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More analysis from less data: an oxymoron?


Fri, Dec 30th, 2005
Posted in Commentary

The Federal EPA proposes to change the Toxic Release Inventory (TRI) programs reporting requirements to reduce the “burden” on industry and business despite being unable to demonstrate significant complaints from business and industry. They propose to require reporting every two years rather than annually. They also propose to increase the threshold for reporting most pollutants from 500 pounds to 5000 pounds and for persistent accumulative pollutants (the worst of the lot) from 10 or 100 pounds to 500 pounds per year. There are other changes, but these are the most egregious. The EPA claims this will free up a million dollars per year to be used for increased analysis of less data. The enabling congressional legislation for the TRI is called the Emergency Planning and Community Right-to-Know Act and does not direct the EPA to analyze the data but to provide it to the public. The result of this would be 10% of all zip codes would lose all TRI data and another 15% would have the amount of data provided cut in half. It would result in between 12 and 21 hours of work reduction for the industry or business entity affected, depending on which EPA document from which you get your information.This proposal is another example of this administration keeping the public and communities in the dark and allowing industries (in some cases) to operate in secrecy. These proposed rules appear to me to be diametrically opposite of a prudent and fruitful course. The TRI should be strengthened and local communities should have access to as much information as can be provided, and more quickly than the current two year delay. This proposal should be scrapped for the following reasons.1.Small emissions are not always safe. More toxic materials emitted in smaller amounts may be more sinister than less toxic material emitted in larger amounts. 2.New knowledge of post emission chemistry is emerging rapidly. Local emissions and depositions of pollutants need to be catalogued and accounted for future generations. 3.Local emergency management teams and hazardous material management teams need to know where and what hazardous materials are in their neighborhood. 4.There is no real evidence this is a “burden” to business or industry. Some believe alternate year reporting may be more difficult and costly. (One item EPA proposes to drop as burdensome is the reporting of the latitude and longitude of the emitting unit. I guess they believe the plants and smoke stacks move around a lot and must have their location rediscovered every year. Could this information be needed 100 years from now after a facility using radioactive material has been closed).5.Since the TRI came into effect the reported emissions have been reduced by over 40%. A great deal of credit has been given to the TRI exposing which industries and companies compare less favorably with their peers. 6.While giving less information to the public and less often there is very little benefit to industry and business. Reducing their work by 12 to 21 hours per year will not make them more competitive or lower costs to the consumer. 7.Small communities suffer the most, because they have less political clout. The industries and businesses in these communities are also frequently smaller units and of the 922 zip codes losing all information from the TRI most will be small rural communities. It is axiomatic that people intuitively know refineries and chemical plants emit large amounts of pollutants. We need information on all emitters. 8.Small companies are the riskiest category. Fortune 500 companies have the wherewithal to hire consultants and comply. They are monitored more heavily and have a lot to lose if not compliant. Small companies may feel it is necessary to cut corners and may inadvertently put their neighbors, volunteer firemen and others at serious risk. Taken in context of the history of the EPA in the current political climate this proposal will solidify this period as the most citizen, public, ecologic and environmentally unfriendly and secretive period since we heard, “what’s good for General Motors is good for the United States”.I would urge any who are interested in transparency in government and in our ecology and environment to write to the EPA and request they reconsider this ill conceived change. The Emergency Planning and Community Right-to-Know Act is intended to give communities important and useful information in a timely fashion. The EPA is proposing to negate the intent of Congress by agency regulation.

You can write to the addresses below. Be sure to include the Docket No. TRI 2005-0073. Access the docket web site at: www.epa.gov/edocket; e-mail oei.docket@epa.gov; fax 202-566-0741; mail OEI Docket, EPA, Mail Code 2822IT,1200 Pennsylvania Ave., N.W., Washington, DC 20460.

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