Meeting Summary

Alliance for Uniform Hazmat Transportation Procedures Regular Meeting of the Alliance Governing Board
In Conjunction with the Annual Meeting of the National Conference of State Transportation Specialists (NCSTS)

Birmingham, Alabama
June 12-13, 2006

Overview

The Alliance for Uniform Hazmat Transportation Procedures consists of seven states that have implemented uniform forms and procedures for the permitting and registration of motor carriers of hazardous materials pursuant to 49 USC 5119. This approach, called the Uniform Program (UP), has been adopted by Illinois, Michigan, Minnesota, Nevada, Ohio, Oklahoma, and West Virginia. A governing board made up of member Alliance states oversees activities related to implementation and operation of the Uniform Program. The Alliance is governed by several documents including the final report of the Alliance working group to the U.S. Secretary of Transportation and the Uniform Program Administrator’s Manual. The Alliance is staffed by the National Conference of State Legislatures (NCSL).

Meeting Attendees

Alliance Board Members:

John Canty, Public Utility Commission of Ohio, Chairman
Donna Redman, Nevada Highway Patrol
Cindy Bahner, Illinois Environmental Protection Agency
Sherri Twidwell, Oklahoma Corporation Commission
Larry AuBuchon, Michigan Department of Environmental Quality (by telephone)
(Absent: Minnesota, West Virginia)

Staff:

Jim Reed, National Conference of State Legislatures (NCSL)
Matt Sundeen, NCSL

Guests:

Rex Young, Alaska Department of Transportation and Public Utilities
Ben Goodin, Missouri Department of Transportation (MODOT)
Chuck Gohring, Missouri Department of Transportation (MODOT)
David Giarratano, Missouri Department of Natural Resources (DNR)
Lamont Johnston, Idaho State Police
Loretta Bitner, Federal Motor Carrier Safety Administration (FMCSA)
Terry Willert, Colorado Public Utilities Commission
Greg Bosque and Noah Lazar, Saforian, Inc. (by telephone)

June 12, 2006

Opening and Introductions

Chairman John Canty gaveled the meeting to order at 9:30 am. He asked that attendees introduce themselves. The meeting summary from the January 2006 meeting in San Diego was reviewed. On motion by Donna Redman, seconded by Sherri Twidwell, the minutes were unanimously approved. John Canty took a moment to thank Jim Reed for his service to the Alliance over the years, especially for the detailed and accurate meeting summaries that form the historical record of the Alliance's activities.

State Reports

Nevada: There are 712 carriers in program and the trend is for a greater number of applicants due to more waste coming into Mercury. Jim Rhode is back in charge of the program. Rules to adopt federal equivalency have been adopted. Nevada is looking forward to the on-line application.

Illinois: The state has 90 carriers, hazardous waste only. Ohio will look at its carriers to see if additional waste carriers could be transferred to Illinois. Transporter numbers will not show up on the uniform manifest anymore due to a change in the form.

Oklahoma: There are 48 carriers total. Oklahoma was unable to adopt rules in the last round of rulemaking to bring in all hazmat carriers to the program. This could bring in an additional 500 more carriers as found in their data base. For now, office space issues are being examined to combine the Corporation Commission offices with the Tax Commission.

Ohio: The state has 2,383 carriers in the system, of which 206 are hazardous waste. Numbers are down somewhat. Ohio has switched from HARPS to a newer state data base tied in with motor carrier registration. Fees payments are on a timelier basis.

Missouri: They are moving towards legislation to be drafted by November for introduction into the legislature in the 2007 session. MODOT is working with DNR to cooperatively implement the new program. They are looking at impacts on industry. Missouri is planning to regulate all hazmat. Currently DNR does the inspection and enforcement for hazardous waste carriers and MODOT issues the credential. Missouri has a new computer system that will be helpful in implementing the new program. They are still learning and will continue to seek input from existing states.

Alaska: Hazmat rules are fairly minimal--use of MS-150 and route approval for explosive shipments. They will be using the incentive grant to determine whether Alaska wants to embark on a more stringent program. Alaska has a large presence of energy and mining companies.

NCSL report: NCSL is awaiting a new cooperative agreement from FMCSA.

On-Line Application and Data Base

Greg Bosque and Noah Lazar of Saforian called-in to discuss the progress on the on-line data base. Through NCSL, the Alliance contracted with Saforian in March 2006 to create and develop an on-line version of the Alliance application process. They walked through a power point of their progress.

The overall goal of the on-line Alliance hazmat application is to make it easier for carriers to complete the permit application process and save data for subsequent renewals. The secondary goal and the goal of the application itself are to allow carrier users the ability to come and go, entering data at their own pace. The application should try to be as flexible as possible and provide assistance when needed.

The benefits and features for Phase 1 & Phase 2 of the on-line Alliance application include:

Consistent data collection
Help and other resources available contextually
Calculations support
Reduced errors
Historical data capabilities
Phase I will incorporate the following:
Unique ID and carrier session persistence, perhaps the USDOT number
Relational database to store field data and carrier user information
The app will generate a PDF file for printing purposes- the application submission will continue to be a manual process for phase I
Completion feedback & status indicators
Collection of various static support content made accessible in a contextual manner

They explained slides that demonstrated the design direction being taken. The wire frames and diagrams have been posted online on Saforian’s extranet. There will be a login page and new users will establish an account. A status bar will show an applicant's progress in working through the application. The data captured in the account establishment process will automatically be transferred for use in populating fields in the application. A "dashboard" page will appear once an account is set up that will give key status indicators and navigation information.

The process will be designed for completion in a linear manner; however, applicants will have the ability to jump around in completing the form, except where there are data dependencies. Member states will pre-populate the data base with USDOT numbers and registration expiration dates. Saforian asked for feedback on which fields could be authorized to leave blank or write "n/a."

Development work will continue:

Moving along with HTML, shell pages coming first then forms will be added.
Goal is to have a shell page available for every screen needed within the application up by June 23rd.
Forms and simple database will be added shortly thereafter.
Error conditioning and validation added next.
Review and testing.

Saforian asked for a copy of the existing logo and branding. Alliance board members were pleased with the progress to date and agreed to continue to give feedback on the Saforian extranet.

The meeting recessed for John Canty's presentation to the NCSTS meeting on the Hazmat Alliance. (See http://www.ncsl.org/slides/transportation/0605hazmat_jpg_files/frame.htm for a copy of the power point presentation he gave.)

Michigan Peer Review

Larry AuBuchon walked through the peer review checklist completed by Michigan.

Discussion ensued about the frequency of desk audits. The recently adopted Alliance desk audit letter was discussed and Larry asked that it be resent so the states can revisit the issue. (See Attachment 2 to this meeting summary.)

Michigan has ongoing problems with carriers not doing the calculations correctly.

The Alliance Board reviewed the eight applications that Michigan had provided. There were no significant questions. Michigan has worked with Windsor Solutions to set up its data systems, and recommended it to the other states.

After its review, the board acted to find Michigan in compliance with the Alliance Uniform Program, based on the peer review checklist and information presented by Larry AuBuchon. On motion by Cindy Bahner and second by Donna Redman, the Alliance Board approved Michigan's peer review and found Michigan in compliance with Uniform Program standards.

The issue of fees for radioactive waste shipments and escorts was discussed and the possibility of incorporating these fees into the program. It was agreed to keep an eye on developments in this area.

Report from Federal Motor Carrier Safety Administration

Loretta Bitner gave an update on behalf of FMCSA. There are new people--Dave Hugel as deputy administrator and John Hill is the new administrator. Dan Hartman is back as associate administrator for enforcement and state programs. All four field administrators are new. Ms. Bitner said she would send out a list of the new personnel.

The new FMCSA-NCSL cooperative agreement is nearing completion of approvals in the acquisitions office.

The Compass project is looking at all 17 FMCSA data systems to integrate them into a single "sign- on" approach. She recommended that the Alliance ensure that its online application development is compatible with what FMCSA is doing.

There is no movement with the working group on uniformity that was mandated by SAFETEA-LU. There is a slight chance of funding this year to get it going.

Another effort has to do with driver safety and driver accountability. CSA 2010 is another effort to implement a variety of new programs by 2010. Ben Goodin will send out a fact sheet on all the new FMCSA safety initiatives required by SAFETEA-LU that the Commercial Vehicle Safety Alliance (CVSA) has prepared.

Ms. Bitner has been getting a variety of inquiries about the Uniform Program. She is concerned about misinformation out there on the Alliance and suggested some new outreach initiatives. Fact sheets and brochures need to be updated. Another suggestion was to take presentations on the Alliance on the road. Ben Goodin mentioned that some states are simply not interested for a variety of reasons. He said FMCSA needs to make a big push on behalf of the Alliance. He talked about some new efforts to increase security through compliance reviews and the new entrants program. There may be dollars to implement this in the states.

Loretta Bitner said she is encouraged by movement of new states interested in the Alliance, especially with Missouri and Alaska taking a hard look. It was suggested to include an article in the CVSA Guardian newsletter on Missouri's reasons for joining the Alliance. John Canty will work with Ben Goodin and Chuck Gohring on this.

Loretta Bitner also will send a flow chart of the federal safety permitting process for distribution to the Alliance. She will also send out the names of the hazardous materials program specialists in each of the Alliance states. There are also 4 regional program managers whose names she will provide.

Alliance-FMCSA MOU

Draft 7 of the MOU was reviewed. The MOU defines various responsibilities for the Alliance and FMCSA as the Alliance implements equivalency with the federal safety permit. Language was added under III. A. 1. d. to help those Alliance agencies that are not MCSAP agencies obtain the necessary security compliance evaluation, saying "If a security program evaluation is not available, the Alliance will request one from the appropriate agency." John Canty moved to adopt the new language and approve the revised version of the MOU, seconded by Donna Redman. It was approved unanimously.

The meeting recessed until the next day.

Alliance Board Meeting
Day Two
June 13, 2006

Unfinished Business: State Reports Continued

Colorado: New discussions about Colorado joining the Alliance have taken place. The Public Utilities Commission and State Patrol are interested in pursuing this again. Meetings among the affected agencies will be taking place over the next several months. Legislation will be required. Preliminary discussions have taken place with the state trucking association.

Michigan: The Michigan program has 355 liquid industrial waste and 79 hazardous waste transporters. Stable staff is keeping the program going.

No report: Minnesota, West Virginia.

Alliance Incorporation and Repository Issues

Matt Sundeen presented information on the history of the Alliance from various key documents relating to the establishment of the Alliance and the Uniform Program. He distinguished between the Alliance working group set up by Congress and the now existing Alliance Uniform Program states. Mr. Sundeen walked through a document he developed relating to aspects of possible incorporation of the Alliance. The questions to be addressed include:

Should the Alliance form a corporation or other more formalized entity to facilitate the agreement?
What legal authority does the current Alliance Board have to form a corporation or other entity?
What should it look like? How should it be governed? What should be the function of the corporation or entity? Does it need to be a corporation?
Is now the correct time to form the corporation or entity? How is the Alliance currently operating? What are the advantages? What are the disadvantages? Can it be supported?
What other issues need to be answered? – Where? How? When?

He came to these conclusions about legal authority to incorporate:

The Alliance is a voluntary agreement among states, so states can ultimately do what they want to do.
The agreement currently contains very specific provisions about a national repository. So, under the current agreement, states must form a national repository to perform the functions of the agreement.
To form a corporation, member states would probably need to amend the agreement.
The authority does not speak to the issue of whether the repository must be a corporation or whether the Alliance can form a corporation that is separate from the repository.

The Alliance is a voluntary organization so states can ultimately do what they want. Incorporation is a lesser issue compared to whether or not the Alliance is now ready to form the repository as called for in the Administrator's Manual. If a corporation is to be formed, several models could be used including the International Fuel Tax Agreement (IFTA), the International registration Plan (IRP), the Streamlined Sales Tax Agreement, and NCSL.

In examining the formation of a repository, the following was noted:

Current operation
- NCSL provides staffing
- Staff coordinate meetings and perform other administrative tasks
- Staff do not perform many of the required repository tasks including database maintenance
- Most information-sharing done directly state-to-state
Advantages of forming the repository
- Could perform all the tasks required in agreement
- Makes agreement more permanent
- Centralizes the agreement
- Can serve as a source for contracting, bringing in money
- Potential legal protections
- Allows staff to perform other functions such as promoting the agreement by lobbying in states
- Provides an entity to represent the Alliance
- Provides potentially better staff support
- Fresh look at Alliance challenges
Disadvantages
- Significant investment needed for a database and IT support, general staff support, initial start up costs, office space, office equipment, etc.
Financial support issues
- For the time being, state investment is not significant enough
- Federal support is possible
Conclusion
- Repository could be beneficial
- Significant costs may be barrier

Other issues that should be addressed include forming an actual base state agreement, tightening state enabling statutes to provide more specific guidance, updating the Alliance model enabling legislation, amending the Administrator's Manual, and updating the Alliance web site.

States were concerned about opening up state enabling legislation due to the degree of difficulty involved as well as potentially unpredictable outcomes. A more doable option and immediate effort would be to amend the model legislation. Another step would be to draft and approve a formal base state agreement. The board agreed to continue work previously started on a base state agreement and to review and update the model legislation.

Loretta Bitner suggested that the Alliance approach a similar organization like IRP or IFTA or the streamlined sales tax group to help mentor and nurture the growth of the Alliance. The work of Saforian on the data base is another piece of this effort. NCSL will do additional research on how IFTA and IRP began, matured and eventually developed into national organizations and how this may apply to the Alliance.

The need for additional financial support was discussed. One scenario is obtaining initial support from the federal government and then the member states would assess themselves appropriate dues to support continuing efforts.

Larry AuBuchon asked that all the changes that may be made to the model legislation be accomplished soon along with other needed "tightening" changes with so that Michigan can go

forward with an entire slate of changes to the legislature. Matt Sundeen will do additional legal research to assist this effort.

Outreach

Outreach contacts by various Alliance states were reviewed, including Colorado, California, Idaho, Massachusetts, New Jersey and Wisconsin. The state outreach efforts matrix will be updated for the next meeting.

The extent of active industry support was assessed. Rick Craig of the Owner-Operator Independent Drivers Association (OOIDA) out of Grain Valley, Missouri is interested in helping the Alliance. They have a daily XM radio show. They have 135,000 members. A more robust industry support group needs to be developed. It was suggested that the Alliance reactivate the industry advisory committee. The Alliance will contact the National Tank Truck Carriers (NTTC), National Private Truck Council (NPTC), and the American Trucking Associations (ATA), plus state motor carrier associations.

The updating of outreach materials was discussed. The brochure will be updated and a white paper prepared to distribute to industry contacts explaining the program. Alliance members will seek out speaking invitations to spread information to various associations. Rex Young suggested a connection with the work being done for CVISN.

Additional Issues

1. Truck weight issue: As requested by Michigan, application instructions for 12a and 12b will be amended to clarify that the Alliance wants to include vehicles below 26,000 pounds. There being no objection, it shall read: "Provide the following information for the applicant's fleet. If the applicant maintains multiple fleets for purposes of IRP reporting, complete a separate copy of this page (Section C) for each fleet. IRP covers only ~~10,000~~ 26,000 pound and heavier vehicles. Therefore, also include non-IRP (and non-IFTA) power units as a separate fleet(s) if necessary." Sherri Twidwell will make the change on the application and send out the revised document.

2. As proposed by Illinois and explained by Cindy Bahner, she requests that the Alliance change the application, page 1, question 33 to say percentage of transportation activity attributed to only hazardous waste....and eliminate the "noted in Item 32." She said the applications she is getting are giving that percentage, and not the percentage of item 32. The change to question 33 is to delete "as noted in Item 32" from question 33. All agreed. Sherri Twidwell will make the change on the application and send out the revised document.

3. Change request form: A change request form was proposed by Jim Rhode of Nevada. It was e-mailed last week for board members' review. The purpose, according to Jim Rhode, is to avoid the inconclusive strings of e-mails proposing changes and instead establish a policy for requesting changes to the Alliance program. This change request (CR) process will allow member jurisdictions to propose changes, staff to review and make recommendations and the Governing Board the ability to vote on them. The process will also allow staff to record CR’s in a sequential manner, document CR proposals and their final outcome. After discussion, Cindy Bahner moved to adopt the change request form, and John Canty seconded. It will be incorporated into the Administrator's Manual. The motion was unanimously adopted. (See attachment to this meeting summary.)

4. Peer Reviews: A new schedule was reviewed by Chair Canty. After discussion, it was adopted by the Board on motion by John Canty, second by Donna Redman. See Attachment 1, "Peer Review Schedule." The next peer review will be Minnesota in late summer or early fall.

5. Administrator's Manual Update: The group assigned at the last meeting will meet by conference call in the next few months. It consists of Cindy Bahner, Alan Abbott, John Canty, Jim Reed and Chuck Gohring. Jim Reed will review the manual and suggest individual sections for the review group to focus upon.

Alaska Issues

Rex Young asked some questions concerning Alaska's potential participation. He discussed the movement of hazmat in Alaska due to the mining, energy and defense industry. He said it's pretty much a free-for-all now with little regulation. The desire is to create more safety and security of these shipments.

He inquired as to whether it was a problem that Alaska is not a member of IFTA or IRP. The answer was no. He stated that Alaska's weight limit for commercial vehicles is 8,000 pounds. It was determined that this was not a problem, since a placarded load is the program standard.

Rex requested a copy of the Administrator's Manual. Jim Reed will send hard copy along with electronic version and the Alliance website URL.

He asked if carriers were members of the Alliance. No.

He asked about membership fees paid by the states and was directed to the Manual. Jim Reed was asked about whether the Alliance gives a one-year grace period to new states for the state membership fee, and in doing research, he found none, though it was discussed during the incentive grant development.

Mr. Young recommended that the Alliance advertise the availability of travel scholarships for potentially interested states as he found it very helpful and thinks other states would benefit

Election of Governing Board Chair and Vice-Chair

Donna Redman nominated James Rhode, Nevada, and Cindy Bahner seconded for the position of Governing Board chair. It was approved unanimously. Donna Redman nominated Alan Abbott, West Virginia, as vice-chair, seconded by John Canty. It was approved unanimously.

Other Business

Sherri Twidwell asked about extending a permit for a month for a carrier that has to wait extra time to receive its IRP mileage report from Texas. The question of fees due was discussed. It was determined that this was an Oklahoma decision.

Donna Redman thanked John Canty for his service on the Board and the Board concurred.

There being no further business to come before the board, John Canty adjourned the meeting. The next regular meeting of the Alliance Governing Board is scheduled for January 22-24, 2007 in Salt Lake City in conjunction with COHMED.

"To Do List"

From Alliance Meeting in Birmingham, June 2006

(Items 7-11, 13-17 are still pending)

1. Send out draft Birmingham meeting summary--Reed (Done)

2. Send logo to Saforian--Reed (Done)

3. Send out desk audit procedures to Alliance states--Reed (Done, attached to this summary)

4. Send peer review approval letter to Michigan--Canty, Reed (Done)

5. Send list of hazmat specialists and field administrators to Alliance states--Bitner (Done)

6. Send flow chart of federal safety permit--Bitner (Done)

7. Ensure that Saforian data base work is compatible with FMCSA efforts--Saforian

8. Distribute CVSA fact sheet on FMCSA initiatives--Goodin

9. Update Alliance brochure--Reed, Bahner, Redman

10. Write Alliance "white paper" to explain program for industry and state use--Reed, with help

11. Write CVSA Guardian newsletter article--Goodin, Canty

12. Finalize MOU, send to FMCSA--Reed, Canty (Done)

13. Send out draft base state agreement again for review and comments--Reed

14. Update model legislation--Reed

15. Update Administrator's Manual-- Reed, Canty, Bahner, Abbott, and Gohring

16. Do additional legal research on formalizing the Alliance, explore history of IFTA, IRP--Sundeen

17. Outreach to industry including OOIDA, NTTC, NPTC, and ATA--volunteers?

18. Seek speaking invitations to promote Alliance--all, as invited

19. Make application changes--12 a and 12b and 33--Twidwell (Done)

20. Conduct Minnesota peer review--Review Team to be named by Alliance chair (Done, 9-27-06)

21. Send Administrator's Manual to Rex Young--Reed (Done)

Attachment 1

Alliance for Uniform Hazmat Transportation Procedures Peer Review Schedule
Agreed to at June 2006 Alliance Board Meeting
(Assuming Peer Reviews Normally Will be Concurrent With Alliance Governing Board Meetings)

State Last Peer Review Recommended Next Peer Review

Illinois October 2000 January 2007

Michigan June 2006 June 2011

Minnesota* August 1995 September 2006

Nevada June 2002 January 2008

Ohio June 2003 June 2008

Oklahoma June 2002 June 2007

West Virginia January 2004 January 2009

*On-site peer review was conducted in September 2006.

Note: The Administrator's Manual does not recommend a specific interval between peer reviews using only the term "periodic." However past board discussions have focused on somewhere between a three- to five- year interval. Starting now, the above schedule assumes a five-year interval, with Nevada at 5.5 years.

Attachment 2

Alliance for Uniform Hazmat Transportation Procedures Desk Audit Questionnaire

Company
Address
City, State, zip

Dear Hazardous Materials Motor Carrier:

The (Alliance State) is conducting a desk audit of your Hazardous Materials Uniform Registration and Permit application.

As part of this desk audit, we ask that you forward legible copies of the requested documents and data to (State agency address) within fifteen (15) days following receipt of this letter.

Requested Documents or Data

Documents supporting the total number of power units owned, leased, or operated by your company.

A copy of the International Registration Plan (IRP), International Fuel Tax Agreement (IFTA) filed by your company for the last billing period. If you do not maintain mileage records for either IRP or IFTA, provide an explanation of the methodology used to calculate the percentages indicated in question 12b of the application.
Provide copies of worksheets or documentation that supports your percentage of hazmat activity, as indicated in question 12c of the application.
A legible copy of your Form MCS-82 or MCS-90, as appropriate, and the cover page of any insurance policies identified in the Form MCS 82 or 90.
Has the applicant been assessed or paid any fines with penalties over $1,000, relating to hazmat transportation the past two years? __ Yes __ No
If yes, please provide date of fines/penalties/judgment levied, date of the action, nature of the violation, cause or reason for the action, and remedial action taken to mitigate the situation, if any.
Has the applicant been involved in an accident while transporting hazardous materials in the past year? ___ Yes ___ No
If yes, attach a copy of applicants accident register.

Hazardous Material Desk Audit

7. Has the applicant been involved in an incident, in the past two years, involving the transportation of hazardous materials that was required to be reported under 49 CFR 171.15(a)(1)? ____ Yes ____ No
If yes, please provide the following information; date, location, cause of the incident, details of the remediation process, and the agency that supervised the remediation.

8. Vehicle Inspection Report and Tank Certification, if applicable. Please provide your companies statement attesting that all vehicles, per 49 CFR 396.17, and tanks, owned and/or operated has been inspected in the last 12 months. Statement should be on company letterhead and signed by a principle of the company.

9. How often are applicant's vehicles serviced, and who services the vehicles?

10. Where are driver logbooks maintained and, how are they evaluated to insure conformance with hours of service?

11. Provide a copy of your Emergency Response Plan, in compliance with OSHA 29CFR 1910.120(q) regulations and, a letter attesting that all applicable employees have been fully trained to deal with hazardous materials, as outlined in 49 CFR 172 subpart H and 177.816. Letter should be on company letterhead and signed by a principle of the company.

12. Provide a statement attesting that the person certifying Part IV of the application is authorized, by the applicant, to certify this application. Statement should be on company letterhead and signed by a principle of the company.

Your prompt cooperation in this desk audit is greatly appreciated. If you have any questions, please do not hesitate to contact this office at (contact number).

Sincerely,

(Name of agency employee)

(Title)

Attachment 3

Alliance Program Change Requests (CR)

When a request is made for a change to The Alliance for Uniform Hazmat Transportation Procedures Program this change request form will need to be filled out and submitted to the Alliance Governing Board for review, consideration and approval.

Using this change request form will allow the Alliance to consistently handle the inevitable change requests from member jurisdictions and allow full discussion and analysis of the proposed changes, budgetary impacts, as well as positive/negative impacts to the program in all member jurisdictions.

The change requests will be maintained in a sequentially in a data base for archival and historical purposes.

Alliance Program Change Request (CR) Form

CR Number Number assigned by staff

CR Requested by: Name of requestor and member jurisdiction

CR Request Date: Date CR is submitted.

Component: Identify what component of the Alliance program is involved, i.e. application, Administers Manual, etc.

Synopsis: One or two sentence description of change request.

Status:   Is this a new CR or has a change been proposed before?

Disposition: Current status of CR. Open, pending comments or discussion. Approved, or Disapproved.

Description: Describe the change being requested. Include a description of impacts to existing program. Provide a business case for the change being requested as justification, and describe the impact if the requested change is not implemented as requested. Discuss any issues of timing of implementation.

CR Impact Analysis:   Describe the impacts on the Alliance program including whether this is in or out of scope of the program. Describe risks associated with this CR or overall impacts of change on the program. Include description of proposed schedule implementation associated with this change. Include information about impacts on budget and provide specific details on costs assoc8iated with the change. Describe any impacts to member jurisdictions, the industry or Alliance program. Describe alternatives to the proposed change. Include a recommendation of proposed action based on recommended change.

Responsibility: Assigned staff managing CR.

Priority: Initially assigned by requestor.

Hazmat meetings