Filed on regulations.gov — full text not in the inline record.
Toxic Release Inventory Burden Reduction Proposed Rule
Activity
League of Women Voters filed 4 comments on this docket between Jan 9, 2006 and Feb 6, 2006. 68 other organizations filed here. The comment window closed 7501d ago.
What League of Women Voters filed (4)
January 13, 2006 Office of Environmental Information (OEI) Docket Environmental Protection Agency Mail Code 28221T 1200 Pennsylvania Avenue, NW Washington, DC 20460 Attention Docket ID No. TRI-0073 TRI Burden Reduction Rulemaking The League of Women Voters of the United States has a long history of support for laws and regulations that control harmful pollution in the interest of human health and environmental protection. Specifically, the League has endorsed various national laws, including the Emergency Planning and Community Right to Know Act, the Toxic Substances Control Act and others that seek both to provide information on pollutant substances and to limit their spread in the environment. The League is therefore concerned about the above referenced rule making proposed by EPA to reduce data reporting requirements under the Toxics Release Inventory program. We are against the proposed changes as we understand them. It is inadvisable to allow toxic chemicals release reporting on a biennial instead of yearly basis, raise the trigger amounts for reporting from 500 to 5,000 pounds, and allow use of a short reporting form, under condition of no current releases, for the persistent, bioaccumulative and toxic (PBT) pollutants. The duty of annual public disclosure has been a strong incentive for development of waste reduction and pollution avoidance processes by the facilities which must report under current TRI rules. The program has been a most beneficial tool in this respect, reducing harmful emissions exposure in communities by more than 50 percent since its initiation. This benefit argues strongly for maintaining the current reporting rules. Moreover, the League holds that effective pollution avoidance and control measures are justified even if higher costs or increased tax burdens on citizens should result. We are concerned that less currency of data on toxic materials at facilities will make emergency response planning more difficult for communities. Also, the proposed, much higher reporting threshold for PBT toxins represents a public information restriction that could critically affect the health of many citizens through exposures of which they would be unaware. These effects represent unacceptable and unneeded risk potential for public and environmental health. The League of Women Voters respectfully urges the Environmental Protection Agency to maintain and not alter the reporting requirements under the Toxics Release Inventory that are currently in place. Sincerely, Kay J. Maxwell, President
Filed on regulations.gov — full text not in the inline record.
Filed on regulations.gov — full text not in the inline record.
Abstract
Point of Contact: Kevin Donovan, TRI Program Division, (202) 566-0676, MC= 2844T, EPA West
View on regulations.gov →Co-filers (68)
See everyone who commented →- League of Women VotersTHIS ORG4 filings · confidence 97%
- Alliance for a Clean Environmenttrade assoc.3 filings · confidence 85%
- Socially Responsible Investment Coalitiontrade assoc.3 filings · confidence 85%
- William C. Velasquez Institutetrade assoc.3 filings · confidence 85%
- AFL-CIO2 filings · confidence 97%
- IPC - Association Connecting Electronics Industriestrade assoc.2 filings · confidence 85%
- National Petrochemical & Refiners Association (NPRA) [Please see Document number EPA-HQ-TRI-2005-0073-1156.1 for the attached comment]trade assoc.2 filings · confidence 85%
- Performance Track Participants Associationtrade assoc.2 filings · confidence 85%
- Portland Cement Associationtrade assoc.2 filings · confidence 97%
- The Aluminum Associationtrade assoc.2 filings · confidence 85%
- " It is our right to know what is going on with our society" sponsoring organization unknowntrade assoc.1 filing · confidence 85%
- "Please maintain the integrity of the toxic release inventory; hold industries accountable..." sponsoring organization unknownunverified attribution1 filing · confidence 70%
- a division of Boston Trust and Investment Management Companyunverified attribution1 filing · confidence 70%
- Air Toxics Committeetrade assoc.1 filing · confidence 85%
- American Association for the Advancement of Sciencetrade assoc.1 filing · confidence 85%
- American Forest & Paper Associationtrade assoc.1 filing · confidence 97%
- American Petroleum Institutetrade assoc.1 filing · confidence 97%
- American Public Health Association (APHA) and Lynn R. Goldmantrade assoc.1 filing · confidence 85%
- Auburn City Counciltrade assoc.1 filing · confidence 85%
- Carnegie Mellon Universityunverified attribution1 filing · confidence 70%
- Children's Health Environmental Coalitiontrade assoc.1 filing · confidence 85%
- Club’s National Environmental Justice Grassroots Organizing Programunverified attribution1 filing · confidence 70%
- Coalition of Journalists for Open Governmenttrade assoc.1 filing · confidence 85%
- Community/Labor Refinery Tracking Committeetrade assoc.1 filing · confidence 85%
- Consumer Specialty Products Associationtrade assoc.1 filing · confidence 85%
- Delaware State Universityunverified attribution1 filing · confidence 70%
- Department of Geography and Geology University of Wisconsin-Marinetteunverified attribution1 filing · confidence 70%
- Domini Social Investments LLCunverified attribution1 filing · confidence 70%
- Eastman Chemical Companyunverified attribution1 filing · confidence 70%
- Edison Electric Institutetrade assoc.1 filing · confidence 97%
- Environment Affairs National Paint & Coatings Associationtrade assoc.1 filing · confidence 85%
- Environment and Agriculture Committeetrade assoc.1 filing · confidence 85%
- Ethical Investment Research Services (EIRIS) Ltd. [This document is an attachment to document EPA-HQ-TRI-2005-0073-1000]unverified attribution1 filing · confidence 70%
- Food First Institute for Food and Development Policytrade assoc.1 filing · confidence 85%
- Friends Fiduciary Corporationunverified attribution1 filing · confidence 70%
- Inc. (LEAF) on behalf of David Ludder. This document was added to replace the images for TRI-2005-0073-4756.3 and 4756.4 to allow for better viewing.unverified attribution1 filing · confidence 70%
- Interfaith Center on Corporation Responsibilityunverified attribution1 filing · confidence 70%
- Massey Universityunverified attribution1 filing · confidence 70%
- Metals Industries Recycling Coalitiontrade assoc.1 filing · confidence 85%
- Montclair State Universityunverified attribution1 filing · confidence 70%
- National Association of Manufacturers (NAM)trade assoc.1 filing · confidence 97%
- National Grain and Feed Association (NGFA) and Grain Elevator and Processing Societytrade assoc.1 filing · confidence 85%
- National Mining Associationtrade assoc.1 filing · confidence 97%
- National Paint and Coating Associationtrade assoc.1 filing · confidence 85%
- National Petrochemical & Refiners Associationtrade assoc.1 filing · confidence 85%
- National Pollution Prevention Roundtabletrade assoc.1 filing · confidence 85%
- National Ready Mixed Concrete Associationtrade assoc.1 filing · confidence 85%
- Natural Resources Defense Council (NRDC)trade assoc.1 filing · confidence 97%
- New Jersey Work Environment Counciltrade assoc.1 filing · confidence 85%
- NH Coalition for Occupational Safety & Healthtrade assoc.1 filing · confidence 85%
- North American Hazardous Materials Management Associationtrade assoc.1 filing · confidence 85%
- Resources Wood Inc.unverified attribution1 filing · confidence 70%
- Sierra Club1 filing · confidence 97%
- Society of Environmental Journaliststrade assoc.1 filing · confidence 85%
- Society of Glass and Ceramic Decoratorstrade assoc.1 filing · confidence 85%
- South Bend-Elkhart Audubon Societytrade assoc.1 filing · confidence 85%
- Sustainable Energy and Economic Development (SEED) Coalitiontrade assoc.1 filing · confidence 85%
- The Graphie Arts Coalitiontrade assoc.1 filing · confidence 85%
- The League of Woman Voters of Mainetrade assoc.1 filing · confidence 85%
- Tufts University School of Medicineunverified attribution1 filing · confidence 70%
- University at Buffalounverified attribution1 filing · confidence 70%
- University of Hartfordunverified attribution1 filing · confidence 70%
- University of Oregonunverified attribution1 filing · confidence 70%
- University of Texasunverified attribution1 filing · confidence 70%
- Washington State University Vancouverunverified attribution1 filing · confidence 70%
- Waterkeeper Alliance andtrade assoc.1 filing · confidence 85%
- West Florida Regional Planning Counciltrade assoc.1 filing · confidence 85%
- Work Environment Counciltrade assoc.1 filing · confidence 85%
- World Resources Institutetrade assoc.1 filing · confidence 85%