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VIA EDOCKET

<http://www.epa.gov/edocket>

Office of Environmental Information

Environmental Protection Agency

1200 Pennsylvania Avenue, N.W.

Washington, DC 20760

Re: Dioxin and Dioxin-Like Compounds; Toxic Equivalency Reporting;
Community Right-To- Know Toxic Chemical Release Reporting (70FR, March
7, 2005. Pages 10919 -- 10930. Docket ID: TRI-2002-0001).

Dear Sir or Madam:

The American Forest & Paper Association (AF&PA) is pleased to submit the
following comments on the proposed revisions to the reporting
requirements for dioxin and dioxin-like compounds category.

AF&PA is the national trade association for the forest, pulp, paper,
paperboard and wood product industry. AF&PA represents member companies
engaged in growing, harvesting and processing wood and wood fiber,
manufacturing pulp, paper and paperboard products from both virgin and
recycled fiber and producing engineered and traditional wood products.
Many of AF&PA's members file TRI reports and thus have a direct interest
in the proposed TRI revisions.

AF&PA strongly supports EPA's proposed revisions to TRI reporting of
dioxin and dioxin-like compounds to include reporting of toxic
equivalents (TEQs). As noted in the preamble of the proposal, AF&PA is
among several trade associations that have advocated for addition of TEQ
reporting to enhance the clarity, consistency and value of the data. The
existing reporting requirement in terms of total grams for the entire
17-congener category, and a single percent distribution of the
individual compounds at the facility does not meet these important
objectives.

The agency has proposed three options for adding TEQ information to the
current reporting data. Option 3 of the proposal is EPA's preferred
option, which we support. Under this option, in addition to reporting
the total grams of dioxin and dioxin-like compounds category, if a
facility has information on the distribution of the quantities of the
individual congeners, the facility must report the individual grams data
for each member of the category. EPA would generate the corresponding
TEQ data from the individual grams reported by the facility, and include
the TEQ data in the TRI database along with all the grams data reported
by the facility.

Among the benefits EPA notes for its preferred option 3 are:

-   Facilities would not have the burden of tracking TEFs and
    calculating the TEQ data from the grams data.

-   If EPA does all the TEQ calculations electronically there should be
    fewer errors and improved data quality, both because there would be
    fewer opportunities for computational errors, and because there
    would be less potential for confusion about which were the
    applicable TEFs as these values change over time.

-   If EPA calculates the TEQ data rather than having facilities report
    the data, EPA can recalculate the TEQ data for all of the reporting
    years once new TEF values are available.

We agree that these specific benefits generally outweigh those for
options 1 and 2 described in the proposal.

EPA also gives a further reason why option 3 may be preferable to the
other two options. Under option 3, EPA would not codify the TEF values
in the TRI reporting regulation, and therefore would not have to go
through rulemaking in order to adopt any internationally accepted
revisions. We appreciate the agency's desire to avoid TRI rulemaking
whenever international TEF values are revised. Nevertheless, TEF values
are used by a number of EPA's program offices for rulemaking and risk
assessments. Because of the importance of TEFs in risk assessment
activities, EPA should, apart from TRI, afford opportunity for public
comment before adopting any internationally accepted revisions.
Furthermore, EPA should not provide early public availability of dioxin
TRI data without TEQs through its electronic Facility Data Release
(e-FDR). To do so would defeat the proposal's purpose of enhancing
clarity, consistency and value of the data to the public.

Finally, EPA candidly notes that because TEQ calculated data under
option 3 does not come directly from the reporting facilities, there
would be no requirement for EPA to continue to provide TEQ data in the
future, although it has every intention of doing so. We urge the agency
to formally commit to providing TEQ data into the future. Only with
continuous reporting of TEQ data can the overall benefits be realized.

AF&PA appreciates this opportunity to comment. If you have any
questions, please contact me at 202-463-2587.

Sincerely,

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John L. Festa, Ph.D.

Senior Scientist