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Advocacy Initiatives - Regulated Agent
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TOPIC


A- near term high impact

B- near to medium term, high impact

C- longer term, medium impact

D- long term impact still TBD


DESCRIPTION*


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complete description

AFFECTS THESE

INDUSTRY SEGMENTS

IMPACT

TIACA ACTION

NEXT STEPS

B

 

Postal Dangerous Goods program

Postal regulations and training programs/capabilities

are not clearly posted or described, posing a challenge for carriers to confirm compliance or prove compliance to civil aviation regulators. A large issue with the continuing expansion of e-trade (e.g. Amazon, Alibaba) transactions using postal modes.

Carriers, some regulated agents, postal operators

Postal operators without clear training and categorized instruction on DG as well as more specific procedures for Lithium Batteries may not be able to transport any DANGEROUS GOODS on commercial aircraft.

Carriers may not be able to accept such shipments w/o ability to verify compliance from Postal sources

Working with UPU to press for wider publication of training procedures available to carriers and Regulated

Agents, more complete training oversight of postal operators by UPU

Follow up discussions with UPU cargo committee, ongoing discussions in conjunction with Advance Data meetings, next discussions set for January 2016 in Geneva

A

 

TSA mutual recognition(EU and Australia near-term)

Mutual recognition (MR) between US and other countries allows carriers to use origin state security programs rather than origin AND destination programs. Some have been in place for 3+ years and are expiring. MR Simplifies training and reduces cost. TSA programs are all for 3 year periods, and renewal as well as renewal timing or advance warning is essential for effective operations. Any changes should be determined well in advance. Threats should be identified and discussed with industry to develop solutions.

 

 

PAX and Cargo Carriers, RA’s, Forwarders,

Ground Handlers

Changes to programs in place after 3 years require training and increased operational cost to PAX and Cargo Carriers, RA’s, Forwarders,

Ground Handling industry segments.

Lack of extension, or any significant modifications , would require extensive re-training, and likely additional (or duplicative) cargo screening for all segments

Working with TSA, as well as EU (DG MOVE) and Australia at present to extend current programs, or at very least, provide extended advance notice of any changes, as well as explanation.

US/Australia is in extended modification period. Continuing dialog with TSA and EU DG MOVE to extend US/EU program intact. Participating in EU/TSA Transportation Sector Consulting Group meeting, next session in DC, December 2015.

B

 

WCO SAFE PLACI standards

Risk analysis segments for any PLACI must be standardized globally. Procedures for transmitting and receiving messages must also be standardized and coordinated with any Civil Aviation Authority regulations. Multiple procedures across similar platforms will be confusing, costly and ineffective. Pilots have tested only part of PLACI data sets. Risk algorithms must be same (or closely similar) to avert risk of transit shipment delays.

 

PAX and all-Cargo carriers, Regulated Agents,

Forwarders, Ground Handlers

PAX and all-Cargo carriers, Regulated Agents,

Forwarders, Ground Handlers may need to file multiple times to several customs regimes, at extra cost, and potentially off- load shipments en route if common rules are not in place

Worked with WCO and customs official, successful in standardizing “7+1” data set, significant work ahead to standardize transmission of data, response mechanisms, and risk algorithms.

Participant in WCO/ICAO JWGACI, as well as directly with current customs regimes (CBP, CBSA, EU DG TAXUD), to clarify issues and develop workable rule sets. WCO implemented the 7+1 as standard in latest SAFE framework as a result of strong industry efforts, eliminated potential for open-ended data submission.

 

Now working with EU and US Customs regulators to ensure proper transition and implementation as individual programs are further developed.

A

 

EU TAXUD implementing and delegating acts

EU is ahead of other PLACI regimes, and is developing Member State transitional Implementing and Delegating Acts for effect in 2016. Combines customs and Civil Aviation measures in single procedure. Challenge for industry to implement. Difficult for transit cargo thru EU states with different Implementing timelines. Rule set language remains confusing.

Regulated Agents, PAX and all-Cargo carriers, postal operators, Ground Handlers, Forwarders for shipments moving into the EU beginning in May 2016

RA’s, PAX and all-Cargo carriers, postal operators, Ground Handlers, Forwarders may incur Shipment delays, high costs to implement with different Member States at different times.

Coordinating with other industry Assns. to pressure DG TAXUD to revise and modify language in Implementing and Delegating Acts,as well as transitional programs, and include industry in further discussions before sending regulatory language for EU Parliamentary proceedings

Ongoing meetings and formal letters/requests to EU, further meetings and discussions in accord with others. Next meetings with EU not yet planned , awaiting further responses on proposed industry language to correct deficiencies,

B

 

TSA all-cargo security program

The program affects all-cargo aircraft operating in and into the US, for US flag as well as non-US flag carriers. Interim program was issued in early 2015. TSA did not include simplified procedures as requested by industry, or include risk-based measures as discussed in earlier sessions.

Program remains unwieldy and confusing, requires multiple amendment to accommodate different modes

All-Cargo and express carriers, forwarder/Regulated Agents will be better able to transfer shipments between modes utilizing same or similar training methods, reducing operational costs

Working with industry colleagues to help develop mutually acceptable language that TSA can incorporate into a revised program. Helped develop an ASAC recommendation in this regard, to which TSA expressed agreement. Follow-up work is necessary to ensure acceptable language and incorporation into revised security programs in all relevant sections.

 

Ongoing discussions with TSA and through the ASAC cargo subcommittee, headed by TIACA.

We are also working with industry colleagues to identify other opportunities for pursuing the revised language and practices.

 

DHS ACAS rule sets

 

(ROLLED INTO PLACI ABOVE)

 

 

 

.

 

C

 

US EPA rulemaking on aircraft emission standards

US issued draft regulation for industry and public comment, regarding decreasing emissions on new aircraft

All industry segments

Potentially higher cost of operations

Issued response to EPA draft, collaborate with other industry groups

Awaiting resolution of industry and public comments from EPA, early 2016

C

 

Paperless standards for US security programs/alignment

US TSA Security Regulations allow some e-reports, but have not arrived at standards. Have not fully adopted E-CSD in programs.

Regulated Agents, Forwarders, all carriers

Regulated Agents, Forwarders, and all carrierswill be able to reduce cost of maintaining records for TSA and streamline operating procedures

Working with TSA to define acceptable formats, and begin development of language for modification of Security Programs

Ongoing discussions as part of ASAC, plus 1:1 with TSA. Longer term project, next meetings after beginning of 2016

B

 

Air Cargo R&D

There is a dearth of screening technology geared to the air cargo environment. This limits efficiency, impedes commercial flows, and creates security gaps.

Forwarders

Airlines

Ground handlers

Shippers

Regulators

Posts,

Airports

Authorized screening parties (forwarders, airlines, etc.) have limited options and must structure their operations to the types of screening equipment that are available.

We have called for R&D geared to the cargo environment. We are leading this effort through our work on ASAC and through chairing the ASAC Air Cargo Subcommittee. The Subcommittee has created an R&D working group which will also work closely with the ASAC Technology Subcommittee. Its objectives will include identifying key channels for stakeholder input into R&D decisions, expanding the range of stakeholders consulted by TSA to include those who use the technology, and identification of capability gaps.

ASAC Air Cargo Subcommittee is setting up a special working group on this subject. The working group will get underway during first quarter 2016.

B

 

E-Commerce Initiatives

 

The industry has been slow to adopt e-commerce solutions, including e-AWB and e-freight.

Forwarders

Airlines

Shippers

Ground handlers

Software vendors

Regulators

E-commerce adoptions will have a major impact on the future of the air cargo industry.

Adoption if e-information, especially for HAWB information processing, will significantly improve the ability for regulators to quickly evaluate risk levels for individual shipments in upcoming PLACI regimes.

Produced the e-commerce Scorecard.

Adding success stories.

Developing collateral benefits to publish with PLACI update information.

Subcommittee reviewed/revised Scorecard. Secretariat posting web section to enable committee members to interactively update material and provide new information requirements for further policy developments and actions (November 2015)

D

 

Infrastructure

 

While a wide range of transportation and communication infrastructure deficiencies can slow air cargo, the most critical are generally inadequate airports, bad roads, and aging air traffic control systems.

Forwarders

Airlines

Ground handlers

Infrastructure gaps and bottlenecks limit air cargo’s speed advantage and competitiveness

Published TIACA position paper.

Support NextGen/Single European Sky.

TBD, longer term issue

B

 

Emissions/carbon footprint

The aviation industry remains a target for emissions limits/reductions.

All industry participants.

Emissions caps, reductions or trading schemes could affect the economics of air cargo transactions.

We have taken targeted actions, e.g. comments to EPA regarding an aircraft emissions standard. TIACA participates on the ICAO CAEP working group developing a draft methodology for calculating the carbon footprint of air cargo shipments. We also participate in the Global Logistics Emissions Council, which is separately developing carbon calculators for transportation modes.

To be evaluated by the Environment and Infrastructure Subcommittee.

C

 

Air cargo traffic rights

Currently, aviation market access negotiations are conducted as a package (passenger and cargo rights). Often, cargo issues are settled quickly, but cargo routes cannot be liberalized until PAX issues are settled. This delays cargo liberalization.

Forwarders

Airlines

Airports

A new approach allowing more rapid conclusion of air cargo agreements could open new routes (“highways in the sky”).

Papers presented to ICAO’s Air Transport Symposium.

Liaise with ICAO working group members to determine status.

D

 

 

Trade facilitation via trade negotiations

Various trade negotiations offer opportunities to obtain trade facilitation commitments.

Forwarders

Airlines

Ground handlers

Modernized customs procedures could enhance air cargo’s speed advantage.

Under review

Under evaluation by Market Access and Trade Facilitation Subcommittee for next steps.

Longer term issue.

C

 

Single window/customs automation

Single window systems and customs automation would facilitate international air cargo transactions.

Forwarders, Regulated Agents,

Airlines

Ground handlers

Could increase the speed and reduce the cost of global air cargo transactions.

General support for Single Window/automation. Evaluating engagement on US export manifest pilot. U.S. Customs is piloting an advance electronic air manifest that could significantly modify reporting practices for air shipments outbound from the U.S.

Under evaluation by Market Access and Trade Facilitation Subcommittee. Course of action to be determined first quarter 2016.

B

 

Intellectual property rights (IPR)

Customs authorities are increasing interdiction of IPR-infringing goods. In some cases, they may seek assistance from intermediaries, such as carriers and forwarders, or even seek to levy penalties on them.

Forwarders, Regulated Agents,

Airlines

 

Customs actions could impose new burdens (legal, operational, and commercial) on carriers and forwarders.

Developing TIACA position paper, under final review. Advocating joint effort to collaborate between industry and regulators to determine best process.

Under final evaluation by Market Access and Trade Facilitation Subcommittee.

 

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