From: Bob Shumaker

Sent: Tue Feb 22 16:11:52 2011

To: ToxicsRuleMaking

Subject: comments on proposed rule

Importance: Normal

We are family forestland owners who have been managing our property in the Banks area for 34 years. We are very concerned about the proposed Human Health Toxic Pollutants rules and how this increased regulation will affect our ability to manage our forestland. The following points must be considered:

· The Oregon Forest Practices Act has significantly improved water quality in Oregon

· Landowners are required to conduct forest practices in compliance with the Forest Practices Act.

· Any regulation and enforcement of forest practices should come from the Oregon Department of Forestry who monitors any changes needed in best management practices based on sound, peer-reviewed science

· Allowing DEQ to directly regulate forest operations is redundant, unnecessary and we fear family forestland owners would be subject to unreasonable and economically inefficient rules.

· Adding another layer of regulation is particularly troubling when the goal of state government at this time should be for efficiency

We support the formal comments and suggested rule language changes submitted by the Oregon Small Woodlands Association (OSWA). As an active participant of the DEQ stakeholder group, we know OSWA seeks to find a positive balance between the need to maintain water quality standards in Oregon and keeping family forestlands economically viable so these lands will contribute a variety of valuable products and services.

Personally, through compliance in the Forest Practices Act and because we love our land and recognize what it contributes to the health of our watershed:

· we practice careful care of riparian areas,

· have established permanent water bars and grass seeding on roads

· afforested 20 acres that was previously pasture land

· control invasive species

· maintain a diverse understory for wildlife and water quality

· have been recognized as “Tree Farmer of the Year” by the American Tree Farm System

· give school tours

Thank you for giving these comments your careful consideration.

Bob and Bonnie Shumaker