19 March 2001

Update on DFAIT Service Level Issues and the Implementation of EICS

The implementation of the new DFAIT permit issuing system (Export Import Control System, EICS) has been postponed from April until July 1, 2001. A decision has been made to outsource the technical administration of the new system to CGI, the company which won the initial contract to develop EICS. Information has been sent to all Canadian brokers about phased-in access to the new system and testing is underway for brokers who are on-line with DFAIT today.

The CSCB, through our DFAIT Consultative Committee, has raised a number of questions about the implementation of the new system, as well as about service issues, throughout the past two years. We recently met with Ian Burney and Barbara Lukaszewicz, two DFAIT Directors responsible for these issues, and the following correspondence summarizes some of our outstanding concerns. We will advise members as soon as we receive a response to these concerns.

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THANK YOU for taking the time to meet with us recently to discuss a number of issues regarding service levels related to permit issuance, today and under EICS.

We have attached for your reference copies of correspondence written over the past two years about these issues. In addition, we thought it would be helpful to summarize our concerns and recommendations.

1. The idea of a first-line call centre, as described to us at our meeting in Toronto on February 14th, provides accountability and tracking mechanisms which are not currently operational today. Although you indicated that you have the capability for detailed tracking of calls today, the reality is that improvements must be made to ensure fair access, timely acknowledgement of status, and clear guidelines for escalation.

If the decision is made not to use a call centre approach, we must be satisfied that standards for service are clearly agreed to, communicated and evaluated. The status quo is not an option.

2. There should be further consideration of identifying a "priority" status for calls. We understand that there is the risk of abuse of such a mechanism, but we are extremely concerned that you will be required to handle an increased number of calls - from brokers with on-line experience, from brokers new to the system and from importers and exporters - without any differentiation and without any additional resources.

3. Once we have agreement on some sort of acknowledgement/tracking/priority system, we need to have clearly agreed and monitored standards for routed permits and rulings, including transparency and accessibility to rulings which could be considered generic for an industry sector.

4. We also need some extension of current hours of service to provide more equitable access from Western Canada.

5. We reiterate our disappointment that DFAIT has not accepted our proposal for a certification or qualification programme as EICS is implemented. This leads us to believe that you underestimate the value that we bring to the process today as a first-line resource for export and import controls, at no cost to you. To be clear on this - all the members of our consultative committee, which include your highest volume permit issuers today, support performance standards and agree unanimously with certification as a way to ensure a minimum level of expertise in the marketplace.

6. We are also disappointed in the level of discussion and the decision regarding contracts and commissions. Will there be some mechanism other than a contract (say, a memorandum of understanding) setting out performance obligations? If so, when will we see something? If not, our view is that brokers' obligations to DFAIT and relationships with clients will fundamentally change. That in turn will have an impact on service issues. We think you have given little, if any, thought to this and we intend to explore this further with our legal counsel.

7. The preceding two points raise our concerns about the broader issue of co