INS RESPONSE TO DRAFT REPORT

U.S. Department of Justice Immigration and Naturalization Service

HQOIA 110/8.2-C

MEMORANDUM FOR	MARY W. DEMORY ASSISTANT INSPECTOR GENERAL FOR INSPECTIONS DEPARTMENT OF JUSTICE
FROM:	Doris Meissner Commissioner Immigration and Naturalization Service
SUBJECT:	INS and Airline Relations; Report Number A-99-07

I appreciate the opportunity to comment on the subject report and solicited input from the senior management official who is most significantly impacted --the Executive Associate Commissioner for Field Operations. I reviewed his response and concur with the conclusions and observations. The response is attached for your review.

We support the conclusions of the report and expect to be able to implement the recommendations. Continually improving the training programs, sharing the tactical information and better communications with the airline representatives are the Carrier Consultant Program goals.

Thank you again for the opportunity to respond to the draft report. If you have any questions, please contact Kathleen Stanley, Audit Liaison, at (202) 514-8800.

Attachment

U.S. Department of Justice Immigration and Naturalization Service

HQOPS 70/20.7

MEMORANDUM FOR THE COMMISSIONER

FROM:	Michael A. Pearson Executive Associate Commissioner Office of Field Operations
SUBJECT:	Report Number A-99-07 Immigration and Naturalization Service and Airline Industry Relations

The Office Field Operations appreciates the opportunity to comment on this Inspector General report on INS relations with the Airline Industry. We concur with all of their recommendations.

RECOMMENDATIONS

1. In conjunction with INS Office of Training, the CAO should develop and implement a professional training evaluation method to gauge the effectiveness of the training provided to the airline industry.

   INS RESPONSE: Concur

   The recommendation was completed in part with the release of the CTC in May 2000. This year, the CAO in consultation with the INS Office of Training completed the development and implementation of a professionally designed training curriculum. If funding is available, the CAO, in conjunction with the Office of Training, will conduct a feasibility study to measure the effectiveness of current training provided to the airline industry. The targeted date for completion is the end of FY 2001.

2. INS, in coordination with the airlines, should identify who needs training in the airline industry, and include this in its strategic plans to meet on-going training needs.

   INS RESPONSE: Concur

   The recommended action has been implemented in part. The CAO develops an annual strategic plan in consultation with the carriers. The plan is disseminated yearly at the November User Fee Advisory Committee meeting to the committee members for their comments. Despite a concentrated effort to communicate with carriers, the CCP has rarely received any comments from the carriers present on the proposed sites for training or on additional sites for training. Nevertheless, the CCP will contact the Air Transport Association (ATA) and International Air Transport Association (IATA) 30 days after the November User Fee Advisory Committee meeting to provide the industry with an additional opportunity to provide input. However, the number of training sites will necessarily be constrained by available funding.

3. INS should develop and implement a process for notifying all airlines of its intended schedule to give as much advance notice as possible, using modern technology such as the Internet, where possible, for notification. The GAO should coordinate the notification process and be provided a copy of the airline-training schedule from each INS entity that conducts training.

   INS RESPONSE: Concur

   INS has already developed and implemented a process for notifying all airlines of its intended schedule to give as much advanced notice as possible. That process can be improved. Notices currently are given to IATA and ATA to forward to their members as soon as it is determined that training will be conducted in a certain location during a specific time-period. The first notification is to the User Fee Advisory Committee in November of critical sites where training is planned. Exact dates are publicized after funding has been approved for training. As part of its mandate to standardize training, the CCP will be able in the future to offer specific training schedules for carriers to assist them in determining a training schedule unique to their needs.

   In FY 2001, the CCP will implement this recommendation with the procedures outlined in the attached draft memorandum to be issued by the Office of Field Operations. The draft memorandum outlines procedures for all districts to report their projected annual schedule of training for the upcoming fiscal year, and to provide updates as the training is amended. It also requires reports on completed training and designation of an Inspections-Air Carrier Liaison Officer who is responsible for sharing limited tactical information with the carrier. (See attached draft memorandum)

   INS held a series of workshops and specifically asked carriers for their suggestions on communications methods. The carriers stated that IATA, SITA, and facsimiles were the ideal method verses the Internet or email for communications. INS also includes updates in its monthly Carrier Information Bulletin.

   By October 1 of each fiscal year, the district offices are to notify the CAO about their intended training for the year. This information will be incorporated into the strategic plan submitted by the CAO to the User Fee Advisory Committee each November. The Office of Field Operations will issue instructions to the field to remind it of its responsibility for timely submission of projected training.

4. INS Office of Inspection should clarify to local INS officials the typical types of information/intelligence that can be provided to the airlines and what information should be provided

   INS RESPONSE: Concur

   Written operation instructions will be drafted to be sent to the field outlining procedures which permit the release of tactical information / intelligence to the airlines by the end of FY 2000.

5. INS should require that a senior local INS port official be designated to approve all tactical information that is furnished to the airlines. The individual who provides this approval must be thoroughly knowledgeable of INS policy on what intelligence information can be disseminated to the airlines.

   INS RESPONSE: Concur

   This will be an aspect of the written operations instructions to the field and will occur by the end of FY 2000.

6. INS should promote the timely exchange of information that helps prevent inadmissibles from boarding inbound flights to the United States. To be timely, this exchange should primarily occur at the local INS airport level with their airline counterparts preferably at the foreign points of embarkation.

   INS RESPONSE: Concur

   Written operation instructions will be drafted to be sent to the field outlining procedures which permit the release of tactical information / intelligence to the airlines by the end of FY 2000.

7. INS should designate an employee at each major U.S. international airport to devote at least some time to actively work with the airlines [at the port-of-entry] to foster relationships that promote the exchange of tactical information on a regular basis.

   INS RESPONSE: Concur

   This requirement is presently included in standard position descriptions for INS Port Directors and Officers-in-Charge. However, this direction will be included in the written operation instructions being drafted, to be sent to the field by the end of FY 2000.

8. INS, in conjunction with the members of the User Fee Committee, should develop a mechanism to report advice to the Commissioner.

   INS RESPONSE: Concur

   At the next scheduled meeting INS will include this issue on the agenda and suggest mechanisms for providing such advice. Projected completion is at the January 2001 User Fee Advisory Committee meeting.

9. INS should establish a point of contact with senior airline executives who can provide adequate representation and speak with authority for all INS offices at the User Fee Advisory Committee meeting (e.g., a representative from the Deputy Commissioner's Office or an individual who can speak for the Deputy Commissioner).

   INS RESPONSE: Concur

   INS currently sends a representative who speaks with authority for all INS at the User Fee Advisory Committee meetings. The User Fee Advisory Committee remains important to all levels of management at the INS. The recommendation of the OIG that a high level representative be named will be forwarded to the Deputy Commissioner. We are confident that senior officials can identify a method to ensure that the concerns of the advisory committee continue to receive appropriate attention. Projected completion is before the January 2001 User Fee Advisory Committee meeting.

10. INS should maintain a list of outstanding issues (that includes completion dates until they are resolved) and provide the airlines a status report at each bi-annual user fee meetings.

    INS RESPONSE: Concur

    At each semiannual meeting a flip chart will be used to record outstanding issues. Status reports will be provided to all attendees within 45 days of the date of the meeting.

11. At the Committee meetings, INS should ensure adequate representation from all relevant offices that can be more responsive to questions from the airlines.

    INS RESPONSE: Concur

    The OIG's concern will be referred to the Deputy Commissioner with a request that she reinforce the importance of headquarters staff attendance at the meetings from all divisions. Projected completion is by the January 2001 User Fee Advisory Committee meeting.

12. INS should extend the practice of having regular meetings with local airline industry personnel, at least quarterly, to all major U.S. international airports where such meetings are not presently conducted

    INS RESPONSE: Concur

    The INS initiated monthly meetings as part of the Port Quality Improvement Committee (PQIC) among all agencies of the federal inspection services (FIS). The major U.S. international airports have continued this initiative between local airline personnel and INS. The PQIC's were also required to have at least semiannual stakeholders meetings at airports, the stakeholders are the airlines and airport authorities. The INS Regional Offices have assumed oversight of the PQICs.

    Each port director is responsible for establishing and maintaining working relationships with the carriers at their international airport. Port Directors will be encouraged to extend the practice of having regular meetings with local airline industry personnel, at least quarterly at all major U.S. international airports. A memo will be sent to all port directors establishing the quarterly requirement. Regional offices will be required to monitor these meetings and report unresolved issues to headquarters operations. We project completion by the end of FY 2000.

For clarification or for answers to additional questions regarding this response contact the Carrier Affairs Office, Thomas N. Perrelli, Director, at 202-305-7007.