ARCHIVED - Remote Border Location Programs — Evaluation Study

This page has been archived.

• CANPASS Remote Area Border Crossing Program
• CANPASS Remote Ports Program, CANPASS Private Boats Plus Program
• Q19 Program

Final Report
Program Evaluation Division
Strategy and Coordination Branch
July 2009

Table of Contents

• Executive Summary
• Introduction and Context
  • Evaluation Purpose and Scope
  • Evaluation Methodology
• Key Findings
  • Relevance
  • Program Design and Delivery
  • Results
  • Program Efficiency
• Key Conclusions, Recommendations and Management Response
• Annex: Acronyms

Executive Summary

The Canada Border Services Agency (CBSA) contributes to the security and prosperity of Canada through the effective and efficient management of the border. The CBSA is an integral part of the Public Safety portfolio, which was established in December 2003 to protect Canadians and maintain a peaceful and safe society. The CBSA's mandate is to provide integrated border services that support national security and public safety priorities and facilitate the movement of persons and goods.

This evaluation report presents the evaluation findings related to four remote border location programs (the CANPASS Remote Area Border Crossing (RABC) program¹, the CANPASS Remote Ports program (RPP), the CANPASS Private Boats Plus program and the Q19 program). The findings address the continued relevance of the four programs, as well as the effectiveness and efficiency of the programs' design, delivery and management.

Methodology

The CBSA's Program Evaluation Division in the Strategy and Coordination Branch planned and conducted this evaluation. The evaluation research was conducted between July 2008 and April 2009, and the following research methodologies were used:

• a review of program documents for the CANPASS RABC, Remote Ports and Private Boats Plus programs, and the Q19 program, and other related documents and data;
• site visits to ports of entry in Northern Ontario, Quebec and New Brunswick;
• one-on-one and group interviews with CBSA management and staff in three regions and at Headquarters; and
• a survey based on a systematic, random sample of current CANPASS RABC members.

Evidence from each of these lines of inquiry was checked for reliability and validity.

Key Conclusions and Recommendations

This evaluation covers the CANPASS RABC, Remote Ports and Private Boats Plus programs, and the Q19 program, which have been in operation for many years in remote areas of Canada and were developed as pilot projects to test seasonal reporting options. The CANPASS RABC program was initially a joint Canada Revenue Agency and Immigration Canada program.

The CBSA spends approximately CAN$500,000 to deliver these programs yearly.

The programs were created to address local needs and highlight the challenges of managing the border and ports of entry (POEs) in remote areas. While the programs facilitate members' access to Canada, their design and delivery may no longer address the needs of current security priorities. While members are risk assessed and known to the CBSA, there are no records of passages linked to the CANPASS RABC and Private Boats Plus programs due to the remote nature of the program area and a lack of reporting required for members who enter Canada without goods to declare. Similarly, the after-hours access to Canada provided by the Q19 program depends on the voluntary compliance of members. Through the CANPASS RPP, members are admitted into Canada using technology such as a card reader and a video camera. However, the technology does not support current standards for reporting and examination.

The number of clients served by these programs is relatively small. CANPASS RABC, the largest program of the four evaluated, has approximately 14,000 members who, on average, crossed into Canada 13 times in 2008² . This program is mostly used for leisure, access to cottages, and/or to save travelling time. While the CANPASS Private Boats Plus program has 522 members, most of whom are Canadian residents, the number of active members is not known, nor is it known how often they use the program. Based on 2008 CANPASS RPP passage statistics, this program was used by only 128 members, which is 21% of those registered as of 2001 when membership was frozen. Program officials indicated that member needs are to access services such as family physicians, pharmacies and retail food after POE hours. The Q19 program also serves an unknown number of private travellers. Their specific levels of use and needs are also not known.

CBSA officials responsible for the Q19 program indicate that it facilitates the import of 21,895 log shipments annually outside POE hours. This represents 72.4% of the overall annual volume of logs entering Canada at the affected POEs for processing at local mills. Of the four programs reviewed in this evaluation, the Q19 program was the only one that was designed specifically to address a significant commercial need. However, these POEs are not designated commercial offices; therefore, they have a limited examination capacity.

The evaluation concludes that the current structures of these programs are not optimal and that some alternatives that better align with CBSA and Government of Canada priorities exist.

Transitioning current CANPASS RABC and Private Boats Plus program members over to the NEXUS or other CANPASS programs would benefit the Agency through more rigorous risk assessments of members. However, because of the remoteness and vastness of the program areas, additional investments in reporting stations and telephone reporting centres may have to be made. The evaluation found that U.S. Customs and Border Protection's infrastructure and new technologies for remote border examination and access may have similar benefits for Canada in the remote areas where the CANPASS RPP and Q19 programs are delivered.

Alternatives to the Q19 program are limited. While the Customs Self Assessment and Free and Secure Trade programs would allow for more frequent and rigorous risk assessments of members, they would not facilitate the after-hours commercial access required during periods when the daytime use of roads for commercial shipments is not possible.

The evaluation recognizes that managing the border in remote areas is inherently challenging. Nevertheless, there is a need to ensure that the CBSA's mandate and priorities are met. In view of these findings, the evaluation recommends the following:

Recommendation: The Agency should develop strategies that would rationalize the CANPASS RABC, Private Boats Plus and Remote Ports programs, and the Q19 program with existing measures to the extent possible. The Admissibility Branch, in cooperation with the Operations Branch, should consider developing a national remote border location strategy that addresses the need for clear national accountabilities and standards (e.g. national eligibility requirements, standard fees and membership durations) and that aligns with the Agency's mandate and responsibilities.

Introduction and Context

The Canada Border Services Agency (CBSA) contributes to the security and prosperity of Canada through the effective and efficient management of the border. The CBSA is an integral part of the Public Safety portfolio, which was established in December 2003 to protect Canadians and maintain a peaceful and safe society. The CBSA's mandate is to provide integrated border services that support national security and public safety priorities, and facilitate the legitimate movement of persons and goods, including animals and plants, that meet all of the requirements under the program legislation.

This evaluation report presents the evaluation findings related to four remote border location programs. The CANPASS Remote Area Border Crossing (RABC) program³ , the CANPASS Remote Ports program (RPP), the CANPASS Private Boats Plus program and the Q19 program are all open to Canadian and U.S. citizens and permanent residents. These programs were developed as pilot projects to test seasonal reporting options. CANPASS RABC was initially a joint Canada Revenue Agency and Immigration Canada program.

The findings address the continued relevance of the four programs, as well as the effectiveness and efficiency of the programs' design, delivery and management. In addition, they assess the progress that these programs have made in achieving results for Canadians.

CANPASS RABC Program

The CANPASS RABC program was launched in 1991 as a cooperative effort by Revenue Canada and Immigration Canada to streamline border clearance for pre-screened, low-risk travellers in remote areas of Northern Ontario. While the program is called CANPASS RABC, it does not have the core elements of other CANPASS programs vis-à-vis applications, passage and reporting requirements. A CANPASS RABC permit is valid only for the remote areas from Pigeon River through to and including Lake of the Woods, the Canadian shore of Lake Superior, Cockburn Island, Sault Ste. Marie (upper lock system) and Emerson West Lynne. The border span of the CANPASS RABC program area is approximately 570 km.

CANPASS RABC application forms are available on the CBSA's Web site and at program area ports of entry (POEs). Applicants pay a non-refundable processing fee of CAN$30 and membership must be renewed every year. The majority of members are accepted into the program without an in-person interview to check their authenticity against that of the identification documentation they submit. All applications are screened through security databases (e.g. the Field Operations Support System (FOSS), the Integrated Customs Enforcement System (ICES), the Canadian Police Information Centre (CPIC) and the National Crime Information Center (NCIC)). False statements made on an application regarding criminal convictions or contraventions of the Customs Act or the Immigration and Refugee Protection Act may result in refusal to issue a permit.

Permit holders can cross the border into Canada in the program area without reporting entry, provided they have no goods to declare. Members must declare imported goods that will remain in Canada or that are valued over their personal exemption. The CANPASS RABC permit does not exempt members from regular reporting processes when entering Canada outside the program area and cannot be used at a land border POE within the program area.

CANPASS Private Boats Plus Program

The CANPASS Private Boats Plus program was designed as a regional compliment to the national CANPASS – Private Boats program in 1997. The program is in operation in the Quebec Region on Lake Memphremagog, Missisquoi Bay (Lake Champlain) and the Richelieu River in a similar fashion as the CANPASS RABC program. Members — pre-approved, low-risk travellers — are exempt from reporting requirements unless they are bringing in goods that will remain in Canada or that are valued over their personal exemption. Completed application forms must be mailed to a CBSA office, where they are risk assessed against enforcement databases. The CAN$40 permit, valid for five years, is only granted for vessels that are licensed in Canada and used for recreational purposes on specified waterways. Members can register an additional boat.

CANPASS RPP

The CANPASS RPP was implemented in 1997 to facilitate the cross-border travel of low-risk, pre-approved residents of specific areas who can demonstrate a need for after-hours access at remote, non-24-hour POEs. Need was limited to personal health and well-being, and included access to gasoline, grocery, medical and religious services. Initially, the program included 21 POEs that the CBSA had identified based on a POE-by-POE risk assessment that accounted for geography, population and economic factors. After 9/11, the program was reduced to four POEs along the New Brunswick–Maine border, and was later reduced to two POEs, Fosterville and Forest City, New Brunswick. The program enables permit holders to enter Canada after POE hours. Passages are recorded by members swiping a membership card and being videotaped. Border services officers (BSOs) review the videotapes afterwards. The program has been closed to new applicants since 2001, at which point there were 615 members in 275 households, divided almost equally between Canadian and U.S. citizens. Similar to other CANPASS programs, applicants were risk assessed before being enrolled.

Q19 Program

The Q19 program was implemented in 1978. The program area spans across 276 km of the Quebec–Maine border. This program enables commercial importers to report after normal hours of operation at four POEs and anytime at an unguarded private road crossing at Saint-Zacharie, Quebec, along the Quebec East Border District. The roads in the area are mostly unpaved, and for large trucks, are passable only at night at certain times of the year. The Q19 program was initially designed to facilitate the entry of logs for sawmills in the area, but the program is also used to import lumber machinery parts and fuel. Importers are required to provide cargo manifests for each passage, which are placed in locked boxes at each of the five POEs. Q19 drivers must report to the nearest open POE when importing personal goods.

Q19 program applicants can apply and receive a membership, free of charge, at four of the POEs in the program area. The CBSA risk assesses applicants (companies, employees and drivers), using criminal, immigration and customs databases to ensure eligibility for and admissibility to the program. Memberships are evergreen, and risk assessments of members are only conducted at the time of application.

The Q19 program also includes an individual traveller component. The members of this component were transferred to the Q19 program when the Q20 program — the companion program for non-commercial members — was closed down after 9/11.

Program Stakeholders

The People Programs Directorate (PPD) in the Admissibility Branch is the CBSA's functional authority for people processing. The Directorate is responsible for developing a strategic vision, national policy and programs for the movement of people that will allow for the full integration of the legacy customs, immigration and food inspection organizations in all modes of transportation (highway, marine, rail and air). The Operations Branch's People Processing section focuses on the effectiveness, efficiency and consistency of the delivery of programs related to the processing of people by the CBSA, providing integrated support for CBSA regional operations.

While the PPD is the functional authority for CANPASS RABC and Private Boats Plus, the programs are regional initiatives managed by the Northern Ontario Region and the Quebec Region's Montérégie Border District. The PPD currently has no resources assigned to the CANPASS RPP. The PPD's counterparts in the Operations Branch have indicated that they have no responsibility for the CANPASS RPP. Currently, this program is strictly functioning as a regional program and is managed by the North-West New Brunswick District.

Similarly, the Commercial Border Policy Division of the Admissibility Branch is responsible for the development of programs, policies and activities that regulate the movement of goods into Canada, and the Operations Branch's Goods Processing Division is responsible for ensuring the effectiveness, efficiency and consistency of the delivery of programs related to the processing of goods entering and exiting Canada. However, the Q19 program is a locally managed program by the Quebec East Border District.

Evaluation Purpose and Scope

The evaluation of the CBSA's CANPASS RABC and Remote Ports programs was identified as a priority for the 2008–2009 fiscal year in the CBSA's 2008–2011 Risk-Based Multi-Year Evaluation Plan. Evaluation priorities are based on annual consultations with CBSA directors general and regional directors general based on their perception of the associated risks. Through these consultations, the CANPASS RABC and Remote Ports programs became priorities for an evaluation. The Agency Evaluation Plan was then approved by the Executive Evaluation Committee. The CANPASS Private Boats Plus and Q19 programs were added to the evaluation in order to assess a fuller range of CBSA remote border location programs and to ensure that evaluation resources are used efficiently.

In preparation for this evaluation, the evaluation team, in consultation with key internal stakeholders, developed a logic model for the remote border location programs. Based on the logic model, key evaluation issues were identified and an evaluation plan was developed.

The CBSA's Program Evaluation Division in the Strategy and Coordination Branch planned and conducted this evaluation. The evaluation research was conducted between July 2008 and April 2009.

Table 1: Key Evaluation Questions

Evaluation Issue	Evaluation Questions
Relevance	To what extent are the CANPASS RABC, Private Boats Plus and Remote Ports programs, and the Q19 program aligned with government-wide and CBSA priorities?
	To what extent do the remote border location programs realistically address an actual need?
Program design and delivery	How effective is the remote border location program governance structure for managing and conducting related activities?
	How effective is the training for delivering the remote border location programs?
	Are performance measurement data collected, analyzed and reported on for the continuous improvement of the remote border location programs?
Results	How compliant are members of the remote border location programs?
	How do CBSA remote border location programs contribute to the security of Canada?
	How satisfied are members of the remote border location programs with the programs?
Program efficiency	Are the remote border location programs delivered efficiently?
	If the remote border location programs did not exist, what would the impacts be?
	Are there alternative approaches and technologies that could improve the success of the CBSA in achieving its dual objectives of security and prosperity in remote border locations?

Evaluation Methodology

The research design for the evaluation included a mix of qualitative and quantitative methods. Where possible, multiple methods and lines of evidence were used to address each research question. The design included the following methods:

1. Review of key documents: These documents included historic and current program communications, program charter documents, reviews and other briefings related to the programs, as well as reports such as the National Port Risk Assessment.
2. In-depth interviews with key stakeholders: In total, 58 CBSA staff at Headquarters (HQ) and in the regions, in addition to one external stakeholder, were interviewed for this evaluation. There were formal and informal interviews, as well as one-on-one and group interviews (Table 2).
   
   

   Table 2: Number of Interviewees

   Interview Category	Number of Interviewees
   Total	59
   CBSA HQ management and staff	36
   CBSA regional management and staff	22
   External stakeholders	1

3. Site visits: A series of site visits were conducted to observe CBSA operations in the remote program areas:
   • Sprague and the First Nations area of the Northwest Angle, Manitoba (CANPASS RABC)
   • the Rainy Lake and Lake of the Woods areas, Ontario (CANPASS RABC)
   • Fosterville, New Brunswick, POE (CANPASS RPP)
   • Forest City, New Brunswick, POE (CANPASS RPP)
   • Sainte-Aurélie, Quebec (Q19)
   • quai Richelieu, Quebec (Q19)
   • Armstrong, Ontario (Q19)
   • Saint-Zacharie, Quebec (Q19)
   • Lake Memphremagog, Quebec (CANPASS Private Boats Plus)
   • Missisquoi Bay, Quebec (CANPASS Private Boats Plus)
   • Richelieu River, Quebec (CANPASS Private Boats Plus)
4. CANPASS RABC member survey: Program records with client information were used to develop a statistically representative sample for a telephone survey of CANPASS RABC permit holders. The main goal of the survey was to identify program performance measures, including the reasons for use, modes of transportation used, frequency of passage⁴ and satisfaction levels, and to assess whether the requirements of the permit are being met through member compliance.
   
   A randomly drawn list of 1,224 2008–2009 CANPASS RABC members was the basis for the survey sample of 1,038 members with valid contact information. A response rate of 65% was yielded from 678 completed surveys. The reasons and rates of non-response were recorded in detail, and potential biases due to non-response were minimal. The survey was conducted in April 2009.

Study Limitations

CANPASS RABC membership information was adequate and provided for a strong survey sample. This was not the case for the other programs examined as part of this evaluation. Data limitations for the other programs included lack of basic information about levels of use, compliance and satisfaction. This lack of data limited the evaluation in determining the extent to which the programs had achieved expected results. As well, financial information could not be extracted and mapped precisely against the programs being evaluated.

Key Findings

Relevance

To what extent are the CANPASS RABC, Private Boats Plus and Remote Ports programs, and the Q19 program aligned with government-wide and CBSA priorities?

The CANPASS RABC and Private Boats Plus programs facilitate passage for members and permit landing in Canada without reporting prior to or upon arrival. The Presentation of Persons (2003) Regulations, as well as restrictions under the Immigration and Refugee Protection Act allow for telephone reporting in advance or upon arrival, but in all cases reporting is required. Since CANPASS RABC allows for passage without reporting, it undermines border integrity.

CANPASS RPP membership has been frozen since 2001. While passages are recorded by video camera, which BSOs review to ensure compliance, vehicles and occupants are sometimes difficult to identify, particularly during the winter months when licence plates may be obscured by snow and ice. In addition, the equipment for swiping members' cards often does not work or does not work properly, with the result that the cards may not be read at all.

While the Q19 program was initially designed only for commercial purposes, individual members of the traveller Q20 program were transferred to Q19 when Q20 was terminated in order to increase security after 9/11. There are no records of the number of non-log shipments, nor are there any data available on the number of passages by non-commercial users of the program (former Q20 program members).

The use of CANPASS RABC has also evolved beyond its original design to include modes of travel other than pleasure craft, such as snowmobiles, which can cross the border at any point along frozen waterways and beyond shorelines. The CBSA's enforcement team in the program area performs some monitoring activities on the water.

To what extent do the remote border location programs realistically address an actual need?

The CANPASS RABC program area is geographically remote and vast with islands scattered throughout, making it very attractive to those with a passion for the remote wilderness. There are few reporting stations for entering Canada along rivers and on islands, and for many, using the reporting stations would mean considerable detours and extra time spent to reach their destination. Similarly, the Q19 program area is mountainous and heavily forested with a few communities dispersed over several hundred kilometres. Several of the access roads are not paved, with the result that carrying commercial goods during the spring thaw can only be done at night when the roads are frozen — thus outside POE hours. While the design of these programs meets geographical challenges and thereby facilitates passages, it does not focus sufficiently on ensuring security.

According to the CANPASS RABC member survey, the most common reason cited for using a CANPASS RABC permit in 2008 was to go hunting or fishing (57.4%) (Table 3). U.S. members (the majority of CANPASS RABC members) were much more likely to use the permit for this purpose (62.9%) than Canadian members (7.5%). Canadian members were more likely to report using the permit to visit a restaurant or bar (24.5%) than U.S. members (0.8%). In comparison, only 2.8% of the 530 members surveyed used the permit for work-related purposes.

Table 3: Main Reasons for Most Recent CANPASS RABC Passages in 2008⁶

Reason	Total U.S. CANPASS RABC permit holders	%	Total Canadian CANPASS RABC permit holders	%	Total U.S. and Canadian CANPASS RABC permit holders	%
Total	477	100	53	100	530	100
Hunting or fishing	300	62.9	4	7.5	304	57.4
Going to own cottage or cabin	54	11.3	4	7.5	58	10.9
Working	11	2.9	4	0.8	15	2.8
Camping	52	10.9	1	1.9	53	10.0
Visiting with family/friends	16	3.4	2	3.8	18	3.4
Sightseeing	15	3.1	3	5.7	18	3.4
Visiting a restaurant/bar	4	0.8	13	24.5	17	3.2
Staying at a lodge or resort	10	2.1	5	9.4	15	2.8
Shopping	2	0.4	0	0	2	2.4
Other7	20	4.2	10	18.9	30	5.6

Source: 2009 CANPASS RABC member survey results.

According to the survey findings, 82.0% of current CANPASS RABC members have been members at some time previous to 2008, which indicates an ongoing appeal to the program. Of U.S. CANPASS RABC members, 82.9% were members in previous years, compared to 74.3% of Canadian members. Almost a quarter (24.5%) of respondents reported that they had been CANPASS RABC members for 10 years or more. While this may indicate that the program is filling a need, the survey found that convenience and leisure are the main drivers.

CANPASS Private Boats Plus members are required to report their passage when they enter Canada with restricted items or goods valued above their personal exemption. Members must also report any non-CANPASS Private Boats Plus passengers. However, no reports were available on members ever having declared goods at telephone reporting centres, likely due to how the information is logged in the systems (i.e. under CANPASS – Private Boats). There was no way to assess use of CANPASS Private Boats Plus, nor the reasons for becoming a member.

The CANPASS Remote Ports program has 615 members, 128 of whom used their permits for after-hours passage in 2008 (Table 4). Each of the 128 members used the program 3.5 times in 2008. Of note is the fact that the program was not used at all for four months in Fosterville, New Brunswick, and typically less than once a day in Forest City, New Brunswick.

Table 4: CANPASS RPP Passages 2008⁸

Forest City Passages	# of Passages	# of Unique Members9
Total RPP	451	128
January	20	5
February	18	4
March	26	7
April	24	6
May	39	16
June	33	9
July	39	11
August	17	6
September	30	10
October	23	7
November	21	6
December	24	5
Total Forest City	314	92
Fosterville Passages	# of Passages	# of Unique Members
January	14	7
February	25	8
March	20	6
April	20	5
May	12	6
June	0	0
July	0	0
August	0	0
September	30	1
October	4	3
November	0	0
December	12	7
Total Fosterville	137	36

Source: CBSA program passage records.

The Q19 program was established for a narrow range of industry stakeholders seeking to use Canadian milling services for their supply chain of lumber products at the Quebec–Maine border. The number of annual shipments is based on the number of cargo manifests collected from the after-hours drop-box — the only source of information on after-hours volume. This represents some 60 shipments a day after hours, a considerable amount of commercial traffic at a POE with no BSOs present.

With the exception of thaw periods when roads are not passable during the day, the need for this enhanced access is not clear. However, interviewees stated that member carriers of the Q19 program use the after-hours service as a way of managing wait-times during regular hours. In other words, the availability of after-hours service (and the one unmanned POE) factors in to the current logistics of log transport in the area. While the program was put in place as an exception to normal passages during regular CBSA hours, it has evolved to be the norm.

Program officials indicated that there are 23 communities in the Q19 program area, ranging from a few hundred to a few thousand residents. The entire area has a population of approximately 60,000 people. Each of these communities is heavily involved in the logging and lumber industry, including mills, secondary processing such as lumber treatment, and transportation. There are many mills and factories that are spread across the 300-400 km border span. While logging and lumber is not the sole industry in the area, it is clearly the most significant, and it works to support much secondary service and commerce.

It is noteworthy that the U.S. Customs and Border Protection (CBP) POEs in the area accommodate the need for after-hours travel during the spring thaw by extending the hours of operation seasonally, and do not provide an after-hours alternative to crossing the border.

Program Design and Delivery

How effective is the remote border location program governance structure for managing and conducting related activities?

Overall, regional officials indicated that governance has not been a problem to date, but agree that governance needs to be addressed in order to harmonize the programs nationally, and to establish clear lines of authority for making program changes. HQ officials also expressed a need for more centralized management and ownership of the programs.

The absence of clear national functional authority has led to inconsistent risk-assessment processes, fee structures and membership renewal requirements. Interviewees noted that the absence of centralized management has created issues, as the remote border location programs have evolved according to local decisions in response to the changing needs expressed by clients. This includes, for instance, the decision to allow CANPASS RABC permit holders to enter Canada with snowmobiles, all terrain vehicles and on foot, and the decision to allow the transfer of CANPASS Private Boats Plus flags between boats. Applicants who are approved for membership in the CANPASS Private Boats Plus program are given a burgee (identification flag) as part of their membership package. In order to identify themselves as CANPASS Private Boats Plus members, they are required to display their flag on their pleasure craft.

How effective is the training for delivering the remote border location programs?

None of those interviewed in the regions expressed concern or a need for training specifically directed at delivering the programs. Nevertheless, some of those interviewed at HQ expressed concern over a lack of program-specific training. Little training is needed in addition to what is provided through Port of Entry Recruit Training and other CBSA courses to screen applicants or process passages since these are the same skills required for other BSO duties in the program areas. The only exception is for the enforcement team in the CANPASS RABC program area, which is responsible for monitoring compliance on the water. These BSOs receive wilderness survival training and training on using boats, which are delivered by private-sector organizations.

Are performance measurement data collected, analyzed and reported on for the continuous improvement of the remote border location programs?

CANPASS RABC has current membership data since membership is renewed annually and contact information is updated upon membership renewal. However, the membership data is incomplete, and elements such as telephone numbers are not mandatory. Approximately 15% of members were not included in the survey sample due to inaccurate or dated contact information. On the other hand, only 15 of approximately 1,400 letters to CANPASS RABC members introducing the survey were returned to the sender. Until this evaluation, no data have been collected for the purpose of assessing CANPASS RABC program results or program improvement.

CANPASS RPP and Private Boats Plus membership information is not up-to-date, and it is not clear whether the current member lists include inactive members. For instance, while CANPASS RPP had 615 members as of 2001, only 128 members used the program in 2008–2009. While there are passage data for CANPASS RPP, the reliability of the data is questionable given the low quality of the videotapes and the periodic malfunctioning of the card readers. There are data for the entry of commercial shipments under the Q19 program, but there are none for Q19 program travellers. No data are collected for CANPASS Private Boats Plus for the purposes of program improvement, and there are no mechanisms in place to collect such data. Moreover, given the passage process for entering Canada under the CANPASS RABC and Private Boats Plus programs, there are few opportunities to collect data to measure performance.

Results

How compliant are remote border location program members?

Approximately 10% of CANPASS RABC member survey respondents indicated that they called a TRC to declare goods in 2008. This proportion of reporting is confirmed by the numbers collected by the TRCs.

There are no data on CANPASS RABC members' overall compliance. Some data are collected by the enforcement team operating out of Fort Frances, Ontario, which conducts on-water monitoring of the Rainy Lake and Lake of the Woods areas two days a week. Based on the team's report for 2008, 35 of the 1,521 travellers they questioned — or 2.3% — were found to be non-compliant. While the team did not record the number of CANPASS RABC members among those intercepted, this provides some indication of the compliance of all travellers in the area.

The CANPASS RABC member survey also revealed misunderstandings of program rules and restrictions. For instance, based on the open-ended responses, some members indicated that the permit meant that they could go anywhere on the water, providing they did not go ashore. Others indicated that they understood the "boundary waters" to be accessible to people on either side of the border without a permit.

The Royal Canadian Mounted Police (RCMP)-led Integrated Border Enforcement Team (IBET) operates between POEs. The only IBET presence in the CANPASS RABC program area is in Eastern Manitoba. The IBET conducts compliance stints in the Northwest Angle, an area where Ontario, Manitoba and Minnesota meet. CANPASS RABC members can access Canada by road in the Northwest Angle without having to report if they are not bringing any goods to declare. In the first five months of 2008–2009, the IBET had conducted 14 stints. Of the 296 vehicles it stopped, it gave two K19s¹⁰ for non-reporting (including one for suspicion of smuggling marijuana) and six warnings. However, it is not clear from the data whether any CANPASS RABC members received the K19s or warnings.

The TRCs do not have any records of reports by CANPASS Private Boats Plus members, which may be explained by the logging of these reports under the CANPASS – Private Boats program. With respect to CANPASS RPP, there are no records of duty and taxes collected at POEs and there are no records of any seizures. The video camera used to monitor CANPASS RPP passages recorded in 2008–2009 a traveller who approached the card reader, was not cleared, and turned around. The camera also recorded snowplow passages after hours; however, the drivers were not CANPASS RPP members. This is the extent of the compliance information available.

How do the CBSA remote border location programs contribute to the security of Canada?

In 2008, 2.1% (252) of the 11,775 CANPASS RABC applications received were rejected, and 0.5% (53) of CANPASS RABC permits were revoked (Table 5).

Table 5: CANPASS RABC Applications and Outcomes by POE for 2008

City (Ontario)	Total Applications	Issued	Refused	Revoked
Pigeon River	269	262	7	0
Rainy River	633	613	12	8
Fort Frances	2,204	2,137	57	10
Thunder Bay	8,669	8,458	176	35
Total	11,775	11,470	252	53

Source: Northern Ontario regional office.

CANPASS RABC program officials in Thunder Bay, Ontario, record application outcomes, including statistics on rates of and reasons for rejecting and revoking membership. According to program information, about half of the applications that were not approved were denied due to driving under the influence convictions. One in five of the applications rejected were the result of previous criminal convictions.

CANPASS RABC membership records show that household dependents can be numerous, and typically include spouses and adult children.

Q19 and CANPASS Remote Ports program memberships are evergreen. Once someone has been enrolled, they receive facilitated passage forever. As a result, the CBSA does not know whether members are in fact still low risk. At the time of evaluation, the CANPASS Remote Ports program was not accepting new members, but the Q19 program was, and these new applicants were risk assessed. CANPASS Private Boats Plus memberships are valid for five years. There are no regular risk assessments for members against enforcement databases.

Some concerns related to security in the CANPASS RABC program area were raised in the open-ended responses to the member survey. As well, some responses point to a lack of clarity on the part of members over CANPASS RABC conditions.

For the Q19 program, the fact that 21,895 log shipments — a full 72.4% of all shipments — pass through five border crossings unobserved and unmonitored poses a potentially high security risk. Moreover, the risk of non-members using the unguarded road in Saint-Zacharie, Quebec, is unknown since the CBSA currently has no BSOs present at this location.

The most recent 2008 Canada Border Services Agency–Citizenship and Immigration Canada National Port Risk Assessment assesses the level of risk for the CANPASS RPP and Q19 POEs, and for the land border POEs within the CANPASS RABC and Private Boats Plus program areas, but not the areas between the POEs (see Table 6). It is not possible to determine whether the risk rating of a land border POE can be extended to waterways nearby. The POEs are grouped into high, medium and low levels of risk¹¹.

Table 6: 2008 National Port Risk Assessment

Program	POE	Rank	Level of Risk
CANPASS RPP	Forest City, New Brunswick	153	negligible
	Fosterville, New Brunswick	150	negligible
CANPASS RABC	Pigeon River, Ontario	52	medium
	Rainy River, Ontario	66	low-medium
	Fort Frances, Ontario	39	medium
	Thunder Bay, Ontario	76	low-medium
Q19	Pohénémagook, Quebec	108	low
	Sainte-Aurélie, Quebec	92	medium
	Saint-Pamphile, Quebec	124	low
	Saint-Just-de-Bretenières, Quebec	161	negligible
	Saint–Zacharie, Quebec	n/a	n/a
CANPASS Private Boats Plus	Saint-Armand/Phillipsburg, Quebec	65	low-medium
	quai Richelieu, Quebec	156	negligible

Source: 2006 National Port Risk Assessment.

How satisfied are remote border location program members with the programs?

The CANPASS RABC member survey shows a high level of satisfaction with the program overall. A full 91.5% of respondents indicated that they were satisfied with the program, and only 4.6% indicated that they were unsatisfied (Table 7). The open-ended responses showed some complaints that are not related to the CANPASS RABC program, such as new restrictions on live bait, and the fact that no fish were caught during the respondents' last trip.

Table 7: Satisfaction with CANPASS RABC by Country of Citizenship

Satisfaction Level	U.S. Members	%	Canadian Members	%	Total	%
Very satisfied	408	70.6	51	67.1	460	67.8
Somewhat satisfied	139	24.0	16	21.1	155	23.7
Somewhat unsatisfied	17	2.9	1	1.3	18	2.8
Very unsatisfied	10	1.7	2	2.6	12	1.8
Don't know/No response	6	1.0	3	4.0	9	1.3

Source: 2009 CANPASS RABC member survey results.

Approximately 50% of the 427 comments made during the survey included medium to high levels of praise for CANPASS RABC. The main reason for the praise was the burden removed by not having to report. In all but a few instances, this was described as saving time and convenient. Members worry that the program will be taken away. This concern is based partly on the reduction of access to the United States in recent years, as well as the recognition by a small portion of members that the program is an exceptional privilege that is threatened by security concerns.

Complaints about the program were evident in less than 5% of the responses. The most common complaint was the cost of the permit and the need to re-apply every year, which makes the CANPASS RABC permit more costly than that of CANPASS – Private Boats and NEXUS.

Program Efficiency

Are the remote border location programs delivered efficiently?

It was difficult to accurately capture the actual costs of program operations for all four programs due to a lack of a breakdown of financial information. However, based on the information that was provided, the evaluation estimates that the CBSA spends approximately CAN$500,000 to deliver these programs yearly.

Table 8: Estimated Resources by Program

CANPASS RABC

	FTEs (#)	Salaries ($)	O&M ($) (2008–2009)	Members (2007–2008)	New members (2007–2008 )
Total for CANPASS RABC	4	$241,231	$142,686	11,47012	11,162
Thunder Bay and Pigeon River, Ontario
Application processing	2.4	$145,219	$122,496
Verification	0.4	$22,203	n/a
Total Thunder Bay and Pigeon River	2.8	$167,422	$122,496
Fort Frances, Ontario
Application processing	0.5	$30,604	$20,190
Monitoring activities13	0.5	$30,604	n/a14
Total Fort Frances	1.0	$60,008	$20,190
Rainy River, Ontario
Application processing	0.2	$13,801	n/a
Total Rainy River	0.2	$13,801	n/a
HQ
Administrative functions	0.5	$33,000	n/a
Total HQ	0.5	$33,000	n/a

CANPASS RPP

	FTEs (#)	Salaries ($)	O&M ($) (2008–2009)	Members (2007–2008)	New members (2007–2008 )
Total for CANPASS RPP	0.06	$3,600	$13,000	61515	N/A16
Forest City and Fosterville, New Brunswick
Application processing	n/a	n/a	n/a
Monitoring activities	0.06	$3,600	$13,00017

CANPASS Private Boats Plus¹⁸

	FTEs (#)	Salaries ($)	O&M ($) (2008–2009)	Members (2007–2008)	New members (2007–2008 )
Total for CANPASS Private Boats Plus	0.56	$36,600	n/a	52219	7820
Quebec Region
Application processing	0.06	$3,600	n/a
Monitoring activities	N/A	N/A	n/a
Total Quebec Region	0.06	$3,600	n/a
HQ
Administrative functions	0.5	$33,000	n/a
Total HQ	0.5	$33,000	n/a

Q19²¹

	FTEs (#)	Salaries ($)	O&M ($) (2008–2009)	Members (2007–2008)	New members (2007–2008 )
Total for Q19	0.77	$46,206	n/a	644	N/A
Quebec Region
Application processing	n/a	n/a	n/a
Monitoring activities	0.77	$46,206	n/a

Total Estimated Resources by Program

	FTEs (#)	Salaries ($)	O&M ($) (2008–2009)	Members (2007–2008)	New members (2007–2008 )
Total for all programs22	5.39	$327,637	$155,686	12,408	11,240

If the remote border location programs did not exist, what would the impacts be?

The CANPASS RABC members surveyed reported making an average of 12.6 passages per year, which translates into at least 75,600 passages²³ into Canada. The CANPASS RABC member survey showed that about 57% of passages involve a day trip for hunting or fishing, which would involve minimal expenditures in Canada. This was confirmed in open-ended responses in which members indicated that they often used the CANPASS RABC permit to fish, and that they do not go ashore in Canada. However, about 9% of trips are for work, shopping or staying at a lodge or resort in the area.

No data are available on the dollar amounts spent by CANPASS RABC members during their trips to Canada, nor on the impact that removing CANPASS RABC would have on the number of actual passages. Therefore, it is not possible to calculate the overall impact that the absence of this program would have on the local economy. However, it is not unreasonable to assume that, in the absence of the program, individual businesses could be negatively impacted. Some lodge owners, who are also CANPASS RABC members, indicated in their survey responses that their businesses were built around the program and that the number of guests would drop considerably if the program were to be cancelled.

The absence of after-hours border crossing privileges would force logging trucks to use longer routes for the transportation of logs to mills during the spring. This would increase the transportation costs that would have to be absorbed by carriers or passed along to mills in the form of higher prices for raw materials. The magnitude of this impact is unknown and its detailed calculation falls outside the scope of this study.

Are there alternative approaches and technologies that could improve the success of the CBSA in achieving its dual objectives of security and prosperity in remote border locations?

The policy for determining eligibility for and membership in the NEXUS program was changed in 2008 from a "zero-tolerance" approach to a new "strict standard". This presents an opportunity to transition many CANPASS RABC members to NEXUS since CANPASS RABC operates with a similar "strict standards" approach. In fact, the CANPASS RABC member survey showed that approximately 10% of current members are already either CANPASS – Private Boats or NEXUS members.

Moving current members over to existing programs was suggested by a number of CBSA senior management members interviewed for this evaluation. The benefits are the harmonized application and passage processes with the United States, and a more rigorous risk assessment process. However, both NEXUS and CANPASS – Private Boats require designated reporting stations for people to report entry into Canada and/or for examinations, and. there are few stations in the CANPASS RABC program area at this time. In addition, reporting to the CBSA by cellular telephone would be difficult due to a lack of cellular telephone towers in the area.

If CANPASS RABC and Private Boats Plus members were to use either NEXUS or CANPASS – Private Boats, the CBSA telephone reporting centres (TRCs) could accommodate the extra volume of calls. The TRCs comprise four separate call centres nationally, and they serve a large number of programs and clients. According to TRC staff, additional calls can be managed effectively by sharing incoming calls across call centres, and by the seasonal addition of employees, as per normal practices.

The Remote Ports Entry Pilot is a U.S. CBP program that enables members to have after-hours entry privileges into the United States at five POEs along the Maine–New Brunswick/Quebec border. The program limits applicants to certain POEs where they must demonstrate a need to access family members or essential caregivers. The program has applied technology for remote examination and gate operation that enables BSOs to question travellers and control access from a single remote location. The technology also allows for the automated record-keeping of passages, enhanced security and 24-hour service.

The cost of this technology, including radio-frequency identification technology (card production and vehicle tags), remote cameras, audio communications and biometric verification (fingerprint) machines is approximately CAN$250,000 per site, and CAN$1 to 2 million for a command centre to serve multiple sites. This is assuming that basic services such as electricity are available at the remote site. Additional costs would also be incurred to connect sites to the command centre. U.S. CBP interviewees expressed a willingness to support the CBSA in developing solutions that would meet the needs of both agencies and the local residents.

The after-hours needs of commercial Q19 permit holders could be addressed through a seasonal tailoring of the hours of operation of the affected POEs to accommodate night passage during the spring thaw when logging roads are not usable during the day. This approach is used by U.S. CBP. The harmonization of CBSA hours with those of U.S. CBP would likely require an additional expenditure of between CAN$2 milllion and CAN$2.4 million in salaries annually.

Key Conclusions, Recommendations and Management Response

This evaluation covers the CANPASS RABC, Remote Ports and Private Boats Plus programs and the Q19 program, which have been in operation for many years in remote areas of Canada and were developed as pilot projects to test seasonal reporting options. The CANPASS RABC program was initially a joint Canada Revenue Agency and Immigration Canada program.

It was difficult to accurately capture the actual costs of program operations for all four programs due to a lack of a breakdown of financial information. However, based on the information that was provided, it is estimated that the CBSA spends approximately CAN$500,000 to deliver these programs yearly.

The programs were created to address local needs and highlight the challenges of managing the border and POEs in remote areas. While the programs facilitate members' access to Canada, their design and delivery may no longer address the needs of current security priorities. For example, the lack of reporting required for CANPASS RABC and Private Boats Plus members who enter Canada without goods to declare does not meet current CBSA and government-wide priorities for border integrity. Similarly, the after-hours access to Canada provided by the Q19 program depends on the voluntary compliance of members. The CANPASS RPP admits program members into Canada using technology such as a card reader and a video camera. However, the technology does not support current standards for reporting and examination.

The number of clients served by the remote border location programs is relatively small. CANPASS RABC, the largest program of the four evaluated, has approximately 14,000 members who, on average, crossed the border into Canada 13 times in 2008. This program is mostly used for leisure, access to cottages, and/or to save travelling time. While the CANPASS Private Boats Plus program has 522 members, most of whom are Canadian residents, the number of active members is not known, nor is it known how often they use the program. Based on 2008 CANPASS RPP passage statistics, this program was used by only 128 members, which is 21% of those registered as of 2001 when membership was frozen. Program officials indicated that member needs are to access services such as family physicians, pharmacies and retail food after POE hours. The Q19 program also serves an unknown number of private travellers. Their specific levels of use and needs are also not known.

CBSA officials responsible for the Q19 program indicate that it facilitates the import of 21,895 log shipments annually outside POE hours. This represents 72.4% of the overall annual volume of logs entering Canada at the affected POEs for processing at local mills. Of the four programs reviewed in this evaluation, the Q19 program was the only one that was designed specifically to address a significant commercial need. However, these POEs are not designated commercial offices; therefore, they have a limited examination capacity.

The evaluation concludes that the current structures of these programs are not optimal and that some alternatives that better align with CBSA and Government of Canada priorities exist.

Transitioning current CANPASS RABC and Private Boats Plus program members over to the NEXUS program or other CANPASS programs would benefit the Agency through more rigorous risk assessments of members. However, because of the remoteness and vastness of the program areas, additional investments in reporting stations and telephone reporting centres may have to be made. The evaluation found that U.S. CBP use of infrastructure and new technologies for remote border examination and access may have similar benefits for Canada in the remote areas where the CANPASS RPP and Q19 programs are delivered.

Alternatives to the Q19 program are limited. While the Customs Self Assessment and Free and Secure Trade programs would allow for more frequent and rigorous risk assessments of members, they would not facilitate the after-hours commercial access required during periods when the daytime use of roads for commercial shipments is not possible.

The evaluation recognizes that managing the border in remote areas is inherently challenging. Nevertheless, there is a need to ensure that the CBSA's mandate and priorities are met. In view of these findings, the evaluation recommends the following:

Recommendation: The Agency should develop strategies that would rationalize the CANPASS RABC, Private Boats Plus and Remote Ports programs, and the Q19 program with existing measures to the extent possible. The Admissibility Branch, in cooperation with the Operations Branch, should consider developing a national remote border location strategy that addresses the need for clear national accountabilities and standards (e.g. national eligibility requirements, standard fees and membership durations) and that aligns with the Agency's mandate and responsibilities.

Management Response:

The Admissibility Branch concurs with the recommendation.

The CBSA has decided to cancel the CANPASS Private Boats Plus program at the end of the 2009 boating season. Current CANPASS Private Boats Plus members will become subject to the requirements of the CANPASS – Private Boats program (of which they are already members) and will be encouraged to apply for the NEXUS (marine) program.

Strategies for the rationalization of the CANPASS RABC and Remote Ports programs and the Q19 program are consistent with the approach that the Admissibility Branch is taking. A technological solution similar to the one used in the U.S. Remote Ports Entry Program to replace the Q19 program in Quebec and the CANPASS RPP in New Brunswick, as well as the transitioning of CANPASS RABC and CANPASS Private Boats Plus members into NEXUS are being proposed.

To ensure border security and adherence to proper reporting procedures under the Customs Act and the Immigration and Refugee Protection Act, replacement of the current programs will require the creation of additional telephone reporting stations for remote locations, in addition to the implementation of the automated technology previously noted. As such, it is anticipated that costs will be significant.

The Admissibility Branch has committed to developing a trusted traveller strategy by March 2010 that includes a review of existing trusted/registered traveller programs. The strategy will take into consideration the need for better harmonization with the United States and improved effectiveness in managing remote border locations across Canada.

Annex: Acronyms

Acronym	Description
CBSA	Canada Border Services Agency
CPIC	Canadian Police Information Centre
FOSS	Field Operations Support System
FTE	full-time equivalent
HQ	Headquarters
IBET	Integrated Border Enforcement Team
ICES	Integrated Customs Enforcement System
NCIC	National Crime Information Center
O&M	operation and maintenance
POE	port of entry
RABC	Remote Area Border Crossing
RCMP	Royal Canadian Mounted Police
RPP	Remote Ports program
U.S. CBP	United States Customs and Border Protection

---

• 1. While this program is called CANPASS RABC, it does not have the core elements of other CANPASS programs vis-à-vis applications, passage and reporting requirements. [Return to text]
• 2. 2009 CANPASS RABC member survey. [Return to text]
• 3. CANPASS Remote Area Border Crossing (RABC) [Return to text]
• 4. 2009 CANPASS RABC member survey. [Return to text]
• 5. This estimate is based on data provided from Thunder Bay, Fort Frances, Rainy River and Pigeon River, Ontario. Dependents may or may not be reflected in this estimate. [Return to text]
• 6. All differences are significant at the .05 level. Figures do not exceed a 3.9% margin of error. [Return to text]
• 7. The most common ‘other' reason for using CANPASS RABC was to use snowmobile trails. Additional ‘other' reasons included checking on a cabin, delivering a boat, purchasing a fishing licence, walking a dog and escorting boy scouts on a camping trip. [Return to text]
• 8. Figures are based on card swipes and supporting video recordings whenever possible. Figures do not include passages by snowplow crews and emergency vehicles, which may also enter Canada after hours. [Return to text]
• 9. "Unique members" refers to members who actually used their CANPASS RPP permit during 2008.  [Return to text]
• 10. A K19 is a customs seizure receipt that must be completed when goods are held or seized. [Return to text]
• 11. The index groups environmental factors for each POE and is based on enforcement and intelligence information. [Return to text]
• 12. Based on information provided by Thunder Bay, Fort Frances, Rainy River and Pigeon River, Ontario. [Return to text]
• 13. Alternate airports, rail examinations and highway examinations were monitored at Fort Frances and Rainy River, Ontario. [Return to text]
• 14. Operation and maintenance (O&M) related to monitoring activities included in CAN$20,190 estimate on previous row. [Return to text]
• 15. Based on the membership listing from 2001. [Return to text]
• 16. CANPASS RPP membership has been frozen since 9/11. [Return to text]
• 17. This represents the yearly maintenance contract between the region and the contractor, which was unlikely to be renewed as of March 31, 2009. [Return to text]
• 18. The CANPASS and NEXUS programs have a single program activity code. CANPASS Private Boats Plus does not have a dedicated budget line. [Return to text]
• 19. Based on regional membership data as of the end of June 2008. Note that membership has declined since April 2003. [Return to text]
• 20. Verbal estimate from the Quebec Region. [Return to text]
• 21. The Quebec Region has not created a specific activity code for its employees that administer the Q19 program. [Return to text]
• 22. This is the total full-time equivalents (FTEs) and O&M for all four remote border locations programs. [Return to text]
• 23. This figure likely underestimates total CANPASS RABC passages. The CANPASS RABC member survey sample was based on approximately 6,000 households, many of which include spouse and dependent child members. Passage data for spouses and children were not collected and are therefore not included in the 75,600 estimate. [Return to text]