Agency Information Collection Activities; Proposed Collection; Comment Request; Toxic Chemical Release Reporting; Request for Comment on Renewal of Propsed; EPA ICR No. 1363.15, OMB Control No 2070- . Toxic Chemical Release Reporting; Alternate Threshold for Low Annual Reportable Amounts; Request for Comment on ICR Renewal; (Form A) EPA ICR No. 1704-08, OMB Control No. 2070-

With this letter, API offers comments on the ICRs, focusing on the proposed Form R and Form A Certification Statement changes. Our comments can be summarized as follows: ?The small business field should be optional. At a minimum, EPA should clearly define what constitutes a small business in the TRI Reporting Forms and Instructions (RFI). ?The additional ?basis of estimate? codes add unnecessary and unjustified complexity to the ?basis of estimate? data element. ?Addition of a field for ?Form Preparer'' for use by a facility if the form preparer is a different individual than the ?Technical Contact'' is problematic and requires reconsideration. ?Adding boxes for mandatory revision codes adds unnecessary complexity to the TRI Program?s reporting requirements. Further, the addition of revision codes will be problematic for a subset of the proposed codes related to enforcement actions. ?API is supportive of the addition of a withdrawal field, but questions the need for the suggested withdrawal codes. ?Based on the extent of the proposed changes, API believes that EPA in its burden assessment significantly underestimates the reporting burden. Many of the proposed changes impose complicated coding systems that will require substantial company time and resources. ?The ICR process is not the appropriate process for taking comments on changes to the data collected under the TRI Program. Such changes warrant full notice and comment through the process established under the Administrative Procedures Act (APA).