
                  Summary of Meeting at ETC on April 28, 2016
                                       
Attendees:
David Case 
James Williams
Tom Baker
Steve Deluse
Carrie Berenger
Craig Hogarth
Andy Marshall
Randy Sparks
Scott Christian
Stephen Donnelly
Bryan Groce


 EPA summarized the Fee Rule Progress and discussed the FY 2018 cash flow or budget planning crunch that is currently delaying OMB clearance of the proposed rule notice.
 EPA also refreshed ETC on the proposals under consideration, including the proposed sanctions, as well as the two sanction options on which we intend to request comment:  (1) denial of services and (2) restriction on waste receipts. 
 ETC didn't appear to support the proposed sanctions nor were they supportive of the other two sanction options. No real explanation was given for their general apprehension on sanctions. 
 One ETC member did mention that often times their customers are delinquent in payments so it would seem unfair to penalize the TSDF in such situations.
 EPA summarized the fee dispute material added to the proposed rule notice during OMB review. In the case of fee disputes, ETC asked whether the 30 day period for payment of manifest transactions apply during fee dispute claims. 
 Our response was No, but payments would be expected once a decision was rendered on the dispute.
 On the hybrid manifest proposal, ETC inquired whether TSDFs will be expected to keep a copy of the signed manifest for the hybrid option. 
 With respect to the request for comment regarding EPA's acceptance of only digital submissions (i.e., no paper copies), ETC indicated that EPA would at the very least need to accept paper copies during the first year of system launch.
 Our response was, only generators retain the paper copy for their records; TSDFs' electronic copies will be the CORs for them. 
 On the issue of billing and collection methods, ETC reiterated that they are in favor of the invoice approach for payments and are opposed to any advanced payment approach.
 ETC requested a pre-publication copy of the rule so that they have adequate time to comment.
 FACA Advisory Board Status: James Williams reported that the appropriators are very pleased with the diversity of the advisory committee.
 System Development Progress:  ETC indicated that they would like it if e-Manifest was more proactive in communicating software development progress/materials to the user community for comment.
 FY 2018 Budget Formulation Considerations:  ETC emphasized that any registration fee, no matter the size, would be considered a tax and they would not use the electronic manifest system but would continue to use paper manifests.


