From: Timothy M. Bliss
Sent: Sat Feb 26 17:03:27 2011
To: ToxicsRuleMaking
Subject: Opposition to Proposed new Water Quality Standards
Importance: Normal
Dear Sirs:
I express opposition to the proposed changes to the rules... for several reasons:
(1) We can't not afford the additional expense at the federal and the state levels. The USA and the State of Oregon already have too many expenses for the income collected from taxes. We are BROKE. We need to be reducing programs, employees, etc., to a level we can afford until the State Oregon and USA have balanced budgets. When we have balanced budgets, then we can take a look at this again.
(2) Businesses can not afford the additional expense. MY GOSH... we are in the middle of the most serious recession since the Great Depression.
(3) More regulation means businesses will have lower profit margins, which means they will have to lay off employees or their business profit margin may be so low the companies may go bankrupt. You are the government OF THE PEOPLE... and the business owners and employees this will adversely affect do not need this or want this. We need LESS REGULATION at this point in time, so businesses can become more profitable and can hire more employees and pay more taxes. The 2010 Oregon tax increase on businesses backfired on the State... and businesses have left the state or laid off employees. These water quality rules will cause a similar problem and will prolong the Oregon recession.
(4) Focus on enforcing the laws and regulations we already have on the books. That is plenty of work for current EPA and ODEQ staff to focus on.
(5) We already have the strictest environmental quality laws of all countries on earth. We don't need more restrictive rules at this time. I took environmental law in graduate school. The case law pointed out how difficult it is to do business in the USA... which is why businesses first moved from the northern to the sourthern states, then overseas.
(6) I am chairman of a 501(c)(3) watershed council; we don't need stricter laws/regs that will make our watershed improvement work more difficult/expensive.
(7) I am part owner of a farm; we don't need more regulations/expenses at this time, hindering our ability to manage our farm and to do watershed improvement work on it.
(8) I am a soil scientist and hydrologist who worked for a federal agency for 30 years; I mapped soils, landslides, floodplains, wetlands, water systems; I took water quality samples; I completed effects analyses; I planned watershed improvement projects and monitoring; I summarized annual implementation and effective monitoring; I saw watershed problems on federal lands that greatly disturbed me, but also I saw adjacent private land that was managed much better than federal land; I NEVER saw any of you regulators poking around federal lands each year to monitor things, to be sure every project complied with water quality laws and regulations ALREADY ON THE BOOKS. That's where you need to be focusing your time and efforts... implementation and effectiveness and validation monitoring.
(9) My final point. I found that environmental organizations... like Hells Canyon Preservation Council... always focused on the front end of projects. That's what EPA and ODEQ are doing, too. There is always lots of money for planning and implementing projects, and for writing laws and regulations, but little money is set aside for implementation, effectiveness and validation monitoring to test how good our planning and implementation was and how good our models were. I found from my experience working for a federal agency, that the efforts of those environmental organizations and of state and federal agencies FOCUS ON THE WRONG END OF THE PROJECT. So... stop writing new regulations... and get out there and monitor all of the projects being done on the ground where your time will be better spent. People at higher levels of government agencies always become too isolated from what's really going on, what is really needed at the grass roots level. Stop writing laws and regulations and get into the field to learn how existing ones are being implemented and how effective they are.
Sincerely,
Timothy M. Bliss
Bliss Enterprises LLC
3805 Cedar Street, Baker City, OR 97814
541-523-5995