3.3.3. Reporting Requirements
The 1986 Emergency Planning and Community Right-to-Know Act (SARA Title III) requires firms that manufacture or process in excess of 25,000 pounds of some 302 chemicals (currently) to report all quantities released to air, water, and public sewage facilities, deposited on land and injected underground. While not a water pollution control statute, per se, SARA Title III requirements may influence the quantity of effluents released to the nation's waters. SARA Title III reporting requirements were viewed by Congress as a powerful stimulus, through their effect on public attitudes, shaping firm behavior. By now a considerable body of evidence demonstrates that disclosure requirements provide a strong incentive to identify and act upon opportunities to reduce accidental and routine releases of listed chemicals.
EPA data support this view. In 1994, 66 million pounds of toxic chemicals were discharged to surface water, down 78% from the 310 million pounds released in 1988. Transfers to POTWs were 255 million pounds in 1994, down 55% from the 570 million pounds transferred in 1988.
To project the potential reduction in annual compliance costs for controlling water discharges to the year 2000, assume as was done for air that the same trends continue. Quantities discharged directly would be reduced to just 13 million pounds and quantities transferred to POTWs to 115 million pounds. This would represent a cumulative reduction of about 750 million pounds in the annual rate of release, relative to a 1988 baseline. Per-pound control cost savings are not likely to be as large as for air. The principal chemicals discharged to surface water are ammonium sulfate, phosphoric acid, methanol, and sulfuric acid. The three largest categories of chemicals discharged to public sewers are ammonium sulfate, methanol and sulfuric acid. Control costs for several of these substances are likely to be relatively modest; for example, acids can be neutralized with limestone at low cost. Consequently, projected savings from Title III reporting requirements relative to a command and control approach for water discharges could amount to $0.50 per pound, or about $400 million annually in the year 2000.