Summary of EPA-ETC Meeting on E-Manifest, 1/22/2015

   * EPA presented 3 options for determining manifest fees, as well as estimates of fees under each option.
   * EPA explained the difference between the 4 proposed manifest submission methods (XML, Image, Paper, and fully electronic).
   * EPA updated ETC on rulemaking and procurement progress.
         o Discussed CROMMER issues 
         o RFP expected to be out by October 2015
   * EPA asked for ETC's help in contacting hazardous waste transporters.
   * ETC informed EPA that manifest volume varies from year to year, sometime substantially.  Gave 1996-1997 as an example.
   * ETC said that employing a backward-looking fee, where each cycle aims to recover costs from the previous one would be amenable to them.
   * ETC suggested requiring all TSDFs to submit manifests either by XML or fully electronic method.
   * ETC suggested that EPA not collect fees for fully electronic manifests in year 1 to bring more companies into the system.
   * ETC expressed that the XML submission option was the most attractive in the short run, that TSDFs would gradually shift from paper to XML to fully electronic manifests, and that companies would always retain the ability to use paper manifests.
   * ETC asked how fees would be charged for rejected shipments.
   * ETC expressed a desire for a simple fee structure.  To this end they said option 1 would be acceptable, especially initially. 
   * ETC said that TSDFs will have little influence to compel independent trucking firms to adopt e-Manifest.
