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Findings 63 on time to successfully exempt checked bags from being seen in the FIS area, or to prevent passengers from having to await data availability. RFID tags: The study team tested the use of RFID tags to track passengers and checked bags through the arrivals process. Several ideas were generated to use this technology to retrieve bags that were exempted from being seen by CBP. The study team views this application as one that could potentially help with large-scale management and retrieval processes, but also views manual or barcode-enhanced retrieval processes as alternative solutions to meet objec- tives. Using RFID to enable recalling passengers at domestic concourses for further CBP scru- tiny at Secondary was also evaluated; however, the privacy impacts of tracking passengers with an electronic tag were deemed highly problematic as a concept of operations. Additionally, the legal status of CBP's interaction with passengers in the domestic departures area could be an issue given the Fourth Amendment (i.e., protection against unwarranted searches, arrests, and seizures of property). Other Findings CBP currently provides full port-of-entry clearance at 14 Preclearance sites, including 8 in Canada. However, since 2002 the interpretation of the Aviation and Transportation Security Act has resulted in the rescreening of checked bags on arrival to meet TSA requirements for explosive detection. For example, at MinneapolisSt. Paul International Airport (MSP), more than 15 per- cent of peak-hour baggage systems are consumed by the rescreening of bags before a connecting international or domestic flight. While it is not the primary focus of this study, implementing solutions for advanced information transmission (e.g., upline X-ray image) may provide some enhanced risk management capabilities relevant for this study. However, an investment in new ATSA-compliant hold baggage screening equipment at Preclearance airports may be the ideal solution to this issue. Evaluation Results Based on tests, process flow analysis, stakeholder input, and peer review, a comprehensive set of 22 criteria was defined to evaluate alternative procedures. The criteria were categorized based on market, airline, airport, and CBP risk management con- siderations that are critical to the potential success of baggage recheck elimination or reduction. The valuation of outputs reflects critical judgment based on a variety of qualitative and quantita- tive factors. In fact, the valuation of "risks" themselves could be quite difficult given the degree of subjectivity about risk/probability/consequence. Wherever possible, space savings and labor savings were calculated (notes are provided in Appendix F). The alternative procedures were evaluated based on the potential to provide immediate oppor- tunities (i.e., near-term) as well as a sustainable solution that would withstand the test of time and market/risk evolutions. Ultimately, the evaluation favored procedures that could be sustainable solutions that would benefit the greatest number of travelers. As shown in Table 6, the alternative procedures were evaluated to provide overall ratings as follows: Positive impact: Sharing TSA X-ray images upon arrival (AP5) and pre-departure informa- tion sharing (AP4) Moderate impact: Exempting bags from CBP outright (AP1), additional CBP officer/process implementation at the connecting level (ramp area) (AP3), and door-to-door baggage service (AP7) Negative impact: Initiatives to leverage other DHS programs (AP6) and establishing new airline/airport obligations for connecting processes (AP2)

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64 Elimination or Reduction of Baggage Recheck for Arriving International Passengers Table 6. Review of alternative procedures based on evaluation criteria. Alternative Procedures 2. New 1. Bags 3. New 4. Enhanced 6. 7. Door- Connecting 5. Category Criteria Exempt Connecting Pre- Leveraging to-Door Bag Process Sharing from Bag Process departure Other DHS Baggage (Airport/ TSA Info FIS (CBP) Information Programs Service Airline) 1A Project volumes Market 1B Time savings 1C Improved customer satisfaction 2A Additional time needed for upline management 2B Cost/materials for upline processing 2C Costs of retrieving n/a bags 2D Other operational Airlines impacts 2E Improved fidelity of n/a baggage handling 2F New routing potential n/a 2G Reduced labor n/a 2H Training n/a 3A New space n/a requirements 3B Additional staff n/a 3C Costs of retrieving n/a bags Airport 3D Incremental revenues n/a 3E Terminal space n/a savings 3F Competitive n/a advantages A Capital costs n/a B Risk management n/a CBP C Re-focusing resources n/a D Redelivery capabilities n/a E Other impacts n/a Overall = Positive Impact; = Moderate Impact; = Negative Impact Table 7 summarizes the evaluation by category and presents a brief overview of the analysis. This evaluation should not discount the opportunity for near-term gains to be realized by Alter- native Procedure 1 or for future developments of new processes or technologies to enhance the potential for others (e.g., Alternative Procedure 2). Specific qualitative and quantitative analysis for each of the evaluation results is provided in Appendix F. It is worth noting that the door-to-door express delivery through a third party was mostly ranked "not applicable," as passengers would use a shipping service through an integra- tor (e.g., DHL, FedEx, UPS) for baggage delivery.

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Findings 65 Table 7. Assessment of each alternative procedure by category. Management Assessment Alternative Procedure CBP Risk Demand Airlines Airport Market Overall Analysis In the near term for international-to-international transfers, this option is the best option for airports and airlines to pursue with CBP. There is also existing precedent at four U.S. airports as well as Preclearance locations. 1 However, the solution does not currently provide CBP with the necessary capabilities to manage potential introduction of contraband to the United States. Introducing new processes presents major challenges to airport operators in terms of space, cost, and overall ability to deal with exceptions. Generally, 2 airlines could incrementally deal with alternative processes on arrivals to meet most CBP requests for risk managing connecting flows. Although CBP recognized the risk mitigation value of a new alternative process for transfer bags, it questioned the utilization of the officers in a satellite location/process. This issue is particularly pertinent at airports with a 3 high variability of "eligible" transfer passengers throughout the day. All stakeholders emphasized that a reduction in baggage clai m/recheck should not be achieved at a net cost to the international arrivals process. To date, there are few examples of advance baggage information being shared for the purpose of border inspection. Augmenting this to include X- ray images, weight, and/or bag pictures could provide CBP with additional capabilities to evaluate an elimination of baggage recheck for onward 4 international connections and potentially for onward domestic connections. Significant implementation issues remain, however, due to the types of technologies (e.g., international standard for multi-view X-ray image, CBP specific algorithm) and process evaluation needed to enable this process. In the short to medium term, CBP recognizes the potential for improved risk assessments with access to TSA X-ray images. However, improved X-ray image assessment (i.e., algorithm) capabilities are required, which is likely to push this procedure to a medium- to longer-term solution. Once resolved, 5 this solution presents a significant opportunity to address all international arrivals connecting onward, regardless of final destination. For airports, proximity of the TSA baggage matrix and the FIS area will facilitate an expedited retrieval process for bags referred to CBP Secondary. Although the use of Global Entry or other DHS programs to provide baggage recheck reduction is a good idea in concept, the major problem is the inability to confirm membership at point of origin. The new Global Entry card with RFID technology is a positive step but electronic verification 6 during check-in is still challenged. The potential of having a non-Global Entry bag accidentally or intentionally inducted into a through-check process was cited as a risk by CBP for introducing a separate bag process for Global Entry members. Using express delivery has major benefits to reducing the actual de mand on foreign airport systems for baggage reception and delivery. However, a sizable market is not expected to be present to take advantage of this 7 n/a n/a capability. Airports and CBP are inconclusive in ter ms of this alternative procedure--primarily because it will not remove or reduce the need for a baggage recheck facility. = Positive Impact; = Moderate Impact; = Negative Impact

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66Elimination or Reduction of Baggage Recheck for Arriving International Passengers Potential time savings were estimated based on the removal of two steps from the current pro- cess, as shown in Figure 33. The actual time savings will vary based on the differences in process steps and timing between airports. For example, baggage claim time could vary by 20 minutes depending on the peak arrival periods or CBP Primary staffing levels. Within the connecting process, the main time variables for the passenger are Primary Process- ing, potential for Secondary Processing, baggage claim, and TSA passenger screening. In elimi- nating or reducing the baggage claim and recheck processes, the passenger will also experience a more reliable connecting process (in addition to the obvious time savings), which should help improve the customer experience. Figure 33. Overview: Potential time savings.