From: Sandy Joos

Sent: Tue Mar 15 20:55:24 2011

To: ToxicsRuleMaking

Subject: Water quality

Importance: Normal

Contamination from pesticide use and other industrial processes has long compromised the quality of Oregon’s waterways, adversity affecting the public’s health, especially for those who frequently eat fish from Oregon’s rivers. If the new standards are adopted, Oregon will be the first state with water quality standards that protect the vast majority of people who consume fish and shellfish from Oregon waterways.

Currently, the majority of Oregon’s standards are designed to protect people who eat 6.5 grams of fish per day— the amount of fish that fits on a cracker. Clearly, these standards fail to protect many people, including tribal members whose traditional diets are not accurately represented. The new standards would better serve all Oregonians, especially those with diets and traditions dependent upon fish and shellfish.

I’m writing to urge the Department of Environmental Quality (DEQ) and the Environmental Quality Commission (EQC) to move quickly to adopt Oregon’s draft human health criteria for toxics based on the accurate fish consumption rate of 175 grams per day. This rate is a joint recommendation of the U.S. Environmental Protection Agency, the Confederated Tribes of the Umatilla Indian Reservation, and DEQ.

Furthermore, I urge DEQ and EQC not to undermine their own efforts by making it easier to obtain exceptions or “variances” to current standards. More specifically, the new rule allowing DEQ to issue variances without EQC approval should not apply to standards that aren’t affected by this rulemaking. The new variance rule should be limited to only those standards that have changed as a result of the current process.

Thank you for considering my comments.

Sandra Joos, PhD

4259 SW Patrick Pl

Portland, OR 97239