customs Organization (WCO), Canada does its part to improve the efficiency and security of international trade. The WCO recently highlighted the importance of building the capacity of member countries to detect and intercept dangerous goods. A survey of Asia-Pacific member countries indicated that eight of nine respondents [ 26 ] employ an "automated risk-management system to standardize the identification and targeting of potentially high-risk shipments and the communication of results."
Targeting also contributes to Canada's commitment to the Security and Prosperity Partnership of North America. At the Montebello Summit in August 2007, Canada, the United States and Mexico agreed to the following:
Targeting supports the mandate and mission of the CBSA and other federal departments.
The mandate of the CBSA is to "provide integrated border services that support national security and public safety priorities and facilitate the free flow of persons and goods, including animals and plants that meet all requirements under the program legislation." [ 28 ] Pre-arrival targeting initiatives such as API/PNR and ACI help the CBSA manage potential risk in a timely way.
Automated systems are strategic risk-management and workload-management tools necessary to process a considerable volume of goods and traveller information within a limited time frame.
Automated tools make it possible to sort the growing volume of travellers and goods coming to Canada, by perceived level of risk, in an expedient way. This is particularly important for travellers and goods arriving by air when time frames are short. If the CBSA had to physically examine every person, package or container arriving in Canada, the cross-border movement of goods and people would halt. In the United States, it is estimated that "it takes five agents three hours to completely inspect a fully loaded forty-foot cargo container… On an average day, 18,000 containers are off-loaded at the ports of Los Angeles and Long Beach. Based on this figure, unloading and inspecting each container would translate into 270,000 man-hours per day." [ 29 ] In Canada, the manual inspection of all incoming marine containers would require 84,246 man-hours per day or 11,232 BSOs working every day.
Pre-arrival targeting compliments other risk assessment approaches.
Pre-arrival targeting relies heavily on the validity of the electronic information provided by carriers, shippers, freight forwarders and importers. Targeters have little time to ascertain the legitimacy of businesses, and they do not have a personal relationship with importers or ongoing communication to clarify the information provided. As such, real-time targeting, random examinations, stints and border checks are important complementary activities to pre-arrival targeting.
The automated systems used in pre-arrival targeting are reactive tools. Therefore, it is a challenge to anticipate and respond to emerging threats in a timely fashion.
The recent melamine contamination of wheat gluten, soy proteins, corn glutens and rice proteins from China [ 23 ] highlights the importance of identifying and interdicting threats before they enter Canada's trade chain. Intellectual property crimes are also garnering greater attention. The Standing Committee on Public Safety and National Security found that the products of intellectual property crime (i.e. counterfeit goods ranging from clothes to pharmaceuticals) appear to be "exposing Canadians to increasing economic and safety risks." [ 31 ] However, current automated pre-arrival systems and processes could identify and intercept these threats if the description of goods (including harmonized system (HS) codes and dunnage) [ 32 ] provided by the carriers is accurate. If this information is flawed or missing, the systems cannot identify the goods for further examination.
Similarly, there is growing concern regarding the potential health risks posed by incoming travellers to Canada, such as Ebola, SARS and virulent tuberculosis, and an increasing need to identify and intercept these travellers. However, when dealing with travellers, human rights and privacy implications also need to be weighed against increased security measures.
The inherent limitation of automated systems is that to be aware of a threat, and then to incorporate this information into the systems takes time. However, targeters obtain oral and/or written updates and alerts from intelligence and other sources that can help them to better assess the data they receive and respond to new issues quickly.
Several components of targeting have been in place for a number of years; however, the pre-arrival targeting function still lacks a single lead to coordinate and monitor the various activities involved.
The CBSA has a number of pre-arrival targeting components in place such as NRAC, automated risk assessment tools (such as PAXIS, TITAN) and expanded regional targeting units.
Many interviewees, including senior management, felt that the roles and responsibilities associated with targeting were generally understood, especially for their individual areas/units. However, targeting at the CBSA has grown; interviews and site visits show that there is a need for a more formal structure to manage the function as a whole. This expansion is related to the integration of legacy agencies such as the Canadian Food Inspection Agency (which is responsible for responding to food, plant and animal risks), the expansion of targeting into other modes (such as air cargo) and increasing support functions to facilitate targeting activities (e.g. information technology). Evaluators found several out-of-date internal documents outlining employees' roles and responsibilities with respect to targeting. Sources cited a number of additional Standard Operating Procedures (SOPs) associated with targeting developed prior to 2000; however, evaluators were unable to secure and verify the content of these documents. As such, there is a need for clearer management structures, coordination, updated policies and procedures [ 33 ] to better manage the targeting function.
The structure of and support to targeting units varies considerably, which has an impact on the efficiency of targeting.
The composition of each targeting unit is not uniform. While the 2004 PAU Action Plan outlines the rationale, benefits of and steps for merging immigration and customs officials under the CBSA, all PTUs/PAUs are still not fully integrated, and food, plant and animal officers are rarely involved.
The mission of the Intelligence Directorate is to identify threats and to support the CBSA, other government departments, and domestic and international partners. In this capacity, HQ intelligence personnel provide products for all targeters, including lookouts, watch-fors and enforcement bulletins. Regional intelligence officers (RIOs) provide immediate advice as needed on how to proceed with specific lookouts or targets, and they can use their databases and networks to search for additional information for a targeter/analyst.
However, this evaluation found widespread variation in the level and type of communication between targeters and intelligence personnel depending on the unit. Over two thirds (69.9%) of targeters surveyed, in units with an RIO, found this arrangement to be helpful to their work. Currently, steps are being taken to increase the collaboration of HQ intelligence and NRAC targeters.
In the absence of one formal functional authority for targeting, the Future of Risk Management Working Group (FRMWG) was formed to integrate the targeting activities of the legacy organizations.
Established in 2004, the FRMWG looks at targeting-related issues across the CBSA with the goal of integrating the components of legacy groups. The FRMWG was tasked with reviewing the requirements, benefits and impacts associated with a centralized versus a regionalized targeting approach. However, over the past three years, this group's activities were redirected to the many immediate operational issues surrounding targeting (e.g. the implementation of automated systems, the enhancement of communications, the gauging and understanding of the progress achieved by the targeting function and the establishment of a pilot project to compare centralized and regionalized targeting approaches).
In spite of emerging issues to contend with, the group made progress in important areas. In addition to monitoring the GTA air cargo pilot project, the group provides a forum for management (from the regions and HQ) to share views and identify current and future issues influencing the efficiency and effectiveness of targeting.
In June 2007, the CBSA formed the Risk Management and Targeting Director General Steering Committee to develop and track a risk-management and action plan to address issues involving the targeting function. However, the targeting function entails a contingent of responsibilities and activities equivalent to those of a program, and neither this committee nor the FRMWG can substitute the single functional authority required to manage such a program.
The concept of "national security" versus other threats is not clearly defined or understood.
Any illegal activity may be a portal to more dangerous ones (e.g. pornography or money laundering are often linked to international organized crime). However, without a clear definition of what constitutes a "national security threat," it is difficult for targeters to identify one.
In principle, NRAC is responsible for identifying national security threats and regional units target other types of threats; however, at times these units overlap. In many ways this is inevitable. More or less the same methodology is used to search for a high-risk people smuggler, cargo contraband carrier or potential terrorist. In each case, targeters use their tools, techniques and intelligence to look for "things that just don't look right," and then continue searching to reveal the specific threat.
A strong national pre-arrival targeting program can include and benefit from both centralized and regionalized components.
The GTA air cargo pilot project was implemented to compare the results between centralized and regionalized targeting approaches. Although the comparison of the results of centralized targeting (e.g. at NRAC for all international airports excluding the GTA) and regionalized (e.g. the ACTU for the GTA) is not yet complete, it is clear that using an integrated centralized and regionalized approach can enhance targeting.
The evaluation shows that targeters in regional targeting units make significant contributions to the pre-arrival targeting of travellers and goods. Regional targeters draw from local knowledge [ 34 ] to identify factors that don't fit and act as triggers for further analysis that may not be perceived by others.
NRAC operations constitute one form of centralized targeting in which targeters are located in the National Capital Region but are responsible for various ports of entry (POEs) nationally. Since implementation, NRAC targeters have uncovered a wide range of seizures (e.g. diamonds, chemical precursors). This evaluation found that centralized targeting contributes to the effectiveness of the program, and could be further strengthened by building upon proximity to other resources (i.e. CBSA HQ, other government departments and agencies).
Staffing continues to be a challenge for the CBSA.
The changing demographics of the public service will impact the CBSA, and it is expected that a sizeable proportion of BSOs and targeters will be retiring in the coming years. As such, a key challenge for the CBSA is to develop and retain skilled and experienced targeters while balancing other staffing needs.
"One of the obstacles for effective targeting is the steep learning curve for targeters because there are many systems that one has to learn to use. Experience as a BSO provides targeters with a familiarity/knowledge of the majority of names, places and companies in the region. In targeting, a computer system does not do the analysis, people do. A computer only provides the information. A system like TITAN helps to shorten the learning curve. It takes one to two years to be a consistently good targeter, to develop good instincts for the unusual." - Regional interviewee
The Agency relies heavily on on-the-job training techniques such as job shadowing.
With the exception of NRAC [ 35 ] and the PTU/PAU in the GTA, the delivery of standardized training on how to target high-risk travellers and goods is limited. [ 36 ] More than a decade ago, formal targeting training was provided to commercial marine targeters, but not to targeters focusing on other modes of transportation. In the absence of a national standardized training program, some units developed and delivered internal training to meet their needs, and most relied upon existing reference materials for the automated systems and job shadowing. Job shadowing can be a valuable method for guiding new targeters through the process, especially if new targeters are partnered with experienced targeters. This enhances the understanding of "how to target."
According to the Human Resources Branch, their staff's expertise in developing curriculum and delivering training has not been used for targeter training. [ 37 ] The Enforcement Branch recently asked the Human Resources Branch to catalogue enforcement training products but not to assess the training needs of targeters and learning/knowledge gaps or propose any product development and training plan. Better coordination of training will improve the consistency of targeting.
To be a good targeter, you need...
"1) Previous life experience, including interest in and knowledge of commerce, trade patterns, geography…2) Complete and thorough understanding of the marine business with an emphasis on local knowledge… 3) Thorough understanding of risk assessment with attention to indicators." - Targeter surveyed
"1) Complete training prior to beginning targeting functions and job shadowing for new targeters to absorb and apply the training tools. Training should include job tools and the philosophy of targeting. 2) Years of experience on the job and diversified background of targeters. 3) Excellent communication between intelligence, examiners, investigators, targeters, other departments and NRAC." - Targeter surveyed
There are few professional development opportunities for targeters to learn, share and network.
The limited amount of training for targeters is a reflection of the lack of recognition of the increasingly important role of targeting. Site visits and survey results confirm that there are few, if any, opportunities for professional development and networking (e.g. no national targeting conferences and few opportunities to attend related law enforcement courses, conferences and meetings). The sharing of best practices is currently limited to interpersonal relationships within units.
Certain units, such as NRAC, have developed a Results-Based Management and Accountability Framework (RMAF) identifying key activities, outputs and intended outcomes. NRAC produces monthly and annual reports on its activities and outcomes.
The Consolidated Management and Reporting System draws information from TITAN, ACROSS, PAXIS and other CBSA databases to facilitate the collection, use and reporting of information. A majority of targeters (80%) believe that access to the results of their targets improves the effectiveness of their targeting activities as a self-learning cycle.
"The CBSA would be much better off if we started off with some real expectations and goals that are clearly measurable… Are we tracking the number of hits we get for the number we are tracking? No. We don't roll any of this up into a senior level management report. We need to establish baselines."What's working or not? Against what?" We need more FACTS. Right now there is only general analysis. It is very raw data, which provides the number of air cargo reports received in the regions. The CBSA needs to get some sense of the volumetrics involved with targeting and what they mean to us." - Senior management interviewee
Numerous "feedback loops" could enhance targeting.
The success of targeting is tied to the activities performed and information gathered by staff from diverse areas of the CBSA. Targeters need ongoing communication with the Innovation, Science and Technology Branch (ISTB) personnel responsible for systems such as PAXIS and TITAN. BSOs need to know why certain persons or goods are referred for examination, and targeters need to know the results of those examinations. Targeters and intelligence personnel work on information from different angles but for the same goal. From a risk-management perspective, the information gathered from activities such as examinations and stints can provide valuable baseline data. Specifically, these data can ascertain that travellers and commercial shipments considered low risk by PAXIS and TITAN are not involved in illegal activity. In addition, these data can reveal emerging trends and assist in the continuing improvement of targeting systems and processes. Each piece contributes to the larger picture.
Communication within the various groups that comprise the targeting function is working well; however, communication between the units and HQ could be improved.
Interviews with stakeholders revealed that communication within the individual areas (e.g. branches, regions, NRAC) is working well. Observations during site visits confirm that targeters take advantage of the open-office environment for ongoing interaction with other targeters, and often with managers and RIOs. The survey of targeters found that 74.8% of respondents are very satisfied/satisfied with communications with their immediate supervisor, and 86.3% are very satisfied/satisfied with communications with other targeters in their unit.
However, this evaluation found that awareness about the other areas involved in targeting was much less clear. There are various communications policies and practices in place, such as regular cross-branch meetings scheduled to discuss information technology issues, e-mail bulletins about system fixes from the ISTB, and generic e-mail boxes to facilitate the flow of communication across other units. However, site visits and interviews confirmed that many targeters would rather contact a former colleague or acquaintance for information (even if they were not in the appropriate area) rather than use these formal mechanisms. Recently, units have taken steps to improve communication with each other.
"Officers in the secondary areas tend to have a negative view of what we do in the PAU/PTU. They feel that we have created extra work for them, not realizing that the percentage of referrals that we initiate is very small in comparison to PIL referrals of non-PTU/PAU passengers. They appear to resent having to complete general information on the Field Operations Support Systems (FOSS) when exams are non-resultant. There is a general misunderstanding, it appears, of the importance or purpose of our work." - Targeter surveyed
JTI targeters are an important part of the "net" of border security activities.
The Canada-U.S. Joint In-transit Container Targeting at Seaports initiative has two objectives: to achieve maximum effectiveness in identifying high-risk containers at the first point of arrival in North America, and to share important law enforcement information from both sides of the border through an exchange of officers.
Under action point #18 of the Smart Border Declaration, CBSA officers are stationed at U.S. seaports while U.S. CBP officers are stationed at Canadian seaports. By working together, Canada and the United States can improve container inspection by jointly targeting marine in-transit containers that arrive in Canada or the United States en route to the other country. JTI officers reported that their relationship with U.S. CBP was working well for the most part.
The CBSA also collaborates with U.S. CBP on the HRTI.
The HRTI is an agreement that enables U.S. CBP and the CBSA, in very specific instances, to share traveller information (API/PNR). The evaluation found that the CBSA currently has sound systems and policies in place for managing and sharing such information on travellers with U.S. CBP. While the evaluation found that the PAXIS system is secure, it did find a few instances where user profiles were not updated in a timely manner. In general, the CBSA reviews PAXIS user profiles regularly and an audit trail is in effect to ensure that only authorized employees have access to the system.
Targeting is about assessing information. If the quality of information is not good, the targeting process is ineffective. This is especially problematic when targeting for national security threats as NRAC targeters only see travellers and commercial goods that the systems filter in as high risk. If the information used to generate the risk scores is inaccurate or incomplete, the information is not useful for targeting.
The CBSA is receiving more advance information on air travellers.
The rate of carrier compliance in the provision of API/PNR data has been steadily on the rise. On average, API data is provided on 94% to 97% [ 38 ] of the over 20 million air travellers arriving in Canada each year. Airlines are required to submit to the CBSA whatever PNR they collect; however, no minimum number of fields is mandated, and many charter airlines and tour operators face additional challenges in collecting PNR. [ 39 ] As a result, the CBSA receives less PNR than API on travellers.
Commercial carriers are required to "provide the API data for all crew members and passengers prior to the arrival of the commercial conveyance in Canada, or within a reasonable time (reasonable time is considered by the CBSA to be within 15 minutes) after that arrival," [ 40 ] otherwise an Administrative Monetary Penalty (AMP) (contraventions C355 and C354) [ 41 ] in the amount of $3,000 will be issued to the airline. [ 42 ] In fiscal year 2005-2006, the CBSA issued 472 AMPs, of which 138 were cancelled via correction or redress processes. In fiscal year 2006-2007, the CBSA issued 247 AMPs, of which 65 were cancelled via correction or redress processes. Since 2003, the CBSA issued 1,804 C355 and 876 C354 penalties. However, interviews with compliance verification personnel revealed that, overall, the timeliness and completeness of the data provided by client airlines have improved since the enforcement of AMPs, and the ISTB is currently working with individual carriers to monitor and improve the submission of PNR. The Risk Management and Targeting Director General Steering Committee is also reviewing this issue and has taken measures to improve carrier data.
Amtrak collects extensive information upon reservation. [ 43 ] In addition, a rail crew report is required at the port of entry at least two hours prior to arrival. However, manifests for crew and passengers arriving by the marine or rail modes of transportation, as well as pre-arrival notifications for vessels are sent by e-mail and/or fax and lack a standard format. As a result, targeters spend a considerable amount of time and energy typing the information into non-standardized, non-networked local databases (such as MAVIS and Microsoft Excel spreadsheets) to conduct queries. This process can lead to data entry errors and spelling mistakes, which in turn can affect risk assessment activities.
TITAN processes nearly all air and marine cargo.
When ACI is incomplete or changes are made prior to the arrival of the conveyance, a carrier or freight forwarder must submit a supplementary report. This supplementary report references the cargo control number from the cargo report, which links the two reports together. The marine carriers interviewed for this evaluation expressed a desire for a systems-generated notification of what information is needed and for confirmation that supplemental information was received. To address this, U.S. CBP, for example, implemented a Web-based system in which carriers can view the information submitted.
As discussed, ACI submitted to the CBSA passes through two key validation points (CECP and ACROSS) before being risk-scored by TITAN and assessed by targeters. Last year, TITAN received 99.8% of marine cargo and 97.0% of air cargo manifests transmitted to the CBSA (Figure 3). [ 44 ] The number of total rejected marine cargo reports by ACROSS has steadily declined from fiscal year 2004-2005 (5,911 or 0.5%) to fiscal year 2006-2007 (1,458 or 0.1%). [ 45 ]
Commodity description fields are not standardized for goods entering Canada.
At present, there are no standards on what to include, or not to include, in the commodity description field of a cargo report, though the CBSA encourages shippers to use short descriptions in plain language. Often, the open-ended field contains information that is not related to the commodity's description (e.g. special handling directions or various phone numbers), which can slow down the processing of this information. In addition to these written descriptions, Canada uses a 10-number code (HS codes) that encompasses the Harmonized Commodity Description and Coding System, to compare against the description fields.
Currently, there are few AMPs levied against air or marine carriers for the non-reporting of ACI, and none for data quality.
Overall, client carriers felt they had sufficient information and time to implement the new ACI requirements, and that they were sufficiently prepared. [ 46 ] According to carriers, the Primary Reference Document package provided prior to the transition to ACI (which stated the expectations and data requirements) was clear. Most carriers also had several face-to-face meetings with CBSA representatives prior to the transition to answer their questions and/or concerns. However, the quality of the ACI data submitted by carriers and freight forwarders remains an issue.
The implementation of AMPs for not providing accurate advance information would improve the level of data reported; however, the CBSA remains without such a penalty system at this time. The key issue is the terminology used in the Customs Act. At present, accountability for reporting lies solely with the carrier; however, CBSA regulations allow freight forwarders to submit information directly to the CBSA without sharing information or notifying the carrier [ 47 ] As such, carriers may not know what information has or has not been submitted. Last year, BSOs issued penalties on the dock for 11 unreported marine containers.
In general, PAXIS and TITAN are reliable systems that have exhibited relatively few outages or serious problems.
Systems that support pre-arrival targeting were implemented in phases in order to respond to immediate needs (post-9/11) and continue to refine and enhance the original design. PAXIS was implemented in three phases. TITAN was implemented in two phases for use in the marine (2004) and air (2006) modes of transportation, and comprised a case flow and analysis tool similar to PAXIS. The evaluation team could not identify any specific aspects of an original concept of the PAXIS system that were de-scoped for initial implementation, but stakeholders at HQ identified several functions for the TITAN system that were. However, stakeholders at HQ indicated that the ISTB's incremental approach proved to be the most appropriate. The lessons learned during the implementation of TITAN Marine contributed to the implementation of about three quarters of the original design of TITAN Air in 2006.
Neither PAXIS nor TITAN experienced many major outages or serious problems since implementation. The bulk of the changes recommended for these systems focus on inter-database connectivity, user interface and improved functionality to enable targeters to use these systems more efficiently and effectively.
"Getting PAXIS and TITAN in place was a huge undertaking. It was a real challenge for the ISTB. The branch was tasked with the development, implementation for rollout, and with systems nothing really goes smoothly. The ISTB tried to ensure that all these aspects (including training on system use) were as complete as possible before implementation. All told, they did as best as could be expected and provided service to NRAC and the regions." - HQ interviewee
The ISTB has taken steps to enhance the change request processes for PAXIS and TITAN.
A process known as Integrated Customs System (ICS) decoupling, developed by the ISTB, will improve how and when PAXIS and TITAN are updated/enhanced. In the current design, PAXIS and TITAN reside on the ICS system interface, housed on CRA [ 48 ] servers with limited access. The new process proposes to decouple the PAXIS and TITAN systems from each other and from other ICS applications, which will enhance the CBSA's ability/flexibility to address new issues and potential threats.
Automated systems enhance the efficiency of pre-arrival targeting, making pre-arrival information immediately available for review and analysis.
In the absence of reliable performance data, it is difficult to quantify the contributions that API/PNR, ACI and the supporting systems have made to pre-arrival targeting. A key improvement is knowing in advance about potential threats. From the targeter's perspective, the automated systems are a marked improvement from the use of hard copy passenger manifests and waybills. During site visits, targeters noted that they had access to a greater span of information and it was easier for them to review information with the electronic systems. Management in the regions and at HQ expressed similar views.
The following highlights from the survey of targeters (conducted for this evaluation) demonstrate the importance of the automated tools in the targeting function:
From both the survey and the interviews, the targeters who worked with TITAN had more issues with the system (e.g. response time, user interface) than those who worked primarily with PAXIS. However, targeters in both the travellers and goods streams consistently expressed that these systems were a huge improvement over the former paper-based methods.
"TITAN itself is good. Definitely better than what targeters had to work with before. But, it is still limited; it is only a tool. We need to keep the people side as the primary focus. TITAN will never become an artificial intelligent that will replace targeters. There will always be a need to overlay local knowledge on the information produced by the tool. Investing in good training is more important than constantly improving the tool." - Regional interviewee
Since there are no data on comparable results from other methods of identifying and interdicting threats, the effectiveness of pre-arrival targeting using algorithms is difficult to quantify.
There is widespread support for the use of automated risk scores for targeting in the CBSA.
An inherent challenge in assessing the effectiveness of the algorithm used for the risk analysis of travellers and commercial goods is that risk criteria are moving targets.
The Research and Corporate Statistics Unit has proven statistically that targeting is a better strategy for interdiction than a random approach. [ 49 ] In other words, examining targeted marine containers will likely result in more seizures than examining only randomly selected containers. Similarly, the Harmonized Risk Scoring and Advance Trade Data (HRS-ATD) Division (ISTB) and the Strategic Intelligence Analysis Division (Enforcement Branch) are working on improving the quality of risk-scoring. The HRS-ATD team has proven mathematically that targeting containers for examination using TITAN risk scores produced by algorithms is 29% more effective than random examinations. This team has developed a new algorithm [ 50 ] and will be assessing it in a new test environment in the near future. The risk-scoring component of PAXIS was developed in accordance with CBSA policies, procedures and existing methodology, and it is functioning as it was originally intended. [ 51 ]
The evaluation team conducted an informal assessment of the risk-scoring mechanism for air travellers by examining information collected on four separate international flights (on different carriers) taken by team members. The results confirmed that the PAXIS system accurately scored these travellers as low risk. The quality of data was within expected parameters.
Targeters believe overwhelmingly that they are identifying high-risk travellers and goods through their work (Figure 4). The quality and completeness of the data received on travellers varies greatly by mode of arrival due to the types of data collection systems and processes in place.
Survey of CBSA Targeting Officers,Q48b (n=135).
The number of air travellers risk-scored by PAXIS has increased over the last fiscal year.
More air carriers are providing API/PNR information, and by extension, more travellers are screened prior to arrival. PAXIS identified 1.2% of air travellers as reaching or exceeding one of the national security threat thresholds, which NRAC targeters further assessed.
In the Atlantic and Pacific regions, few travellers arriving by sea were identified as high risk.
In 2006, the Atlantic region had 163,181 cruise/vessel passengers, of which 12% (19,595) were further assessed. In the Pacific region, 12% of the 439,087 passengers were referred to secondary processing for further examination. Of the 184,319 crew arriving in Canada, 200 (or 1%) were subject to further action. Travellers were denied entry to Canada primarily if they had a "hit" on FOSS, Integrated Customs Enforcement System (ICES), Canadian Police Information Centre (CPIC) or other databases for criminal activity. Crew tend to be higher risk; therefore, all crew are screened.
Marine Cargo Targeting
The total number of TEUs entering Canada in fiscal year 2006-2007 was over 2 million (Table 5), [ 52 ] increasing slightly over the previous year.
|Fiscal Year 2005-2006||Fiscal Year 2006-2007|
|TEUs||% of Total||TEUs||% of Total|
|Containers that arrived to Canada||2,929,581||100%||3,215,745||100%|
|Freight that remained on-board vessel||1,032,903||35%||1,168,860||36%|
|Containers that entered Canada (net)||1,896,678||65%||2,046,885||64%|
In fiscal year 2006-2007 MCTUs conducted over 2.1 million cursory reviews of marine cargo manifests, up from 1.9 million the previous year. The vast majority of marine cargo shipments are cleared or authorized to move by targeters during cursory reviews.
In the last fiscal year, NRAC issued 386 "do not load" orders. A proportion of these containers were resolved with subsequent information received from the carrier/freight forwarder (which demonstrated that the shipment was not a security threat) and the remaining containers were referred for examination or received "do not unload" orders upon arrival in Canada. Containers are examined using a variety of methods. Table 6 represents the types and totals of marine container examinations used in fiscal year 2005-2006. Not all of these containers were identified by a targeter, as pier and Vehicle and Cargo Inspection System (VACIS) teams also identify containers for examination based on real-time assessments.
This demonstrates that the CBSA's multi-layered approach to border security--from employing pre-arrival mechanisms to sift through data sent in advance to the real-time examination of incoming goods at a port--provides several opportunities to intercept suspicious cargo.
|Port||Full Offloads||Pier Examination||VACIS|
|Count||% of total||Count||% of total||Count||% of total|
Source: CBSA management using Consolidated Management Reporting System (CMRS) data.
Air Cargo Targeting
|Total Number of Air Cargo Reports||25,090||16,496|
|Resultant||10 (3.08%)||25 (3.16%)|
The current division of responsibilities between NRAC and ACTUs is a pilot project. Performance data on the units' activities are scarce.
Site visits to NRAC showed that in order to cope with the massive influx of air cargo reports, NRAC uses filters in TITAN to sift out cargo deemed low risk. The GTA tends to target high-risk flights using the country of origin as its main indicator rather than the case management strategy used by NRAC. The resultant rate for both units is nearly identical, although the contraband they seize differ (Table 8).
|Port||Mode||Targets Resulting in Interdiction||Contraband (Types/General Trends)||Total Value|
|Halifax||Marine||8A||Primarily drugs (e.g. cocaine, hash and opium)||$166,749,025|
|Montréal||Marine||3A,B||Primarily drugs in primarily small amounts (e.g. 7 to 9 grams of marijuana or 5 kg of ecstasy)||$2,000,665|
|Vancouver||Marine||23||Primarily cigarettes (some chemicals, alcohol and weapons)||$17,395,050|
|Toronto/Pearson||Air||31||Primarily drugs (e.g. khat)||$21,724,750|
|NRAC||Air||7C||Varies (precursor chemicals, medicines and pepper spray)||N/A|
During site visits, it was mentioned to the evaluation team that both human and physical constraints limit the number of examinations that can be conducted. For instance, when additional personnel were added to the targeting teams, no additional resources were provided to increase the number of examination teams or facilities to process the increasing number of referrals. In one airport, targeters mentioned that processing TITAN referrals took a large amount of their time.
JTI targeters provide another layer of security.
As part of the Canada/U.S. Smart Border Declaration, JTI targeters located United States review marine containers arriving at U. S. ports destined for Canada (by rail or truck). U.S. CBP assesses all shipments for national security threats while JTI targeters concentrate on identifying contraband smuggling. Table 9 provides an overview of JTI targeter reviews for the past two fiscal years.
|Fiscal Year 2005-2006A||Fiscal Year 2006-2007|
|Count||% Reviews||Count||% Reviews|
|Referrals - VACIS||84||3.2%||277||2.4%|
|Examinations - VACIS||78||2.9%||256||2.2%|
|Referrals - Full offload||26||1.0%||150||1.3%|
|Examinations - Full offload||20||0.8%||127||1.1%|
The expertise and experience developed from the Winfall project could benefit eManifest, an integrated approach to land-border management that is currently under development.
Winfall targeters focus on inbound rail shipments originating in the United States and Mexico. Between December 2005 and November 2006, Winfall targeters reviewed approximately 45,000 intermodal containers and 344,000 railcars. However, only a few contraband seizures can be attributed to the Winfall project since its inception, and this is largely linked to the lack of appropriate rail examination facilities. A new CBSA initiative, eManifest will integrate the land-border processing of goods and crew for various modes, and could benefit from incorporating the expertise developed and lessons learned through the Winfall project.
Although deterrence remains one of the intermediate outcomes of pre-arrival targeting, it is a difficult aspect to measure, especially in the relative short term. There were differing thoughts on the importance of the potential deterrent effect of pre-arrival targeting. Many senior management interviewees did not believe that this is its primary purpose. People involved in illegal activities will continually try new ways to circumvent "the system," and the primary purpose of pre-arrival targeting is to identify and intercept them before they do.
"Sometimes the best result is the one that can't be quantified. It is no secret that ACI targeting is being conducted and this most likely produces a deterrent effect, creating at the very least an impression that commercial shipping streams are not as easy to utilize for any number of dubious agendas as they once were." - Targeter surveyed
Given the current lack of consistent and comparable performance data, this evaluation cannot demonstrate that pre-arrival targeting is more or less effective than other measures employed by the CBSA to intercept high-risk goods and travellers. However, this evaluation found that pre-arrival targeting fills a niche and contributes to the continuum of the intervention processes in place. Better baseline information on all forms of interception and inspection--from pre-arrival targeting, real-time targeting, stints, random examinations and compliance verification activities to post-release examinations--are necessary to more clearly determine which approach works best, with what or whom and when.
Overall, Canada is at the forefront of pre-arrival targeting in the air and marine modes of transportation. However, lessons can be learned from other countries. U.S. CBP makes Web-based information available to marine carriers to keep them apprised if supplementary information is submitted by the freight forwarder, which enables carriers to keep track of the information that is needed and the information that has been submitted and amended.
Overall, the unintended consequences of targeting have been few. Targeters and BSOs indicate that some air travellers are repeatedly targeted as their travel patterns are flagged, although they have legitimate reasons for it (e.g. frequent business trips). Small importers complain that they now incur additional costs due to examinations, late deliveries and lost sales. As with any system, sometimes problems arise; however, these errors have been few and easily resolved.
Determining the extent to which the pre-arrival targeting function makes the best use of resources is complicated by the lack of quality data on targeting activities and on comparable activities (e.g. random examinations and stints), and difficulty tracking funding sources. What this evaluation can provide is a rough estimate of the resources dedicated to targeting activities and a comparison with other jurisdictions of the costs associated with similar initiatives.
Pre-arrival targeting is not a program. Consequently, no single system or area is responsible for tracking funding related to targeting. Most components of pre-arrival targeting activities are funded primarily under the Public Safety and Anti-Terrorism (PSAT) Initiative resulting from the Smart Border Declaration and the Manley-Ridge 32-point Action Plan. In fiscal year 2006-2007, the API/PNR program received $46.9 million, and the ACI program received $13.1 million through the PSAT Initiative as well as monies from the Customs Action Plan (CAP).[ 57 ]
The risk-scoring component of the API/PNR program is estimated to have cost $4.8 million over the course of fiscal year 2003-2004 to fiscal year 2006-2007 (Table 10).[ 58 ] Approximately $4.7 million was spent on ACI-EDI reporting for air development over the course of fiscal year 2005-2006 and fiscal year 2006-2007.[ 59 ]
Many countries that employ some form of pre-arrival targeting do not separate the costs of this function from other passenger operations. For example, in fiscal year 2006-2007, Australia[ 60 ] spent $297 million on "passenger movement and intelligence," which includes all forms of risk assessment and processing relating to incoming and departing passengers, crew, baggage, cargo and mail, as well as intelligence and targeting activities for the identification of people and goods of interest, law enforcement strategies and security. According to open sources, U.S. CBP spent $50.9 million last year[ 61 ] on targeting systems and staffing for the National Targeting Center alone (see Figure 11).
|Initiative/Budget Activity||Fiscal Year 2005-2006||Fiscal Year 2006-2007||Fiscal Year 2007-2008 (Request)|
|Systems for Targeting||$27,922,000||$27,298,000||$27,580,000|
|National Targeting Center||$16,449,000||$23,635,000||$23,950,000|
Pre-arrival targeting is part of the continuum of methods and systems--pre-arrival, point of entry and post-arrival screening--that the CBSA employs to ensure that dangerous goods and persons are prevented from entering Canada. The Agency has implemented key components supporting a pre-arrival targeting function in recent years, such as NRAC, improvements in automated risk-assessment tools and the expansion of regional targeting units.
Advance information is collected, processed and disseminated using two primary systems. PAXIS uses API/PNR data to screen commercial air travellers. Targeters focusing on other traveller modes--rail, cruise ships and vessels--do not use PAXIS but receive basic pre-arrival information on the crew and/or passengers entering Canada, submitted directly to the CBSA by fax, e-mail or another non-automated method. On the goods side, TITAN processes incoming cargo using ACI data provided by commercial carriers and/or freight forwarders in the air and marine modes of transportation. Overall, this evaluation found that the major systems developed for pre-arrival targeting are sound and have excellent potential, yet there are areas where improvements to their efficiency and effectiveness can be made. As well, these systems can be expanded to other modes.
Data quality, completeness and timeliness are essential for generating meaningful risk scores and for targeting generally. The quality, quantity, accuracy and timeliness of the data provided to the CBSA in advance vary greatly. To this end, the use of AMPs for the non-submission of API data resulted in a significant increase in compliance by air carriers. Further expansion of AMPs, where possible, to penalize for incomplete and inaccurate data (primarily PNR) and continued client outreach and verification (e.g. client report cards) will improve data quality. The expansion of AMPs for other modes of passenger travel (i.e. rail, cruise ships and bus) could facilitate the receipt of essential information for targeting in these modes. In terms of commercial goods, the introduction and enforcement of appropriate penalties would provide an additional tool to improve data quality.
Pre-arrival targeting is a critical component of the CBSA's risk-management approach. Without pre-arrival targeting to identify high-risk goods and travellers, the movement of people and goods would be greatly delayed by more intensive scrutiny at primary, and would incur an enormous cost to the CBSA and to air, marine and rail transport providers and related entities (e.g. importers and exporters). It is the opinion of the evaluators that pre-arrival targeting is in a position to achieve expected results; however, due to inconsistent and/or absent methods of collecting data on targeting activities, this evaluation cannot conclude that it is more effective, efficient and cost-effective than other approaches.
Pre-arrival targeting has not yet realized its full potential. With the proper leadership, design and delivery framework, electronic systems, training and regulatory support, pre-arrival targeting could become an excellent risk-management and workload-management tool for the CBSA. In addition, the examples and "lessons learned" in Canada may assist other countries in their development of systems and processes for pre-arrival targeting and the further harmonization of processing travellers and goods.
Consider creating a cohesive targeting program, with appropriate resources, coordinated by a single functional authority.
The CBSA concurs with this recommendation. The Enforcement Branch is leading work to develop options for the governance structure and conceptual framework of a single functional authority to manage CBSA targeting activities. Recommendations will be presented to CBSA senior management before the calendar year end of 2007. Implementation of the new model would begin in 2008.
Strengthen an integrated approach for pre-arrival targeting that includes both centralized and regionalized components.
The CBSA concurs with this recommendation. To develop a national integrated approach, the new functional authority (see management response to Recommendation 1) will conduct an in-depth review of NRAC, including possible future roles and responsibilities. The study will be completed by the end of fiscal year 2007-2008. With support from the Risk Management and Targeting Steering Committee (RMTSC) and the Risk Management and Targeting Working Group (RMTWG), the new authority will also review and select options for centralized and regionalized models by the end of June 2008. Once options are selected, the CBSA will develop a transition strategy and a communications plan to support the new models.
Take steps to improve the advance data provided by commercial stakeholders on both travellers and goods.
The CBSA concurs with this recommendation. The advance electronic information program has been highly successful and merits consideration for expansion to other modes of transportation, including marine and rail. The CBSA is already exploring this proposal through an inter-branch working group, and is analyzing costs and implementation impacts from both program delivery and resource perspectives. The RMTSC and the RMTWG will support the new functional authority (see management response to Recommendation 1) in setting priorities. Senior managers will have an initial strategy discussion about this issue in the last quarter of fiscal year 2007-2008.
The CBSA has an API/PNR Compliance Management Strategy to identify areas for improvement, with most of this work already underway. An API/PNR data integrity team is examining the quality of data received from carriers and is working with them and the CBSA service provider to correct issues. They will complete a detailed analysis by August 2008. As part of the PNR Push initiative, to be implemented in late 2008, technical changes will also be introduced.
New penalties for the commercial environment will be introduced in fiscal year 2009-2010 and new contraventions will be added to cover issues not in the original regime
Develop and implement approaches to move further toward the 100% pre-arrival risk assessment of marine and air commercial shipments, and travellers to Canada, against cost-benefit considerations.
The CBSA concurs with this recommendation. The new functional authority (see management response to Recommendation 1), with the support of the RMTSC and the RMTWG, will analyze the various risk-assessment tools currently in place to help develop and implement an approach to continue progress toward this goal.
The CBSA will continue to monitor carrier compliance with API/PNR and ACI requirements and work with carriers to ensure that non-compliance issues are addressed. Obtaining bay plan information from carriers of commercial goods transported by sea on a mandatory basis, 96 hours prior to arrival, will enable the CBSA to further harmonize with U.S. CBP.
Continue to refine aspects of the automated targeting systems to improve the accuracy and efficiency of pre-arrival targeting.
The CBSA concurs with this recommendation. A new technical process to test and implement new technology, including system enhancements and problem corrections, will be fully operational in early 2008. This will speed up the Agency's ability to implement new functionalities.
The HRS-ATD project team is designing a sophisticated mathematical model to enable targeters to better identify the probability of risk and is identifying ways to improve risk indicators to further address marine security gaps. Changes are being made in TITAN Marine to best address existing deficiencies. The project itself spans three years, with the first major delivery scheduled for September 2008 and the inclusion of advance trade data currently scheduled for January 2009.
Through their review of risk-scoring in PAXIS, the Intelligence Directorate and the ISTB will determine how PAXIS can be adjusted to improve its functionality and establish a regular review process. As part of the PNR Push initiative, PAXIS system enhancements will be introduced in early 2008.
Transition the risk assessment activities of the Winfall project and the Joint Targeting Initiative to the next phase of ACI (the eManifest initiative).
The CBSA concurs with this recommendation. The Enforcement Branch will work with the ISTB and the Admissibility Branch to ensure that an integrated approach to targeting is considered in the implementation of eManifest. The CBSA will capitalize on best practices learned from the JTI and the review of the Winfall project while these processes are re-engineered.