Border Trade Alliance

The Border Trade Alliance (BTA) Environment and Health Committee developed and submitted comments on the WHTI Draft Programmatic Environmental Assessment (PEA) to U.S. Customs and Border Protection on Wednesday July 18th, 2007. The Draft PEA analyzes environmental consequences of three alternatives and one “no-action” alternative for changes in procedures and document requirements for U.S. citizens entering the United States from Mexico, Canada, or Bermuda at land or sea ports-of-entry. The following are the comments in full that were submitted to CBP:

RE: Review and Comment on WHTI Draft Programmatic Environmental Assessment “USCBP-2007-0060”

Dear Sir or Madam:

The Border Trade Alliance (BTA) thanks the U.S. Customs and Border Protection for the opportunity to review and comment on the Western Hemispheric Travel Initiative Draft Programmatic Environmental Assessment (PEA). The Draft PEA analyzes environmental consequences of three alternatives and one “no-action” alternative for changes in procedures and document requirements for U.S. citizens entering the United States from Mexico, Canada, or Bermuda at land or sea ports-of-entry. The BTA requests that its comments be entered into the official record:

Initial and Early Operation
The Draft PEA states that implementation of WHTI and impacts from the first months of its introduction (early operational stage) are “assumed to be temporary in duration” (Page 30). The document also defines the early operational stage as occurring during the first six months of operation (Page 29). The BTA believes these statements underestimate the length of time necessary for introduction of WHTI, which will require a change in habit and way of life for many U.S. border residents.

Recommendation
The BTA recommends the timeframe for the “early-operational stage” be extended from six months to a more realistic, one- to two-year period.

Socioeconomic Impact
The Draft PEA provides a section on border socioeconomics, but the section neglects to address potential impacts to regional economies from any of the three “action” alternatives. The BTA sees this as a serious omission. The U.S. Federal Reserve-Dallas reports that U.S. border communities derive considerable economic benefit from cross-border trade and commerce. In some smaller communities, a majority of the economy may be based on the movement of goods and people between two neighboring nations. Implementation of WHTI has the potential to generate significant economic impacts within border communities.

Recommendation
The BTA highlights the omission of an adequate economic impact section in the Draft PEA and requests that such a chapter be included.

A Fifth Alternative
Insufficient manpower often is cited as the major reason for excessive wait times at land POEs. Recent deployment of extra manpower at southern land POEs has demonstrated improved efficiencies at land POEs and a reduction in illegal entries into the United States (i.e., Operation Jump Start). Even if DHS implements the RFID “action” alternative, as proposed, the BTA believes that increases in manpower may be required to minimize the impact to cross-border commerce and tourism.

Recommendation
The BTA recommends the addition of a fifth “action” alternative to include the impact of hiring and training new personnel as a method for implementing WHTI.

Extending the geographic range

The BTA remains on record as advocating for extending the geographic range at which wait times at land POEs are measured to include the entire queue. Using only the POE footprint, as is done now, miscalculates the actual wait time for vehicle traffic and fails to provide an accurate benchmark for evaluation or comparison.

Recommendation

The BTA recommends a recalculation of wait times to include the entire queue, not just the POE footprint, to more accurately assess a benchmark that can be used for evaluation and comparison of policy alternatives.

Sincerely,

Pete Sepulveda, Chair Maria Luisa O’Connell, President Erin Ward, Chair: Environment & Health Committee

Download the BTA comments document (PDF)..

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