Co-op America: Tell the EPA to Save Toxics Release Inventory

Co-op America joins our partners at the Social Investment Forum in alerting the public about a dangerous EPA proposal.

Concerned Americans have until January 13, 2005 to voice their concerns on a controversial Environmental Protection Agency proposal that would severely weaken the public's access to information on polluters through Toxics Release Inventory (TRI) data. TRI was created to inform and protect the public from potentially catastrophic problems caused by companies using toxic chemicals.

Investors use TRI data to gauge the true risks and liabilities of companies that pollute. In response to pressure from polluters, the EPA wants to significantly scale back required TRI reporting.

Subject:

To: Office of Environmental Information (OEI) Docket
Environmental Protection Agency
Mail Code: 28221T
1200 Pennsylvania Avenue NW
Washington, DC 20460
Attention Docket ID No. TRI-2005-0073

I am deeply concerned about the controversial rule changes proposed for the Toxics Release Inventory (TRI) reporting requirements under section 313 of the Emergency Planning and Community Right-to-Know Act (EPCRA).  The changes recommended by the EPA would be detrimental to communities living near major polluters and also to investors who use TRI data to identify companies that foul the environment.  I urge the EPA to withdraw this proposal.

We need TRI to alert the public to the potentially catastrophic consequences to neighborhoods, the environment, and livelihoods that take place when companies release toxic chemicals into the air, water, or ground.  Communities across the United States rely on TRI data to accurately prepare their emergency responses to such tragedies.  Disclosing TRI data has encouraged companies to cut back on these toxic chemicals, creating safer neighborhoods across America.  TRI has also allowed for informed negotiation between corporations and community members.

TRI provides investors with "hard" data that is crucial for evaluating and analyzing corporate performances.  Traditional financial disclosure requirements do not reveal all of the risks, liabilities, or advantages associated with a corporation's environmental performance.  TRI data provides additional information that is necessary for investors to make informed financial and investment decisions.

This vital information for investors is often unavailable elsewhere.  For instance, TRI data is used to identify companies with a competitive advantage (those who use materials more efficiently than their competitors) as well as identifying companies at greater risk of liability claims (due to pollutant releases).   Moving to an every-other-year reporting requirement would make it more difficult to track the performance of polluters and would make it harder to raise questions and concerns with problem companies in a timely fashion.  Raising the reporting threshold by 10 times and allowing companies to withhold information on low-level production of persistent bioaccumulative toxins (PBT) will simultaneously blind communities to the true risks of living in their areas (as small amounts of these chemicals are potentially harmful) and investors to the true liabilities associated with these corporations.

The Toxics Release Inventory program has succeeded in keeping the pressure on companies to voluntarily reduce emissions of harmful chemicals.  This is good for the environment; it is good for nearby communities; and it is good for investors who want avoid investing in companies with major pollution-related liabilities.  For all of the above reasons, I strongly urge the EPA to withdraw its proposal to gut TRI data reporting.

Sincerely,
Your Name, Your City & State