Waste Tire Manifest System

1. Waste Tire Manifest System

2. Report on Waste Tire Manifest System • Electronic Data Transfer Pilot Project (EDT) expansion • Retreader Issue

3. WTMS Manifest Background • 1993 – SB 744 established the Hauler Registration Program and initial manifesting requirements for haulers. • 1998 - AB 117 required a report to the Legislature on the Used and Waste Tire Programs. The 1999 report recommended “closing the loop” and provided the basis for SB 876. • 2000 - SB 876 established the “California Uniform Waste and Used Tire Manifest” system which requires each party to a waste tire transaction to submit a copy of the manifest form to CIWMB.

4. EDT Pilot Project Expansion SB 876, PRC 42961.5, provides two means of collecting and submitting waste tire manifest information to the Board: • Paper based form submittal • Electronic Data Transfer Both methods are currently in effect.

5. PRC 42961.5, requires that Waste / Used Tire Generator Hauler End Use Facility each complete a Manifest form and/or trip log. “Closing the Loop” on accountability EDT haulers are permitted to use their own CIWMB approved forms. Report tire transaction data on behalf of their clients – pickup and deliveries EDT Pilot Project Expansion Collection Paper EDT

6. PRC 42961.5, requires that Waste / Used Tire Generator Hauler End Use Facility submit, via the mail, a copy of that form to CIWMB for processing. EDT haulers submit WTMS data monthly on pick ups, hauls and deliveries. Submittal is done electronically via the Board’s Website/Internet EDT Pilot Project Expansion Submittal Paper EDT

7. EDT Pilot Project Expansion Paper Manifest Processing Steps: • Collect forms from the Post Office • Open mailed forms and prepare for scanning • Scan the form into the computer, verifying form template • Scan form for data accuracy using OCR • Correct questionable handwritten entries • Move corrected and completed form data into WTMS data base for the reconciliation process.

8. Forms from each of the 3 participants come in at different times. 60,000 backlog of forms to be processed Staff and time intensive. EDT data is processed electronically in large volumes. EDT data is submitted complete loads. Much less staff time spent in processing EDT data. No backlogs exist for EDT data. EDT Pilot Project Expansion Processing Paper EDT

9. WTMS paper forms have a lower data accuracy rate than EDT data. Critical data is often missing; Pick up or delivery, decal no., etc. Waste Tire Trips are more difficult to reconcile due to lower data quality and varying dates when the forms are received. Staff follow up often required via telephone, “advisory letters” and field visits. EDT data is electronically processed and verified to ensure data is complete. If data is not complete, EDT participant must correct and resubmit. EDT has a high trip reconciliation rate. EDT Pilot Project Expansion Data Quality Paper EDT

10. EDT Pilot Project Expansion Profile of waste tire hauler community • 850 (est.) registered waste tire haulers • 50 large volume haulers • 100 - 300 middle tier haulers • 450 - 600 small business haulers • Currently 2 large volume haulers are in EDT Pilot program. • EDT Pilot Project in production since July 1, 2003.

11. EDT Pilot Project Expansion Analysis of WTMS Paper Manifest Option and EDT • Large volume hauler submission rates: • 25 haulers account for one-half all forms received to date • 14 haulers account for over one-third of all forms received to date • While it would be desirable to have 25 haulers in the EDT Pilot program, a more realistic estimate is that 14 – 15 haulers could be brought into EDT program through a moderate expansion of the pilot project. Staff estimate that 14 – 15 haulers in the EDT Pilot Project would decrease current paper form processing volumes by one-third or more.

12. EDT Pilot Project Expansion • EDT and Industry • Businesses say that they can see the potential for EDT in their business but lack technical resources to make it happen. • EDT Pilot Project Haulers find the WTMS easier to administer than the paper based forms. • Industry would welcome some sort of assistance to achieve more efficiency in the WTMS reporting requirements. • CIWMB has developed and provided an EDT User’s Guidance Manual to approximately 25 waste tire haulers.

13. EDT Pilot Project Expansion • Benefits of expanded EDT Pilot Project • Leverages existing industry business practices. • Significant cost savings/avoidance for CIWMB in staff time and resources. • Faster data collection, submittal and processing times while ensuring higher data quality. • Proven record of CIWMB EDT Pilot Project success since July 1, 2003.

14. Proposed Approach for EDT Pilot Expansion Phase I Assessment $ 25 K Readiness, software type and experience, level of automation, onsite staff support. Phase II Focused technical assistance $ 125 K As appropriate, based on above, assist with programming changes and/ or identify specific business processes to be modified to participate in EDT. (20 – 25 haulers this FY with additional haulers in future FYs.)

15. Proposed Approach for EDT Pilot Expansion Phase III Development of a standalone automated system for use by Haulers $ 100 K To address small businesses, with minimal automated capabilities, staff would develop a a standalone system (MS Access), to provide basic customer account information and the ability to capture key-entered data for submission electronically and generate “EDT Manifest” data for submittal to CIWMB.

16. Retreader Issue

17. Retreader Issue • Under the previous manifest system, from 1995 to 2003, retreaders were allowed to prepare a single invoice for each pick up of tire casings and attach those invoices to a single manifest for the day’s route. • Retread tire casings fall within the definition of a “waste and used tire” as defined in Public Resources Code 42805.5 and 42807. • Retreaders maintain that because the retread tire casing is “owned” by their clients and not the property of the retreader, the likelihood of illegal disposal is nil. Once the casing is retreaded, it no longer falls under the definition of a waste or used tire.

18. Retreader Issue • Retreader position • Retreaders feel they are unduly burdened by the manifesting requirements. • Retreaders are asking the Board to modify current requirements but still allow for them to submit the needed tire documentation on quantities of casings being retreaded, recycled or disposed.

19. Retreader Issue Objective: Ease the burden placed upon the Retread Industry without sacrificing the information needed to track the flow of casings and waste tires.

20. Retreader Issue • Stakeholder Impacts • If manifesting requirements are changed for retread industry, other tire groups may seek special consideration. • Staff believe the retread situation is unique and that different manifesting requirements be developed for them. This could be done with emergency regulations.

21. Summary • EDT Expansion • Staff to proceed with the expansion of the EDT Pilot Project within the framework of the existing program. • Retreader Issue • Staff to work with stakeholders and interested parties to draft emergency regulations.