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EPARulemakingEPA-HQ-TRI-2005-0073

Toxic Release Inventory Burden Reduction Proposed Rule

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American Petroleum Institute filings
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American Petroleum Institute filed 1 comment on this docket between Jan 24, 2006 and Jan 24, 2006. 68 other organizations filed here. The comment window closed 7501d ago.

What American Petroleum Institute filed (1)

Jan 24, 2006· Comment submitted by Howard J. Feldman, Director, Regulatory Analysis and Scientific Affairs, American Petroleum Institute (API)· EPA-HQ-TRI-2005-0073-1961

The American Petroleum Institute (API) is pleased to submit comments to the U.S. Environmental Protection Agency (EPA) on EPA?s proposal to revise requirements for reporting to the Toxics Release Inventory (TRI). Our comments are provided in detail in the attached letter and are summarized below: ?EPA?s current proposal to expand applicability for Form A would not provide significant burden reduction. An API analysis of TRI data from 2003 suggests that EPA?s estimated burden reduction resulting from the proposed rule is largely overstated, particularly for the petroleum industry, due to not taking into account low utilization of Form A. ?Notwithstanding the limitations stated above, API supports expansion of Form A eligibility for non-PBT filers and PBT filers, and modification of the Annual Reportable Amount (ARA) (for non-PBTs) to include Section 8.8 management information. ?There are several areas of EPA?s burden analysis that need improvement to accurately characterize TRI reporting burden. Most importantly, EPA should use an actual survey for any new estimates of unit burden, not an engineering analysis. ?Alternate year reporting (i.e., biennial reporting) would be the most effective approach as a burden reduction measure, reducing burden for not only industry, but for EPA and the states, as well. ?Other approaches aimed at burden reduction that EPA does not discuss in the current proposal should not be abandoned. Depending on the outcome of EPA?s efforts to alter the reporting frequency of the TRI program, it may be necessary to focus the Agency?s resources on one or more of these alternate approaches.

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Abstract

Point of Contact: Kevin Donovan, TRI Program Division, (202) 566-0676, MC= 2844T, EPA West

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Co-filers (68)

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