The Environmental Protection Agency (EPA) recently initiated Phase II of a stakeholder dialogue to develop options for reducing the burden associated with reporting under the Toxic Release Inventory (TRI). EPA is seeking reactions and comments on several burden reduction options outlined in an online white paper. The EPA's burden reduction white paper details five specific options that the agency appears to be considering, as well as a vague catch-all sixth option that encourages comments on ideas not detailed in the paper. Unfortunately, each of the burden reduction options described in the paper also represents a significant loss of information for the public. EPA's five ideas detailed in the paper include:

• Raising reporting thresholds for small businesses so that fewer toxic releasers would be required to report under the program;
• Raising reporting thresholds for certain classes of facilities or chemicals so that fewer facilities would have to report on fewer releases;
• Reducing the eligibility requirements for allowing more facilities to file the simpler and less informative TRI Form A;
• Allowing facilities that meet certain criteria to simply file a "no significant change" report if the facility's toxic releases are not significantly different from a baseline; and
• Allowing facilities to report toxic releases in ranges rather than specific amounts.

The range of burden reduction proposals is disappointing. Reporting industries would most likely support any and all of these proposals. While each proposal would certainly reduce the reporting burden, they do so by sacrificing either the amount or the accuracy of data collected under TRI. The TRI program has been a flagship-reporting program for EPA, demonstrating the usefulness of environmental data to the public and the power of information in producing change. Given the importance of the TRI program and demonstrable progress it has spurred, it is surprising that EPA did not include at least one proposal preserving the level of information and suggesting greater education and use of electronic reporting. In a period when the government is continually advancing use of the Internet through e-government and e-rulemaking policies, this seems like an obvious option to explore. The agency is also using this opportunity to solicit comments on possible enhancements to its TRI-ME reporting software, but any proposals for the software would only aim to further reduce reporting burden. EPA is accepting comments through Jan. 5, 2004 and has posted online both the white paper and federal register notice explaining how to submit comments.