From: John Sundquist
Sent: Mon Mar 21 16:59:50 2011
To: ToxicsRuleMaking
Subject: Comments on Water Quality Standards for Human Health Rulemaking
Importance: Normal
John Sundquist
31139 Lanes Turn Rd.
Coburg, OR 97408
541-683-1905
March 21, 2011
To DEQ rulemakers--
I am a Lane county farmer, mine and timberland owner who is interested in children's health and education, and I eat fish daily. I want to thank the DEQ for revising Water Quality Standards for Human Health Toxic Pollutants and Water Quality Standards Implementation Policies.
I work with Forestland Dwellers, whose mission is --
We can agree--
--If our family hunts, we want to be eating clean meat.
--When we retire, we will take the grandkids fishing in pristine streams in an intact ecosystem.
--We foresee a healthy rural economy, where people can work near home, and families are safe living in forest and agricultural areas.
--We understand that a landscape of naturally diverse species may survive the uncertainties of climate disturbance.
Our Forestland Dwellers core concerns are with pesticide drift, revolatilization and runoff from forestry lands, but we are working to reduce harm from pesticide pollution in its many other forms. Improvements for human and environmental health are overdue and essential to our children's future and the economic health of our state.
The current Oregon pesticide regulation scheme, using the Oregon Department of Agriculture (ODA) to enforce the Federal, Insecticide, Fungicide and Rodenticide Act (FIFRA), is shown in many instances to be deficient in protecting water quality and human health. At Forestland Dwellers we hear numerous reports of personal harm and see numerous reports of human and environmental testing that demonstrate unacceptable levels of pesticides and other pollutants in our bloodstreams, in our state waters and in our wildlife, and we must conclude that the ODA/FIFRA regulatory scheme is a failure.
I attended the March 10 Board of Forestry Pesticides Workshop and heard the testimony of Dick Pederson, Administrator of DEQ. Missing from his slide presentation about the administratilon of Clean Water Act Nationall Pollution Discharge Elimination System (NPDES) permits for discharges of pesticide residues into waters of the state was the word "near." NPDES permits are necessary for discharges in, over and near water that result in chemical residues.
All forestlands in western Oregon are seasonally wet, with traditional fish runs into the most ephemeral streams and headwaters. Virtually all westside forestlands must be considered near water. USGS and other testing agencies repeatedly find pesticide residues in streams emanating from private timberlands. These timberlands cannot be exempted from NPDES regulation.
The DEQ Administrator also mentioned "we are working with the legislature" to transfer NPDES regualtion and authority from DEQ to ODA. The bill he was referring to is HB 2121, originating with ODA. DEQ has failed to notify the public making comments on NPDES permits (including myself) that the intended fate of NPDES regulation will be handed over to ODA. It is clear from reading HB2121 that all water quality control regulation authority can be transferred from DEQ/EQC to ODA. Also intended for regulatory diversion is water and pollution emanating from Confined Animan Feeding Operations, dairies, feedlots and chicken farms.
It is completely unacceptable for the DEQ to be soliciting rulemaking comments while not disclosing it sown agency activity intending rulemaking transfer to ODA.
The outcomes of ODA's current regulation of FIFRA authority can be measured in the chemical residues found in state waters, lands and in the tissues of citizens and wildlife. ODA has demonstrably failed to protect the state through FIFRA regulations. I hope you can direct two questions of conern to Administrator Pederson--
--Who wrote HB 2121?
--Why is DEQ so eager to vacate its responsibilities to protect Oregonians from toxic drift and runoff?
FIFRA rulemaking essential toxicology of pesticides and pesticide residues--synergy, bioaccumulation and terrain geography, climate and weather. You must make sure all DEQ rulemaking includes these essentials.
John Sundquist