Mar 7, 2005· Comment submitted by Howard J. Feldman, Director, Regulatory Analysis and Scientific Affairs, American Petroleum Institute (API)· EPA-HQ-TRI-2004-0001-0017
API generally supports the proposed changes. API urges EPA to make the proposed modifications to reporting Forms A and R effective for the 2005 reporting year. As EPA acknowledges in the proposal, the proposed modifications provide only a ?modest? amount of burden reduction for reporting facilities. API urges EPA to continue its analysis of the burden reduction options discussed in Phase II of EPA?s TRI Stakeholder Dialogue, and encourages EPA to adhere to the planned release date of the second rulemaking proposal.