February 4, 2004


The Honorable Kimberly T. Nelson
Assistant Administrator for Environmental Information
U.S. Environmental Protection Agency
Ariel Rios Building, 2810A
1200 Pennsylvania Avenue, N.W.
Washington, DC 210460

Re:   Toxic Chemical Release Reporting; Online Dialogue Phase
      II; OEI Docket TRI-2003-0001; 68 Fed. Reg. 62759 (November
      5, 2003).

Dear Assistant Administrator Nelson:

     The Office of Advocacy of the U.S. Small Business
Administration (Advocacy) welcomes the opportunity to provide
comments to Phase II of the Environmental Protection Agency's
(EPA) Online Dialogue on the Toxics Release Inventory (TRI). We
applaud EPA's efforts and hope that this important initiative
will lead to paperwork burden relief for TRI reporters by July
2005 (for the 2004 Reporting Year).
     As you know, the Office of Advocacy submitted comments on
TRI paperwork burden reduction to EPA on September 2, 2003, in
response to the request for comments on the Information
Collection Request (ICR) for the TRI Form A, which is the
alternate threshold form used by many small businesses as a
substitute for the longer Form R.  In that letter, Advocacy
recommended specific changes to enhance the Form A and proposed a
new "Form NS" to provide a certification of "no substantial
change" from a baseline year in which a Form R would have been
filed.  A copy of Advocacy's September 2, 2003, letter is
enclosed for EPA's consideration as part of the Online Dialogue
Phase II.  Our goal is to improve the TRI program by
supplementing the Form A with additional data, providing
substantial burden reductions to thousands of TRI reporters,
while still preserving TRI data quality.
     To enhance EPA's consideration of the regulatory options to
achieve TRI paperwork burden reduction, we have engaged, Jack
Faucett Associates, to perform an in-depth analysis of the
Enhanced Form A and Form NS.  The contractor's report will also
touch on additional options, such as expanding the use of
reporting in ranges to all sections of the Form R and a new
reporting threshold for two small business industries with very
small releases (chemical and petroleum wholesale facilities).
Advocacy expects to provide the report to EPA for its
consideration within the next few weeks, and we will work with
EPA to advance this important initiative to provide paperwork
burden reduction in time for the 2004 TRI reporting yearcycle.
     The Office of Advocacy appreciates the opportunity to
participate in Phase II of the Online Dialogue.  If you have any
further questions, please do not hesitate to contact me or Kevin
Bromberg kevin.bromberg@sba.gov or 202-205-6964) of my staff.
                         Sincerely,


                         Thomas M. Sullivan
                         Chief Counsel for Advocacy




                         Kevin Bromberg
                         Assistant Chief Counsel for Advocacy

Enclosure

Cc:  EPA Docket Center, EPA West, Room B102, Environmental
Protection Agency, 1301 Constitution Avenue, N.W., Washington, DC
20460

     Dr. John D. Graham, Administrator, Office of Information and
Regulatory Affairs