ITGO Letter Re: E-Manifest and Cashless Tolls at Land Border Crossings

August 4, 2017

Acting Commissioner Kevin McAleenan
U.S. Customs and Border Protection
1300 Pennsylvania Avenue NW
Washington, D.C. 20004

Dear Acting Commissioner McAleenan:

On behalf of the Buffalo Niagara International Trade Gateway Organization (ITGO), a Western New York-based collaboration of private, public and academic stakeholders working to create a globally-recognized logistics center in the bi-national Buffalo Niagara region, I write to you in support of two initiatives that we believe will help to improve border commerce procedures in our region, and across the U.S. northern border. Both of these measures were supported by our region’s Congressional members, Chris Collins and Brian Higgins, in a joint letter to your office on July 10, 2017:

1. Require all empty trucks and other shipment classifications to report via e-manifest.

Since 2007, the use of e-manifest by the carrier community has been a requirement to enter the U.S.; however, the requirement does not extend to empty trucks and truck cabs. For example, at the Peace Bridge approximately 20% of the trucks entering into the U.S. are empties not utilizing e-manifest, and as such require manual entry of their information at the border. At some northern border crossings, the percentage of non e-manifests is as high as 50%. Each manual entry adds approximately 75 seconds of processing time, adding to congestion, delays and an inefficient use of U.S. Customs and Border Patrol (CBP) resources. As you are aware, the Canada Border Services Agency (CBSA) began requiring e-manifest for all trucks including empties in 2012. CBP should also implement this requirement.

2. Cease the practice of CBP officers manually collecting the border user fees at the port-of-entry.

Approximately 90 percent of trucks at the U.S. northern border pay the applicable border fees either through prepayment, or via a transponder. The small percentage that do not, add approximately 90 seconds to their processing time as CBP officers must collect cash or process credit card payments. This impedes the border throughput of the vast majority of vehicles that have prepaid and unnecessarily results in delays and congestion. Whether the fee is collected at the primary inspection booth or in secondary inspection, it is an unnecessary misuse of resources to have Customs officers collecting small fees and payments when they should be focusing on their mission of national security and commerce flow. Making pre-payment mandatory is a simple, common sense solution.

As an organization that advocates for streamlined logistics services at the CanAm border, and whose membership is comprised of companies that deal daily in cross-border commerce, we believe these relatively simply process improvements will significantly reduce congestion and delays, optimize use of existing infrastructure, and more efficiently utilize CBP resources. It is our understanding that these changes are widely supported throughout the border security community, and felt it was important for you to be aware of the Buffalo Niagara region’s industry support, as well. We look forward to these recommendations being implemented as soon as possible.

Craig W. Turner
Executive Director
Buffalo Niagara International Trade Gateway Organization

cc: Hon. Chris Collins, Member of Congress
Hon. Brian Higgins, Member of Congress