From: Lyle Bridge
Sent: Thu Feb 24 06:41:17 2011
To: ToxicsRuleMaking
Subject: FW: fishconsumption
Importance: Normal
From: Lyle Bridge [mailto:wwtp@cityoflagrande.org]
Sent: Wednesday, February 23, 2011 2:14 PM
To: 'toxicsrulemaking@deq.stateor.us'
Subject: fishconsumption
Dear Andrea
The City of La Grande WWTP has concerns with the rule changes being made on fish consumption for Oregon.
We do not believe that that Oregon Fishers can produce the amount of fish to support the new consumption rate. The new rule states that the population of Oregon (3.826 million) consumes 8oz. of fish 23 times a month or 44 million pounds of fish a month.
The newest ODFW survey I can find is from 2006 (Oregon Licensed angler Survey) this survey states that there were 364,514 fishing licenses issued in 2006. 73% of these fish for trout, 33% for freshwater salmon, 30% for steelhead, and 26% warm water game fish. The new rule is saying that these 364,514 licensed fishermen are catching 44 million pounds of fish every month or 120 pounds each. But we need to keep in mind that the fisheries are not open year around. Salmon, steelhead season is 8 months long and trout season is only open 5 months.
I am sure that there are individuals that consume 8oz of fish 23 days a month but it has to be a small population. Oregon could not produce this amount of fish year after year.
We are also concerned with the Arsenic Water Quality Standard. Arsenic is natural found in the soils in Eastern Oregon and this has to be taken into consideration when making theses rules.
The landscape as well as the culture of Oregon varies a great deal from one side of the state to the other. One standard does not fit all.
Thank You
Lyle Bridge
City of La Grande WWTP