This is a practical but important next step in TRI reporting. As a member of an agency that seeks to compare the TRI data of some of our facilities with that same data from some comparable private sector facilities, requiring all applicable facilities to report electronically will increase the reliability of the data that we look at.
In addition, this proposed rule would streamline the process, reduce the potential for human error, and make results available much more quickly. While the mode of data reporting is not necessarily written into law, in this case "good enough" is not good enough. Submitting TRI data in a paper form is an out-of-date system that most entities have moved beyond already; making this a requirement will allow everyone to be on the same page and not let certain facilities fall through the cracks in the confusion.
Anonymous public comment
This is comment on Proposed Rule
Electronic Reporting of Toxics Release Inventory Data
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