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Action Alert: Defend Our Right-To-Know
Fair Use Statement

Please sign on by responding to Paul Orum at paul_orum@yahoo.com

Links to referenced Federal Register documents

ACTION ALERT.

DEFEND OUR RIGHT-TO-KNOW.

PLEASE SIGN ON TO THE LETTER BELOW.

Deadline June 9

[O] The Clinton Administration is studying a sweeping initiative to reduce reporting burden on industries under environmental laws.

[O] In this process, the chemical industry and others are actively promoting anti-right-to-know ideas.

[O] We invite you to sign-on to the letter below, in which we take exception to the Administration's burden reduction initiative and propose better alternatives for environmental information reform.

TO SIGN ON: Please provide the information below. We will send the letter "signed" by many groups. Please provide:

1] Your name
2] Your organization's name (you must represent one)
3] Your postal mailing address
4] Your phone and e-mail address.

Please respond to paul_orum@yahoo.com (or 202-546-2461 fax) by JUNE 9.

We will send you a copy of the final letter upon request.

For more information, see the Federal Register pages cited in the letter (65 FR 25004 and 64 FR 32859) [linked above], which are available on-line through the Library of Congress.

HERE'S THE LETTER:

[Final Draft Version, June 1, 2000]

John Spotila, Administrator
Office of Information and Regulatory Affairs
Office of Management and Budget
350 Eisenhower Executive Office Building
Washington, DC 20503

Dear Administrator Spotila:

Our organizations submit this letter in response to the Office of Information and Regulatory Affairs’ (OIRA) burden reduction initiatives noticed in the Federal Register (65 FR 25004 and 64 FR 32859). This letter raises our serious concerns about potential changes to the Toxics Release Inventory (TRI) and the Resource Conservation and Recovery Act (RCRA). We also propose constructive alternatives.

Our organizations strongly support "proactive" environmental information reform. Proactive initiatives reduce burdens on both providers and users of environmental information. Further, proactive initiatives improve government capacity to accomplish program goals.

Our organizations vigorously oppose OIRA’s burden reduction initiative as it is currently designed. This initiative could aid regulated entities only minimally while further reducing the public's right-to-know and weakening protections for public health and the environment. In this initiative, OIRA asks, "what information can the government get rid of?" instead of "what information do people need to protect public health and the environment, and how can they get it most efficiently?" As currently designed, OIRA's initiative does not focus as intended on "improving the quality of information agencies collect while minimizing the collection burden particularly through the use of information technology." (65 FR 25004, emphasis added)

STATUTORY REQUIREMENTS AND COMMON SENSE DEMAND PROACTIVE REFORM

Statutory requirements and common sense demand that OIRA’s burden reduction initiatives increase program effectiveness and reduce burdens on the public and regulated entities. The "Paperwork Reduction Act" (PRA) and the "Government Performance and Results Act" (GPRA) require that government agencies create information management systems that are easily used by regulated entities, government, and the public to produce integrated, results-oriented data.

The PRA’s "purposes" and its requirements for "burden" reduction, "information resources management,” the “collection of information,” and the “control of paperwork” demand that OIRA reduce burdens on individuals who access publicly available government information, not merely regulated entities. Accordingly, OIRA’s actions also must promote the goals of agency programs and efficacious information management. OIRA can accomplish both of these goals, as well as reducing burden on regulated entities and the public, by undertaking a proactive approach to environmental information management.

A proactive approach to environmental information reform broadly includes:  “smart reporting software,”  electronic reporting,  a unified national facility identification system,  cross-program databasing (that integrates all relevant information from all programs and agencies),  one-stop reporting and data retrieval,  goal-oriented data needs assessments (assessing data gaps and delivery systems), and  open, participatory planning processes.

Importantly, even regulated entities have supported proactive initiatives, including cross-program databasing, one-stop reporting, and electronic reporting. Proactive reforms can increase the value of information by making it more useful to both regulators and the public, and can help improve data quality by increasing the use of collected information. The greatest benefits may derive from integrating EPA databases and from integrating reporting across entire corporations.

Likewise, under GPRA, agencies must develop high quality, results oriented, cross-program data integration systems. The General Accounting Office and the Inspector General of the Environmental Protection Agency have noted numerous problems with EPA’s data quality and information management systems. In order to address these problems, EPA should develop a proactive information management system, not simply reduce the amount of information used to determine compliance with the law.

Ultimately, OIRA’s “burden reduction initiatives” are better described as “information reduction projects” because they will decrease the amount of useable information, rather than increasing the utility of collected data. This is a 1980s response to a twenty-first century problem. Unfortunately, OIRA’s response threatens to weaken key reporting and record-keeping requirements that protect public health and environmental quality, and that supply the public with vital information, as described below. Rather than undercutting protections, OIRA should usher in a new era of information management by emphatically embracing the proactive agenda discussed above.

OIRA’S BURDEN REDUCTION INITIATIVES ARE "REACTIVE" AND UNBALANCED

OIRA’s burden reduction initiatives, particularly under TRI and RCRA, will result in only minimal benefits to regulated entities, while increasing public burdens and weakening public protections. This could undercut the core purposes of these vital programs, rather than building on past successes with proactive innovations. Certainly, some of the proposals are of indeterminate origin and do not merit the special hearings that OMB has afforded them.

OIRA’s Proposals for TRI Undercut Public Right-To-Know Without Reducing Burden

OIRA’s proposal to require that regulated entities only report significant changes in emissions from the prior year would undercut the public’s right-to-know about toxic emissions without any appreciable reduction in reporting burden and would exacerbate current TRI data inaccuracies. There would be little, if any burden reduction because industries must still determine if there has been a significant change in emissions. This determination remains the most substantial aspect of reporting.

Other similarly problematic proposals were discussed at the April forum, including biannual or tri-annual TRI reporting. These modifications would severely weaken the TRI program. Currently, there is a two-year time lag between submission of TRI data and its public release. A two or three year interval between reporting cycles would increase that lag to a truly appalling four or five-year delay. Time series tracking is a fundamental attribute of TRI, used by government, industries, and the public alike to track successful emissions reductions. This attribute must be retained through annual TRI reporting. TRI is already a small island of successful information disclosure in a vast sea of environmental ignorance. More than twenty exemptions, thresholds, and restrictions already limit the TRI program (see attachment). These regressive proposals would magnify these current TRI limitations.

OIRA’s RCRA Initiatives Would Undercut Protections

OIRA’s proposal to delete from data submission 100 requirements under RCRA, yet still require data generation and analysis, would accomplish little burden reduction. As industry has stated, most burden is associated with analysis, not reporting. However, the proposal could seriously weaken protections for public health and the environment, and the public’s right-to-know, because even submitting information to agencies creates a deterrent effect on regulated entities. Even OIRA’s notice acknowledges that failing to require data submission provides an incentive for regulated entities to flout the law. Unfortunately, it would also increase the difficulty of deciding where to focus scarce enforcement resources and how to accomplish enforcement goals.

OIRA’s proposal to altogether delete 100 of RCRA’s substantive requirements suffers from similar and even worse problems. It would eliminate protections that discourage generators, transporters, and storage and disposal facilities from mismanaging or illegally disposing of hazardous waste. The federal government should not promote such policies. If a rationale for eliminating these requirements is that agencies have trouble keeping track of information, and consequently fail to consistently use it, then this highlights a need to proactively manage information, not reduce information that should be used to ensure compliance. Developing a proactive information management system would better address the problem, while increasing program efficiency and effectiveness.

We also urge EPA and OMB to retain all protective aspects of reporting on RCRA worker training requirements that are not included in the corresponding OSHA requirements. These include "groundwater contamination incidents", "automatic waste feed cut-off systems", and "shut down of operations". Given the lack of effective training to hazardous waste workers, the deletion of record keeping requirements in section d(3) would further weaken the current level of training. Rather than reduce reporting, we urge EPA and OSHA to improve enforcement of both RCRA and OSHA requirements.

OIRA Should Focus On Efficiently Reducing Burdens

OIRA should focus its burden reduction efforts on those agencies with the greatest potential for burden reduction, rather than mandating that each agency reduce reporting burdens by 40 percent. Focusing burden reduction efforts is consistent with the PRA’s statutory requirements and principles of responsible management. Section 3505 of the PRA requires a “Governmentwide goal” for reducing information collection burden by 40 percent, by the year 2001. The term “Governmentwide” clearly means that the entire government, but not each agency, should reduce information collection burden by 40 percent. Section 3506(h) of the PRA supports this interpretation because it clearly distinguishes between the terms “Governmentwide” and “agency,” as these terms relate to information “management policies, principles, standards, and guidelines.” Consequently, it is clear that Congress never intended that each agency reduce its information collection requirements by 40 percent.

Distinguishing between “Governmentwide” and agency-specific information collection reductions is grounded on sound principles of responsible management. Forcing all agencies to reduce their information collection requirements by equal amounts could eviscerate a lean agency’s enforcement capabilities while ignoring obvious opportunities at another agency.

Further, the PRA specifically states that burden reduction efforts should “foster greater sharing, dissemination and access to public information.” EPA can most constructively meet this goal by developing "smart reporting software," electronic reporting, and integrated national databases.

The EPA accounts for only about 1.6 percent of the governmentwide information collection burden, while the Internal Revenue Service accounts for about 80 percent. Importantly, over the last decade, EPA’s budgets have been cut in relation to the agency's responsibilities. Clearly, OIRA should focus on ensuring efficient, tailored burden reductions goals on an agency by agency basis, rather than rely on the administratively easy yet fundamentally flawed path of an across the board cut of 40 percent by each agency.

CONSOLIDATED EMISSIONS REPORTING WILL HELP EPA CREATE A UNIFORM, NATIONAL REPOSITORY OF HAZARDOUS AIR POLLUTANTS

Our organizations generally support initiatives to consolidate and improve reporting on criteria and hazardous air pollutants. More accurate and complete air pollution data will help people understand and address pollution problems. Consolidated reporting will reduce burdens on regulated entities, will help provide consistent national data, and, will reduce burdens on people who obtain and use this information.

Many states already collect information on air pollutants, but these data are generally inconsistent, incomplete, and not readily comparable. Synchronized reporting timelines and formats across the state and federal levels will reduce industry burden and improve government efficiency. Consolidated emissions reporting will help EPA create a consistent national repository of emissions data to help government, industry, and the public gauge progress on clean air and GPRA goals.

EPA AND OMB SHOULD USE CAUTION WHEN ESTIMATING BURDEN

Our organizations urge OIRA and other agencies, including EPA, to use caution when estimating regulatory burdens. Since many environmental programs are delegated to states, estimating burdens can be difficult. However, inflated burden estimates could misinform burden reduction efforts, and thereby undermine enforcement and public health protections. Where questions of accuracy arise, the agency should err on the side of protecting public health and the environment.

Our organizations stand ready to work with OIRA to develop forward-looking environmental information reforms.

Sincerely,

Co-signing organizations, including...

U.S. PIRG
Working Group on Community Right-to-Know
Environmental Defense
National Environmental Trust
OMB Watch

=====

Working Group on Community Right-to-Know
218 D Street, SE; Washington, DC 20003
Phone: 202-544-9586; Fax: 202-546-2461

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