VZCZCXRO5021
RR RUEHCHI RUEHDT RUEHHM RUEHNH
DE RUEHGP #1612/01 2430020
ZNR UUUUU ZZH
R 310020Z AUG 07
FM AMEMBASSY SINGAPORE
TO RUEHC/SECSTATE WASHDC 3897
INFO RUCNASE/ASEAN MEMBER COLLECTIVE
RUEHHK/AMCONSUL HONG KONG 6244
RUEHGV/USMISSION GENEVA 0852
RUEAHLC/DEPT OF HOMELAND SECURITY CENTER WASHINGTON DC
RHMCSUU/DEPT OF ENERGY WASHINGTON DC
RULSDMK/DEPT OF TRANSPORTATION WASHDC
RUCPDOC/DEPT OF COMMERCE WASHDC

UNCLAS SECTION 01 OF 02 SINGAPORE 001612 
 
SIPDIS 
 
SENSITIVE 
SIPDIS 
 
E.O. 12958 N/A 
TAGS: PREL PGOV PTER PHSA ETRD EWWT SN
SUBJECT: GOS LETTER TO DHS REGARDING NEW CARGO SCANNING LEGISLATION 
 
REF: STATE 119837 
 
¶1.  (U) Transportation Minister Raymond Lim recently sent the letter 
in paragraph 2 to Secretary Chertoff highlighting Singapore's 
concerns about our new cargo scanning legislation.  Per State 
119837, we will report other local reactions septel. 
 
¶2.  (SBU) Begin text of letter: 
 
MINISTER FOR TRANSPORT 
REPUBLIC OF SINGAPORE 
 
6 August 2007 
 
The Honorable Secretary Michael Chertoff 
Department of Homeland Security 
The United States of America 
 
LEGISLATION REQUIRING 100% SCANNING FOR CONTAINERS 
BOUND FOR THE UNITED STATES 
 
Dear Mr. Chertoff: 
 
We have noted with concern the requirement for all containers bound 
for the United States to be pre-scanned at foreign ports from 1 July 
2012, which has been included in the legislation that was recently 
passed in Congress.  I am writing to share our serious concerns 
about the significant negative impact that this 100% container 
scanning requirement will have on maritime trade efficiency and 
consumers. 
 
Feasibility study still in progress 
----------------------------------- 
 
You would be aware that when Congress passed the SAFE Port Act on 13 
October 2006, the Department of Homeland Security (DHS) was tasked 
to conduct pilots at six foreign ports under the Secure Freight 
Initiative (SFI) to evaluate the feasibility of 100% scanning for 
containers bound for the United States.  As a major transshipment 
port and partner of the United States in many key security 
initiatives, Singapore agreed to participate at the request of DHS 
to assist in evaluating the feasibility of implementing 100% 
container scanning in a transshipment hub. 
 
With the SFI pilot study only just beginning, the necessary data to 
evaluate the feasibility and viability of 100% scanning is still 
unavailable.  The United States and other participating countries 
therefore do not yet have a good appreciation of the full slate of 
issues that could arise, although there is already considerable 
feedback from the ground operators on the negative impact of such a 
regime on global trade and business.  This would be detrimental to 
all parties concerned, including the United States. 
 
Higher cost for shippers and consumers 
-------------------------------------- 
 
Already, we can expect 100% scanning of containers bound for the 
United States to undermine operational efficiencies in ports and for 
shippers.  In the absence of data from the SFI pilot study, we will 
not be able to assess the full implications of this regime and 
undertake measures to mitigate its possible disruptions to maritime 
trade.  For example, longer container handling time will result in 
longer berth time and shipping charges.  This will inevitably 
translate into higher costs for American consumers.  In this regard, 
we note that several American and international business and 
industrial groups have also raised similar concerns over this issue. 
 Furthermore, the requirement on 100% container scanning could also 
encourage other ports to adopt similar measures for containers bound 
for their countries, including those originating from the United 
States.  Such retaliatory measures would have adverse impact on 
international trade. 
 
Impact on effective risk assessment 
----------------------------------- 
 
In addition, implementing a 100% scanning regime without the 
requisite technology to undertake an intelligent risk analysis of 
the data collected will in fact undermine efforts to improve 
security.   In such circumstances, the surge of data can actually 
degrade our risk assessment ability.  This would potentially put us 
in a situation worse off than with the targeted risk-based approach 
which we employ today. 
 
As the largest container port in the world handling more than 24 
million containers annually, Singapore is fully committed to 
 
SINGAPORE 00001612  002 OF 002 
 
 
ensuring security in the global supply chain. Since the United 
States is Singapore's 2nd largest trading partner, with total trade 
amounting to S$90 billion in 2006, the impact of the legislation on 
trade between Singapore and the United States is therefore very 
significant. 
 
Some of the technical concerns associated with a 100% scanning 
regime are outlined in the attached document.  Singapore will 
appreciate the Administration's consideration of these points, and 
the subsequent findings of the SFI trial, in assessing the 
feasibility of implementing 100% container scanning requirements at 
the Singapore Port. 
 
Yours sincerely, 
 
RAYMOND LIM 
Minister for Transport 
Singapore 
 
Technical Concerns in Implementing 100% Scanning of Containers Bound 
for the United States: 
 
¶1.  Current Scanning Technology Inadequate.  Existing scanning 
technology does not support the fast and efficient scanning of 
containers.  The portal-based system not only creates chokepoints in 
port operations but also increases handling and movement times of 
containers.  All these factors will inevitably translate into higher 
port charges for shippers and cargo owners.  Ultimately, consumers 
will end up bearing this increased cost of movement through the 
supply chain. 
 
¶2.  Duplication of Programmes.  The US already has several security 
initiatives in operation in many ports around the world, including 
but not limited to the Container Security Initiative (CSI), Megaport 
Radiation Detection Initiative (RDI), Proliferation Security 
Initiative (PSI), and Customs-Trade Partnership Against Terrorism 
(C-TPAT).  These measures provide for a layered approach to security 
today. To further mandate an additional blanket measure like 100% 
container scanning will result in duplication of resources for 
marginal gains. 
 
¶3.  Prohibitive Cost of Implementation.  To effectively impose 100% 
scanning in a major port will require a significant number of 
non-intrusive imaging and radiation detection equipment in order to 
minimize the impact to operational efficiency.  In a port like 
Singapore with a throughput of more than 24 million containers a 
year, the number of scanners required would be extremely 
prohibitive.  The shipping industry will also be hurt by such 
expensive measures. 
 
¶4.  Lack of Clarity on Funding.  The bill does not address the issue 
of funding for 100% scanning.  The cost of implementing such a 
programme will be significant and many ports will turn to the US to 
fund this requirement. 
 
¶5.  Total Supply Chain Security Approach.  A total supply chain 
approach to security -- one where all stakeholders in the supply 
chain play their part to secure the shipment from node to node -- is 
a more viable option.  The Authorised Economic Operators (AEO) 
programmes advocated by the World Customs Organisation (WCO) and a 
recognition of each country's secure supply chain procedures will 
provide a more effective and robust security approach.  This, 
coupled with effective risk-targeting of containers, will serve the 
world trading community better, both in terms of security and 
trade. 
 
End text of letter. 
SHIELDS