Internal Audit and Program Evaluation Directorate
Horizontal evaluation of the single window initiative
December 2020

Table of contents

• Acronyms and abbreviations
• Exhibits and graphs
• Executive summary
• 1. Introduction
• 2. Achievement of benefit 1 – Improved information sharing within the GC
  • 2.1 Infrastructure for the electronic exchange of information
  • 2.2 Capacity of PGAs to share information for regulated commercial imports
  • 2.3 Challenges in sharing information for regulated commercial imports
  • 2.4 Summary
• 3. Achievement of benefit 2 – Improved threat identification and risk management
  • 3.1 Infrastructure for the electronic exchange of information
  • 3.2 Capacity of PGAs toblckxrp share information for regulated commercial imports
  • 3.3 Challenges in sharing information for regulated commercial imports
• 4. Achievement of benefit 3 – Simplified border processes for the GC and TCPs
  • 4.1 Simplified border processes for the Government of Canada
  • 4.2 Simplified border processes for TCPs
  • 4.3 Key components to simplifying border processes for SWI stakeholders
  • 4.4 Summary
• 5. Conclusion: The Future of the SWI
  • 5.1 Completion State of the SWI Deliverables
    • Recommendation 1
    • Recommendation 2
  • 5.2 Ongoing funding to support the SWI
  • 5.3 Training delivered within the Government of Canada
    • Recommendation 3
  • 5.4 Decommissioning of the legacy OGD service options
  • 5.5 Expanded use of the SWI service options
    • Recommendation 4
• Appendix A: Management response and action plan
• Appendix B: Evaluation definitions
• Appendix C: SWI logic model (2012)
• Appendix D: Evaluation methodology and data limitations
• Appendix E: SWI stakeholder roles
• Appendix F: SWI Project Governance Bodies
• Appendix G: SWI deliverables across analytical themes and PGAs
• Appendix H: Alignment with international standards and recommendations
• Appendix I: Definitions of international standards & recommendations
• Appendix J: SWI information sharing and decision making models
• Appendix K: Commercial release request volumes
• Appendix L: SWI stakeholder roles in the delivery of internal training
• Appendix M: Quality and timing of training delivered internally by SWI stakeholders

Acronyms and abbreviations

ACROSS

Accelerated Commercial Release Operations Support System

BRMS

Business Rules Management System

BSO

Border Services Officer

CBSA

Canada Border Services Agency

CFIA

Canadian Food Inspection Agency

CITES

Convention on International Trade in Endangered Species of Wild Fauna and Flora

CNSC

Canadian Nuclear Safety Commission

CTB

Commercial and Trade Branch [CBSA]

DFO

Fisheries and Oceans Canada

DG

Director General

DIF

Document Imaging Functionality [also referred to as SO927 or LPCO Images]

EAC

Evaluation Advisory Committee

ECCC

Environment and Climate Change Canada

ECCRD

Electronic Commerce Client Requirements Document

EDI

Electronic Data Interchange

FY

Fiscal Year

GAC

Global Affairs Canada

HC

Health Canada

HS

Harmonized Commodity Description and Coding System

ICS

Integrated Customs System

IEWG

Interdepartmental Evaluation Working Group

IID

Integrated Import Declaration [also referred to as SO911]

ISTB

Information, Science and Technology Branch

IT

Information Technology

LPCO

Licenses, Permits, Certificates, and Other Documentation

MRAP

Management Response and Action Plan

NRCan

Natural Resources Canada

OB

Operational Bulletin

OCCTP

Officer Core Commercial Training Program

OGD

Other Government Department

PARS

Pre-Arrival Review System [for EDI, this includes OGD PARS (SO463) and Regular PARS (SO125)]

PED

Program Evaluation Division [CBSA]

PGA

Participating Government Departments and Agencies

PHAC

Public Health Agency of Canada

QRG

Quick Reference Guide

RMD

Release on Minimum Documentation [for EDI, this includes OGD RMD (SO471) and Regular RMD (SO257)]

SO

Service Option

SOP

Standard Operating Procedure

SWI

Single Window Initiative

TB

Treasury Board

TC

Transport Canada

TCP

Trade Chain Partner

U.S.

United States

U.S. CBP

United States Customs and Border Protection

VP

Vice-President

WCO

World Customs Organization

Exhibits and graphs

Exhibits:

• Exhibit A: Description of analytical themes for 2012 TB submission deliverables
• Exhibit B: Number of interviews, by Government of Canada stakeholder group
• Exhibit C: Qualitative Data Analysis and Reporting
• Exhibit D: Field Research Locations Conducted by the CBSA PED
• Exhibit E: Roles of key stakeholders in the context of the SWI Implementation
• Exhibit F: SWI project governance structures
• Exhibit G: SWI Models by Respective PGAs

Graphs:

• Graph 1: SWI Budget from FY 2012 to 2013 to 2016 to 2017
• Graph 2: TCP clients certified and using the SWI IID significantly increased as of March 2019
• Graph 3: TCP survey respondents were mostly positive when comparing the SWI SOs to the…
• Graph 4: The use of the SWI IID (SO911), by TCPs, increased in FY 2019 to 2020
• Graph 5: Seven (13%) deliverables were not completed within project timelines

• Graph A: Volumes of commercial EDI release requests from FY 2016 to 2017 to FY 2019 to 2020

Note: The source for all Exhibits listed above, and all unlabelled boxes herein, is the analysis conducted by the Canada Border Services Agency’s (CBSA) Program Evaluation Division (PED) (i.e. a compilation of multiple lines of evidence).

Executive summary

Evaluation purpose and scope

The horizontal evaluation of the Single Window Initiative (SWI), led by the Canada Border Services Agency (CBSA), examined the SWI project implementation between Fiscal Year (FY) 2012 to 2013 and FY 2016 to 2017. This was supplemented with information up to November 2019.

The evaluation report presents the assessment of the intended benefits of the SWI implementation, as outlined in internal government documents, which are as follows:

1. improved information sharing within the Government of Canada
2. improved threat identification and risk management and
3. simplified border processes for the Trade Chain Partners (TCP) and the Government of Canada (including reduced administrative burdens for the TCPs)

Initiative description

The SWI was a horizontal initiative led by the CBSA, in collaboration with the following nine other Participating Government Departments and Agencies (PGA) which regulate commercial imports: Canadian Food Inspection Agency (CFIA); Canadian Nuclear Safety Commission (CNSC); Environment and Climate Change Canada (ECCC); Fisheries and Oceans Canada (DFO); Global Affairs Canada (GAC); Health Canada (HC); Natural Resources Canada (NRCan); Public Health Agency of Canada (PHAC); and Transport Canada (TC).

Each PGA, including the CBSA, had specific deliverables to complete to achieve the benefits of the initiative.

Evaluation Methodology

The evaluation team used qualitative and quantitative research methods and collected data through multiple data sources. These methods included:

• document review>
• operational, performance, and financial data
• semi-structured interviews with PGA program representatives
• field research at the CBSA’s regional offices
• a survey of TCP representatives and
• secondary data from a survey of CBSA commercial frontline personnel

Evaluation findings

Achievement of Benefit 1: Improved information sharing within the Government of Canada

Summary: The evaluation found that the Government of Canada, through the implementation of the SWI, benefited from an enhanced capability of the CBSA and the other PGAs to share information related to regulated commercial imports. Despite the benefits achieved, some SWI deliverables were not completed, leading to limitations to other PGAs’ abilities to exchange information with the CBSA.

Achievement of Benefit 2: Improved threat identification and risk management

Summary: The evaluation found that the Government of Canada, through the implementation of the SWI, benefited from a more collaborative process for threat identification and the management of potential risks related to regulated commercial imports. Nonetheless, the Government of Canada has not yet enhanced interdepartmental risk management for these goods and an integrated risk management framework was not included in the chosen project scope. This has limited the overall analytical capacity of the Government of Canada, including: distinguishing high from low risks; updating business rules; and leveraging commodity identifiers.

Achievement of Benefit 3: Simplified border processes for the Government of Canada and Trade Chain Partners

Summary: The evaluation found that the Government of Canada achieved a simplified border process (including reduced administrative burdens) for TCPs through the implementation of the SWI. The realization of this benefit was most apparent following project closure and subsequent to an increase in TCP certification and use of the SWI SOs from FY 2018 to 2019 to FY 2019 to 2020. TCP survey respondents reported that most aspects of the process for the importation of regulated commercial goods (e.g. the submission of Licenses, Permits, Certificates, and Other Documentation (LPCO)) have been streamlined. Conversely, the Government of Canada’s internal stakeholders (i.e. PGAs) were unable to fully benefit from a simplified border process, due to a series of ongoing challenges related to the implementation of the SWI (e.g. a lack of sufficient training for personnel involved directly in the commercial border process and the delayed onboarding of TCPs). Additionally, certain aspects of the commercial import process have become more cumbersome for some of these internal stakeholders.

Recommendations

The findings of the evaluation led to the following recommendations:

• R1. To deliver the stated benefits of the SWI, it is recommended that Health Canada (HC), the Public Health Agency of Canada (PHAC), Global Affairs Canada (GAC), and Environment and Climate Change Canada (ECCC):
  • a. review incomplete and partially complete deliverables for continued relevance and alignment with the intended benefits of the SWI for both the TCPs and the Government of Canada
  • b. develop and implement an action plan to complete the necessary deliverables and
  • c. report on the achievements of deliverables to the SWI interdepartmental forum.
• R2. It is recommended that the CBSA and NRCan individually develop and implement action plans to prioritize and resolve their unique internal IT systems issues.
• R3. To support the delivery of customized SWI training for all end-users, it is recommended that all PGAs:
  • a. assess the training needs of all PGA personnel (involved in the SWI for data analytics and/or release request decision-making) and identify gaps
  • b. create an action plan to deliver training to eliminate the identified gaps and
  • c. specifically, the CBSA should revise its current SWI training to provide hands-on training opportunities for the CBSA’s frontline personnel (This will require that the other PGAs provide the CBSA with the information needed to consistently apply PGA regulatory requirements at the border)
• R4. To support the future improvement of the Government of Canada’s border management, it is recommended that the CBSA, supported by the other PGAs:
  • a. establish an interdepartmental forum, led by the CBSA, to further support strategic collaboration across all PGAs in managing the issues stemming from the SWI import process for regulated commercial goods. This interdepartmental forum will focus on areas, including:
    • measurement of the achievement of SWI benefits for the commercial import process
    • impacts of the use of commodity identifiers to assess and manage the potential risks of regulated commercial imports
    • interdepartmental cooperation in support of effective and efficient commercial import examinations
    • collaboration in engagement with TCPs (e.g. report on progress and receive feedback)
    • training on, and communication of, PGA regulatory requirements and SWI IID requirements and processes and
    • management of the interdepartmental Request for Change process
  • b. Establish a process to provide progress updates on the results of the interdepartmental forum meetings to the appropriate governance body, identified by the CBSA

1. Introduction

1.1 Evaluation Purpose and Scope

This report presents the results of the horizontal evaluation of the Single Window Initiative (SWI). The horizontal evaluation, led by the Canada Border Services Agency (CBSA), was originally planned for Fiscal Year (FY) 2016 to 2017 but was granted an extension until FY 2018 to 2019 due to SWI implementation delays. The horizontal evaluation fulfills the requirements of the 2016 Treasury Board Policy on Results.

The horizontal evaluation examined the SWI project implementation between FY 2012 to 2013 and FY 2016 to 2017. This was supplemented with an assessment of SWI information up to November 2019, as the SWI IT solution was only fully implemented in March 2017. In particular, the horizontal evaluation assessed whether the SWI achieved a modernized and streamlined approach for the electronic submission and risk assessment of data for regulated commercial goods being imported into Canada.^{Footnote 1}

The implementation of the SWI was expected to deliver on the following benefits, as outlined in the 2012 Treasury Board Submission:

1. improved information sharing within the Government of Canada^{Footnote 2}
2. improved threat identification and risk management and
3. simplified border processes for Trade Chain Partners (TCP) (e.g. importers and customs brokers) and the Government of Canada (including reduced administrative burdens for TCPs)^{Footnote 3}

To assess the SWI implementation, within the context of the SWI benefits, the evaluation team examined the 2012 SWI Logic Model (Appendix C) and developed evaluation questions^{Footnote 4} (Appendix D) which focused on the following:

• the project deliverables that were established by each Participating Government Department and Agency (PGA) in the 2012 Treasury Board Submission
• immediate outcomes from the 2012 SWI Logic Model and
• other topics (e.g. outreach conducted by the Government of Canada with TCPs, training delivered internally, by each PGA, and SWI project expenditures)

1.2. Evaluation Methodology

The evaluation team used qualitative and quantitative research methods and collected data through multiple data sources. The data collection methods used included: document review; operational, performance, and financial data; 107 semi-structured interviews with PGA program representatives; field research at the CBSA’s regional offices; a TCP survey with 163 respondents; and secondary data from a survey of 610 CBSA commercial frontline personnel.

Evaluators from each PGA participated throughout the Horizontal Evaluation of the SWI as members of the SWI Intergovernmental Evaluation Working Group. In particular, they contributed to the coordination of data collection within their respective organizations in support of the SWI horizontal evaluation.^{Footnote 5}

The main limitation of the evaluation was the lack of operational/performance data available for the SWI, particularly during the five-year implementation period (due, in part, to delays in the SWI implementation). While program representatives undertook some performance reporting prior to and following project closure, access to data for the SWI SOs has and continues to be limited (e.g. solely volumetric).^{Footnote 6} The evaluation mitigated these challenges by extending the data collection period to November 2019 and by adding additional questions when interviewing Government of Canada stakeholders. Please refer to Appendix D for more details on limitations.

1.3 Background: The Single Window Initiative

The Beyond the Border^{Footnote 7} action plan was announced in 2011 by Canada and the U.S. as a joint commitment^{Footnote 8} to improve their collective security and to facilitate the flow of legitimate goods, services, and people at and beyond the Canada-U.S. border. The SWI was one of thirty-two priorities identified in this 2011 joint action plan.^{Footnote 9}

The SWI was a horizontal initiative led by the CBSA, in collaboration with the following nine other PGAs which regulate the import of commercial goods into Canada: Canadian Food Inspection Agency (CFIA); Canadian Nuclear Safety Commission (CNSC); Environment and Climate Change Canada (ECCC); Fisheries and Oceans Canada (DFO); Global Affairs Canada (GAC); Health Canada (HC); Natural Resources Canada (NRCan); Public Health Agency of Canada (PHAC); and Transport Canada (TC). Each PGA, including the CBSA, had specific deliverables to complete to achieve the benefits of the initiative.

1.3.1 The Government of Canada SWI IT Solution

Prior to the SWI, TCPs were required to transmit (on paper or electronically) import data for regulated commercial goods separately to most PGAs.^{Footnote 10} The Government of Canada implemented the SWI with the development of an IT solution.^{Footnote 11} This IT solution included Service Options (SO), designed to enable TCPs to electronically submit regulatory information (including licenses, permits, and other documentation) to all PGAs through a “single window.” Where possible, this would enable import declarations to be submitted through the SWI SOs prior to the arrival of commercial goods at the border. PGA information sharing models were also developed for PGA decision-making and were intended to facilitate the exchange of regulatory import information, across the PGAs, as well as admissibility recommendations (to the CBSA from the other PGAs, where applicable).

The SWI SOs were made available to some certified TCPs and some other PGAs, once released into production in March 2015. All nine PGAs and their associated programs were onboarded by March 31, 2017, marking project closure. Originally, the SWI was intended to be released into production in December 2014.^{Footnote 12} However, an official Request for Change was documented and approved, through the Transformation, Innovation, and Project Portfolio Committee, to delay this production date.^{Footnote 13} The Request for Change resulted from delays in the “baselining and delivery of R141 in addition to CBSA, PGA and Trade state of readiness.”^{Footnote 14}

While the horizontal evaluation focused on the use of the SWI SOs for the import of regulated commercial goods, TCPs were also permitted to submit release requests for non-regulated goods through the SWI SOs, following the launch of the Government of Canada SWI IT solution.

1.3.2 SWI Stakeholders

The key stakeholders involved in implementing the SWI were the ten PGAs (Section 1.3) and the TCPs. Each stakeholder had specific roles in supporting the initiative (Appendix E).

The CBSA, as the lead PGA for the implementation of the SWI, had the largest role. The CBSA’s Information, Science, and Technology Branch (ISTB) led the implementation of the SWI from April 1, 2012 to March 31, 2017. As of April 1, 2017, the SWI project transitioned to the then Programs Branch,^{Footnote 15} now known as the Commercial and Trade Branch (CTB). The CBSA’s ISTB continued to be responsible for technical requirements. The CBSA’s Other Government Departments (OGD) Programs Unit, within CTB, was responsible for continued governance, implementation, onboarding, and to increase TCP usage, following the transfer.

The TCPs involved in the SWI consisted of importers, customs brokers, and software/service providers. The SWI IID was designed to be used for the importation of goods into Canada in all commercial import modes (marine, rail, air, and highway).

1.3.3 Governance

The CBSA, as the SWI implementation lead, was the only PGA to have included governance in its 2012 TB submission deliverables. The CBSA used multiple governance structures with the objective of ensuring proper oversight, decision making, and authority amongst all SWI stakeholder groups throughout the lifecycle of the SWI project.

There were three key governance structures in place for the implementation of the SWI:

1. the governance structure for the Beyond the Border (BtB) initiatives,^{Footnote 16} which was leveraged to advise and to report on the state of the SWI implementation
2. an internal CBSA governance structure, which was used to ensure projects were appropriately managed at both the project and agency levels and
3. the interdepartmental governance bodies (e.g. SWI Project Management Working Group), led by the CBSA, which were used to facilitate engagement with the nine other PGAs.^{Footnote 17}

These three governance structures maintained committees and working groups with the aim of engaging SWI stakeholders and streamlining decision making (Appendix F).

1.3.4 Performance Measurement

As part of the SWI TB submission, the Government of Canada was responsible for establishing a Performance Measurement Framework for the initiative. The governance bodies (Appendix F) were responsible for measuring and reporting on SWI performance and the achivement of intended outcomes and benefits.

1.3.5 Deliverables

During the five-year implementation of the SWI, each PGA committed to completing specific project deliverables, in close collaboration with the CBSA and the other PGAs. These deliverables were intended to support the achievement of the SWI benefits. The number and nature of deliverables varied across the PGAs and were dependent on their respective needs and operational contexts. The other PGAs were responsible for the governance of their respective SWI deliverables.

For the horizontal evaluation, deliverables that supported similar issues were grouped into common themes for an analysis of the extent to which SWI deliverables were completed.^{Footnote 18} The list of analytical themes that were assigned to the SWI deliverables is in Appendix D (Exhibit A).

1.3.6 SWI Implementation Budget

In the 2012 TB submission for the SWI project, PGAs requested approximately $83.2M in funding to complete project deliverables (Appendix G).^{Footnote 19} In total, PGAs received a budget of approximately $78.2M between FY 2012 to 2013 and FY 2016 to 2017 (a variance of approximately $5M from requested funding). As the lead PGA, the CBSA received the largest allocation of funds, a total of $30.8M.

Graph 1: SWI budget from FY 2012 to 2013 to FY 2016 to 2017^{Footnote 20}

Source: Analysis by CBSA, PED. Evidence provided by PGA program representatives, summer 2019.

Table format

Graph 1: SWI budget from FY 2012 to 2013 to FY 2016 to 2017

Graph 1: SWI budget from FY 2012 to 2013 to FY 2016 to 2017

Department or agency	Total funds requested (TB Submission)	Total funds received (Budget)	Total spent (Actual Expenditures)	Base Variance
CBSA	$29,771,875	$30,843,833	$29,745,805	$1,098,028
HC	$13,760,000	$13,080,000	$10,889,485	$2,190,515
PHAC	$5,090,000	$5,090,000	$2,733,251	$2,356,749
ECCC	$10,939,999	$7,317,918	$4,989,257	$2,328,661
NRCan	$3,905,589	$3,905,589	$3,905,589	–
CNSC	$3,994,995	$3,710,000	$2,584,408	$1,125,592
GAC	$1,879,804	$1,715,857	$1,715,857	–
DFO	$1,600,600	$1,119,115	$787,810	$331,305
CFIA	$8,759,997	$8,600,000	$8,840,200	$180,200
TC	$3,449,585	$2,732,066	$2,218,808	$513,258

Overall, the Government of Canada implemented the SWI within budget (Graph 1).^{Footnote 21} This was related, in part, to delays in the SWI implementation timeline which caused lapsed funding for some PGAs.

2. Achievement of benefit 1 – Improved information sharing within the Government of Canada

To achieve the expected benefit for all PGAs to have “better information and improved information sharing” within the Government of Canada,^{Footnote 22} a commitment was made to review existing regulatory requirements and identify information for electronic conversion deemed essential for regulatory purposes. Furthermore, automated mechanisms were created so that the CBSA and the other PGAs could improve the electronic sharing of import data/information for regulated commercial goods. This section of the report focuses on the extent to which the Government of Canada achieved improved information sharing across PGAs, as a result of the implementation of the SWI.

Note: The issues related to information sharing between the Government of Canada also affect the achievement of Benefits 2 and 3.

2.1 Infrastructure for the electronic exchange of information

Prior to the implementation of the SWI, the technical infrastructure did not exist to enable the electronic exchange of information between many PGAs and the CBSA, as well as between most PGAs and TCPs. As the lead PGA, the CBSA delivered the central IT system needed to support the sharing of information between all SWI stakeholder groups. For this purpose, the CBSA modified its existing IT systems. This included developing the SWI Integrated Import Declaration (IID) (SO911) and the Document Imaging Functionality (DIF) (SO927) to provide TCPs a single portal through which to electronically submit import data and digital images for regulated commercial goods. Each of the other PGAs developed or modified their IT capabilities to enable them to exchange information with the CBSA’s IT systems to align with the CBSA information sharing models.

Note: The implementation of the SWI aligned with the United Nations Centre for Trade Facilitation and Electronic Business (UN/CEFACT) recommendation for governments to develop a single entry point system that disseminates information, where appropriate, to PGAs (Appendix H).

Through the Government of Canada’s SWI IT solution, all of the other PGAs now have the foundation to:

• share regulatory requirements with the CBSA, in the form of business rules, which are applied automatically by the CBSA’s IT systems when assessing regulated commercial import data and/or
• receive and send information (from/to the CBSA) on commodities that require the review and/or admissibility recommendation of other PGAs.^{Footnote 23}

2.1.1 Service options 911 and 927

What are they?

The SWI IID (SO911) is an electronic release SO that can be used by TCPs to submit information that meets all Government of Canada import requirements to obtain release of regulated commercial goods being imported into Canada.^{Footnote 24}

The DIF (SO927) enables TCPs to electronically submit digital images of Licenses, Permits, Certificates, and Other Documentation (LPCO). These images have replaced the need for TCPs to present the LPCOs in a paper format.

How do they work?

When TCPs use the SWI IID (SO911), they are transmitting the IID to the CBSA’s IT systems to request approval for their goods to enter into Canada (referred to as a “release request”). The CBSA’s IT systems, in turn, apply validation rules against the IID data and automatically transmit these data to the other PGAs responsible for regulating the goods being declared. In some cases, these data are transmitted to the other PGAs with the expectation that it will be reviewed and the other PGAs will return an admissibility recommendation to the CBSA (refer to Section 2.1.2).^{Footnote 25}

When TCPs use the DIF (SO927), they are transmitting a digital image to the CBSA’s IT systems. The DIF (SO927) is only used by TCPs, in conjunction with SWI IID (SO911), and when the verification of an LPCO image is needed to adhere with PGA requirements.

2.1.2 Information sharing models

What are they?

The other PGAs built IT system capabilities to align with one of three SWI models (Model 1, Model 1a, and Model 2) for exchanging information with the CBSA, and for providing admissibility recommendations (Model 1 and Model 1a only).^{Footnote 26} The decision to adopt Model 1, Model 1a, or Model 2, and on the extent of IID data to be transmitted by the CBSA, was made by each of the other PGAs, with consideration for the operational needs and resources of each of their PGA programs to support the model’s implementation (Appendix J). These decisions were formalized and documented in data sharing agreements and the business requirements documents developed collaboratively between the CBSA and the other PGAs.^{Footnote 27}

How do they work?

Model 1 (CFIA, TC^{Footnote 28})
The CBSA transmits a commercial release request that has been submitted through the SWI SOs (IID data and applicable LPCOs) with the other PGA. The other PGA actively assesses the SWI IID (SO911) in real time, based on their regulatory requirements, and transmits an admissibility recommendation to the CBSA. The CBSA requires that PGAs functioning as a Model 1 operate (i.e. can provide admissibility recommendations) on a 24/7 schedule. The CBSA transmits the transactional information (e.g. the final disposition) with the other PGA(s) in near-real time.

Model 1a (GAC)
The CBSA transmits a commercial release request that has been submitted through the SWI SOs (IID data and applicable LPCOs) with the other PGA. In certain instances, the other PGA actively assesses the SWI IID (SO911) in real time, based on their regulatory requirements, and transmits a response to the CBSA (e.g. permit validation, permit application approval, admissibility recommendation). For example, GAC was intended to operate as a Model 1a PGA for the purposes of permit application approval/validation. In these instances, the CBSA requires that PGAs functioning as a Model 1a operate on a 24/7 schedule. In some cases, the CBSA does not wait for an active response from the other PGA. Instead, the CBSA uses the other PGAs’ business rules (Section 3.1.2), housed within the CBSA’s IT systems, to render an admissibility recommendation/decision, and does so on behalf of the other PGA. In all instances, the CBSA transmits the transactional information (e.g. the final disposition) with the other PGA in near-real time.

Model 2 (CNSC, DFO, ECCC, HC/PHAC, NRCan, TC^{Footnote 29})
The other PGA does not provide an active admissibility recommendation to the CBSA for any commodity types. Instead, the CBSA validates the information submitted through the SWI IID (SO911), electronically, against the other PGAs’ business rules and/or reference data (e.g. valid permit numbers) provided to the CBSA by relevant, other PGAs. In most cases, the CBSA shares the transactional information (e.g. final disposition) with the other PGA in real-time. Otherwise, the CBSA transmits the transactional information with the other PGA post-release, through a batch process, using an Enhanced Pathfinder.^{Footnote 30})

2.2 Capacity of PGAs to share information for regulated commercial imports

Overall, 8 out of 15 SWI deliverables related to IT systems were completed in full. The PGAs that were successful in completing these deliverables included the CBSA, CFIA, TC,^{Footnote 31} CNSC, DFO, and NRCan (Appendix G).

Canada Border Service Agency (CBSA)

Through the SWI, the CBSA enabled its IT systems to automatically: receive TCP import data; exchange release request transactions with other PGAs to obtain admissibility recommendations (Model 1 and Model 1a only); and transmit near-real time transactional import data to the other PGAs. In order for this process to work as expected, the CBSA’s IT systems needed to be functioning, user-friendly, and connected to all of the other PGAs’ IT systems.

Canadian Food Inspection Agency (CFIA) and Transport Canada (TC)

The CFIA and TC both implemented the required technical changes to their internal IT systems to accommodate the secure sharing of information on regulated commercial imports. These two PGAs currently receive referrals and transmit admissibility recommendations on regulated commercial imports to the CBSA’s IT systems, as required. Both PGAs also receive near-real time SWI IID and LPCO data (transmitted by the CBSA’s IT systems).

Fisheries and Oceans Canada (DFO), Canadian Nuclear Safety Commission (CNSC) and Natural Resources Canada (NRCan)

DFO, CNSC, and NRCan completed deliverables related to implementing the IT systems capabilities to retrieve and access near-real time SWI IID data transmitted by the CBSA’s IT systems.

2.3 Challenges in sharing information for regulated commercial imports

Overall, 7 out of 15 SWI deliverables related to IT systems were incomplete or partially completed, with ongoing work required by some PGAs (Appendix G). ECCC, GAC, HC, and PHAC were unable to fully complete their IT system deliverables. These PGAs encountered specific challenges in sharing information with the CBSA and/or retrieving information transmitted by the CBSA. Additionally, some PGAs faced challenges with the use of their IT systems, despite completing their deliverables for the SWI.

Global Affairs Canada (GAC)

GAC is currently unable to electronically exchange information, as intended, with the CBSA. Specifically, GAC’s IT system was designed to validate import data and, based on the commodity, enable GAC to actively provide permit numbers to TCPs and admissibility recommendations to the CBSA. At present, GAC is unable to deliver this function. However, further development of GAC’s IT system for the SWI is underway.

Health Canada (HC) and Public Health Agency Canada (PHAC)

HC and PHAC shared resources and efforts to implement and manage the SWI. HC was responsible for producing the IT systems needed to enable both organizations to electronically exchange information with the CBSA. Challenges encountered following the implementation of the SWI affected both HC and PHAC PGA programs.

HC’s and PHAC’s Model for Information Sharing

At the outset of the SWI project phase, HC and PHAC intended to electronically exchange information with the CBSA using an approach similar to Model 1a (i.e. hybrid). As such, HC and PHAC planned to:

• share business rules (and license and permit information) with the CBSA, enabling the CBSA to render decisions on their behalf (as with Model 2 PGAs) after regular business hours and
• actively provide admissibility recommendations to the CBSA (as with Model 1 PGAs) during regular business hours

HC designed, built, and successfully tested an IT system (i.e. the “Referral Manager”) to ensure that HC and PHAC could exchange information with the CBSA as a Model 1a (i.e. IT capabilities of a Model 1 and a Model 2 PGA were functional). Delays in TCP onboarding and use of the SWI SOs limited the extent of testing undertaken by HC/PHAC of their internal IT system. Nonetheless, risks related to the functionality of the IT system were known and documented by HC/PHAC program representatives.

However, the CBSA requires that other PGAs functioning as a Model 1 or a Model 1a provide admissibility recommendations on a 24/7 schedule. This requirement ensures that the needs of the Government of Canada and TCPs for the processing of regulated commercial goods are met. As HC and PHAC did not meet this operational requirement,^{Footnote 32} it was decided that both PGAs would adopt a Model 2 approach (for all HC and PHAC regulated commodities). While in FY 2015 to 2016, HC/PHAC still planned on adopting a Model 1a approach, the decision to adopt a Model 2 approach was agreed upon by HC, PHAC, and the CBSA before the SWI IT Solution was fully implemented in 2017. The horizontal evaluation found that there was miscommunication and confusion in messaging between the CBSA and HC/PHAC.

Functionality of HC’s and PHAC’s SWI IT Systems

While HC’s IT system was considered functional, based on Model 1 and Model 2 test scenarios, potential risks to its functionality, once put into production, were documented. Testing was only completed prior to the full implementation of the SWI in March 2017, and before the majority of TCPs began using the SWI SOs (Appendix K)

Document review and interviews with HC and PHAC program representatives highlighted that HC’s IT systems require continual effort to achieve the envisioned functionality (including the internal referral and reporting databases). HC/PHAC program personnel have been unable to retrieve the near-real time SWI data (including IID data, LPCO images, and final disposition information) that the CBSA transmits to HC and PHAC. HC and PHAC continue to receive and have access to the post-release import data transmitted by the CBSA (i.e. for non-SWI SOs).^{Footnote 33} However, SWI SO data currently comprise the majority of electronic release request data.^{Footnote 34} To mitigate this situation, the CBSA continues to use fax, email, and/or telephone to share referrals with HC and PHAC on a case-by-case basis.

Example: Updates to license and permit information must be transmitted to the CBSA to ensure the effective processing of HC and PHAC-regulated goods. As a possible result of miscommunication between the CBSA and HC/PHAC, HC and PHAC did not (until recently) transmit these updates automatically and out-of-date information was being housed within the CBSA’s IT systems. In turn, SO911 release requests involving one or both of these PGAs resulted in TCPs receiving numerous, unnecessary rejects. CBSA program representatives reported that, to resolve these errors and to facilitate the border process for TCPs, the CBSA had to undertake a manual process of contacting HC to request the transmission of updated information for an active release request or following each reject. Once the issue was raised by the CBSA, HC IT automated the transmission process needed for the SWI (FY 2019 to 2020).

Canada Border Service Agency (CBSA)

BSOs use the CBSA’s internal IT systems to complete their portion of the commercial import process. However, the CBSA faced challenges in aligning the functionalities of internal CBSA IT systems with the SWI SOs. Based on interviews with the CBSA’s program representatives and frontline personnel, the CBSA’s IT systems (e.g. ACROSS) are considered “outdated.” This has created challenges for BSOs in viewing the information needed to process commercial release requests (refer to Section 4 for additional details). In interviews, CBSA program representatives also mentioned challenges in accessing SWI data, internally, due to limited SWI IID (SO911) reporting mechanisms. This was described as having limited their ability to report on performance (despite continued efforts to produce reports on the available volumetric data).

Environment and Climate Change Canada (ECCC)

ECCC has been able to retrieve the SWI data transmitted by the CBSA and electronic connections exist, internally, to support the segregation of and access to SWI data to ECCC’s PGA programs. However, further improvements are required to optimize data sharing and dissemination across ECCC’s IT systems and to fully benefit from improved information sharing as a result of the SWI.

Natural Resources Canada (NRCan)

NRCan experienced challenges in updating its internal IT systems,^{Footnote 35} which limited the department’s ability to share (with the CBSA) the information required to update its data reference tables.

2.4 Summary

Overall, the implementation of the SWI has enhanced the capability of the CBSA and the other PGAs to share information related to regulated commercial imports. However, incomplete (i.e. partially or in full) deliverables and other challenges related to internal IT systems have affected the ability of some other PGAs to electronically transmit information.

3. Achievement of benefit 2 – Improved threat identification and risk management

An expected benefit of the SWI was to “determine threats earlier and improve the risk management of goods imported into Canada.”^{Footnote 36} To achieve this benefit, the Government of Canada initially planned to develop an integrated risk management framework, including coordinated inspection protocols, and enhanced methods of commodity identification.^{Footnote 35} This section assesses the extent to which the approaches used by the Government of Canada to improve risk assessment and management under the SWI were achieved as planned.

Note: Limitations in achieving Benefit 1 (Section 2) also affected the Government of Canada’s ability to maximize the anticipated benefits of Improved Threat Identification and Risk Management (Benefit 2). Further, the realization of Benefit 2 affected the achievement of Benefit 3 (Section 4).

3.1 Methods for assessing and managing risks under the SWI

Overall, PGAs fully completed 12 of 16 SWI expected deliverables related to improving the assessment and management of risks (Appendix G).^{Footnote 37} Collectively, PGAs completed all of the SWI expected deliverables related to the improvement of IID data elements and commodity identification. A few of the deliverables related to PGAs’ analytical capacity were completed in full (3 of 7 deliverables).^{Footnote 38},^{Footnote 39}

The CBSA defines risk assessment as “the process used to determine the potential for or the existence of non-compliance and its effect on government objectives such as health, safety, security, and economy.”^{Footnote 40} Risk management is defined by the CBSA as “a multi-layered strategy to sort out suspicious persons, goods, or conveyances from the legitimate movement of people or goods.”^{Footnote 41} In turn, the Government of Canada manages potential risks and identifies high-risk goods and conveyances for further inspection with the use of pre-arrival information and intelligence.^{Footnote 42}

The evaluation found that an integrated risk management framework, with coordinated inspection protocols, was ultimately excluded from the chosen scope of the SWI project and was, therefore, not delivered. The option for the SWI project scope which included such a framework/protocol was not chosen for SWI implementation to ensure that the SWI project was delivered on time and within budget.

Nonetheless, the Government of Canada enhanced its capacity to collectively identify and assess the potential risks of commercial imports under the SWI through the:

• revision of the information collected to support commodity identification and
• internal, automated process (e.g. use of the other PGAs’ business rules) for assessing the compliance of regulated commercial imports

These aspects have enabled the use of more relevant and specific pre-arrival and post-arrival information (collected through the SWI IID) for performing facilitation and enforcement activities at the border.

3.1.1 Revised data elements and commodity identifiers

The Government of Canada assesses the potential non-compliance of commercial imports through, in part, the review of the import information submitted by TCPs. In the context of the SWI, the CBSA worked with the other PGAs to:

• revise the list of essential information (IID elements) required of TCPs when importing regulated commercial goods into Canada and
• improve the capacity of the IID to provide an accurate description of commodities

The purpose of the revision of IID data elements and commodity identifiers was to simplify the information that is required of TCPs, while collecting and providing more relevant information on regulated commodities to the other PGAs. Based on the revisions completed by the PGAs, the following are some of the data elements included in the SWI IID:

• transaction Control (e.g. cargo control number, PGA responsible, port of clearance, and transaction number)
• name and address identifier (e.g., importer, broker, manufacturer, and delivery party);
• LPCO related definitions (e.g. digital image reference, and document reference number) and
• commodity (e.g. commodity identifier, intended use, description of goods, and HS code)

With regards to commodity identification, the standard approach for identifying commercial goods involves the use of Harmonized Commodity Description and Coding System (HS) codes.^{Footnote 43} To supplement the use of HS codes, the SWI project included the development of new commodity identification methods. Eleven new commodity identifiers^{Footnote 44} were included in the SWI IID as potential data elements for TCPs to utilize. Some of the new commodity identifiers included in the IID are:

• United Nations dangerous goods code
• vehicle identification number
• automated import reference system end use and
• U.S. Food & Drug Administration product code

Note: HS codes are key data elements used by the Government of Canada to identify commodities. Developed by the World Customs Organization, they were originally designed for collecting tariffs and, in some cases, are not detailed enough to properly identify goods for risk assessment and compliance verification.

3.1.2 PGAs’ business rules: Enabling the automated assessment of commodities

Each of the other PGAs developedbusiness rules to document regulatory requirements and needs (e.g. risk tolerance levels). Under the SWI, certain PGA-developed business rules are housed within the CBSA’s IT systems and they are applied by the CBSA for the automated assessment of commercial goods. In this way, goods assessed as low-risk by the other PGAs’ business rules can be processed by the CBSA in a more expedited way, compared to goods identified as being high-risk or having specific regulatory requirements. The automated use of other PGA business rules lessened the burden on the CBSA BSOs to identify risks related to specific PGA-regulated commodities. Additionally, it allowed the Government of Canada, as a whole, to concentrate resources on assessing the admissibility of the regulated goods that pose a higher-risk^{Footnote 45} (i.e. compared to low-risk regulated goods).

While the other PGAs are responsible for defining and maintaining their business rules, the CBSA houses these business rules within its own IT systems. The other PGAs are required to abide by an established governance process (managed by the CBSA) to implement any required updates to their business rules. Furthermore, the effective application of business rules is dependent on accurate commodity descriptions provided by TCPs in the SWI IID. For this reason, the CBSA continues to actively engage with the other PGAs to further improve the existing methods for commodity identification and update business rules within the CBSA’s IT systems.

3.2 Challenges for assessing and managing risks under the SWI

The Government of Canada completed most deliverables^{Footnote 46} related to assessing and managing risk, as outlined in the 2012 Treasury Board submission. However, four out of seven deliverables related to the PGAs’ analytical capacity were incomplete or partially completed.^{Footnote 47} Deliverables under this theme were focused on improving the Government of Canada’s approach to the analysis of regulated import data. The other PGAs intended to implement systematic approaches to analyze SWI data for intelligence purposes and the identification of trends related to higher-risk commodities or shipments. While these approaches were not fully implemented as planned, representatives from most PGAs reported that SWI commercial import data have increased in volume (e.g. regulated and non-regulated). This has created the opportunity to enhance the analysis of commercial import data, given the breadth of information available.

Despite the implementation of the SWI, the Government of Canada continues to face challenges in improving its capacity to assess and manage the potential risks associated with regulated commercial imports, declared using the SWI SOs. The main challenges are related to:

• ensuring commodities are accurately identified
• enhancing the capacity of each PGA to leverage commercial import data for systematic analysis and
• the lack of a Government of Canada-wide approach for risk management

3.3 Summary

Through the implementation of the SWI, the Government of Canada has enhanced the automated verification of PGA regulatory requirements at the border. Risk assessment is now more collaborative, as the CBSA’s role in assessing and managing regulated commercial imports is supported closely by the other PGAs. As such, the CBSA reviews the import information once the other, relevant PGAs have provided automated admissibility recommendations based on their regulatory requirements. However, incomplete deliverables, particularly related to analytical capacity, have affected the ability of some of the other PGAs to update business rules and use commodity identifiers to assess and manage potential risks.

4. Achievement of benefit 3 – Simplified border processes for the Government of Canada and TCPs

In the 2012 Treasury Board submission, all PGAs committed to establishing “simplified border processes for [TCPs] and the Government of Canada that support [the] consistent and transparent application of regulatory requirements.”^{Footnote 48}

To achieve this benefit, the Government of Canada intended to improve commercial processes for PGAs and TCPs by:

• reducing administrative burdens and costs for TCPs, including eliminating redundant, duplicate, and paper-based processes
• providing a single channel for TCPs to submit import data for regulated, commercial goods and
• enabling relevant PGAs to provide admissibility recommendations to the CBSA, prior to the arrival of regulated, commercial goods at the border (where applicable)

Note: The achievement of simplified border processes for all stakeholders was affected by the extent to which Benefit 1 and Benefit 2 were achieved.

4.1 Simplified border processes for the Government of Canada

Overall, seven PGAs committed to deliverables related to business process improvements in the 2012 TB submission for the SWI. The completion of these deliverables contributed, in part, to the Government of Canada’s efforts to simplify border processes through the implementation of the SWI. The CBSA, CFIA, CNSC and DFO completed their deliverables related to business processes. Whereas, ECCC, HC, and PHAC did not fully complete these deliverables (Appendix G).

In addition to the completion of relevant deliverables, the following improvements were required to simplify border processes (including border management) for the Government of Canada:

1. streamlined and user-friendly IT systems functionalities which enable access to SWI IID data for risk assessment and other, analytical purposes
2. greater collaboration between the CBSA and the other PGAs and
3. further alignment of PGA regulatory requirements with the reduction of paper-based processes

4.1.1 Improvements to border processes

As described in Section 2 and Section 3, the Government of Canada delivered an IT solution for the SWI which enabled certain border process improvements for the government, as a whole. These improvements included: increased automation in the collaborative assessment and management of PGA regulatory requirements for commercial imports; and the conversion of 180 types of LPCOs from paper-based to electronic processes. Improvements also included greater collaboration in risk assessment practices across PGAs and an enhanced capacity to render admissibility recommendations/decisions for PGA-regulated goods. While some of these examples are indicative of the extent to which the Government of Canada achieved other benefits, they also highlight elements of the SWI implementation which have simplified border processes for internal Government of Canada stakeholders.

4.1.2 Challenges in improving border processes

Streamlined and User-Friendly IT Systems Functionalities

The CBSA’s IT Systems
During the evaluation field research, the CBSA’s frontline personnel raised numerous concerns related to the internal IT systems used to process SWI IID (SO911) release requests. These concerns included:

• the CBSA’s IT systems were not considered user-friendly. CBSA interviewees reported that the information derived from the SWI SOs was displayed in a cumbersome manner in the CBSA’s IT systems (e.g. ACROSS)^{Footnote 49}
• ongoing IT problems, which were not previously encountered with the legacy OGD SOs, were considered to have affected the reliability of the CBSA’s IT systems

The CBSA’s internal IT systems issues were exacerbated by a lack of hands-on training for CBSA frontline personnel (refer to Section 4.3.1). BSO interviewees reported a lack of familiarity with: the unique commercial business processes associated with the SWI IID (SO911); the location of key indicators (including risk indicators) within the IID data; and methods for accessing LPCO images submitted through the DIF (SO927). These challenges may have negatively affected the consistency (e.g. in applying PGA regulatory requirements) and timeliness of BSOs in processing release requests submitted through the SWI SOs.^{Footnote 50}

Example: Data from the SWI IID were not intended to be viewed using the existing CBSA IT systems. The SWI was originally planned to enter production following the implementation of eManifest (definition in Appendix B), which was to include a specialized “viewer” for SWI IID data. The purpose of this viewer was to support BSOs’ efficient and thorough review of SO911 release requests. However, the SWI was de-scoped from eManifest and implemented without the “viewer.” To address the concerns of frontline personnel, the CBSA has implemented a partial solution (i.e. a viewer) that now enables BSOs to view relevant SWI IID data and to make more informed admissibility recommendations/decisions.

Other PGAs’ IT systems

Some of the other PGAs (e.g. CFIA) benefitted from improved (e.g. more timely) processes for obtaining import declaration data and/or providing admissibility recommendations to the CBSA (in turn, simplifying border processes).^{Footnote 51} However, due to limitations with internal IT systems (Section 2), some of the PGAs were unable to integrate SWI IID data into their regular business practices (e.g. GAC) and streamline overall border processes.

Greater collaboration between the CBSA and the other PGAs

Coordinated exam and inspection practices

New business processes were introduced alongside the SWI SOs. These new business processes included amendments to coordinated examination and inspection practices. The evaluation found that there was a lack of clarity and accountability, amongst PGAs, related to these practices, at the border. This included, for example, reported uncertainty in the communication between PGAs on referrals, rejects, and exam notices (due to SWI-specific CBSA IT systems language and a lack of related training). This has resulted in ambiguity in the distinct examination roles and responsibilities of relevant PGAs’ frontline personnel when processing release requests transmitted through the SWI SOs. In some cases, this has also contributed to delays in the examination process. Government of Canada stakeholders reported that unnecessary delays specific to SWI SO release requests were of particular concern when shipments contained perishable goods or live animals.

Note: These challenges may have also affected the achievement of simplified border processes for TCPs, due to the costs associated with prolonged examinations such as, warehousing fees and the loss of perishable shipments. (This solely affects those TCPs with commercial imports held for examination.)

Unintended impacts on the workload of the CBSA's frontline personnel

Limitations in the interdepartmental management of commercial border processes restricted the Government of Canada from proactively addressing certain aspects of the SWI IT solution which had unintended impacts on the CBSA’s frontline workload:

• the business rules of the other PGAs were aligned with the risk tolerance levels of each department/agency. In select cases, the automated application of business rules (which rely on broad HS code categories) has resulted in increases in the auto-referral of low-risk commodities declared via the SWI IID (SO911) and, subsequently, increases in the exam workload of the CBSA’s frontline personnel^{Footnote 52}
• GAC’s IT systems remain incompatible with the CBSA’s IT systems for actively issuing permit numbers through the SWI IID (SO911). The permit numbers are currently issued separately, through a legacy service option. When processing SWI IID (SO911) release requests containing GAC-regulated goods, the CBSA’s BSOs must undertake additional steps to remove the associated permits from their worklists. Prior to the SWI, permits were removed automatically, once the CBSA had processed the relevant release requests ^{Footnote 54}

Example: The CBSA’s frontline interviewees reported that some low-risk commodities, such as finished granite products, were detected and referred for examination based on the application of CFIA business rules. In this example, granite products for tombstones were grouped under the commodity classification of “stone,” without a specific identifier for “finished” versus “unfinished.” This has resulted in backlog at some ports of entry and increased examination costs for TCPs.^{Footnote 53}

Unintended impacts on the workload of the CBSA’s program representatives

As the SWI project lead, the CBSA continues to maintain responsibility for collaborating with the other PGAs to implement changes to the Government of Canada SWI IT solution. Updates are often needed to simplify border processes for TCPs and PGAs. This, in turn, has an unintended impact on the workload of the CBSA’s SWI program representatives. Routine changes can include:

• updates to business rules specific to the other PGAs (some resulting from legislative changes)
• amendments to the other PGAs’ data elements (contained in the IID) and
• CBSA IT systems updates

Each of these changes can also affect the communication of SWI information to stakeholders (internal and external) through numerous key documents, such as: the CBSA’s internal Standard Operating Procedure (SOP); Operational Bulletins and Customs Notices; online tools; and webpages.

To monitor progress in implementing changes, the CBSA’s program representatives maintain a log of SWI-related concerns and requests. The log contains items that have been submitted by CBSA frontline personnel, TCPs, and the other PGAs. Additionally, there is a governance process in place to implement proposed changes to the business rules of the other PGAs. As these are housed within the CBSA’s IT systems, this process (i.e. Request for Change) is managed by the CBSA.

Timelines for the completion of requests are based on the nature and complexity of the changes required. At present, the process to implement changes to PGA business rules can take between six and 18 months. PGA representatives suggested that this process could be streamlined to better enable border process improvements and enhance collaboration between the CBSA and the other PGAs. Additionally, timelines are not always aligned with the operational needs of all SWI stakeholders.

Alignment of PGA regulatory requirements with the reduction of paper-based processes

Certain regulations are currently limiting the ability of some of the PGAs to fully dematerialize or digitize LPCOs. Despite the creation of a working group on legislation/regulations for the implementation of the SWI, ECCC and NRCan (for example) have not yet digitized all of their paper permits, declarations, and/or movement documents due to existing regulatory requirements. However, neither department expected to accomplish this task as part of the SWI project. The CBSA continues to work collaboratively with the other PGAs in this area. This limits improvements to commercial business processes for certain PGA programs and the Government of Canada’s ability to simplify the overall border process.

Example: The CBSA must undertake special procedures when processing release requests for goods regulated by certain PGAs (e.g. ECCC and NRCan). While the new procedures have been communicated to the frontline, CBSA interviewees reported that they have caused confusion amongst frontline staff, as they are contradictory to the processes previously undertaken by BSOs. In the past, CBSA BSOs would reject SO911 release requests containing regulated goods which required the presentation of paper permits. At present, BSOs must process the electronic SO911 release request and stamp the paper permit, when presented. According to CBSA interviewees, use of this “combination” (electronic and paper) process limits the intended benefits of paper reduction, slows down the processing of release requests, and results in duplication for the CBSA. These limitations affect all SWI stakeholders.

4.2 Simplified border processes for TCPs

The SWI was designed, in part, to create border process efficiencies for TCPs by removing the need to submit import information multiple times, to multiple PGAs. In turn, the onboarding (i.e. certification) of TCPs, and their use of the SWI SOs, was imperative to the achievement of simplified border processes for TCPs.

The percentage of TCP clients certified to use the SWI IID (SO911) first began to increase one year after SWI project closure, with approximately 22% of TCP clients certified as of March 2018 (Graph 2). The most significant increase in certification occurred between September 2018 and March 2019 (increase of approximately 58 percentage points, from 36% to 94% certification).

Graph 2: TCP clients certified and using the SWI IID significantly increased as of March 2019

Source: Analysis by CBSA PED. Data from the CBSA’s CTB and Technical Commercial Client Unit, December 2019.

Table format

Graph 2: SWI budget from FY 2012 to 2013 to FY 2016 to 2017

Graph 2: TCP clients certified and using the SWI IID significantly increased as of March 2019

	FY 2017 to 2018			FY 2018 to 2019			FY 2019 to 2020
	Apr 2017	Sep 2017	Mar 2018	Apr 2018	Sep 2018	Mar 2019	Apr 2019
TCP clients submitting IIDs	2	4	41	49	76	282	307
Budget (funds received)	0.61%	1.21%	22.02%	25.05%	35.56%	93.54%	98.99%

As of April 2019, approximately 99% of TCP clients were certified to use the IID. However, in the same month, 307 TCP clients submitted release requests through the SWI IID (SO911), representing approximately 61% of all certified TCP clients. Therefore, not all TCP clients that were certified immediately began to (regularly) submit release requests through the SWI IID (SO911). In order for TCPs to fully benefit from, or contribute to, simplified border processes they needed to adopt the SWI SOs as their exclusive means for electronically submitting release requests for regulated commercial goods.

4.2.1 Improvements to border processes

75% of TCP survey respondents reported that they were satisfied/somewhat satisfied with the Government of Canada’s commercial import process, as a whole.^{Footnote 55},^{Footnote 56} For example, most TCP survey respondents indicated that the introduction of the SWI improved the efficiency of the process for submitting LPCOs (Graph 3).^{Footnote 57}

Graph 3: TCP survey respondents were mostly positive when comparing the SWI SOs to the legacy OGD SOs

Source: Analysis by CBSA PED. Data from TCP Survey, July 2019.

Table format

Graph 3: TCP survey respondents were mostly positive when comparing the SWI SOs to the legacy OGD SOs

Graph 2: TCP clients certified and using the SWI IID significantly increased as of March 2019

	Disagree	Somewhat disagree	Somewhat agree	Agree	Not applicable
Overall, the introduction of the SWI service options has resulted in more efficient and streamlined border processes for my organization	24.10%	20.40%	38.00%	18.00%	0.00%
The process to submit a commercial release request is less onerous (less effort and time) through the SWI service options	35.00%	25.00%	26.00%	15.00%	0.00%
The Government of Canada provides more timely release decisions through the SWI service options	12.00%	19.00%	31.00%	39.00%	0.00%
The introduction of the SWI service options has reduced the requirement to communicate with multiple government departments and agencies to provide the same information	17.00%	23.00%	31.00%	29.00%	2.00%
The process for providing licenses, permits, certificates, and/or other documentation to the CBSA is more efficient through the SWI service options	5.10%	13.10%	33.00%	47.00%	2.20%
There are fewer administrative requirements, and paper-based processes (photocopying, faxing, etc.) through the SWI service options	20.00%	15.30%	22.00%	43.10%	2.00%

Timely border-related decisions

One of the planned immediate outcomes of the SWI is “timely border-related decisions.” This is of greatest benefit to TCPs, as their businesses depend on the timely import of their goods. 70% of TCP survey respondents reported that the Government of Canada provides more timely release decisions for the SWI IID (SO911), when compared to legacy OGD SOs.^{Footnote 58} Unfortunately, TCP perception (from the TCP survey) is the only reliable source on the timeliness of border-related decisions, due to a lack of performance data available during evaluation conduct, which prevented the evaluation team from undertaking further quantitative analyses.^{Footnote 59}

From November 2017 to March 2019, approximately 85% of SWI IID (SO911) release requests were processed within the CBSA’s 45-minute service standard for rendering a final admissibility decision.^{Footnote 60} The evaluation could not compare this finding with the processing times of legacy OGD release requests, due to lack of data. Additionally, the evaluation team found that the CBSA had not established a target for measuring the timeliness of border-related decisions (i.e. an acceptable percentage of total SWI IID (SO911) transactions processed within the 45-minute service standard).

4.2.2 Challenges in improving border processes

While the Government of Canada was successful in improving most aspects of the commercial border process for TCPs, TCPs still have some challenges in submitting release requests through SWI IID (SO911). The CBSA Audit Review of the SWI (2016), PGA interviewees, and TCP survey respondents highlighted the following areas of concern:

• cumbersome and duplicative reporting requirements
• new and/or additional technical challenges and
• lack of clarity in SWI IID rejection notices

Based on these concerns, 60% of TCP survey respondents found that the process for submitting release requests was not made less onerous (i.e. effort and/or time) following the implementation of the SWI SOs.

Cumbersome and duplicative reporting requirements

The Government of Canada consulted TCPs on IID data elements, during the SWI project phase. However, TCP survey respondents reported that the inclusion of certain additional data elements in the IID may have limited the realization of a simplified border process for TCPs. The CBSA continues to coordinate consultation processes to address concerns related specifically to the rationale for the inclusion of some new and additional data elements (per PGA), which do not appear to align with PGA regulatory requirements.

Example: A few PGA interviewees reported that certain data elements may have been included for statistical data collection, in addition to those needed to meet PGA regulatory requirements.

As mentioned in Section 4.1.2, other reporting requirements were not fully simplified for TCPs, such as the ongoing regulatory requirements of certain PGAs which continue to necessitate the presentation of paper LPCOs at the border.

Technical challenges and IT support

Most TCP respondents (74%) reported experiencing technical issues just as often/more often when using the SWI SOs.^{Footnote 61} While most TCP survey respondents were satisfied/somewhat satisfied with the technical support services provided by the Government of Canada,^{Footnote 62} they also referenced the need for more accurate and timely IT support. This may be linked to the inconsistent understanding of the functionality of the SWI SOs amongst Government of Canada personnel (Section 5.3).

Additionally, CBSA program representatives suggested that new or ongoing IT systems issues became more apparent following significant increases in TCP certification and use of the SWI SOs (Appendix K). These IT systems issues are being tracked by the CBSA.

4.3 Key Components to simplifying border processes for SWI stakeholders

The extent to which the Government of Canada was able to simplify border processes for TCPs and PGAs was dependent, in part, on the achievement of Benefit 1 and Benefit 2, as well as the successful delivery of the two following key components:

• delivery of training within the Government of Canada to increase knowledge and awareness of SWI operations and data amongst internal SWI end-users^{Footnote 63} and
• delivery of outreach to TCPs to increase their awareness and use of the SWI SOs.

4.3.1 Delivery of internal training

To support the Government of Canada in delivering simplified border processes for all SWI stakeholders, each stakeholder group was responsible for delivering internal, SWI-specific training to their staff (Appendix L) to achieve a level of knowledge and expertise aligned with their role within the commercial import process.

Note: In addition to the international standards and recommendations referenced in Appendix H, UN/CEFACT cites the importance of the following factors in ensuring the successful implementation of a Single Window project:

• accessibility and user friendliness
• comprehensive operating instructions and guidelines for users and
• delivery of practical training courses^{Footnote 1}

Training delivered by TCP companies to their internal, SWI end-users, was not within the scope of the horizontal evaluation. Therefore, it has not been assessed herein.^{Footnote 64}

Training delivery within the Government of Canada (i.e. all PGAs)

Given the varying roles of PGAs within the commercial import process, training needs differed by department/agency. However, no PGAs included the training of internal users as a deliverable in the 2012 TB submission (Appendix G). Additionally, training was not included in the SWI logic model.

Nonetheless, the delivery of comprehensive instruction and practical training were required to facilitate the delivery of a simplified border process for TCPs, as well as for Government of Canada stakeholders that are directly involved in the commercial import process.

CBSA

Based on the review of SWI project documentation, during the implementation of the SWI, the CBSA delivered a series of training activities to the Agency’s internal stakeholders. These included in-person training demonstrations (delivered in April 2015) and the following online tools:

• WebEx sessions and demonstration videos
• SWI Wiki Page and SWI Toolkit
• uestions and answers
• user guides and Standard Operating Procedures (SOP) (e.g. the SWI SOP, QRGs, ICS BSO Guide) and
• operational bulletins (OBs)

The concept of the SWI was incorporated into the Officer Core Commercial Training Program (OCCTP) during the project phase of the SWI.

Significant increases in the use of the SWI by TCPs from FY 2018 to 2019, onwards, provided CBSA frontline personnel with greater exposure to the SWI IID (SO911) in an operational context (Appendix K). However, hands-on training was not re-delivered after April 2015.

According to the survey responses from approximately 498 BSOs operating in the commercial mode, 69% responded they were dissatisfied, to some extent, with SWI training quality and timing (Appendix M).^{Footnote 65} Furthermore, 89% of commercial BSOs^{Footnote 66} and 74% of commercial manager/supervisor level^{Footnote 67} survey respondents reported that they had received no SWI-specific training.

Example: The CBSA is in the process of updating the SWI SOP, to provide more practical guidance on how to process release requests submitted through the SWI SOs. The CBSA’s program representatives reported that this update was developed in consultation with the Agency’s frontline personnel and other PGAs. However, due to internal publication limitations, the CBSA’s program representatives have encountered delays in publishing the update via the Agency’s internal webpage.

As a result of gaps (e.g. quality, adequacy, and timing) in the internal delivery of training, the CBSA’s BSO interviewees reported relying heavily on on-the-job, self-guided learning and knowledge sharing with experienced colleagues (Appendix M). Additionally, certain regions (e.g. Southern Ontario) developed local training tools to increase awareness and knowledge of the SWI amongst the CBSA’s frontline personnel.

The lack of hands-on training delivered to the CBSA’s frontline personnel was reported to have affected BSOs’ ability to perform everyday tasks, due to limited awareness of the functionality of the SWI SOs. This contributed to more cumbersome processes for BSOs, when assessing SWI IID (SO911) release requests.

Example: TCPs were provided with the Electronic Commerce Client Requirements Document (ECCRD) and the information for the SWI Helpdesk, by the Government of Canada. However, during interviews, BSOs reported receiving calls from TCPs who required technical support when submitting IIDs through SO911. Due to a lack of practical SWI training and the ad hoc communication of troubleshooting measures, CBSA frontline personnel were often ill-equipped to provide adequate assistance.

TCPs and other PGAs are reliant on the CBSA’s BSOs for the consistent, accurate, and streamlined processing of release requests for regulated commercial goods. As such, both groups were affected by the lack of SWI-specific training that was delivered to the CBSA’s frontline personnel.

Other PGAs

The horizontal evaluation found that most PGA representatives lacked a consistent and/or thorough understanding of the SWI, as well as of their role within the commercial import process for the SWI. This may have been a result of the quality, adequacy, and timing of the SWI-specific training delivered by each of the other PGAs, to relevant staff (Appendix M).

Based on interviews with representatives from the other PGAs, the following training was delivered by each PGA, internally, to SWI end-users:

• 1 of 9 PGAs (CFIA) reported providing SWI-specific training to all relevant personnel
• 3 of 9 PGAs (HC, PHAC, & ECCC) reported providing SWI-specific training to some relevant personnel and
• 5 of 9 PGAs (TC, GAC, CNSC, NRCan, & DFO) reported that they did not provide internal training to any personnel

Training delivery amongst the three Model 1 PGAs was, to some extent, in alignment with each PGAs’ role in the commercial import process.^{Footnote 68} This included:

• GAC – As GAC’s IT system for the SWI has not yet been fully implemented, training delivery was not undertaken. According to GAC program representatives, training may be valuable in the future, once internal IT system functionality has been aligned with the SWI
• TC – While classified as a Model 1 PGA, only one of TC’s two PGA programs is in practice a Model 1. The other TC program operates as a Model 2.^{Footnote 69} The processing of release requests for TC’s Model 1 PGA program is primarily automated. This may have reduced the relevance for SWI-specific training delivery for TC end-users and
• CFIA – The CFIA is considered the most active of the other PGAs. Therefore, the CFIA has more operational training requirements than many other PGAs. In order to ensure its continued relevance and applicability, training was delivered to relevant personnel within CFIA on multiple occasions throughout the implementation of the SWI

Amongst current, Model 2 PGAs, the extent of internal training delivery varied, based on an initial understanding of PGA program-specific needs:^{Footnote 70}

• CNSC – Representatives from CNSC reported that training was not delivered as it was not necessary for their operations
• HC and PHAC – Representatives from HC and PHAC reported conducting training multiple times in anticipation of regional personnel’s end-use of the internally developed IT systems for the SWI and
• ECCC, DFO, and NRCan – Some representatives within ECCC, NRCan, DFO, to whom internal training was not delivered, expressed that training would be beneficial moving forward and/or would enhance knowledge, transparency, and understanding of SWI data and its benefits

4.3.2 Delivery of outreach by the Government of Canada

The CBSA, CFIA, HC, and TC committed to and completed outreach deliverables, outlined in the 2012 TB Submission (Appendix G). However, a total of nine PGAs reported conducting outreach activities as part of SWI implementation.^{Footnote 71}

As the lead PGA, the CBSA was responsible for developing “communications products to assist importers with understanding border requirements.”^{Footnote 72} Additionally, the CBSA committed to conducting “consultations with the import community to identify only essential data for electronic conversion.”^{Footnote 73} The outreach deliverables of the CFIA, HC, and TC were centered on the CBSA’s outreach activities. For example, the CFIA promised to engage in outreach, “in cooperation with the CBSA,” and HC to “participate in CBSA led consultations with importers.”

Use of the SWI SOs by TCPs was considered critical to the achievement of the SWI’s intended benefits. In particular, for TCPs to fully benefit from the streamlined aspects of a simplified border process, TCPs had to adopt and use the SWI SOs. The Government of Canada’s outreach activities were developed and delivered to support the overall achievement of simplified border processes, with the objective of increasing TCP awareness and buy-in, and ensuring timely onboarding and use of the SWI SOs.

Outreach activities delivered

The Government of Canada began outreach activities with the TCPs in 2012. Across nine PGAs, the Government of Canada’s outreach efforts for TCPs included:

• e-mail communiques
• webpages
• participation in industry events and conferences
• consultative sessions and committees
• teleconferences and in-person meetings
• workshops and
• webinars

Due to delays in TCP certification and use of the SWI, and in response to the CBSA Audit Review of the SWI (2016), the CBSA developed an Adoption Strategy (November 2016) and the SWI Stakeholder Engagement Plan (March 2017). These documents formalized and outlined outreach strategies and provided a more focused approach, with detailed timelines, for the delivery of activities intended to further facilitate adoption of the SWI by TCPs.

Example: In collaboration with the other PGAs, the CBSA developed the following tools for external stakeholders, prior to project closure:

• SWI Trade Technical Design Sessions
• SWI Electronic Commerce Client Requirements Document (ECCRD)
• WebEx training
• Customs notices
• D-Memoranda
• participants Requirements Document for the DIF and
• SWI webpage

Impact of outreach on awareness and use of the SWI SOs by TCPs

Despite outreach conducted by the Government of Canada during the SWI project phase, minimal TCP onboarding (i.e. certification and use of the SWI SOs) was achieved prior to project closure in March 2017. Upon project closure, only one major business (of 500 TCPs) had completed the certification process for the SWI IID.^{Footnote 74}

The Government of Canada intended for SWI IID (SO911) release requests to comprise 30% of the total number of commercial release requests, by FY 2018 to 2019.^{Footnote 75} This target was not achieved. As it was not mandatory for TCPs to use the SWI SOs, many certified TCPs continued to use the legacy OGD SOs to submit release requests for regulated commercial goods.

Following project closure, additional outreach activities were undertaken to support TCPs in adopting the SWI and to increase awareness and use of the SWI SOs. This included the communication of decommissioning timelines for the legacy OGD SOs (considered an important factor in the realization of SWI benefits, refer to Section 5.4).

As of October 2019, SWI IID (SO911) release requests amounted to approximately 71% of all Electronic Data Interchange (EDI) release requests submitted in FY 2019 to 2020 (Graph 4). This reflected a marked increase from FY 2018 to 2019, during which SWI IID (SO911) release requests comprised approximately 10% of all EDI release requests. Nevertheless, the target of 100% use of the SWI SOs by April 2019, amongst TCPs importing PGA-regulated goods, has not yet been achieved. The CBSA’s program representatives anticipated that this target would be met following the decommissioning of the legacy OGD SOs (Section 5.4).

Graph 4: The use of the SWI IID (SO911), by TCPs, increased in FY 2019 to 2020^{Footnote 76}

Source: Analysis by CBSA PED. Data from the CBSA’s CTB and ISTB, December 2019.^{Footnote 77}

Table format

Graph 4: The use of the SWI IID (SO911), by TCPs, increased in FY 2019 to 2020

Graph 4: The use of the SWI IID (SO911), by TCPs, increased in FY 2019 to 2020

Fiscal year	OGD PARS – SO463	OGD RMD – SO471	PARS – SO125	RMD – SO257	IID – SO911
2016 to 2017	31.94%	4.57%	53.33%	10.12%	0.03%
2017 to 2018	26.30%	3.72%	61.76%	7.70%	0.52%
2018 to 2019	23.96%	3.46%	55.28%	7.33%	9.98%
2019 to 2020	4.95%	1.52%	17.91%	4.97%	70.66%

Overall, limited data were available to demonstrate a causal link between the Government of Canada’s outreach efforts and adoption of the SWI SOs by TCPs. As a result, recent increases in TCPs’ use of the SWI SOs could not be fully attributed to outreach efforts undertaken prior to or following SWI project closure.

Nonetheless, the conduct of outreach activities by the Government of Canada, following project closure, undoubtedly increased TCPs’ awareness of the SWI SOs. According to the evaluation team’s survey of TCP representatives, approximately 71% of TCP respondents participated, to some extent (i.e. rarely, occasionally, or frequently), in at least one type of outreach activity.^{Footnote 78},^{Footnote 79} However, overall, the evaluation found that the frequency of participation in outreach activities (i.e. participation per activity) was low amongst these TCP respondents.^{Footnote 80}

Most TCP survey respondents that participated in at least one outreach activity agreed/somewhat agreed that the activities in which they participated increased their awareness of the SWI.^{Footnote 81} The majority of these respondents also reported that outreach activities improved their level of comfort in managing/using the SWI SOs and increased their overall knowledge of import reporting requirements.^{Footnote 82}

4.4 Summary

Overall, the implementation of the SWI improved certain commercial business processes for the Government of Canada. This included the increased automation of the assessment and management of PGA regulatory requirements. Nonetheless, the Government of Canada has not yet fully achieved a simplified border process for its internal stakeholders (i.e. PGAs), as intended. This was due, in part, to specific challenges related to TCP onboarding, training for SWI end-users, IT systems functionality, duplicative/additional reporting requirements, and existing regulations, as well as other, overarching factors (Section 5).

The implementation of the SWI has simplified most aspects of the border process for TCPs importing regulated, commercial goods. For example, the introduction of the SWI SOs reduced administrative burdens for the TCPs, by eliminating many redundant, duplicative, and paper-based processes.

5. Conclusion: The future of the SWI

As part of the SWI, the Government of Canada created an IT solution which enabled TCPs to electronically submit release requests for commercial imports through a single point of entry. This has improved information sharing for most PGAs and has simplified the border process for the TCPs (e.g. reducing some administrative burdens). The SWI also delivered a platform that enabled more streamlined, flexible, and strategic collaboration across the Government of Canada. Nonetheless, the implementation of the SWI is only the first step in improving and modernizing the border process for all TCPs and PGAs.

In a fast-changing landscape for border management, the scope of the Government of Canada’s SWI IT solution continues to expand. The SWI SOs are now being used to process greater volumes of regulated and non-regulated commercial goods and the SWI IID (SO911) is expected to be used for non-commercial goods in the future. As a result, the Government of Canada will continue to collect more extensive and detailed sets of commercial import data through the SWI IT solution. This larger collection of data will support the Government of Canada in rendering more proactive decisions, adaptable risk management, and strategic policy through enhanced data analytics. Moving forward, increased collaboration across the PGAs will also be required to support and manage the SWI IT solution and the ongoing assessment of the admissibility of regulated commercial goods (e.g. risk management).

Additional work is required by all PGAs to fully realize the benefits of the implementation of the SWI and to solidify the gains made to-date.

5.1 Completion state of the SWI deliverables

While the PGAs (as a group) completed 38 of the 52 (73%) expected deliverables for the SWI implementation, seven (13%) were only partially completed, and seven (13%) were not completed (Graph 5).^{Footnote 83}

Graph 5: Seven (13%) deliverables were not completed within project timelines

Source: Analysis by CBSA PED. Evidence gathered from PGA documentation on 2012 TB submission deliverables.
Note: TC has an additional deliverable that was deemed “no longer relevant” by TC and, as such, has not been included in this graph or the analysis for the Horizontal Evaluation Report (Appendix G).

Table format

Graph 5: Seven (13%) deliverables were not completed within project timelines

Graph 5: Seven (13%) deliverables were not completed within project timelines

Department or agency	Number completed	Number partially completed	Unber not completed
CBSA	7	0	0
CFIA	5	0	0
DFO	5	0	0
CNSC	4	0	0
NRCan	2	0	0
TC	4	0	0
GAC	4	0	2
HC	5	3	2
ECCC	2	2	1
PHAC	0	2	2
Total	38	7	7

The status of some incomplete deliverables has prevented the Government of Canada from fully achieving the anticipated benefits of the SWI. Therefore, a review and assessment of partially completed or incomplete deliverables for continued relevance is required by some of the other PGAs. In particular, continued efforts are needed by certain PGAs to complete or update IT tools or internal systems/processes, as challenges in these areas have affected information sharing between some of the other PGAs and the CBSA.

Despite having completed all deliverables, the CBSA also encountered challenges with its internal IT systems, which limited the achievement of the SWI benefits.

5.2 Ongoing funding to support the SWI

The CBSA was the only PGA that received ongoing SWI funding ($1,341,315^{Footnote 84} beginning in FY 2017 to 2018). Despite the transfer of SWI-related responsibilities from the CBSA’s ISTB to CTB in March 2017, 94% of actual expenditures for FY 2017 to 2018 were spent by the CBSA’s ISTB, and overall project spending varied by 1.2% that year. From FY 2018 to 2019 onward, the CBSA merged SWI ongoing funds with regular program (A-base) funds. There has been no assessment, by any stakeholder or the horizontal evaluation, to determine whether these dedicated, ongoing funds have sufficiently supported the ongoing needs of the SWI.

Program representatives from five of the other PGAs reported that additional SWI-dedicated funds would be beneficial for the realization of SWI benefits, for their organizations.^{Footnote 85} Representatives from four of these other PGAs noted that, while the funds received for the SWI project were sufficient to complete most deliverables, continued efforts to improve internal business processes related to the SWI are limited due to lack of ongoing funds. For example, representatives from CNSC, ECCC, and NRCan noted that the lack of ongoing funds has posed challenges for the continual update and maintenance of regulations and IT systems.

Each PGA should consider dedicating (or seeking new) departmental/agency funds to optimize the realization of SWI benefits and to support ongoing SWI-related activities and improvements.

5.3 Training delivered within the Government of Canada

Overall, there is lack of understanding of the Government of Canada SWI IT solution, and its functionality, amongst all PGAs. In particular, the lack of hands-on, SWI-specific training for the CBSA’s BSOs was highlighted as an area of concern amongst all SWI stakeholders. This affected the achievement of all SWI benefits.

The delivery of SWI training within the Government of Canada, to relevant personnel, was inconsistent (and, at times, lacking) when compared to training needs (Appendix L). This was a factor which limited the:

• clarity and effectiveness of information sharing between PGAs within an operational context
• level of support provided to TCPs, by the Government of Canada, in adopting and utilizing the SWI SOs
• Government of Canada’s delivery on border management priorities (such as the consistent application of risk assessment practices and PGA regulatory requirements) and
• improvements to the Government of Canada’s commercial business processes

There is a need to enhance the knowledge and awareness of the SWI SOs (and the associated commercial border processes), across PGAs, to ensure that the Government of Canada has the capacity to manage increasing volumes of SWI SO release requests.^{Footnote 86} This may include, for example, additional SWI-specific training and guidance and further communication and collaboration between the CBSA and the other PGAs. Improvements in these areas would support a more cohesive, cross-government understanding of the SWI and the role of each PGA within the commercial import process.

5.4 Decommissioning of the legacy OGD service options

Despite the Government of Canada’s outreach efforts with TCPs, all SWI stakeholder groups pointed to one or more of the following three factors as having delayed TCP and PGA onboarding and having affected the overall realization of SWI benefits:

1. lack of (mandatory) requirement to onboard/use the SWI. In particular, no adoption strategy at the outset of the project (FY 2012 to 2013)
2. delayed project timelines, for example, in postponing the decommissioning of the legacy OGD SOs and
3. lack of guidance for Government of Canada stakeholders and for TCPs

The 2016 CBSA Audit Review, as well as the PGA interviewees, referenced the need to prioritize the processing of release requests submitted through the SWI IID (SO911) (over the legacy OGD SOs) to encourage use of the SWI by TCPs. Decommissioning of the legacy OGD SOs (i.e. OGD PARS and OGD RMD) was also recommended as a means of increasing use. For this purpose, the CFIA introduced an incentive policy, in which standard processing times no longer applied to release requests submitted through the legacy OGD SOs.^{Footnote 87} According to the TCP survey results, the anticipated decommissioning of the legacy OGD SOs was considered the most influential factor in TCP representatives’ (and their companies’) decision to adopt the SWI.^{Footnote 88} Furthermore, communication of decommissioning timelines was reported (through document review, interviews, and the TCP survey) as a key factor in TCPs’ ability to plan for and adopt the SWI SOs.

Example: For some PGAs, the implementation of the SWI increased the number of SOs for which PGA personnel were required to provide service. In turn, delayed decommissioning timelines limited the realization of SWI benefits for these PGAs, as they were required to continue to allocate resources toward maintaining the legacy OGD SOs.

The decommissioning of the legacy OGD SOs was originally scheduled to take place in April 2018. This was later delayed to April 2019, at which point the CBSA began a phased approach to decommissioning. Despite delays in the decommissioning timeline, the number of TCP clients using the SWI SOs increased between the latter half of FY 2018 to 2019 and the beginning of FY 2019 to 2020 (Graph 2). This increase may have been related (in part) to: the renewed and continual communication of decommissioning timelines (for legacy OGD SOs) with TCPs; and the CFIA’s and the CBSA’s adjustments to service standards for the legacy OGD SOs.

An anticipated completion date for the phased decommissioning of the legacy OGD SOs was set for August 2020.^{Footnote 89} The completed decommissioning of these SOs, alongside ongoing communication between the Government of Canada and the TCPs, is necessary to achieve the target of 100% use of the SWI SOs by TCPs importing regulated commercial goods.

5.5 Expanded use of the SWI service options

As the volume of release requests (e.g. regulated, non-regulated, and non-commercial) processed through the SWI SOs continues to increase, the challenges faced by the Government of Canada in realizing the benefits of the SWI will continue to evolve.

The growth in the volume of commercial release requests is due, in part, to the inclusion of non-regulated and non-commercial goods in SWI SO release requests. The expanded use of the SWI SOs has the potential to exacerbate ongoing issues (e.g. IT systems limitations) and affect information sharing and risk assessment within the Government of Canada, as well as the achievement of a simplified border process for all SWI stakeholder groups.

All PGAs would benefit from increased collaboration, coordination, and resource alignment to:

• support the Government of Canada’s responsibility to deliver on border management priorities and report on the SWI benefits
• create a more cohesive, government-wide approach to the maintenance of the SWI (e.g. facilitating the request for change process) and
• enhance government-wide coordination for managing commercial import risks

5.5.1 Governance and performance measurement

The implementation of the SWI has provided the Government of Canada with the structure to support interdepartmental collaboration in the processing of regulated commercial imports entering Canada.

The Government of Canada met the majority of international standards and recommendations related to governance, planning, and leadership (Appendix H) for implementing a single window system. However, limitations during the SWI implementation negatively affected the achievement of all the SWI benefits as:

• project timelines and the needs of all PGAs shifted throughout the implementation of the SWI^{Footnote 90}
• project governance was complex and the transition from the “project” area to the “program” area, by the CBSA, may have been premature, given the low rates of certification and use amongst TCPs, at the time and
• cross-government Performance reporting (on the achievement of SWI benefits) was limited during the project phase

Further engagement to simplify the current governance process for the SWI is required. As recommended by Treasury Board,^{Footnote 91} the governance of horizontal initiatives is expected to be intensified after an initiative is delivered. Therefore, the creation of a new governance forum, for all PGAs, to collaborate and communicate SWI updates, challenges, and every day business would allow the Government of Canada to work together more effectively. Additionally, strengthened governance and collaboration would support: well-defined roles and responsibilities of all PGAs; more strategic management for better balance and results; and enhanced performance measures to monitor and report on the achievement of the SWI benefits.

Example: To assess the achievement of simplifying border processes for the import of PGA-regulated goods during the project phase, the CBSA solely reported on: TCP onboarding and use of the SWI SOs; PGA onboarding; and the number of LPCOs converted into electronic format. In using these deliverables as evidence for the achievement of an anticipated benefit, the CBSA could not adequately demonstrate whether the implementation of the SWI streamlined border processes for the TCPs. It may be more beneficial to establish and monitor (amongst other dynamic performance indicators) targets for border-related decisions on SWI IID (SO911) release requests. CBSA program representatives presently report on the available volumetric IT systems data for the SWI SOs.

Concerns surrounding the measurement and reporting of the SWI performance were raised in the OAG report on the Beyond the Border Action Plan (2016).^{Footnote 92} The OAG report found that the CBSA, for example, had not developed performance indicators during the SWI project phase to assess the achievement of SWI benefits. Instead, the criteria that were developed focused primarily on whether an activity or deliverable was completed.^{Footnote 93} The OAG report recommended that the CBSA develop performance indicators to measure the achievement of SWI benefits. While the CBSA committed to and completed actions to address this recommendation, there is no evidence, to date, that suggests the SWI performance indicators that were developed were effective in measuring the SWI benefits. Nonetheless, the CBSA’s program representatives have continued to report on the available SWI volumetric data. Overall, these challenges have limited the horizontal evaluation in assessing the achievement of all SWI benefits, for TCPs and the Government of Canada.

More robust performance measurement related to the SWI SOs, as a component of the Commercial Program, will be vital, moving forward, as the volume of SWI IID (SO911) release requests continues to increase. This will allow for ongoing monitoring of and reporting on the benefits of the SWI to all stakeholder groups and more complex analyses of relevant and accurate data to support overall border management.

5.5.2 Risk management

Due to the effects of certain IT systems limitations on the sharing of electronic information (Benefit 1), some PGAs were unable to enhance their business intelligence. In some cases, they do not have access, internally, to the SWI data required to conduct analyses of commercial import patterns, trends, and/or potential areas of risk and concern.

Furthermore, the Government of Canada’s ability to fully achieve the SWI benefit of improving the collaborative risk management of regulated commercial imports was affected by the decision to exclude the development of an integrated risk management framework, and national PGA-CBSA coordinated inspection protocols, from the project scope for the SWI implementation.

To address the ongoing challenges related to verifying the compliance and managing the potential risks of regulated commercial imports, improvements to the following areas are required:

• secure exchange (sharing) of and access to SWI data / information across the Government of Canada
• further refinement of IID data elements based on necessity and value, to facilitate use of the SWI SOs by TCPs and to ensure the consistent and accurate identification of commodities by Government of Canada personnel
• alignment of other PGA risk tolerance levels with respective resources dedicated to border management (e.g. to support CBSA) and
• coordination of an interdepartmental approach to the management of risks (including PGA ability to leverage commercial data for analytics)

The launch of the Government of Canada SWI IT solution has automated and streamlined many aspects of the commercial import process for regulated goods. However, it is only the beginning. The SWI requires increased and continual interdepartmental collaboration, as well as engagement with TCPs, to support the Government of Canada’s future border vision. This includes a strengthened commitment to further automate the border process by using digital technology and data analytics to support effective (e.g. risk mitigating) commercial border processes and service delivery (e.g. timely admissibility decisions).

Moving forward, the effective, proactive, and functional management of the SWI, as a component of the commercial border process, will support the Government of Canada in establishing new and innovative measures to ensure the health, safety, and security of Canada and Canadians.

Appendix A: Management response and action plan

Appendix B: Evaluation definitions

CBSA IT systems: The IT systems housed, maintained, and used by the CBSA in support of the SWI. Example: CBSA BSOs use the CBSA’s internal IT systems when processing release requests submitted through the SWI SOs.

Compliance Verification: This term refers to the act of verifying compliance with the legislation administered by the CBSA in the areas of cargo and release. Verification may be in the form of random or targeted examinations, review of trade information, and periodic on-site audits or investigations. The compliance verification program carries out analyses and develops specific targets for cargo and release programs such as misdescription, enclosure, and other government departments, and measures and reports on levels of compliance in these areas. By monitoring these targets, the extent of compliance/non-compliance is assessed. These responsibilities are outside the Enforcement Branch mandate and, therefore, do not constitute “enforcement” activities.

Document Imaging Functionality (DIF): The functionality that was implemented, as part of the SWI, to enable the submission of LPCO images, when the LPCO data could not be dematerialized and included in the IID. For the CBSA, ICS is the interface used to view the LPCO image, when a TCP has submitted a release request via SO911 and SO927.

eManifest: The eManifest Portal is an option developed by the CBSA to allow TCPs to electronically transmit their pre-arrival information through the Internet.

(SWI) End-User: There are three categories of SWI end-users: 1) Personnel responsible for rendering admissibility recommendations and/or decisions actively, or on a case-by-case basis, as well as leveraging the data collected through the SWI SOs for analytical purposes; 2) Personnel responsible solely for leveraging the data collected through the SWI SOs for analytical purposes; and 3) (TCPs) Personnel responsible for submitting commercial release requests to the Government of Canada (i.e. responsible for data entry) through the SWI SOs.

Enhanced Pathfinder: Enhanced Pathfinder was developed as part of the SWI. It is a data/information sharing method, between the CBSA and the other PGAs, which comprises post-release, transactional data from the legacy service options, as well as from the SWI IID. This method was originally developed to support the other PGA programs (that had little import and export data, prior to the SWI) in identifying the data elements that they would require from the SWI IID. At present, two of the other PGA programs solely receive post-release SWI data through the Enhanced Pathfinder solution: 1) TC, Tires Program; and 2) ECCC, New Substances Program.

Enforcement: Enforcement is the act of compelling adherence to the law. Enforcement represents an essential tool in ensuring we meet our goal of compliance. It includes a wide range of activities (examination, audit, investigation, seizure prosecution, etc.) designed to detect, correct and deter non-compliance.

Examination: An examination is an inspection applied to goods, baggage, and conveyances for the purpose of appraisal or classification, to confirm a declaration made concerning goods, baggage, and conveyances, or to search for contraband or unreported or improperly reported goods.

Government of Canada’s SWI IT solution: The IT systems housed, maintained, and used by the CBSA and other PGAs in support of the SWI. Example: The Government of Canada’s SWI IT solution was developed to facilitate the exchange of information between all PGAs.

Other PGA Business Rules: Other PGA-developed business rules, housed within CBSA IT systems (such as, BRMS and ACROSS) and used by the CBSA, on behalf of the other PGAs, to assess commercial release requests.

Indicator (i.e. within a release request): A single piece of information, trend, abnormality, or inconsistency that, when added to other information or data, raises a concern to a targeting officer about the threat presented by a traveller or shipment. Indicators may be based on current or historical data, API/PNR information, ACI data, supplementary database information or other information.

Integrated Import Declaration (IID): The SWI service option (SO911) through which TCPs must provide all required import information electronically to the CBSA. In turn, the CBSA transmits this information to the PGA responsible for regulating the goods declared.

Intelligence: Intelligence is evaluated and analyzed information; information that has been studied, correlated, interpreted, and confirmed. The purpose of intelligence is to provide the user with knowledge of events that are likely to occur which are counter to the user’s aim. For CBSA purposes, intelligence concerns potential or actual risk situations of a tactical, operational, or strategic nature. For example, intelligence can forewarn of contraband concealment methods, conveyance routes, and modes of transportation, as well as the subjects involved in contraband smuggling.

Intelligence Data (or Information): Intelligence data forewarns of activities that are likely to occur.

Legacy Service Options: Prior to the implementation of the SWI, these were the primary service options used to submit release requests for OGD-regulated (SO463 and SO471) and non-regulated (SO125, SO257, and paper) goods.

Legacy OGD SOs: [Refer to definition for: Legacy Service Options] At the time of the horizontal evaluation conduct, the CBSA was in the process of decommissioning the legacy OGD EDI service options OGD-PARS (SO463) and OGD-RMD (SO471).

Model 1 (Active): The CBSA transmits a commercial release request that has been submitted through the SWI SOs (IID data and applicable LPCOs) with the other PGA. The other PGA actively assesses the SWI IID (SO911) in real time, based on their regulatory requirements. Following this assessment, the other PGA transmits an active (live) admissibility recommendation to the CBSA. The CBSA requires that other PGAs functioning as a Model 1 operate (i.e. can provide admissibility recommendations) on a 24/7 schedule. The CBSA then shares the transactional information (e.g. the final disposition) with the other PGA in near-real time. The PGA is responsible for sorting and storing the SWI data, once received.

Model 1a (Hybrid): The CBSA transmits a commercial release request that has been submitted through the SWI SOs (IID data and applicable LPCOs) with the other PGA depending on the commodity types. For these commodity types, the other PGA actively assesses the release request based on their regulatory requirements. Following this assessment, the other PGA transmits an active (live) recommendation to the CBSA (e.g. permit validation, permit application approval, admissibility recommendation). In these instances, the CBSA requires that other PGAs functioning as a Model 1a operate (i.e. can provide recommendations) on a 24/7 schedule. For other commodity types, the CBSA does not wait for an active (live) recommendation from the other PGA. Instead, the CBSA uses the other PGAs’ business rules, housed within CBSA IT systems, to render an admissibility recommendation/decision, and does so on behalf of the other PGA. For all commodity types, the CBSA transmits the transactional information (e.g. the final disposition) with the other PGA in near-real time. The PGA is responsible for sorting and storing the SWI data, once received.

Model 2 (Passive): The other PGA does not provide an active (live) admissibility recommendation to the CBSA. Instead, the CBSA validates the information submitted on the SWI IID (SO911), electronically, against the other PGA’s business rules, housed in the CBSA IT system. The CBSA does not wait for an active (live) admissibility recommendation from the other PGA. In most cases, the CBSA transmits the transactional information (e.g. final disposition) with the other PGA in real-time. The PGA is responsible for sorting and storing the SWI data, once received. In some cases, the CBSA transmits the transactional information with the other PGA post-release, through a batch process, using an Enhanced Pathfinder. The frequency that data is provided to the other PGA, via the batch process, is dependent on the established needs of the other PGA.

Other PGAS: All Participating Government Departments and Agencies (PGA) in the SWI, excluding the CBSA.

PGAs: All Participating Government Departments and Agencies (PGA) in the SWI, including the CBSA. PGAs or all PGAs are also referred to as “the Government of Canada.”

Pathfinder: The (legacy) Pathfinder was first implemented in 2010, and is a data/information sharing method, between the CBSA and other PGAs, which comprises post-release, transactional data from the legacy service options. The Pathfinder was expanded (refer to Appendix B, Enhanced Pathfinder) in June 2016 to include the sharing of SWI data/information for certain other PGA programs.

Referral: A referral is the result of designating selected persons, conveyances, and/or goods for further customs processing; most commonly from primary to secondary for activities such as payment of duties and taxes, examination, etc. There are three types of referrals:

• Mandatory Referral – A referral that a Border Service Officer must make for further documentation or examination, whether it is for CBSA purposes or for that of other government departments. Mandatory referrals can be based on a specific lookout or target, an alert, a computer generated “hit”.
• Random Referral – Referrals based on a system, sometimes computer generated, which selects shipments and persons for examination in an indefinite pattern.
• Selective Referral – A referral that a Border Services Officer makes to the secondary inspection area following the establishment of point of finality because they have reasonable grounds to suspect that additional examination or investigation is necessary to make a decision on release.

Release Request: TCPs submit release requests to the CBSA for the importation of commercial goods. When submitted through the SWI SOs, release request data is also sent to other relevant PGAs. Through the SWI, Model 1 PGAs and the CBSA assess the information contained in the SWI IID and, when available, the LPCO image, to determine admissibility. The following terms are used to denote final dispositions on admissibility: Released, Abandoned, Destroyed, Seized, Refused Entry, and Refuse Exit.

Resultant: A “resultant” examination is a situation whereby the CBSA has identified, during the examination process, a contravention to the Customs Act and/or any other act of Parliament administered or enforced by the CBSA on behalf of other government organizations. An examination is resultant if any one or more of the following actions occur during an examination:

• seizure
• administrative and Monetary Penalty System
• ascertained Forfeiture
• notice of Determination and/or
• inadmissible goods, by the CBSA’s or OGDs’ determination, that are ordered removed from Canada or sent for destruction

Risk: Risk is the chance of an event occurring that will adversely affect compliance with the CBSA mandate and/or the mandates of the other PGAs. Risk is measured in terms of probability, magnitude, and the significance of the loss or the injury. The level of risk is determined from the relationship between the likelihood of the event occurring and the consequences should the event occur, using both qualitative and quantitative factors.

Risk Assessment: This refers to the process used to determine the potential for or the existence of non-compliance and its effect on government objectives such as health, safety, security, and economy. Risk assessment involves the identification, collection, and analysis of information pertaining to the risk, and the development of hypotheses on the nature of the threat. Judgments are made on the likelihood of non-compliance, the level of impact on Canadian society, and the relative degree of risk. A level of risk is assigned based on the degree of damage that could occur should non-compliance remain undetected and corrective measures not be taken. In the CBSA environment, there are three levels of risk:

• High – Will cause serious social or economic damage to the well being of Canadians. Requires close management and preparation of a formal plan to manage the risk.
• Medium – Likely to cause some damage that will have an impact on socio-economic objectives. Requires some action, such as formal and informal plans to address, control, and diminish the risk.
• Low – Unlikely to cause much damage or damage will not significantly impact policy or objectives. Requires some action, such as formal and informal plans to address, control, and diminish the risk.

Risk Indicator: A risk indicator differs from an “indicator” as it is not for a specific good, commodity, or conveyance. An example of a risk indicator is “a first time importer.” If a particular business number appears as a first time importer, a target for the person, goods, and/or conveyance could be input.

Risk Management: This is a systematic method of identifying, evaluating, and controlling potential adverse events and consequences. Risk is measured in terms of probability, magnitude, and the significance of the loss or injury. In the customs environment, risk management is a multi-layered strategy to sort out suspicious persons, goods, or conveyances from the legitimate movement of people or goods. This strategy is focused on the use of good strategic and tactical intelligence, but also relies heavily on the screening of advance pre-arrival information to select high-risk persons, goods, or conveyances for inspection. It allows us to achieve compliance with legislative requirements through a blend of facilitation and enforcement. It also provides management with concrete information to make decisions on existing and emerging threats and to allocate resources to high-risk areas.

SWI Project Closure: The SWI project was closed, as the project owners determined that it had been completed within the predetermined time, scope, and budget outlined in the SWI Interdepartmental Business Case. This included the launch of a SWI IT solution, available to all identified stakeholders that were informed, consulted, and trained throughout the process.

Appendix C: SWI logic model (2012)

Discription for Logic model – BtB – Single window initiative

Mandate

Create a streamlined approach for the collection, dissemination, and risk assessment of import-related commercial trade data between the Government of Canada and the import community

Inputs

Funding, IT infrastructure, FTEs, WCO Data Model, PGA Participation

Activities and Outputs

The activities and outputs for the SWI are distinguished into three separate groups: the Development / Maintenance group, the Collaboration / Partnerships group, and the Delivery group. Each activity leads to a series of outputs.

A. Development / Maintenance

• i. Activities: Develop and maintain policies, procedures, legislation and regulations, and corporate reporting.
• i. Outputs: Policies, Standard Operating Procedures, Legislation, Regulations, Governance Framework, Cabinet Documents, Performance Measures, Service Standards, Reports.
• ii. Activities: Enhance, develop, implement and maintain data, business processes, and IT systems.
• ii. Outputs: Extended Pathfinder, Standardized and aligned data model, commodity ID, reengineered business processes, IT systems (support), and data quality reports.

B. Collaboration / Partnerships

• i. Activities: Conduct outreach activities.
• i. Outputs: Outreach Strategy, outreach materials, and information workshops.
• ii. Activities: Collaborate with domestic and international partners. Develop and maintain partnerships with the trade community.
• ii. Outputs: Identified minimal essential data elements, Harmonized US/Canada import data requirements, and Written Collaborative Agreements.

C. Delivery

• i. Activities: Receive Integrated Import Declarations (IIDs).
• i. Outputs: Import data and permit verification.
• ii. Activities: Transmit information to PGAs.
• ii. Outputs: PGA risk assessments, PGA risk management, and PGA risk recommendations.
  1. Note: This is not “integrated risk management.” This represents each individual PGA risk management processes.
• ii. Additional outputs: Release, Referrals, Inspections, and Trigger post-border processes.

Immediate Outcomes

[Associated with activities under Activity and Outputs groups “Development / Maintenance,” and “Collaboration / Partnerships.”]

• Enhanced capacity to electronically receive and exchange all information required to comply with customs and government regulations
• Increased awareness by the Trade Community
• Business process improvement
• Increased alignment of Canadian import processes to US and International standards

[Associated with activities under Activity and Outputs group “Delivery.”]

• Efficient risk assessment and management by PGAs and the CBSA
• Timely border-related decisions

Intermediate Outcomes

[Associated with Immediate Outcomes “Enhanced capacity to electronically receive and exchange all information required to comply with customs and government regulations,” “Increased awareness by the Trade Community,” “Business process improvement,” and “Increased alignment of Canadian import processes to US and International standards.”]

• Streamlined border processes

[Associated with Immediate Outcomes “Efficient risk assessment and management by PGAs and the CBSA,” and “Timely border-related decisions.”]

• Increased identification and control of regulated imports

Ultimate Outcomes

[Associated with Intermediate Outcome “Streamlined border processes.”]

• Maximize the opportunity to increase our economic competitiveness

[Associated with Intermediate Outcome “Increased identification and control of regulated imports.”]

• Ensuring the integrity of the import program

PAA Link: Increased capacity to focus on high-risk goods at the ports of entry.

CBSA Strategic Outcome

International trade and travel is facilitated across Canada’s border and Canada’s population is protected from border-related risks.

Appendix D: Evaluation methodology and data limitations

The Single Window Initiative (SWI) has an approved logic model and performance measurement framework. These were developed in 2012, as part of the planning phase for the implementation of the SWI. Both documents were updated in 2015. The Canada Border Services Agency (CBSA) Program Evaluation Division (PED) consulted these performance measurement tools during the development of the evaluation project scope and for the development of the evaluation plan.

The evaluation plan, which included the evaluation questions, was developed based on the evaluation scope (refer to Section 1) and the SWI logic model (Appendix C), in consultation with two groups:

• the SWI Interdepartmental Evaluation Working Group (IEWG) comprising evaluators from the other Participating Government Departments and Agencies (PGA) and
• the CBSA’s SWI Evaluation Advisory Committee comprising key CBSA stakeholders

The evaluation team also consulted the CBSA’s SWI Subject Matter Experts (SME) to identify a process for accessing and analyzing SWI data and information. This group of SMEs formed the Office of Primary Interest (OPI) and the Office of Secondary Interest (OSI) networks.

Evaluators from other PGAs (i.e. IEWG members) coordinated the exchange of information and data between their SWI SMEs and the CBSA PED. This relationship allowed the CBSA PED to collect other PGAs’ SWI data, as well as schedule interviews with key stakeholders from the other PGAs.

Evaluation Questions

The evaluation questions are, for the most part, aligned with the anticipated benefits of the SWI. The following evaluation questions were developed to guide the assessment of the achievement of SWI benefits, as well as additional overarching issues.

Overarching Issues:

• to what extent did the 10 PGAs complete the expected project deliverables as listed in the 2012 TB Submission?
• to what extent did changes to planned project deliverables (delayed completion, incomplete deliverables, etc.) have an impact on the implementation of the SW and the achievement of immediate outcomes?
• what can be done to better achieve the SWI outcomes?
• what impact did any variances between planned and actual resourcing have on implementation of the SW?

Benefit 1: Improved information sharing within the Government of Canada

• for whom and to what extent has the introduction of the Single Window facilitated information exchange on border decisions related to the importation of regulated goods?

Benefit 2: Improved threat identification and risk management

• To what extent has the implementation of SW improved the ability of the PGAs to manage their programs, in terms of risk assessing and ensuring compliance with requirements for importing regulated goods?

Benefit 3: Simplified border processes for Trade Chain Partners and the Government of Canada (including reduced administrative burdens for Trade Chain Partners)

• to what extent have outreach activities conducted by all PGAs resulted in increased awareness, onboarding, and use of the SW service option and increased knowledge of import requirements by the Trade Chain Partners (TCPs)?
• what were the barriers, facilitators and other root causes that influenced the uptake and engagement of TCPs in terms of using the SW?
• has SW facilitated more timely admissibility decisions on regulated imports, both pre-border and at the border?
• how has the availability, timeliness, and quality of SW training for PGA end-users impacted the effectiveness of the SW?
• to what extent has the introduction of the SW streamlined the process for TCPs to import regulated goods into Canada?
• to what extent has the introduction of the SW improved the efficiency of the business process for the GoC to facilitate the importation of regulated goods into Canada?
• to what extent has the SWI aligned with other CBSA commercial initiatives to gain additional efficiencies for PGAs and TCPs?
• to what extent have relevant import processes for regulated goods been aligned with US and International Standards?

Data collection methods/sources

Multiple data collection methods and sources were used to address the evaluation questions, including:

• document review
• financial and operational data
• semi-structured interviews with Government of Canada stakeholders
• field research and
• surveys

The evidence that was collected based on the above-mentioned methods and sources was compiled and analyzed, as a whole. The common themes that emerged from multiple lines of evidence contributed to the development of preliminary evaluation findings. These findings, alongside the evidence that informed them, were presented to the OPI/OSI networks, the CBSA SWI EAC, and the SWI IEWG, for review and input. The feedback from these consultations was incorporated, where relevant, into the final evaluation report and recommendations.

Document review

The document review took place throughout the evaluation project, from the planning to the examination phases. It was used to inform the evaluation scope, plan, and questions. Over 100 documents were reviewed, including internal CBSA project documents and those shared by the other PGAs. Documents were reviewed systematically and, where appropriate, evidence was compiled and used to inform and address the evaluation questions.

Financial and operational data

The CBSA PED collected and analyzed financial and operational data from all PGAs (this includes the CBSA).

Financial data

For the analysis of financial data, the CBSA PED collected information on the SWI budget and expenditures. The analysis focused on assessing trends in expenditures across all PGAs throughout the lifecycle of the SWI project (i.e. Fiscal Year (FY) 2012 to 2013 to 2016 to 2017). For the CBSA, the analysis included the additional funds received in FY 2017 to 2018 (the CBSA was the sole PGA to receive ongoing funding).

Operational data

The analysis of operational data included:

• the completion status of the SWI project deliverables outlined in the 2012 TB Submission and
• the commercial release request data collected from the CBSA’s IT systems

The analysis of the SWI deliverables assessed whether or not each PGA completed the commitments outlined in the 2012 SWI TB Submission. Data sources for this analysis included: the SWI TB Submission; PGA Project Closure Reports; documentation on PGA outreach efforts; and spreadsheets completed by all PGAs on the state of completion for each deliverable. To support this analysis, the evaluation team grouped the deliverables of all PGAs into common analytical “themes” (Exhibit A).

The operational data was provided to the CBSA PED by the CBSA’s Commercial and Trade Branch (CTB) and Information, Science and Technology Branch (ISTB). Data originated from the CBSA’s IT systems based on release requests submitted by TCPs through the SWI IID (SO911), from October 2017 to October 2019. Due to limitations associated with the CBSA’s internal reporting tools for SWI IID data, CBSA stakeholders advised the CBSA PED that a direct pull of data from CBSA IT systems would affect the validity of results.

Semi-structured interviews with Government of Canada stakeholders

Interviews were conducted in-person or via teleconference with SMEs from each PGA, including the CBSA (Exhibit B).

In advance of the interviews, interviewees received semi-structured interview guides comprising an outline of key issues and questions for discussion. The topics discussed during interviews varied based on the participant’s position (e.g. Director, Manager, Program Officer) and nature of engagement with the SWI (e.g. designing and delivering the SWI, participating in training as an instructor or trainee, or assessing TCPs’ release requests). Most interviews took place between June 2019 and October 2019.

The interview data was analyzed with the support of the qualitative data analysis software, NVivo. Based on the evaluation questions and emerging themes from interviews, the CBSA PED developed a hierarchy of “codes” (i.e. themes and sub-themes) to analyze the interview data. Results from this content analysis were discussed amongst the CBSA’s horizontal evaluation team members to ensure that the data were interpreted in a consistent and accurate manner. Where appropriate, qualifiers were used to describe interview results based on the proportion of interviewees associated with a given insight or finding (Exhibit C).

Exhibit C: Qualitative Data Analysis and Reporting

Scale	Response Percentage Range
All	The shared views, opinions, or experiences of 100% of the respondents
Most	The shared views, opinions, or experiences of 75% - 99% of the respondents
Many/Majority	The shared views, opinions, or experiences of 56% - 74% of the respondents
Half	The shared views, opinions, or experiences of 49% - 55% of the respondents
Some	The shared views, opinions, or experiences of 25% - 48% of the respondents
A few	The shared views, opinions, or experiences of 1% - 24% of the respondents
None	The shared views, opinions, or experiences of 0% of the respondents

Field Research

The CBSA PED carried out field research at select ports of entry and inland offices (Exhibit D).

Exhibit D: Field Research Locations Conducted by the CBSA PED

CBSA Region	Time-period	Ports of Entry	Modes addressed
Atlantic (multiple cities, New Brunswick & Nova Scotia)	Jul 29 to Aug 3, 2019	7 POE	Air, Land, Marine
Prairie (multiple cities, Manitoba)	Aug 12 to 16, 2019	4 POE	Air, Land,
Greater Toronto Area and Southern Ontario (Windsor and Toronto, Ontario)	Sep 16 to 19, 2019	3 POE	Air, Land, Marine
Pacific (Vancouver, British Columbia)	Phone interviews in January 2020	2 POE	Marine

Field research was planned and executed in coordination with the Evaluation of the Commercial Program. This strategy (i.e. combined field visits) was intended to reduce costs and the burden on the CBSA’s commercial frontline personnel. As such, the CBSA PED conducted evaluation activities (such as, interviews and job shadowing) based on the combined interests of both evaluation projects. The following CBSA ports of entry and offices were visited in each region:

• Atlantic Region: Woodstock; St. Leonard; St. Stephen; Saint John; Suzie Lake (Halifax Commercial Operations), Halifax; Halifax Stanfield International Airport (HSIA), Halifax; Waterfront Cargo Inspection Unit, Halifax
• Greater Toronto Area & Southern Ontario Regions: Windsor-Detroit Tunnel; Ambassador Bridge, Windsor; Commercial Operations District, Toronto Pearson International Airport; and
• Prairie Region: Emerson Commercial; Crystal City; Snowflake; Winnipeg Longroom; Winnipeg Air Commercial; and Winnipeg Intelligence and Investigations Unit

During the visits, the evaluation team conducted semi-structured interviews, and observed how the CBSA’s frontline personnel processed release requests submitted via the Single Window and legacy service options. Phone interviews were also conducted to accommodate the availability of interviewees and evaluation project timelines. Interviewees received interview guides outlining key issues and questions for discussion. The topics discussed during interviews varied based on the participant’s position (e.g. Chief, Superintendent, BSO).

Surveys

Survey of the CBSA’s commercial frontline personnel

The horizontal evaluation leveraged results from a survey of the CBSA’s commercial frontline personnel,^{Footnote 95} conducted by the CBSA PED as part of the Evaluation of Field Technology Support. The survey was administered from April 18, 2019 to May 10, 2019. The CBSA PED received survey responses related specifically to SWI training from 610 CBSA commercial frontline employees (comprising 498 BSOs and 112 managers/supervisors).^{Footnote 96}

Survey of Trade Chain Partners

An online survey was administered to TCPs from May 30, 2019 to July 2, 2019. The goal of this survey was to better understand challenges and benefits experienced by TCP personnel using the SWI SOs. Survey responses were received from 163 TCP personnel, with representation from at least 97 unique organizations (19% of the Canadian TCP companies).^{Footnote 97} The number of responses vary, at times, by survey question. The structure and design of the survey ensured that respondents answered only those questions that were relevant to their roles, responsibilities, and levels of engagement with and use of the SWI SOs. For example, some questions were only asked of respondents that frequently used the SWI SOs to submit release requests to import commercial goods.

Results from the surveys were presented using percentages and/or qualifiers, as displayed in Exhibit C.

Key Limitations identified during data collection and analysis

Some limitations and challenges were identified during the data collection and analysis process.

Semi-structured interviews with Government of Canada stakeholders

Staff turnover may have affected the level of knowledge and/or experience of interviewees (i.e. some SWI SMEs were no longer employed with the PGAs). Most interviewees had partial knowledge of the SWI project and its history and relied, to some extent, on knowledge transfer from former colleagues.

Field research

Due to evaluation project timelines, field research was postponed from late-Spring and early-summer 2019 to later-summer and early-fall 2019. This shift limited the number of site visits that the CBSA PED could conduct for the horizontal evaluation of the SWI. The CBSA PED evaluation team could not, for example, travel to the Pacific Region. As an alternative, phone interviews with CBSA personnel in the Pacific Region were conducted to validate and inform the horizontal evaluation’s preliminary findings.

Financial data

The other PGAs SWI budget and actual expenditures were reported to the CBSA PED by the other PGAs. According to Treasury Board guidance, the lead department/agency of a horizontal initiative (such as, the SWI) should, coordinate “the collection and validation of financial information from partner departments.”^{Footnote 98} However, the CBSA did not track financial data on behalf of the other PGAs. As a result, the analysis of financial data was reliant on the financial reporting of each PGA. For example, two PGAs reported that their expenditures were the same as their budgets, resulting in no reported variance.

The SWI financial data were not linked to specific SWI deliverables in the 2012 TB Submission. As a result, the CBSA PED’s analysis of financial data was limited to variances between budgets and actual expenditures, per FY. The CBSA PED could not assess the efficiency of the delivery of SWI deliverables, across PGAs.

Operational data (CBSA IT systems)

The CBSA’s reporting system for SWI IID data is considered unreliable or invalid by CBSA SMEs. The reporting system is not yet finalized, and the tools available within the application may not accurately reflect the data stored in the CBSA’s IT systems.

The operational data used by the CBSA PED was provided by SMEs in the CBSA’s CTB and ISTB. This data was extracted from the CBSA’s IT systems and validated by the SMEs, before it was provided to the CBSA PED, and did not rely on the CBSA’s reporting system.

While the availability of data was limited when compared with the planned quantitative data analyses of the horizontal evaluation, it was invaluable in providing context for the evaluation. Commercial release request data was available by month, from October 2017 to October 2019, and included:

• volumes of commercial release requests submitted via the SWI SOs
• volumes of commercial release requests submitted via other EDI SOs and
• time-stamps related to the processing of SWI release requests

A lack of data specific to the other processing times of EDI SOs (including legacy service options) limited the CBSA PED’s ability to assess the overall performance of the SWI SOs.

The current lack of a reliable and valid reporting systems for SWI IID data has been recognized by the CBSA and is captured in the SWI issues log. According to this log, no timeline has been established for the resolution of reporting limitations.

Lack of a SME on commercial and SWI data extraction

There are limited subject matter experts on SWI data extraction in the CBSA’s ISTB and CTB. The SWI evaluation team did not have an SME to support data extraction from the CBSA’s IT systems related to each SO.

Surveys

With regards to the TCP survey, the CBSA PED obtained contact information for 291 Canadian TCP companies out of a total population of 500 companies. Of the 291 companies, representatives from more than 97 companies participated in the survey. With the help of the Canadian Society of Customs Brokers (CSCB), the survey gained an additional 33 participants. However, due to the method with which the CSCB shared the survey, the number of unique companies represented by these 33 survey participants could not be identified.

Appendix E: SWI Stakeholder Roles

Exhibit E: Roles of key stakeholders in the context of the SWI Implementation

CBSA rolesFootnote 99	Other PGAs rolesFootnote 100	TCPs
As the Project Lead for the implementation of the SWI, the CBSA provides project coordination and governance in accordance with Treasury Board best practices. Compiles requirements from the other PGAs and the CBSA to incorporate into the integrated import declaration and prioritize the implementation plan. Implements the technical capacity to receive the declaration and modify business processes to eliminate paper. Provides electronic commercial trade data collected by the CBSA to the other PGAs. Implements the capability to collect and share information based on international commodity identification standards. Consults with the import community and integrates their feedback into Government of Canada approach. Provides Government of Canada importer information services and communications strategies. Defines formal performance measurement metrics and leads the collection of information around border improvements, on behalf of all stakeholders.	Identify the information needs of their regulatory programs. Define and implement new business processes based on the integrated import declaration and opportunities to eliminate paper. Analyze their needs for improved data delivery and work with the CBSA to establish and prioritize the requirements. Design and implement the ability to collect (and share) information with the CBSA based on pre-defined data and decision-making needs. Manage expectations and identify solutions on the availability of data and data quality. Consult with importers and contribute to the construction of integrated Government of Canada importer information services and communication strategies. Determine performance measurement metrics and key success factors.	Identify entities (e.g. customs brokers or SSPs) to design and implement the IT system(s) necessary for TCPs to interact with the Government of Canada’s SWI IT solution. When consulted, provide feedback to the CBSA and other PGAs on communication/information services and data elements required for the IID. Identify technical or process challenges that require solution, through appropriate mechanisms (e.g. the SWI help desk).

Appendix F: Project governance bodies

Exhibit F: SWI project governance structures^{Footnote 101}

CBSA BtB governance (Agency)	CBSA internal governance (Project and Agency)	SWI interdepartmental governance (Project)
Perimeter Vision Senior Level Committee Executive Committee VP Major Projects Steering Committee Director General Perimeter Vision Steering Committee Strategic Policy and Program Committee Modernization, Innovation and Transformation Committee Corporate Management Committee	CBSA Directors General Projects Steering Committee CBSA Project Directors Steering Committee CBSA Business and IT Managers Committee	SWI Assistant Deputy Minister Advisory Committee SWI Directors General (DG) Steering Committee SWI Project Management Working Group SWI Trade Consultation Committee Border Commercial Consultative Committee Border Commercial Consultative Committee OGD Sub-Committee CBSA/U.S. CBP SWI Sr. Management Committee CBSA/CBP SWI Working Group

Sources: SWI Project Charter, January, 2013; Government of Canada. “Treasury Board Submission: Funding for the Implementation of the Single Window Initiative,” 2012.

Appendix G: SWI deliverables across analytical themes and PGAs^{Footnote 102},^{Footnote 103}

Appendix G description

Appendix G: SWI Deliverables Across Analytical Themes and PGAs

Appendix G: SWI Deliverables Across Analytical Themes and PGAs

Deliverable themes	CBSA
A. Business processes	Deliverable 7 (completed)
B. IT System Capacity	Deliverable 2 & 4 (completed)
C. IID Data Elements	Deliverable 3 (completed)
D. Commodity Identification	Deliverable 5 (completed)
E. Analytical Capacity	Not applicable
F. Outreach	Deliverable 6 (completed)
G. Internal Services & Resources	Not applicable
H. Governance	Deliverable 1 (completed)

Model 1

Deliverable themes	CFIA	TC	GAC
A. Business processes	Deliverable 2 (completed)	Not applicable	Not applicable
B. IT System Capacity	Deliverable 3 (completed)	Deliverable 1 (completed) Deliverable 4 (Not applicable)	Deliverable 1 & 2 (Not completed)
C. IID Data Elements	Deliverable 1 (completed)	Deliverable 2 (completed)	Not applicable
D. Commodity Identification	Deliverable 4 (completed)	Not applicable	Deliverable 5 (completed)
E. Analytical Capacity	Not applicable	Not applicable	Deliverable 3 (completed)
F. Outreach	Deliverable 5 (completed)	Deliverable 3 (completed)	Not applicable
G. Internal Services & Resources	Not applicable	Deliverable 5 (completed)	Deliverable 4 & 6 (completed)
H. Governance	Not applicable	Not applicable	Not applicable

Model 2

Deliverable themes	CNSC	DFO	NRCan	ECCC	HC	PHAC
A. Business processes	Deliverable 1 & 2 (completed)	Deliverable 3 (completed)	Not applicable	Deliverable 1 (Partially completed) Deliverable 2 (completed)	Deliverable 5 (completed) Deliverable 3 (Partially completed) Deliverable 9 (Not completed)	Deliverable 1 (Partially completed)
B. IT System Capacity	Deliverable 1 & 4 (completed)	Deliverable 4 (completed)	Deliverable 1 (completed)	Deliverable 3 (Not completed) Deliverable 4 (Partially completed)	Deliverable 2 (Not completed)	Deliverable 1 (Not completed) Deliverable 2 (Not completed)
C. IID Data Elements	Not applicable	Deliverable 2 (completed)	Not applicable	Not applicable	Deliverable 4 (completed)	Not applicable
D. Commodity Identification	Not applicable	Not applicable	Not applicable	Not applicable	Deliverable 6 (completed)	Not applicable
E. Analytical Capacity	Deliverable 3 (completed)	Not applicable	Not applicable	Deliverable 5 (completed)	Deliverable 1 (Partially completed) Deliverable 10 (Not completed)	Deliverable 3 & 4 (Not completed)
F. Outreach	Not applicable	Not applicable	Not applicable	Not applicable	Deliverable 7 & 8 (completed)	Not applicable
G. Internal Services & Resources	Not applicable	Deliverable 1 & 5 (completed)	Deliverable 2 (completed)	Not applicable	Not applicable	Not applicable
H. Governance	Not applicable	Not applicable	Not applicable	Not applicable	Not applicable	Not applicable

Appendix H: Alignment with international standards and recommendations

The World Customs Organization (WCO), United Nations Centre for Trade Facilitation and Electronic Business (UN/CEFACT), and the United Nations Economic and Social Commission for Asia and the Pacific (UN/ESCAP) are globally recognized as references for economic relations, trade and customs. Therefore, these organizations developed Standards and Recommendations for a successful implementation of a “Single Window” IT system.^{Footnote 104} These Standards and Recommendations were grouped into four themes, and used to analyze the success of the Government of Canada Single Window system.^{Footnote 105} The tables below represent this analysis.

Theme: Governance, planning and leadership

International standards & recommendations

• agenda setting and political will establishment
• establishing formal structures and political mandate
• strong lead agency and
• establishment of clear project boundaries and objectives

The majority of these international standards and recommendations were found to be achieved by the Government of Canada in implementing the SWI, as there was:

• strong political will to improve the overall process for the importation of regulated goods, as evidenced by the inclusion of the SWI in the Canada-U.S. Beyond the Border action plan
• a Memorandum to Cabinet, and a Treasury Board submission were developed and supported by all relevant PGAs
• the CBSA was established as the lead Agency due to its presence at the border and its mandate in enforcing border-related legislation and
• project boundaries and objectives were defined, communicated to, and agreed-upon by all stakeholders

However,

• project timelines and PGA needs shifted, the project governance was complex, and the transition from project to program may have been premature, given the low rates of certification and use amongst TCPs, at the time"

Theme: Outreach

International standards & recommendations

• stakeholder/ interagency collaborative platform establishment
• promotion and marketing
• communication Strategy and
• managing transition to a single window

These international standards and recommendations were only partially achieved as:

• the Stakeholder Management Plan was developed only years after the project was launched, and may have been too high-level, at it omitted specific roles and responsibilities for stakeholder engagement
• the Single Window Service Delivery (SWSD) Communications Strategy and Plan was developed one year after launching the SWI SOs for use by TCPs
• an onboarding plan for TCPs was not established as part of the SWI project. Overall, stakeholders were encouraged to participate in trade forums and most PGAs held engagement sessions. (refer to Section 4.3.2)
• each PGA was at different stages of preparedness, and although SWI was phased in (early adopters, followed by the remaining PGAs), not all PGAs were ready to transition
• slow TCP onboarding and use of the SWI, led to a recommendation to develop a Stakeholder Engagement Plan in March 2017, after the Government of Canada’s SWI IT solution was launched
• confusion and lack of knowledge of the SW processes, updates and data, and limited communication forums for stakeholders were mentioned as issues by 8 out of the 10 PGAs

Theme: Data and IT systems

International standards & recommendations

• data Harmonization
• ensuring data quality, security & privacy
• dematerialization & paperless processing
• service functions (application architecture) design
• user friendliness and accessibility
• interoperability and
• ability to Make Payments

One of these international standards and recommendations was achieved in full as:

• there is 96% data harmonization and alignment between Canada and the U.S.

The other international standards and recommendations related to data and IT systems were only partially achieved as:

• a Privacy Impact Framework was developed collaboratively with all 10 PGAs. Although PGAs collaboratively established essential IID elements engaging with TCPs, data quality is an ongoing area of concern for some of the PGAs
• not all PGAs intended to go paperless during the SWI implementation phase, as some tied to legislation/regulations (e.g. ECCC CITES). Work in this area is currently underway
• integration and functionality between the CBSA IT systems is limited. The SWI SOs were designed to be integrated with and viewed by CBSA frontline personnel through Commercial Passage (herein referred to as the specialized viewer for the SWI IID data), an eManifest^{Footnote 106} interface. Due to delays in the delivery of eManifest, the SWI was implemented without Commercial Passage. As such, the ACROSS interface (herein referred to as “CBSA IT systems”) is used by BSOs to process release requests submitted through the SWI SOs. Frontline staff reported that ACROSS is not user-friendly
• TCPs were required to develop their own IT systems to interact with the CBSA’s SWI application, but there is still work being done in this area and
• there is IT interoperability between the CBSA and the 9 other PGAs (as planned). However, there is no IT interoperability amongst the 9 other PGAs (i.e. excluding the CBSA) or between Canada and the US

However,

• the ability to pay through the SWI is not available, nor planned for the SWI. This is due to CBSA being solely responsible for collecting payment and have a new system currently under development

Continued improvement

As the CBSA IT systems, used for processing SWI release requests, were viewed as not being “use-friendly,” work on finding solutions to support the ease of use for frontline personnel began in FY 2019 to 2020. The FY 2019 to 2020 regional tour of the CBSA’s Commercial and Trade Branch Vice-President and the Director General of the Commercial Directorate reinvigorated the need to address CBSA’s IT system functionality. By summer 2019 to 2020, the highway mode had access to the specialized viewer for SWI IID data (i.e. Commercial Passage), and by the winter of the same FY, all the other modes had access as well. Continued work internal to the CBSA continues to improve CBSA’s IT system functionality (refer to Section 4 on simplified border processes).

Theme: Performance and risk

International standards & recommendations

• identification of possible obstacles
• erformance management & sustainability and
• integrated risk assessment

These international standards and recommendations were found to be only partially achieved due to some items being excluded from the project scope:

• SWI project documentation reflects an assessment of project risks. In this regard, the CBSA established a help desk generic email box, which is accessible by all stakeholders to report any issues
• the integrated risk management framework was excluded from the chosen scope of the SWI project. Going forward, re-examining the benefits of the aforementioned may address current issues related to a lack of clarity and accountability on the joint risk assessment and inspection process at the border and
• the Performance Measurement Framework was established with PGA collaboration and was later superseded internally to the CBSA by a Benefit Realization Plan. The OAG found SWI performance measures lacking. Risk assessment is now shared between the PGAs (business rules were defined collaboratively). However, no integrated framework exists

Appendix I: Definitions of international standards & recommendations

Ability to Make Payments: A system for the payment of government fees, taxes, duties and other charges. This can be a very attractive feature for both government and trade, and is especially important when the system is required to generate revenue.

Agenda Setting and Political Will Establishment: Political will and strategy is well articulated, validated for its substantive value, and securely mandated by the right authorities and sponsors. Clear and impartial information on objectives, implications, benefits and possible obstacles in the establishment of SWI. The availability of resources.

Communications Strategy: Establishment of a proper mechanism for keeping all stakeholders informed on project goals, objectives, targets, progress (and difficulties).

Data: Ensuring quality, security & privacy – Early risk assessment is premised on the capability of the government and TCPs to trust the source of data; be assured of the quality of data provided and received; and have confidence that the data that is exchanged will be handled safely and protected from unauthorized access.

Data Harmonization and Alignment: Data Harmonization is conducted, which includes the analysis of information in a set of trade documents to identify those information objects which are shared between Government agencies.

Dematerialization & Paperless Processing:

Ability to submit regulatory transactional data electronically via declarations, along with references to supporting documents.

Establishing Formal Structures: Political mandate – Existence of a mandate that is legally valid and administratively sound.

Establishment of Clear Project Boundaries and Objectives: Clearly defined goals and objectives for the SWI at the outset exist to guide the project through its various development stages.

Identification of Possible Obstacles: Existence of a mechanism to identify and address the specific concerns of opponents as early as possible in the project.

Integrated Risk Assessment: A single entry point. All PGAs intervene to assess risk and identify consignments suspected to be in violation of regulations. Continuous two-way communication and monitoring of border process actions and the organization implementing it. An overall concept of risk management at the organizational level (including all PGAs).

Interoperability: The ability of two or more IT systems or components to exchange and use information without additional effort on the part of the user.

Managing Transition to a Single Window: A transition plan ensures all stakeholders buy in. Co-ordinated actions with other agencies at the border are carried out.

Performance Management & Sustainability: Existence of a performance measurement framework (PMF) that will enable organizations to answer questions related to the achievement of outcomes/goals, functionality as planned, satisfaction of stakeholders, improvement of regulatory goals, and reduction in border process costs.

Promotion and Marketing: The promotion campaign involves representatives from all the key government and trade stakeholders in the system, as these parties can provide valuable information on the expectations of the user community and help to direct the promotion and marketing messages. A clear implementation timetable is established and promoted at the earliest possible stage, as this assists in the marketing of the project and helps potential users to plan their related operations and investments according to this schedule.

Stakeholder/ Interagency Collaborative Platform Establishment: Representatives from all relevant public and private sector agencies are invited to participate in the development of the system from the outset. Stakeholders participate in all stages of the project, from the initial development of project objectives, situational analysis, and project design through to implementation.

Service Functions Design (application architecture): Provides a blueprint describing services and functions, and includes the different sub-systems and components of the software solution, their interactions, and their relationships to the core business processes of the Government agencies and business users.

A Strong Agency Lead: A strong, resourceful and empowered lead organisation is identified to launch the project and see it through its various development stages.

User Friendliness and Accessibility: Comprehensive operating instructions and guidelines are available for users. Help Desk and user support services, including training, are established, especially in the early implementation phase of the project. The need for and value of practical training courses for users cannot be over-emphasised. The multilingual requirements are addressed.

Appendix J: SWI information sharing and decision making models

Appendix K: Commercial release request volumes

The volume of EDI commercial release requests has increased over time (Graph A).^{Footnote 109} Following project closure in March 2017, the volume of commercial release requests submitted through the SWI IID (SO911) has also increased. Alongside the increase in SWI IID (SO911) release request volumes, the volumes of commercial release requests submitted through regulars PARS (SO125) and regular RMD (SO257) (two EDI SOs through which release requests for non-regulated commercial goods are submitted) have declined. This is most notable between FY 2018 to 2019 and the beginning of FY 2019 to 2020. The observed trend may be reflective of the reported increase in the use of SO911, by TCPs, for release requests containing non-regulated (in addition to regulated) commercial imports.

Graph A: Volumes of commercial EDI release requests from FY 2016 to 2017 to FY 2019 to 2020

Source: Analysis by CBSA, PED. Data provided by the CBSA CTB and ISTB from CBSA IT systems, October 2019.

Table format

Graph A: Volumes of commercial EDI release requests from FY 2016 to 2017 to FY 2019 to 2020

Graph A: Volumes of commercial EDI release requests from FY 2016 to 2017 to FY 2019 to 2020

Fiscal year	OGD PARS – SO463	OGD RMD – SO471	PARS – SO125	RMD – SO257	IID – SO911	Total
2016 to 2017	4,805,503	687,991	8,023,964	1,522,540	5,263	15,045,261
2017 to 2018	5,346,923	756,997	12,558,559	1,565,753	105,909	20,334,141
2018 to 2019	4,888,744	705,062	11,279,773	1,495,480	2,037,393	20,406,452
2019 to 2020	557,076	171,555	2,017,396	559,328	7,959,213	11,264,568

Appendix L: SWI stakeholder roles in the delivery of internal training

Appendix M: Quality and timing of training delivered internally by SWI stakeholders

Date modified:

2024-11-18