From: MOORE Beth
Sent: Mon Feb 28 09:37:35 2011
To: MATZKE Andrea
Subject: FW: NPDES permit comment
Importance: Normal
Andrea..This is a comment for the ‘revised human health WQ standards’ as well as the pesticide general permit that I am working on. See the comment after the Furthermore.
Beth Moore
General Permits Coordinator
DEQ WQ-Surface Water Management
Phone: (503) 229-6402
Fax: (503) 229-6037
From: Dave Pranger [mailto:mcweed@co.morrow.or.us]
Sent: Thursday, February 24, 2011 10:06 AM
To: MOORE Beth
Subject: NPDES permit comment
DEQ/Beth Moore, I would like to submit a brief comment about the proposed NPDES permit. I have read the proposed guidelines and rules regarding this permit and find that I could operate without too much heartburn within the proposed limits currently proposed by the permit as it stands right now. I would like to strongly urge though that the regulations proposed either stay as they are or at least not become any more restrictive then they already are. Adding additional restrictions to the use of pesticides that are already governed by the EPA and FIFRA seems to me to be a waste of tax payer time and energy. Furthermore, I sat in on the hearing in Pendleton regarding the increase in the fish consumption limits proposed to be used for testing purposes and was blown away by what was proposed as the amount of fish consumed. I think that the DEQ should use the default level of 6.5 gr/day or 8 oz/week. That seems like a much more realistic figure then the proposed figure of 175 gr/day. I do not know anybody that could eat that much fish on a regular basis. Indians included.
Dave Pranger
Morrow County
Weed Control Supervisor