MEMORANDUM

SUBJECT:		Derivation of E-Manifest Cost Savings Estimate of $75 Million/Year
			From the 2009 e-Manifest Alternatives Analysis Document
                                       
Date:			November 13, 2013
From:			Richard LaShier, Workgroup Chair
To:			e-Manifest Regulatory Docket

EPA has not prepared a detailed regulatory impact assessment for this regulation, as we have deferred the detailed evaluation of costs, burdens, savings, and other benefits until the later promulgation of the Fee Rule.  However, the final rule does include statements (consistent with EPA's 2012 testimony on e-Manifest legislation) indicating that when e-Manifest is implemented, we expect cost savings exceeding $75 million per year.  To support this statement, we are including in the docket this derivation of this cost savings estimate, which was prepared by EPA economist Chris McMinimy in the Office of Resource Conservation and Recovery.
                                       
   * EPA expects e-Manifest will reduce RCRA hazardous waste manifest compliance burden
         o 2009 eManifest Alternatives Analysis estimates administrative costs of approximately $300 million
         o Estimates reduction in administrative costs of 25%
         o Estimates annual cost savings of approximately $75 million
            
   * EPA estimates reductions in administrative costs in 2009 eManifest Alternatives Analysis Document

         o Estimates three types of administrative costs
            
               1. Federal Manifest administrative costs
                     * Industry burden from complying with federal RCRA manifesting requirements
                     * 2,137,000 federal manifests generated annually
                     * Industry cost per manifest: $51
                     * Total cost: $108,987,000
                        
               2. State Manifest administrative costs
                  
                     * Industry burden from complying with state RCRA manifesting requirements
                           o More stringent than federal RCRA, only applicable to some states
                           o 2,947,000 state manifests generated annually
                           o Industry cost per manifest: $51
                           o Total cost: $150,297,000 
                              
                     * State government burden from administering RCRA manifest collection programs
                           o 2,947,000 state manifest generated annually
                           o Average per manifest cost: $5
                           o Total cost: $14,735,000
                              
               3. RCRA Biennial Reporting Administrative Costs
                     * Burden from complying with RCRA hazardous waste biennial reporting requirements
                     * Costs included because e-Manifest will eventually incorporate biennial reporting
                     * Total cost: $22,988,000
                        
         o Estimates reductions in administrative costs as 25% of all administrative costs
                     * Sum of federal manifest, state manifest, and RCRA biennial reporting administrative cost: $297,007,000
                     * 25% = $74,251,750
