WASHINGTON D.C, 20460
                                                           OFFICE OF THE ADMINISTRATOR
                                                             SCIENCE ADVISORY BOARD
                                     July 12, 2005
EPA-S AB-COM-06-001
The Honorable Stephen L. Johnson
United States Environmental Protection Agency
Ariel Rios Building  .
1200 Pennsylvania Avenue, N.W.
Washington, DC 20460

       Subject: Toxics Release Inventory Data

Dear Administrator Johnson:

       This commentary was developed by the Science Advisory Board (SAB) Environmental
Economics Advisory Committee (EEAC) to address the importance of maintaining comparability
and validity in the Toxics Release Inventory (TRI) data. Although the committee has not
conducted a formal study of the proposed changes to the TRI, we are sufficiently concerned
about the potential negative impact of these changes on scientific research that we offer this
commentary. The SAB economists view the maintenance of the integrity of TRI data as a high
priority for EPA and the research community at large.             ,

       Recently, EPA has proposed rule changes that would curtail TRI data collection in two
significant ways. The first, which we understand is in the final stage of rulemaking, increases the
number of facilities eligible to submit a shorter certification statement (Form A), rather than a
full statement on releases.  The second, which we understand has not yet been formally proposed,
involves a change in reporting requirements so that facilities will report releases biennially rather
than annually.  This may compromise the comparability and quality of the data in the TRI series.
The SAB is concerned that these proposed changes may hinder the advances of environmental
research used to protect public health and the environment.

       TRI data are widely used to evaluate changes in facility and firm environmental
performance, to conduct risk assessments of changes in toxic release levels, and  to conduct
spatial analyses of toxic hazards. The TRI data provide the  only reliable source of longitudinal
data for this type of research. Over 120 scholarly articles have been published using the Toxics
 Release Inventory data  to address a wide range of public health, economic and social science
  sues.  The list of these publications may be found in the TRI Docket (at www.regulations.gov)
  comment number EPA-HQ-TRI-2005-2273-2099.2.                     ,     ,
                                               US. EPA Headquarters> library
                                                      Mail Code 3404T
                                               1200  Pennsylvania Avenue, NW

       This type of research can indeed inform EPA in developing environmental programs and
 conducting analyses, including benefit-cost analysis, environmental justice analysis, and
 children's health analysis, mandated under various executive orders, for program evaluations
 required by the Government Performance and Results Act, and for the Program Assessment
 Rating Tool program required by the Office of Management and Budget.

       In our view, the proposed changes will specifically affect the value of TRI data in the
 following two ways.

 1. Increased eligibility for Form A reporting will obscure the extent of facilities' releases of toxic
 chemicals. The changes in reported toxic chemical release levels will make the data
 incomparable overtime and across facilities. Further, they will impair researchers' ability to use
 TRI data to assess spatial health impacts of toxic chemical releases, and may also reduce
 variation in the data that are useful in identifying epidemiological  and other relationships. These
 research effects could significantly limit the national picture of the effect of toxic chemicals in
 the environment.

 2. Biennial reporting will make it impossible to track actual emissions in communities (or by
 facilities) from year to year. This will also make it very difficult to conduct reliable scientific
 studies, since the releases in the "off-year" will be unobserved unless the biennial reports contain ,
 release information for all years. This would seriously undermine the value of the TRI for
 scientific research, and also make it less useful for other intended purposes.

       We hope this commentary offers some insight into the importance of the Toxics Release
 Inventory data for scholarly research that supports EPA's mission and provides critical
 information to the scientific and policy communities as well as the public.  For this purpose, it is
 important to consider the impact of these TRI reporting changes on the validity and
 comparability of the TRI data and to explore ways in which such data collection could be
 improved in the future. The Committee will be pleased to answer any questions you or your staff
 may have.

 Dr. M. Granger Morgan, Chair
 EPA Science Advisory Board
Dr. Maureen Cropper, Chair
SAB Environmental Economics Advisory


       This report has been written as part of the activities of the EPA Science Advisory Board
(SAB), a public advisory group providing extramural scientific information and advice to the
Administrator and other officials of the Environmental Protection Agency. The SAB is
structured to provide balanced, expert assessment of scientific matters related to problems facing
the Agency.  This report has not been reviewed for approval by the Agency and, hence, the
contents of this report do not necessarily represent the views and policies of the Environmental
Protection Agency, nor of other agencies in the Executive Branch of the Federal government, nor
does mention of trade names of commercial products constitute a recommendation for use.
Reports of the SAB are posted on the EPA website at http://www.epa.gov/sab.

                    U.S. Environmental Protection Agency
                            Science Advisory Board
                Environmental Economics Advisory Committee
Dr. Maureen L. Cropper, University of Maryland, College Park, MD
Dr. Anna Alberini, University of Maryland, College Park, MD

Dr. Ted Gayer, Georgetown University, Washington, DC

Dr. Michael Greenstone, Massachusetts Institute of Technology, Cambridge, MA

Dr. James K. Hammitt, Harvard University, Boston, MA
      Member: COUNCIL

Dr. W. Michael Hanemann, University of California, Berkeley, CA

Dr. Gloria Helfand, University of Michigan, Ann Arbor, MI

Dr. Arik Levinson, Georgetown University, Washington, DC

Dr. James Opaluch, University of Rhode Island, Kingston, RI

Dr. William Pizer, Resources for the Future, Washington, DC

Dr. Stephen Polasky, University of Minnesota, St. Paul, MN

Dr. Kathleen Segerson, University of Connecticut, Storrs, CT
Dr. Holly Stallworth, Designated Federal Officer, 1200 Pennsylvania Avenue, NW,
Washington, DC

                    U.S. Environmental Protection Agency
                            Science Advisory Board
                                    BOARD                                 ^   ^
                                                                           -J   3.0
Dr. M. Granger Morgan, Carnegie Mellon University, Pittsburgh, PA
CHAIR             .             '                                          ||
MEMBERS                           '
Dr. Gregory Biddinger, ExxonMobil Biomedical Sciences, Inc, Houston, TX         3:.-   >.
Dr. James Bus, The Dow Chemical Company, Mildland, MI                      -*''   s. ^
                                                                        Oi    r  
Dr. Trudy Ann Cameron, University of Oregon, Eugene, OR
      Also Member: COUNCIL

Dr. Deborah Cory-Slechta, University of Medicine and Dentistry of New Jersey and Rutgers
State University, Piscataway, NJ

Dr. Maureen L. Cropper, University of Maryland, College Park, MD

Dr. Virginia Dale, Oak Ridge National Laboratory, Oak Ridge, TN

Dr. Kenneth Dickson, University of North Texas, Denton, TX                       

Dr. Baruch Fischhoff, Carnegie Mellon University, Pittsburgh, PA

Dr. A. Myrick Freeman, Bowdoin College, Brunswick, ME

Dr. James Galloway, University of Virginia, Charlottesville, VA

Dr. Lawrence Goulder, Stanford University, Stanford, CA

Dr. Rogene Henderson, Lovelace Respiratory Research Institute, Albuquerque, NM
      Also Member: CASAC

Dr. Philip Hopke, Clarkson University, Potsdam, NY

Dr. James H. Johnson, Howard University, Washington, DC

Dr. Meryl Karol, University of Pittsburgh, Pittsburgh, PA

Dr. Catherine Kling, Iowa State University, Ames, IA

Dr. George Lambert, UMDNJ-Robert Wood Johnson Medical School/ University of Medicine
and Dentistry of New Jersey, New Brunswick, NJ

Dr. Jill Lipoti, New Jersey Department of Environmental Protection, Trenton, NJ

Dr. Genevieve Matanoski, Johns Hopkins University, Baltimore, MD

Dr. Michael J. McFarland, Utah State University, Logan, UT

Dr. Jana Milford, University of Colorado, Boulder, CO

Dr. Rebecca Parkin, The George Washington University, Washington, DC

Mr. David Rejeski, Woodrow Wilson International Center for Scholars, Washington, DC

Dr. Joan B. Rose, Michigan State University, E. Lansing, MI

Dr. Kathleen Segerson, University of Connecticut, Storrs, CT

Dr. Kristin Shrader-Frechette, University of Notre Dame, Notre Dame, IN

Dr. Robert Stavins, Harvard University, Cambridge, MA

Dr. Deborah Swackhamer, University of Minnesota, Minneapolis, MN

Dr. Thomas L. Theis, University of Illinois at Chicago, Chicago, IL

Dr. Valerie Thomas, Georgia Institute of Technology, Atlanta, GA

Dr. Barton H. (Buzz) Thompson, Jr., Stanford University, Stanford, CA

Dr. Robert Twiss, University of California-Berkeley, Ross, CA

Dr. Terry F. Young, Environmental Defense, Oakland, CA

Dr. Lauren Zeise, California Environmental Protection Agency, Oakland, CA
Mr. Thomas Miller, Designated Federal Official, Science Advisory Board Staff Office,
Washington, DC