Justification to change numbers back to pre-Burden Reduction rule

Estimate of Burden Changes due to the Toxics Release Inventory Form A Eligibility Revisions Implementing the 2009 Omnibus Appropriations Act
Form R's
Burden:	Responses		Hours
Previous1	67,707		3,218,179
New2	81,382		3,677,162
Difference between Previous and New
Change due to New Statute3	13,675		458,983
Change due to Agency Discretion
Change due to Agency Adjustment
Change due to Potential Violation of PRA
NOTES:
1Previous is defined as the "New" estimate of hours and responses from the NOA dated 3/23/09.
2Sum of Previous (above) and Change due to New Statute responses and hours.
3 Number of forms that will lose Form A eligibility and must be reported on Form Rs minus the Form Rs that may revert to Form A eligibility. Estimate of hours reflects the increase in Form R reporting burden. Note that these estimates of responses are calculated using the RY 2007 PDR. Burden hours are calculated based on the Form R ICR dated December 10, 2007.
Form A
Burden:	Responses	Hours
Previous1	10,235	515,901
New2	4,019	197,483
Difference between Previous and New
Change due to New Statute3	-6216	-318,418
Change due to Agency Discretion
Change due to Agency Adjustment
Change due to Potential Violation of PRA
NOTES:
1Previous is defined as the universe of Form As and associated reporting burden from the NOA dated 3/2/08 for the Form A ICR. Note that these estimates were generated using the RY2005 PDR.
2Sum of Previous (above) and Change due to New Statute responses and hours.
3 Number of Forms that will lose Form A eligibility and must be filed as Form Rs minus the Form Rs that may revert to Form A eligibility. Since Form As on average address 2.2 chemicals, the number of Form A "Responses" is the number estimated for Form Rs, above, divided by 2.2, and is listed as a loss instead of a gain. Note that these estimates of responses are calculated using the RY 2007 PDR. Burden hours are calculated based on the Form A ICR approved by OMB in the NOA dated 3/2/08.