E-Manifest: Sustaining the e-Manifest National System through User Fees

By Mathy Stanislaus

Recently, I blogged about the selection of members for our e-Manifest Advisory Board, an exciting step in the creation of an electronic system for tracking hazardous waste shipments from “cradle-to-grave.” This system, known as e-Manifest, will improve access to timely hazardous waste shipment data and will reduce burdens associated with the current paper manifest system.

How are we funding this system? In the e-Manifest Act, Congress required that EPA recover all of the costs of developing and operating the system. E-Manifest will be entirely supported by user fees charged to those who use manifests to track shipments of their hazardous wastes. Congress directed EPA to create a system for collecting user fees, which makes lots of sense. After all, the cost of handling and tracking hazardous waste ought to be borne by those who generate it, not the tax payer. After all, maybe they will generate less!

Today, I’m pleased to highlight another important step toward our goal of deploying the e-Manifest system in the spring of 2018. We have released a proposed rule that explains how we propose to establish and revise the system’s user fees. Now it’s your turn; we want your input. We are looking forward to getting informed and insightful public comment. The proposal covers:

  • Who must pay e-Manifest user fees,
  • The types of transactions that will incur fees,
  • The formula we’ll use to set fees,
  • Options for paying fees electronically,
  • A process for periodically revising user fees, and
  • Sanctions for non-payment.

Our proposal plans to levy user fees on the facilities that receive manifested waste shipments, with the fees tailored to whether paper or electronic manifests are submitted to the system. Paper is a lot more expensive to handle and process. At EPA we’re advocates of reduce, reuse, recycle. The bottom line is that we’re trying to set this system up so that paper becomes the choice of last resort. If we are successful the system will be more efficient, cost less and save more.

I encourage you to tell us what you think. Comments on this proposal will be accepted for 60 days following publication of this rule in the Federal Register. EPA is requesting commenters to use the new comment platform, which can be found at https://epa-notice.usa.gov/. Information on the new platform can be found in the Federal Register Notice for the proposed rule, as well as on the EPA e-Manifest proposed rule Web page. You may follow progress on EPA’s development of the e-Manifest system on our website. If you subscribe to the e-Manifest ListServ, you will receive project updates in real time and information about opportunities to provide feedback. EPA will also conduct an upcoming webinar to discuss the user fee proposals under consideration and encourage all interested parties to participate.

Once we’ve reviewed the public comments and feedback from the Advisory Board, EPA will finalize the user fee methodology and establish user fees for the e-Manifest system, which we expect to do in late 2017. We are excited about the strides we are making in realizing this national system, and remain dedicated to maintaining open dialogue and continuing collaboration. For more updates, visit our e-Manifest website.