A | B | C | D | E | F | G | H | I | |
---|---|---|---|---|---|---|---|---|---|
1 | __id | first_name | last_name | email_address | organization | state | comment | additional_document_name | additional_document_url |
2 | 871 | Arlene | Williams | awilliams222@outlook.com | resident of polluted zone | OR |
As a resident of a polluted zone near Precision Castparts in SE
Portland, I am concerned about the proposed rule. The rule proposal
seems to be inadequate in addressing the true emergency and risk
to public health, as it: will allow unexplainably for the emission of chromium 6 at levels 20 times less protective than Oregon's established ambient benchmark; will allow DEQ to unilaterally make decisions that affect human health, including for production to recommence, without adequate public involvement; will not sufficiently safeguard against ongoing racial injustice and environmental justice disparities caused by toxic air pollution, by too narrowly limiting which facilities will be subject to this rule. |
||
3 | 872 | Millie | Wilson | milliewilson48@gmail.com | self | TX | this is a solid company and it has many customers who depend on the glass. | ||
4 | 873 | Susan | Shea | sue@stainedglassresources.com | Stained Glass Resources, Inc. | Massachusetts |
Stained Glass Resources, Inc. is quite concerned with the steps
taken by the DEQ with regards to Bullseye and Uroboros glass
manufacturers. We fully agree with the Stained Glass Association
of America's response. 'The Stained Glass Association of America (SGAA) fully supports improved emission control systems, corporate responsibility, and a clean environment. We care about the effects that manufacturing can produce, but we also place high emphasis on scientific fact. The temporary rules that are being imposed on the glass manufacturing companies, Bullseye and Uroboros, are not being investigated fairly through scientific testing. Our organization fears that hastily written regulations will have a harmful ripple effect across this nation, causing irreparable harm to the stained glass industry by taking away the very materials used in our craft. 'Regulatory decisions must be based on science, not political issues. A leading scientist, Dr. William LaCourse of Alfred University, has said Bullseye's furnaces do not burn hot enough to produce toxic chromium. If it did, it would ruin the glass being produced. We urge DEQ to rely on science and fact and not to rush to impose these poorly written and misdirected rules. 'The SGAA asks that the DEQ continue to work with these companies under the current regulations and agreements until all of the testing is completed and the results are understood. Only then should the DEQ issue regulations that address and solve the specific problems. Again we ask that the DEQ's temporary agreement be flexible enough to change based on new factual information that will emerge. As these companies work to fix the emission problem, we ask that the DEQ remove limits and restrictions imposed on them. We speak on behalf of hundreds of our members who will be negatively affected by these regulations. Because of the limitations of these two glass-manufacturing companies, the DEQ is creating waves of upheaval and uncertainty for an entire art form and industry. Stained Glass Resources, Inc. respectfully requests that the DEQ work with scientific facts and evidence and not participate in a politically driven witch hunt. Sincerely, Susan M. Shea Vice President of Stained Glass Resources, Inc. Immediate Past President of the Stained Glass Association of America |
||
5 | 874 | Marny | Spoons | marnyspoons@gmail.com | Eastside Portland Air Coalition | Oregon | I stand with EPAC, Shawn Ingersoll, Robin Denburg, Jessica Applegate Paul Ruscher, Chris Winter, Mark Riskedall, Jennifer Jones, Mary Peveto and other concerned citizens in favor of protective temporary rules to effectively control HAP emissions from polluters in Portland. I am a parent and longtime resident of Portland, living seven blocks away from Bullseye Glass for the last sixteen years, and within 1 mile for the last twenty years. Members of my immediate family have tested high for these HAP's, but we are not part of the erroneously low statistics cited by the OHA in their attempts to reassure the public. We have been called hysterical, ignorant, fear-mongering loudmouths who want to squash art and business. My spouse is a multimedia independent artist who believes, as I do, that inspiration and artistic expression involves the world around us and requires a consciousness and deep regard of that world in our work. This includes a regard for the impact this art and business has on the health of those who live here. I'm not asking that Bullseye and other polluters go away; but I do ask that they are regulated with the Precautionary Principle in mind, that they effectively filter 99 % of their emissions of HAP's, that they are held accountable with large enforceable penalties if they don't, and that the state regulatory agencies that are put in place to protect our environment and our health do just that. | ||
6 | 875 | brianna | ortega | bo2@pdx.edu | south portland air coalation | Oregon | I stand with DEQ! I want healthy Portlanders! I want there to be no more arsenic in my blood! | ||
7 | 876 | John | Peterson | jkpete@gmail.com | Oregon |
Greetings DEQ, I am writing to encourage you to develop and enforce rules, laws, regulations, etc... with incentives, penalties, teeth, etc... to prevent, control, stop, etc... air, water, and soil pollution by chemicals that are known to cause harm to wildlife and people in our state. These rules should have no loopholes and should be applied to pollution emitters regardless of size. thank you John Peterson SE Portland |
|||
8 | 877 | Elizabeth | Mead | egmead@gmail.com | Washington, DC |
Bullseye glass has a long history of responsible operation. I
stand with Bullseye Glass in its efforts to continue operations
as a responsible citizen of the social and business community
of Portland, Oregon. Regulatory decisions must be based on science, not political issues. A leading scientist, Dr. William LaCourse of Alfred University, has said Bullseye's furnaces do not produce toxic chromium. We urge DEQ to rely on science and fact, and not to rush to impose these poorly written and misdirected rules. |
|||
9 | 878 | Jennifer | Sorcinelli | jenniwhit@yahoo.com | Oregon | I stand with Eastside Portland Air Coalition. I live less than a mile from Bullseye Glass. I have two small children. We have a garden. I am a Science Teacher. I expect my students to be respectful and responsible citizens. We should expect no less from the companies in our community. | |||
10 | 879 | Cordelia | Tilghman | Cordiet@comcast.net | none | Oregon | I am a resident of Rose City Park and live in an area identified as having high levels of arsenic pollution. I am concerned that DEQs temporary rule too narrowly limits which facilities will be subject to your temporary rule. I believe that it is imperative that DEQ immediately put in strong regulations that also apply to smaller glass manufacturers who may be polluting residential neighborhoods. Without strong regulations in place, people who live near smaller businesses that also may be causing unhealthy levels of arsenic to affect the air quality remain at risk. This should not be permitted by DEQ. | ||
11 | 880 | Elizabeth | Mead | egmead@gmail.com | NCAAG | Washington, DC | Uroboros glass has a long history of responsible operation. I stand with Uroboros Glass in its efforts to continue operations as a responsible citizen of the social and business community of Portland, Oregon. Regulatory decisions must be based on science, not political issues. | ||
12 | 881 | Susan | Katz | Oregon Physicians for Social Responsibility | Oregon |
Oregon PSR has signed on to the comments submitted by the CRAG
Law Center, but I wish to make an additional point about health
based standards. OHA has been emphasizing only Cancer Risks. EPA looks at , and OHA also must look at, considerable Non-Cancer risks of arsenic and cadmium exposure. Recent literature is exploring epidemiological evidence of significant risks from low dose exposures, according to a new paradigm that recognizes that early pre- natal and post natal effects of such exposures cause long term poor health outcomes other than cancer. I attach our two recent Fact Sheets on Health Effects of Arsenic and Cadmium to illustrate such new developments in scientific evidence about excess exposure to these two elements. New health based standards should take these into account . In the meantime, these interim rules should not minimize risks. |
Cadmium Cadmium and Public Health v3 - OPSR_v2S 2-2015.docx | https://data.oregon.gov/views/trwb-z8xe/files/f387c364-bf4b-4518-bb8a-88829ca2b8e7 | |
13 | 882 | Lara | Miyahira | Ryanandlara@comcast.net | Oregon | I stand with EPAC. I lived .3 miles from bullseye glass for 13 years and am very concerned about this issue. | |||
14 | 883 | Joanna | Tower | tower.joanna@gmail.com | Oregon |
I do not support these temporary regulations. These newly proposed
regulations are based on politics and fear, not science and fact.
Scientific evidence clearly indicates furnaces won't turn Cr(III).
into Cr(VI). I am a 7th generation Oregonian and lifelong resident. I worked at Bullseye Glass for 12 years and live in Southeast Portland. This is where I am raising my child and growing a garden. Most of my former coworkers are doing the same in the same area. Bullseye is the kind of place you are proud to work at - the people who work there are good people who make an amazing product and are good citizens of this city. Allowing ignorance and fear to jeopardize a business that is clearly working to install filtration and be as safe as possible is a horrendous mistake. |
|||
15 | 884 | Mary | Jackson | marjack202@msn.com | Oregon | I would like to see the ruling put on hold. It seems very discriminatory to direct this ruling against a VERY limited group of businesses. Remedies have been suggested by the glass companies and there should be a very short timeline to have them in put in place. Testing at that time would determine if the remedy was successful. | |||
16 | 885 | Jim | Scheller | self | Oregon |
I am in support of clean air and good health for all. As I said in my verbal comments at the EQC meeting on March 15, 2015, this temporary rule seems rushed. There where errors in the in what was presented by the DEQ to the EQC (e.g. CR IV vs. CR VI typographical error). The rule is not precise and attention to detail is lacking. The rule as written is not based on good science. At the public review I asked the EQC to please, please do their homework. This temporary rule may not solve the health problem and by reducing their product line by ~50% might possibly put Bullseye into a financial position where there is no business remaining to rule. Rushing, not actually solving the problem and destroying a small business in the process would not be a good result. While being in compliance with the existing rules and permits Bullseye did and continues to do the right thing. They halted production using the chemicals in question. They started work on a baghouse pilot that will allow for testing of emission control. Once proven they will expand past the pilot. I urge the DEQ and other involved agencies continue to work WITH Bullseye on this filtration pilot and expedite the permitting and other requirements. (Expedite, not rush, going forward everything must still be precise and based on good science) Respectfully, Jim Scheller |
|||
17 | 886 | Ray | LaRanger | laranger26@gmail.com | LaRanger Studio,Inc | NY |
Bullseye glass has a long history of responsible operation. I
stand with Bullseye Glass in its efforts to continue operations
as a responsible citizen of the social and business community
of Portland, Oregon. Regulatory decisions must be based on science, not political issues. A leading scientist, Dr. William LaCourse of Alfred University, has said Bullseye's furnaces do not produce toxic chromium. We urge DEQ to rely on science and fact, and not to rush to impose these poorly written and misdirected rules. |
||
18 | 887 | Robert | Bailey | email@rpbailey.com | Citizen | Oregon | We need a public involvement rule like state land use has (Goal One). Citizens have a right to know what is going into their air as permits are under consideration. DEQ needs more detailed guidance re public notification and public hearings. Citizens and communities should have notification when DEQ learns air quality is compromised. | ||
19 | 888 | Kerry | Ryan | kerrysilvaryan@gmail.com | OR | Please see attached file. | Final Group Comments on Temporary Rule (Crag Law, EPAC).pdf | https://data.oregon.gov/views/trwb-z8xe/files/e800be97-5d6a-4278-8c37-4ba08767b2c8 | |
20 | 889 | Karen | Azinger | k_azinger@hotmail.com | voting citizen of Portland | Oregon | I am a local Portland artist urging you to use sound science and sense when it comes to your decision about Bullseye. I attended the public meeting and heard zero scientific evidence that PROVED Bullseye was the source of the problem. And the company is voluntarily trying to work with the DEQ. Don't make a rash decision based on BAD science. Bullseye is a a rare jewel for Portland. A very good company that created a new art form. Don't kill an entire industry, and entire art form beloved across the US for the sake of political points. Use science, work with Bullseye not against them, and keep this company in business while we solve the air quality issue. | ||
21 | 890 | anne | Myrthue | myrthuea@gmail.com | Oregon | It is time for DEQ to take real action to ensure good air quality in Portland! For too long DEQ has knowingly failed to protect the city's residents who live in areas with the highest levels of toxic air pollution, and too often poor people and communities of color are at the highest risk. We want DEQ, as well as our city council and Mayor to take decisive action toward establishing local air quality management to ensure clean safe air for all of our residents. Thank you for your attention to this critical public safety and community livability issue. | |||
22 | 891 | John | Ratliff | john.conklin.ratliff@gmail.com | N/A--Retired Industrial Hygienist | Oregon |
I tried to submit a minute ago, and if that went through, you
can ignore this one. But I got an "error" message.
I'll therefore keep this short, and rely upon the file I wrote. What is happening here appears to be a situation of "mass hysteria" concerning Portlands "Toxic Air." I think DEQ made a significant mistake in releasing maps purportedly showing air concentrations of toxic pollutants based only on one sample period and the moss samples. The science isn't there, and I explain that in this blog post that I put onto both Google+ and Facebook. I think you need to walk back that misinformation, and talk directly about the science, and how it would need many, many more samples in order to validate that the moss samples say anything about possible toxic exposures to people. You also need to discuss what the word, "toxic" actually means, the relationship between toxicity and dose, and to say that so far, you have not documented toxic doses in people. Concerning the two glass manufacturers, you need also to tell the public that almost all their toxic components stay in the glass. Very little goes up the stacks. But because of this publicity, the use of better technology will reduce these components further. I hope this helps. John John C. Ratliff, CSP, CIH, MSPH 855 NW Winged Foot Terrace Beaverton, OR 97006 Cell: 503-707-2568 |
Portland Cadmium Data.pdf | https://data.oregon.gov/views/trwb-z8xe/files/4cacef34-3d49-46e5-9691-1949afb42861 |
23 | 892 | Lauren | Oliver | Resident | Oregon | I stand with EPAC | |||
24 | 893 | Susan Kennedy | Sommerfeld | susan@kennedysstainedglass.com | Kennedy's Stained Glass | Montana | As one who's career is dependent on the stained glass manufacturer's ability to produce glass, I ask that extensive studies be done before harsh regulations are made. I, of course, do not want anyone's heath or lives to be jeopardized but any action should be based on scientific proof for the protection of not only the communities, but those who's livelihood depend on the glass manufacture's production. Thank you, Susan Kennedy Sommerfeld | ||
25 | 894 | Brandy | siegrist | brandysiegrist@gmail.com | Oregon | Please close loopholes & adapt much stricter guidelines to protect our air. Filtration systems should be required for glass manufacturing. As a life long Portland resident we plead with you to do the right thing, correct current laws, and make our air more clean & safe. | |||
26 | 895 | Susan | Gere | susangere@gmail.com | Friends of Baltimore Woods | OR | I am writing because it is time to make air quality a priority in Portland. For too long the state has knowingly failed to protect the city's residents who live in areas with the highest levels of toxic air pollution, and too often poor people and communities of color are at the highest risk. We want our city council and Mayor to take decisive action toward establishing local air quality management to ensure clean safe air for all of our residents. Thank you for your attention to this critical public safety and community livability issue. | ||
27 | 896 | Chris | Bonner | bonnerc@hasson.com | Citizen | OR | There is no reason that chemicals known to cause cancer and/or death in humans should not be regulated as much as possible. To ignore this sort of risk is a violation of the public interest. | ||
28 | 897 | Kari | Minnick | kari@kariminnick.com | Kari Minnick Art Glass Studio | OR |
Bullseye glass has a long history of responsible operation. I stand with Bullseye Glass in its efforts to continue operations as a responsible citizen of the social and business community of Portland, Oregon. Regulatory decisions must be based on science, not political issues. A leading scientist, Dr. William LaCourse of Alfred University, has said Bullseye's furnaces do not produce toxic chromium. We urge DEQ to rely on science and fact, and not to rush to impose these poorly written and misdirected rules. |
||
29 | 898 | Markus | Klein | markus.klein@tgk.de | TGK GmbH | Germany |
Dear Sirs, Thank you for the opportunity sending a comment here.
We are one of the largest European companies importing American
art glass and distribute it over the entire Europe, North Africa
and few other. It is a pleasure to work with American art glass
companies and further more it is the basis of our business as
well. American Art Glass has the highest reputation worldwide
- There isn't any competitive. One of our main supplier is Bullseye
Glass with a long history of responsible operation. WE stand
with Bullseye Glass in its efforts to continue operations as
a responsible citizen of the social and business community of
Portland, Oregon. Regulatory decisions must be based on science, not political issues. A leading scientist, Dr. William LaCourse of Alfred University, has said Bullseye's furnaces do not produce toxic chromium. We urge DEQ to rely on science and fact, and not to rush to impose these poorly written and misdirected rules. Many businesses in the worldwide art glass business are effected already. We count on you making decisions by scientifically based facts only. Thank you Kind Regards from a friend of American Art Glass |
||
30 | 899 | Kathy | Gomez | Gomezx3@me.com | OR | I urge you to do the right thing. Please ensure our air is safe to breathe and establish relevant metrics to test and monitor quality. | |||
31 | 900 | Judith | Arcana | ja@juditharcana.com | Oregon | DEQ has to deal with this sooner than later - and not just "temporarily." Mind you, I don't want to banish manufacturing from the city - indeed, what I want is that any/all industrial practices be healthy for their workers and all nearby species. I stand with Eastside Portland Air Coalition, Neighbors for Clean Air and the revisions to the proposed temporary rules submitted by Chris Winter and Mark Riskedahl. | |||
32 | 901 | jeffrey | kipilman | jbkip@comcast.net | Portland Public Schools | Oregon | i support EPAC. i want strong emission controls without any loopholes. this has been going on too long! the DEQ has played a large part in this problem with it's lax attitude towards toxic emissions. anyone with a car has to pay to make sure it's emissions are safe. businesses should be held to the same standards. | ||
33 | 902 | Bridget | Stiverson | bkstiverson@gmail.com | Concerned Glass Artist | Montana | Please do not implement temporary rules that are not based on science but political embarrassment. Doing so will not only impact the businesses and families in the Portland area, but also those businesses and individuals who make a living utilizing the products made or make ancillary tools and equipment. | ||
34 | 903 | Terri | Grant | terrig423@gmail.com | WA |
I am a physician, an artist and a customer of Bullseye glass.
I have dedicated my life's work to the health and safety of
others. I base my decisions about patient care on scientific
data. I have practiced medicine long enough to have see conclusions
from small anecdotal studies be proved incorrect on many occasions
and that is why all physicians in the US currently use "evidenced
based medicine" to guide decision making for patient care. I
know that the State of Oregon and the DEQ is as concerned about
the health and safety of it's citizens as I am about my patients.
That being said, having looked at the data presented by the
DEQ and CDC guidelines, I have the utmost confidence that SE
Portland is a safe place to live, and raise a family filled with
happy, healthy children. Bullseye Glass is an outstanding company and community and I am proud to say that I plan to be a lifelong customer. They been in compliance with the state of Oregon since the beginning and have gone above and beyond in terms of safety, safety for their staff, their customers and the general public. The proposed DEQ guidelines would cripple the company for an unknown period of time. The DEQ has shown that they are understaffed and underfunded. Please do not place the well meaning board members in the untenable position of enacting a rule that they don't yet fully understand the science behind and aren't capable of enacting due to the above mentioned concerns regarding staffing/budget issues. Please do not enact rules that have decade long implications when there is no immediate need to do so. The state toxicologist, health department and the cdc has not found cause for alarm. This should reassure the DEQ that it has time to consider this decision. I urge you to say no to the proposed regulations in order to avoid "causing more harm than good". Bullseye Glass is a terrific and responsible company and a shining star in the world wide art and glass community. Thank you very much. Respectfully, Terri Grant MD |
|||
35 | 904 | Emily | Pezzulich | emily@pezzulichglassworks.com | Pezzulich Glassworks | Virginia |
The proposed "temporary rules" are arbitrary, and unsupported
by any scientific evidence of unacceptable levels of toxins in
the air or ground in the neighborhoods surrounding small glass
manufacturers in Oregon. In fact, recent studies by the Oregon
Health Authority (OHA) and the Multnomah County Health Department
have clearly stated that there is no immediate health risk to
the community. There is no sense in adding regulations to address hypothetical and speculative air quality or unproven community health issues at the expense of Oregon jobs, and the entire art glass industry. Please do your homework to ensure that regulations for any industry are based on empirical, scientific data, rather than vague possibilities of damage to the community. |
||
36 | 905 | sharon | Rowland | sharon@artinglass.com | Maryland | I've read many of the comments already submitted. Most of the testing that I have read about shows levels emitted from Bullseye and Uroboros glass manufacturers are not the problem. Also some have said that they have done nothing to enhance the emissions from the factory. This is not true!! These manufacturers are very concerned about emissions and even though it is not proven they have taken further efforts to reduce emissions. Please don't pass this bill. | |||
37 | 906 | Alice | Johnson | aliceljohnson@mac.com | Alice Johnson Stained Glass | MA | It is my understanding that it is thought that there might be a problem -- not that there actually is one. In view of this, and the need we in the glass/art business have for the unique glass made by these small-production factories, I urge you to be sure that a problem actually exists before making rules, even if "temporary" ones. | ||
38 | 907 | Margaret | Wells | info@artglassbywells.com | Art Glass by Wells | Texas | This will greatly impact stained glass artisans and businesses all over the nation. Not only suspending work and jobs locally but nationally. Please reconsider. | ||
39 | 908 | Daisy | Lemvke | Daisylembke@gmail.com | I stand with east side air coalition! | ||||
40 | 909 | Ann | Byron | ann_byron@yahoo.com | National Capital Art Glass Guild | Maryland |
Bullseye glass has a long history of responsible operation. I
stand with Bullseye Glass in its efforts to continue operations
as a responsible citizen of the social and business community
of Portland, Oregon. Regulatory decisions must be based on science, not political issues. A leading scientist, Dr. William LaCourse of Alfred University, has said Bullseye's furnaces do not produce toxic chromium. We urge DEQ to rely on science and fact, and not to rush to impose these poorly written and misdirected rules. |
||
41 | 910 | Steve | Wilson | info@artglassbywells.com | Art Glass by Wells | Texas |
Bullseye glass has a long history of responsible operation. I
stand with Bullseye Glass in its efforts to continue operations
as a responsible citizen of the social and business community
of Portland, Oregon. Regulatory decisions must be based on science, not political issues. A leading scientist, Dr. William LaCourse of Alfred University, has said Bullseye's furnaces do not produce toxic chromium. We urge DEQ to rely on science and fact, and not to rush to impose these poorly written and misdirected rules. |
||
42 | 911 | Chris | Winter | chris@crag.org | Crag Law Center | Oregon | The attached comments are submitted on behalf of Crag Law Center, Northwest Environmental Defense Center, Neighbors for Clean Air, OPAL Environmental Justice Oregon, Eastside Portland Air Coalition, Coalition for Communities of Color, Oregon Environmental Council, Oregon Physicians for Social Responsibility, Verde, Beyond Toxics, and the Portland African American Leadership Forum. These groups support the adoption of a stronger set of temporary rules that better protect public health and ensure adequate public participation in decisions affecting public health. | 3-30-16 - Final Group Comments on Temporary Rule.pdf | https://data.oregon.gov/views/trwb-z8xe/files/9baa5022-35cd-42b3-8d64-71d43c8972f0 |
43 | 912 | Taylor | Materio | taylor@mcmow.com | McMow Art Glass | Florida |
To whom it may concern: My family and I operate McMow Art Glass located in Lake Worth, FL. We are a family-owned and operated art glass studio celebrating our 40th anniversary this year (and we hope to continue that legacy for another 40). Throughout our duration Bullseye Glass has been the backbone of the art glass industry, our business, and livelihood. In addition to our family, McMow employs 15 individuals, all with families of their own. We could not agree more that the public's safety is always priority number one which is why we support Bullseye Glass Co. They have operated safely and under the guidelines necessary to manufacture glass for their community, employees and consumers of their products, as instructed by the regulatory entities in Portland. We have seen absolutely NO evidence to the contrary. Emotions aside, it should also be noted, perhaps more importantly, that Bullseye has been operating under the DEQs guidelines this entire time. They have not once stepped out of their boundaries on this, and even attempted to go above and beyond by halting their production of the glasses in question, even when no guidelines forced them to. If we allow these temporary regulations to go into effect, we will be punishing a business that provides to communities, not just in Portland, but all throughout America. We implore the DEQ to base its upcoming decision in regard to temporary regulations on actual, scientific fact, and not fear. The temporary regulations which you are considering would be crushing to our industry, as well as the entire community in Portland. Bullseye is a small business which has supported the Portland community in many ways. Not only have they done so through employment opportunities, but also by being at the epicenter of the artistic hub which has made Portland a destination for artists of all kinds from all over the world. If you, as regulators, turn your back on the businesses who have worked to embrace Portland, the ripple effects will be felt for years to come. We hope that the DEQ will work WITH Bullseye, not against them, in order to create a solution. The economic impact of this type of sweeping, and discriminatory action should be seriously considered as the consequences to such an irresponsible precedent are yet to even be considered. Here at McMow we are already trying to cope with the lack of access to the material we so desperately need. Think about the people all over the country – like us – who will be horrifically impacted when they can no longer pay their employees, and provide for their families. Sincerely, The Materio Family McMow Art Glass |
||
44 | 913 | Jeanne | deParrie-Turner | jeannedeparrie@gmail.com | Oregon | I stand with Eastside Portland Air Coalition. | |||
45 | 914 | Shirley | Hendel | sdhendel@yahoo.com | MD | Please reconsider your strict rules with Bullseye and Uroboros glass. I have been using their glass for over 10 years now with no ill effects. Why can't you look at it from a reasonable viewpoint, instead of having a knee jerk reaction, which may put many people out of work. and to add to that, there are other companies in OR that are in the area that could be the culprits .... and take a step back, there is cadmium for example in all the dyes that are used for your reds, i.e., lipstick and clothing. | |||
46 | 915 | Chris | Winter | chris@crag.org | Crag Law Center | Oregon | We have included a proposed set of temporary rules to accompany our earlier comments. | 3-30-16 - Proposed Temporary Glass Mfr Rules.pdf | https://data.oregon.gov/views/trwb-z8xe/files/3de04433-1fc2-4380-928c-14bee73d21c2 |
47 | 916 | Kate | Cox | katyjack6@gmail.com | OR | Thank you for creating these rules and for allowing us all to comment on them. Overall, they seem sound and thoughtful. Thank you. A couple of questions/ concerns: 1) Are glass factories allowed to emit air toxics prior to September 1st? As a resident living close to one of the factories, I hope not. I'm recovering from treatment for an aggressive form of cancer with a high rate of metastasis and my treatment contributed to a disabling neuropathy in feet. I'm doing everything I can to heal from treatment and to keep metastasis at bay. Continued exposure to known carcinogens and neurotoxins isn't part of my care plan. On behalf of all residents who are in a fragile state of health, please protect us from any further exposure to these substances. We don't have the luxury of waiting until September 1st. 2) I know that pollution control technology isn't cheap and that there will be some burden on smaller businesses. But I'm curious how you determined the criteria of '10 tons of colored glass. Could you put that in perspective for those of us not in the glass-making industry? How many tons of glass is made by Bullseye and Uroboros, for example? What other glass manufacturers produce that much glass? Are emissions that are created during processing 9 tons of glass considered negligible? 3) Why don't these rules apply statewide? Even if the current concerns are specific to Portland, it seems important to include the entire state in the rules. The same health impacts are a concern wherever a plant is located, particularly if people live nearby. 4) Please consider requiring filters for lead and all other potentially hazardous materials. Let's not take a 'wait and see approach to public health. Again, thank you for taking steps to improve our air quality. | |||
48 | 917 | Anthony | Farrugia | anthony11@bellnet.ca | Kuta Glass Accessories Ltd | Ontario Canada | Our hopes are that after a thorough and comprehensive study, guidelines should be provided to protect both the environment and our Industry. We are also wondering if other non glass related Industries will be looked at and have similar guidelines put in place to also protect the environment.. | ||
49 | 918 | Joanne | Cooper | jo.cooper@att.net | Art Glass Creations LLC | Missouri | As someone who restores and creates art, windows, stained glass; it would be very hurtful to our business and customers to not have the glass products we need to do the work. Stained glass has a rich history in the US and when restoring that history, there are glass products that just need to be made; even at The Capitol Building, The White House, etc.... There needs to be more of a study and a solution vs just shutting down production. Thank you for your time. This shut down would hurt many businesses and may cause lay-offs. | ||
50 | 919 | Lisa | Foster | lizalindsay@hotmail.com | OR | For months now there has been what amounts to a 'witch hunt' of the 2 local art glass factories, largely due to the media's sensationalist reporting. Both the DEQ and OHA have since stated that the levels of metal detected in the air would be unlikely to cause any health problems for people. Further, they found no "toxic" levels of harmful materials in the soil around Bullseye Glass Factory. So I see no reason to institute broad so-called "temporary" regulations on them. They are a responsible company. They have complied with all the changes that have been asked of them, and are currently installing a new bag house. Please work with them and with scientific facts, instead of media-driven hysteria. There are many of us who depend on them, for our art and our living. Thank you. Regards, Lisa Foster |
51 | 920 | Tracy | Sawyer | travelintrace@hotmail.com | Oregon |
As a SE Portland resident living near Bullseye Glass, I support
EPAC's comments that have been submitted. The DEQ's mission statement says the DEQ is to protect our air, land and water. In order to achieve this mission, DEQ must base the regulations of glass manufacturers on standards that lead to zero emissions of toxins in our environment and not based on industry thresholds in their productions. In other words, DEQ should be setting limits based on health standards and not on what works within industry's manufacturing process. Small manufacturers must filter all emissions just as larger manufacturers must. The same stringent guidelines should be put into place and enforced regardless of the size of the manufacturer. The temporary rules should include the filtering of nickel. The temporary rules should start at once and not wait until Sept 1st, which allows industry to pollute our air for 5 more months. DEQ should require companies to test Every controlled and uncontrolled outlet stack to ensure that no toxic emissions are overlooked. It is important that steep enforceable fines are clearly noted in the temporary rules so that industry has a clear incentive to follow the new rules. True level of compliance must also be achieved by clandestine air monitoring, thorough toxicity testing through moss and soil sampling, plus blood/urine testing of those living nearby to get an accurate assessment of contamination and to ensure that our environment is properly cleaned up. A thorough assessment of contamination has not bee done and needs to occur immediately. Emissions should be tested for Chromium VI as there seems to be no clarity on whether it is being created in emissions. Finally, these new regulations should include small and medium sized manufacturers in other industries as well to truly improve our air, land and water quality. Thank you for the opportunity to comment on the temporary rules. Sincerely, Tracy Sawyer |
|||
---|---|---|---|---|---|---|---|---|---|
52 | 921 | Carol E. | Webb | c3studiosinc@bellsouth.net | C3 Studios, Inc. | Georgia |
March 30, 2016 My name is Carol E. Webb and I am the owner of: C3 Studios, Inc. 2805 Buford Hwy Suite #106 Duluth, Georgia 30096 678-957-9663 C3studiosinc@bellsouth.net C3studiosinc.com I have been associated with Bullseye Glass since1998, becoming an Authorized Dealer in 2002. My business success depends on Bullseye Glass. Not only do I, as an artist use Bullseye glass, I am an instructor and teach with Bullseye glass. C3 Studios is also is a 2200 square foot working artist studio that resells Bullseye glass. I usually have a very large sale every April to celebrate our anniversary. C3 could not offer the sale this year due to lack of a large number of colors our customers demand in the spring time (red, yellow, orange, etc.). If you, as politicians and environmentalists respond in a knee jerk reaction and place even temporary restrictions on Bullseye and Uroboros glass manufacturers, you will be putting my company and livelihood in jeopardy, as well as many of our local artists. Take some time to gather all the FACTS before implementing any restrictions. Portland Oregon is currently the focus of the entire world's glass artists and other glass manufacturer's attention. If my company, C3, is forced to close, I will no longer have any need to travel to Portland Oregon for the Bullseye Conference's, purchasing trips, or trips to take educational classes. On a personal level, I recycle everything (home and studio), I compost in my yard at home, and I take the environment seriously. It is my understanding that Bullseye and Uroboros Glass manufacturers have been more than complainant and willing to work with the local officials. Slow down and know all the facts before you make decisions that will have a really large ripple affect around the world. Sincerely, Carol E. Webb C3 Studios, Inc. |
||
53 | 922 | Laura | Griffiths | laura.griffiths737@hotmail.com | OR | Portland has become a destination. With more and more people moving here permanently and more and more people visiting, it's essential we stay on top of air quality! Our children and our naturally beautiful landscapes deserve the best we can do. | |||
54 | 923 | Bryant | Stanton | bryant@stantonglass.com | Stanton Studios | Texas |
The Uroboros Glass and Bullseye Glass companies both have over
40 years of history in responsible operation. I stand with both
companies in the efforts to continue operations as responsible
citizens of the social and business community in Portland, Oregon.
I fully support improved emission control systems, corporate responsibility, and a clean environment, but progress in these areas should be based on science and proven facts. Hastily written regulations will have a harmful ripple effect across this nation, causing irreparable harm to the stained glass industry by taking away materials used in our craft. Each sheet of glass produced at both of these facilities are, in fact, handcrafted one sheet at a time by experienced glass workers. The art glass being produced by these two companies is unique only to Portland and is not produced anywhere else in the world. To saddle these companies with knee jerk regulations based on myth and not science could shutter these businesses and disrupt the operations of thousands of businesses around the world. Regulatory decisions must be based on science, not political issues. A leading scientist, Dr. William LaCourse of Alfred University, has said Bullseye's furnaces do not produce toxic chromium. I urge DEQ to rely on science and fact and not to rush to impose these poorly written and misdirected rules. During my 35 years as a stained glass artist, I have enjoyed a partnership with both Uroboros and Bullseye, and almost all of my custom art glass designs incorporate sheet glass from one or both of these companies. I can truthfully say that any misdirected regulations against these highly-respected companies will impede production and prices for stained glass studios across America. It is my hope that fact and science will be heralded over false, political pretenses. |
||
55 | 924 | Donald | Cooper | artglass.creations@att.net | Art Glass Creations LLC | Missouri | Bullseye, along with other glass manufactures have always had safety at the heart of their work. I strong request that you do not shut down production. This would hurt our glass industry and put many people out of work. Bullseye has a history of excellence in the products and work ethics. Please consider more testing too see if there really is a problem; and options to shutting down production. This would be a terrible hardship to many companies in the glass industry throughout the United States, even World Wide. I am respectfully asking that you do not shut down production of a much needed product. | ||
56 | 925 | Judith | Conway | vitrum@vitrumstudio.com | Vitrum Studio, Inc. | Maryland |
I own Vitrum Studio in the Washington, DC area with a studio partner.
We have been in operation for almost 20 years, and teach classes
with Bullseye glass and products exclusively. We depend upon
our studio for our income. Our financial survival is dependent
on Bullseye's products. Many of our customers are professional artists who use Bullseye's glass exclusively. Their livelihoods are also dependent upon Bullseye glass. There is no substitute, no other glass, that we or they can use. The Oregon Environmental Quality Commission should consider the temporary rule only when credible evidence demonstrates the rule is needed to prevent 'serious prejudice to the public interest. This is not the case here. There is no immediate health risk. The recent OHA studies found there was no increased cancer risk in SE Portland attributable to Bullseye's use of these materials. As OHA states on its website, 'it is unlikely that the level of metals detected in the air would cause any immediate health problems for people. OHA also concluded that current data shows 'long-term health risks are relatively low. Further, DEQ found no health concerns resulting from cadmium, arsenic, total chromium or hexavalent chromium in the soil around Bullseye's factory. Soil samples showed soil levels were generally below naturally occurring or 'background levels of heavy metals. Keith Johnson, manager for the DEQ's Northwest Region Cleanup Program, stated, '[o]ngoing emissions from the Bullseye facility are not resulting in harmful impacts to soils around the facility. These temporary rules do not protect the public and they place undue restrictions on Bullseye Glass. They also will cause extreme restrictions to those of us who depend upon Bullseye's products for our livelihood. There has been no evidence that emissions from the factory pose any acute health risk, or that Bullseye's 42 years of operation have resulted in areas of health concerns in the vicinity of the facility. If the EQC were to implement this temporary rule, numerous significant sources of toxic air pollution will remain from many unregulated businesses. Thus, the temporary rule would not effectively protect the public. Furthermore, DEQ's and OHA's own statements provide that the rule is not needed to prevent 'serious prejudice to the public interest. Instead of a hasty and discriminatory temporary rule, I urge that DEQ focus on permanent rules, based on scientific investigation and a thoughtful process to address Portland's air quality issues. New regulations should cover all businesses, not just target minor specific industries. With the livelihoods and well-being of so many people at risk due to Bullseye's current severely reduced production, I am requesting that DEQ bring all capability to bear to help expedite whatever solution is determined best for all parties. Respectfully, Judith Conway Vitrum Studio, Inc. Beltsville, MD 20705 |
||
57 | 926 | Mary | Stoneman | mary.stoneman@meltings.com | Meltings | OR |
Like most living, breathing people I want to have clean air, and
support rational regulations to make it so. As a local glass
artist and president of the Oregon Glass Guild I also am very
concerned about the viability of Portland's glass makers. The
cost implications of remedies are huge to these companies, and
I think they should be applauded for the grace with which they
have undertaken steps toward this end. Onerous restrictions
based on emotion rather than fact would threaten their ability
to continue to operate and also negatively impact the small businesses
who rely on Bullseye and Uroboros products for their existence.
I urge you to approach these issues with a thoughtful, science-based
approach. Respectfully, Mary Stoneman |
||
58 | 927 | Michael | Janis | mjanis2@aol.com | Washington Glass School | District of Columbia |
Bullseye & Uroboros Glass has a long history of responsible operation.
I stand with Bullseye & Urobors Glass in their efforts to
continue operations as a responsible citizens of the social and
business community of Portland, Oregon. Regulatory decisions must be based on science, not political issues. A leading scientist, Dr. William LaCourse of Alfred University, has said Bullseye's furnaces do not produce toxic chromium. We urge DEQ to rely on science and fact, and not to rush to impose these poorly written and misdirected rules. |
||
59 | 928 | David | Parrendo | huntsg@msn.com | Hunt Stained Glass Studios Inc | Pennsylvania | After reading all of the documentation regarding this subject, I am led to question are "good neighbor" practices being applied here. Have members of DEQ and EQC actually taken the time and effort to have a productive conversation with members of these small glass manufacturers to learn the entire process of their operations? Also, where is the use of scientific investigation in the process of addressing clean air quality with regard to all industries and not just targeting glass manufacturers. I cringe when a government entity will make a decision that they "believe is in the best interests of its citizenry" without quantifying data and evidence. I believe government is supposed to be of the people, by the people and for the people. When it "targets" an industry unfairly it belies its own truth. Have the members of these government agencies looked at the larger picture? Please use your intelligence wisely. | ||
60 | 929 | Markus | Klein | klein@tgk.de | TGK GmbH | Germany |
Dear Sirs, Thank you for the opportunity sending a comment here.
We are one of the largest European companies importing American
art glass and distribute it over the entire Europe, North Africa
and few other. It is a pleasure to work with American art glass
companies and further more it is the basis of our business as
well. American Art Glass has the highest reputation worldwide
- There isn't any competitive. One of our main supplier is Uroboros Glass Studios with a long history of responsible operation. We urge DEQ to rely on science and fact, and not to rush to impose these poorly written and misdirected rules regarding use of chromium. Many businesses in the worldwide art glass business are effected already. We count on you making decisions by scientifically based facts only. Thank you Kind Regards from a friend of American Art Glass |
||
61 | 930 | Amanda | simmons | amanda.simmons@btinternet.com | Amanda J Simmons | Scotland |
I am a glass artist based in Scotland and have used Bullseye Glass
here in the UK for the last 12 years. Bullseye are a very special
company of international repute who not only provide very high
quality supplies for artists but educate and support the art
glass community across the globe.. The support they have given
me as an artist has helped me gain an international reputation
for my teaching and my glass work. I have much respect for all
involved at Bullseye Glass and believe they are doing more than
needed to sort the issue of air toxicity in the Portland region
and have responded extremely quickly to the problem. I would
not use a product from so far away if I thought the company involved
did not care for the local community and the bigger global picture
when it comes to environmental concerns. I am very disappointed
that the facts are being ignored when it comes to the limitations
of production made on the company and how it will affect many
hundreds of local Portland families and thousands of artists
around the world if full production of glass is not able to start
again. I urge all those involved to review the proposed temporary rules, look at the facts and let Bullseye restart the production of their products using the new filter equipment that is being implemented. Amanda Simmons |
||
62 | 931 | Kerby | Strom | Kerbystrom@hotmail.com | No affiliation | Oregon | Clean up the air! What are our tax dollars doing? | ||
63 | 932 | Rudolf | Gritsch | rgritsch@aon.at | HTL Glass&Chemistry | Austria/Europe |
Statement regarding Temporary Rulemaking / Bullseye Glass. With kind regards, Rudi Gritsch |
PDF statment temporary stop in production.pdf | https://data.oregon.gov/views/trwb-z8xe/files/a8fc1cde-60d9-479e-b5e6-5b07e40605e8 |
64 | 933 | Guy | Maguire | guy.maguire.m@gmail.com | Oregon |
I appreciate the work being done to address the recent revelations
about our dirty air in Portland. However, I am concerned because
these companies have been allowed to pollute under DEQ regulations
for many years, and I fear the proposed temporary DEQ changes
will not adequately address the depth of the problem. I urge
our government to consider supporting the creation of a local
air quality management institution, like has been successful
in other areas in Oregon. As a resident who lives near PCC in SE Portland, I am deeply concerned about the heavy metals myself and my family are exposed to daily. I understand these companies have ample resources to afford pollution control devices. We need to be asking them to be good neighbors and take steps to curb pollution. The people affected by pollution should not be the ones responsible for footing the bill. That should be the responsibility of the corporations who pollute, and should be considered a cost of doing business. I believe the creation of a local agency to monitor the air and advocate for the people will be a necessary step in this process. Thank you for your attention to this important issue. |
|||
65 | 934 | Gail | Sherman | gsherman@reed.edu | OR |
I want to add my voice to a comment made by Katharine Salzmann,
who expresses my thoughts succinctly: ""Our sciences
and technologies are coming of age now. Our former ignorance
regarding the health effects of toxic pollutants that allowed
them to disperse or "dilute" into the ecosystem has
become completely unsustainable. There is no longer any meaningful
excuse, particularly when appropriate containment technologies
exist, to allow any industry, large or small, to continue to
risk the health of anyone, anywhere. For quite some time now,
in Oregon and elsewhere, lax or insufficient regulation and monitoring
have favored industry. It is time to shift the balance and implement
a truly health-based permitting and regulatory system. " I am a 35 year resident of Portland, working on the East Side, and I stand with Eastside Portland Air Coalition, Neighbors for Clean Air and the revisions to the proposed temporary rules submitted by Chris Winter and Mark Riskedahl. |
|||
66 | 935 | Laura | Robbins | laura@laurarobbinsmosaics.com | self-employed artist | NM |
Although I believe it of utmost importance to protect our air
and water, I ask that further research be done before penalizing
Bullseye Glass Co. and not allowing them to continue to create
certain colors of glass. I have found them to be an extremely
responsible company- unusual in this day and age. I believe they
would do everything in their power to do the right thing. Thank you. Laura Robbins |
||
67 | 936 | Sarah | Nelson | New Mexico | Please, do not support the Air Quality 2016 Temporary Rules. There is great concern regarding the proposed temporary restrictions to be imposed by the State of Oregon / EQC / DEQ regarding heavy metal emissions in the city of Portland. I am concerned because there is still a significant lack of understanding of the facts regarding elevated levels of these heavy metals, including the cause of the elevated levels. I understand that there is a concern for the public health and well-being, however I would point out that there are significant risks associated with implementing public policy based on a public outcry motivated by fear, rather than based on scientific fact. In the case of Portland, imposing restrictions without understanding the scientific facts runs the risk of causing significant and possibly irreparable economic damage to the glass manufacturing industry in Portland. Furthermore, there is a greater risk to the public well being by implementing what may possibly be the wrong policy. If the scientific facts regarding the origin and impacts of the heavy metals are not well understood, the proposed policies may not be effective at correcting the underlying problems, while lulling the public into a false sense of security that would reduce the motivation to investigate the matter appropriately. This could result in the potential health risks increasing in severity, rather than mitigating those risks because the problem would remain unsolved. It is for these reasons that I urge the State of Oregon / EQC / DEQ to delay implementing any new restrictions until a thorough scientific investigation of the facts has been conducted. | ||||
68 | 937 | Paul | Seer | paul.seer.labor@gmail.com | OR | Portland's air quality has been repeatedly documented as being some of the nations worst. Anything you could do to move in the direction of cleaner air would be greatly appreciated. Having said this, the current proposal regarding heavy metal emissions is inadequate as it will allow unexplainably for the emission of chromium 6 at levels 20 times less protective than Oregon's established ambient benchmark. It will also will allow DEQ to unilaterally make decisions that affect human health, including for production to recommence, without adequate public involvement. And lastly, it will not sufficiently safeguard against ongoing racial injustice and environmental justice disparities caused by toxic air pollution, by too narrowly limiting which facilities will be subject to this rule. Take this opportunity to create a safe standard that addresses all of these concerns, and ensures the safety of our citizens and the cleanliness of our air. | |||
69 | 938 | Amanda | Jarman | Amanda@amandajarman.net | Eastside Portland Air Coalition | OR |
I am a neighbor who lives five blocks away from Bullseye Glass.
My neighbors and I joined together to form a grassroots coalition
to address our neighborhood air quality, the Eastside Portland
Air Coalition. I agree with the statement submitted by Eastside Portland Air Coalition. |
||
70 | 939 | Kathy | Barnard | kathysgaa@gmail.com | Stained Glass Association of America | Please see our attached statement | DEQ_SGAA.pdf | https://data.oregon.gov/views/trwb-z8xe/files/a6a3003c-b9a3-43b0-b34c-9a5ad234e198 | |
71 | 940 | Yoko | Yagi | yoksfuser@gmail.com | Hyogo, Japan |
I would like you to think more carefully to adopting this temporary
rules. As you know, Bullseye Glass already has been start installing Baghouses to improve their filtering system for their furnace. So, let them do the right job step by step. Please do not push them into a big risk of give up the factory by adopting the temporary rules. I am an Japanese glass artist. (please forgive my poor English!) Who uses solely Bullseye Glass. Bullseye Glass is the only art glass manufacturer provide right (fired compatible) colored glass for me to create my artworks. To make intricate, many colors fused together, multiple firing required fused art works like mine, artists need absolutely well made fusible glass. Bullseye Glass is the one. We all fusing artists are rely on the company. Because of the reason, for us, Portland is Mecca of Glass Fusing. Again, please do not act based on emotional and speculations. Rules should set by scientific datas. Thank you for reading through. For your reference, here is my works at my web page. : http://fusedglassart.sakura.ne.jp/FusedGlassArtYagi/FusedGlassArtYagi/gallery.html You can see how many different color in each piece. These pieces shows how amazing development Bullseye Glass achieved to create many many firing compatible glass for these over 40 years. Yoko Yagi |
|||
72 | 941 | Ingersoll | Oregon |
As a parent of a former daycare child, pulled from daycare in
light of the air pollution findings - I completely agree with
the proposed temporary rules being put into effect to protect
the public surrounding these glassmaking facilities. I would hope that further research will take place to really determine the safety of those exposed, including workers within the glassmaking facilities. At the least, if pollution controls are available it is the responsibility of these businesses to take the health and safety of their employees and the public seriously and to install them. I will not feel safe in the community if these businesses are not taking their responsibility seriously by installing proper pollution controls. I hope that DEQ, OHA, EQC, and business owners work together to ensure beyond a doubt that the public is safe when it comes to air quality exposure. We count on these entities to be experts in their field and to collaborate to make sure events like this one do not occur. |
|||||
73 | 942 | Caten | Layland | Oregon | I stand with the Eastside Portland air coalition. | ||||
74 | 943 | Jolinda | Marshall | Jolinda.public@gmail.com | Imagine Design | California |
PLEASE reconsider this unfair and unbased temporary ruling. It
comes as a political reaction and it has not been proven with
any solid empirical evidence! that Bullseye glass is providing
any damage to the community. In fact, the only extensive scientific
tests which have been done have proven just the opposite. PLEASE
be fair and not reactionary in potentially shutting down a company
which brings significant beauty and art into our shared world,
and has a long history of being fair and environmentally minded!
ACT ON THE TRUTH, STAND FOR WHAT IS FAIR! Thank you for this courage, Jolinda Marshall |
||
75 | 944 | Robert | Thompson | Salalscape@yahoo.com | Neighbor | Oregon |
Dear DEQ, I agree with the concerns raised by the Eastside Portland Air Coalition as well as their requests. Thank you, Robert Thompson |
||
76 | 945 | Timothy and Christopher | Cosby | ccosby2002@yahoo.com | Cosby Art Glass Co. Inc. | Missouri |
To Whom it may concern, We recognize the great need for laws protecting the health of the environment and the public. We only ask that the companies concerned be given adequate time to correct their manufacturing processes in order to comply with the health needs of the community. It would be a great loss to the art glass trade worldwide if these two companies were to go out of business. |
||
77 | 946 | Jill | Tanenbaum | jill@jtdesign.com | creative glass design | Maryland |
Bullseye glass has a long history of responsible operation. I
stand with Bullseye Glass in its efforts to continue operations
as a responsible citizen of the social and business community
of Portland, Oregon. Regulatory decisions must be based on science, not political issues. A leading scientist, Dr. William LaCourse of Alfred University, has said Bullseye's furnaces do not produce toxic chromium. We urge DEQ to rely on science and fact, and not to rush to impose these poorly written and misdirected rules. Bullseye Glass Co. has a payroll of $7.5 million dollars. 130 Portland families and 20 other Bullseye families depend on Bullseye for jobs. Hundreds of Oregon artists and craftspeople depend upon Bullseye products. Tens of thousands of artists across the United States and the world depend upon Bullseye products. |
||
78 | 947 | Kim | Thomas | Tollertwins@gmail.com | Washington |
Bullseye Glass has a worldwide reputation as one of the finest
glass manufacturers. Their products are in use by thousands of
artists all over the world. Bullseye are obviously acting in an environmentally conscious manner. There have been NO instances where soil and air quality measurements have indicated hazardous measures of anything, but they are voluntarily installing bag houses to filter almost everything out anyway. Additionnaly, respected PhD's in glass manufacturing have stated that if Cr3 were converted to Cr6 that the glass batches would not be green. They also state that this process is completely under the control of the process engineers. So unless you are accusing Bullseye of intentionally polluting, restricting the ability to make these glasses is an action based on speculation (and probably not a small amount of sensationalism in an already bizarre election year). If you are concerned about human error, there are many, meant OTHER industries that you should be targeting where human error could cause much more disastrous results. I urge you to both protect American jobs and to protect a well respected American product by NOT enacting these restrictions But to instead work with Bullseye and the appropriate scientific community to determine what, if any, actions actually need to be taken on the matter of green glasses. |
|||
79 | 948 | Claudia | Borella | claudia@claudiaborella.com | New Zealand | DEQ,Assist these companies to monitor air quality not suspend thousands of people out of employment. Bullseye Glass a small company world famous put Portland on the map.DEQ address how you implement clean air strategies before you implement damaging laws that destroy your world famous local economy. Clean air is needed, so is employment. Bullseye Glass are voluntarily addressing any issues and are demonstrating their willingness to make change. Laws should create change for the betterment of all, not at the expense of some. | |||
80 | 949 | Claudia | Borella | claudia@claudiaborella.com | New Zealand | DEQ,Assist these companies to monitor air quality not suspend thousands of people out of employment. Bullseye Glass a small company world famous put Portland on the map.DEQ address how you implement clean air strategies before you implement damaging laws that destroy your world famous local economy. Clean air is needed, so is employment. Bullseye Glass are voluntarily addressing any issues and are demonstrating their willingness to make change. Laws should create change for the betterment of all, not at the expense of some. | |||
81 | 950 | Kirsten | Burt | kirsten.inga.burt@gmail.com | Oregon |
Thank you for taking action to protect Oregonians against toxic
emissions from glass manufacturing facilities! As a parent, who lives within a few miles of the SE Portland glass factory, I'm very concerned about the health effects of these emissions. I urge you to adopt stronger measures to ensure public safety. I'm concerned that the current proposal will allow for high levels of chromium 6 in emissions. Please also ensure that the public is involved throughout this process. |
|||
82 | 951 | Diana | Feuer | ddmfeuer@aol.com | Feuer Glass Design Studio | Maryland | Small art glass manufacturers are not the problem. Don't restrict their production without full proof they add to air pollution. | ||
83 | 952 | Tracy | Sawyer | travelintrace@hotmail.com | Oregon |
As a SE Portland resident living near Bullseye Glass, I support
EPAC's comments that have been submitted. The DEQ's mission statement says the DEQ is to protect our air, land and water. In order to achieve this mission, DEQ must base the regulations of glass manufacturers on standards that lead to zero emissions of toxins in our environment and not based on industry thresholds in their productions. In other words, DEQ should be setting limits based on health standards and not on what works within industry's manufacturing process. Small manufacturers must filter all emissions just as larger manufacturers must. The same stringent guidelines should be put into place and enforced regardless of the size of the manufacturer. The temporary rules should include the filtering of nickel. The temporary rules should start at once and not wait until Sept 1st, which allows industry to pollute our air for 5 more months. DEQ should require companies to test Every controlled and uncontrolled outlet stack to ensure that no toxic emissions are overlooked. It is important that steep enforceable fines are clearly noted in the temporary rules so that industry has a clear incentive to follow the new rules. True level of compliance must also be achieved by clandestine air monitoring, thorough toxicity testing through moss and soil sampling, plus blood/urine testing of those living nearby to get an accurate assessment of contamination and to ensure that our environment is properly cleaned up. A thorough assessment of contamination has not bee done and needs to occur immediately. Emissions should be tested for Chromium VI as there seems to be no clarity on whether it is being created in emissions. Finally, these new regulations should include small and medium sized manufacturers in other industries as well to truly improve our air, land and water quality. Thank you for the opportunity to comment on the temporary rules. Sincerely, Tracy Sawyer |
|||
84 | 953 | Julie | ries | julieries@hotmail.com | none | OR | I stand with EPAC. We have enough pollution already. Please do your job. Hold those responsible for endangering the only air we all share and an essential quality of our very lives. | ||
85 | 954 | Susan | Pearce | char@handpdx.org | Hosford Abernethy Neighborhood Association | Oregon |
Dear Commissioners O'Keeffe, Armstrong, Rider, Johnson, and Eden, The Hosford Abernethy Neighborhood Association (HAND) represents the area just north of Bullseye Glass in Portland, including one of the larger residential areas impacted by toxic air emissions from the Bullseye facility. Our neighborhood also includes part of the Central Eastside Industrial District, so we understand the challenge balancing the needs of those governed by DEQ's proposed temporary rules with the health and safety of those living and working nearby. First, we'd like to thank you for creating the opportunity for public comment on the proposed temporary rules governing air toxics in the Portland area. We believe the proposed temporary rules are a good start, but we would like to see them strengthened in the following ways: 1. The proposed rules should apply to all small industries, not just manufacturers of art glass – We feel that any industry emitting toxic materials should be regulated by these temporary rules. Metals such as cadmium and arsenic are equally damaging to health if they are emitted from a glass maker or from a metal plating shop. The Forest Service's moss data tells us there are many more uncontrolled emission sources than there are glass factories, and we feel all should be covered by the emergency rules. 2. The temporary rules should include both filtration and monitoring – In addition to installing state-of-the-art emission control equipment, we feel there is a need to continuously monitor what is being emitted into the air by these facilities. The cost of monitoring should be considered just another cost of using hazardous materials in an urban setting. 3. The threshold for being covered by these rules should be lowered – The proposed rules only cover facilities using more than 10 tons of raw materials per year, not including recycled glass or cullet. We feel this threshold is far too high, and that the minimum-size facility these rules would apply to should be much smaller. It is unlikely that a hobby glass maker would process even a single ton of material in a year. We also feel that recycled cullet should be considered a raw material for the purposes of this rule, to avoid creating an artificially distinction between facilities using recycled glass and those starting from raw materials. 4. All furnaces in facilities processing hazardous materials should be controlled – The proposed rules cover only a small subset of materials of concern, and if a facility has both controlled and uncontrolled furnaces, the potential exists for an operator to, intentionally or not, melt toxic materials in an uncontrolled furnace. Filtering all furnaces would eliminate that possibility. 5. Unmade decisions should default to 'No – When DEQ receives a notice of intent to construct/modify/change an emission control system, the proposed rules state that by doing nothing, the application will be deemed approved. Instead, if no decision is rendered, the application should be deemed denied. Approval should require affirmative action by DEQ. 6. Penalties for evading these regulations should be made more severe – Intentionally evading these or other environmental rules should carry a more severe penalty, and should include a private right to action to allow those harmed by such evasion to allow enforcement when DEQ does not act. Thank you for considering our comments, Susan E. Pearce, HAND Chair |
HAND DEQ Comments.pdf | https://data.oregon.gov/views/trwb-z8xe/files/9ea86d41-c1a0-4b21-8b94-642d3879947c |
86 | 955 | Diana | Chase | dc@dianachase.com | Diana Chase Design | TX | I have depended on Bullseye Glass to supply glass for my business as a glass artist for 26 years. Bullseye is very environmentally conscious and would not endanger the health of citizens close to their factory. This rule is premature and will damage my ability to support myself as an artist. Please do not enforce this . | ||
87 | 956 | Fawn | Livingston-Gray | fawnapril@yahoo.com | OR | As a neighborhood resident who lives near Bullseye Glass (about a mile away), I support the Eastside Portland Air Coalition requests for changes and expect that the DEQ will keep the safety and health of me and my family, including my 7 year old daughter, as the priority when considering changes. My partner works for a small business so I am not unsympathetic to their needs, but I believe this and other common sense regulation which is already present in other states is reasonable to request of business and, more importantly, necessary to insure our health and safety. | |||
88 | 957 | Beth | Williams | b_b3@juno.com | Portland |
DEQ and the EQC seem to be relying on a public panic reaction
to guesses derived from an unproven use of mosses as an indicator
of heavy metals in the soil. Other tests since the first panic
show that there is no reason to grab up torches and tear off
to lynch two businesses in all of Portland, as if they were responsible
for all the pollution in the metro area. This is not the responsible, reasoned approach one would expect from public agencies which have access to experts and proven tests. It is more like a contagious panic reaction that, instead of seeking a solution to possible, suspected, unproven contamination, is rather more interested in engaging in an overwhelming "kill response" merely to quiet the storm of fear that is based on just that: fear itself. I would rather that DEQ and EQC take note of scientific studies, rational arguments, proven tests, and the rapid response of Bullseye Glass in ceasing the glass making in question and proceeding with the purchase and installation of the air scrubbers to eliminate any possible contamination of the environment. Bullseye has been in operation for years, but there are no proven tests to show that there are any health risks caused by their production. They have workers at their facility who have been there for years and appear to be in fine health. Recent OHA studies confirm this for their neighborhood, too. DEQ's own manager of the NW Region Cleanup Program states that there are no "harmful impacts to soils around the facility". This panic attack resulting in an effort to implement draconian rules which will damage and possible destroy these two glass companies is an irrational reaction to a suspected "maybe" of a possible problem. Our community expects more of our agencies than mob-reaction. Instead, they should formalize as a rule what Bullseye is already doing: Mandate that they cease production of the glass DEQ is so concerned about until the scrubbers are up and running and then step back, reassure the community, and let Bullseye and Ouruborous live and thrive. As a further note, in addition to its ominously growing reputation as being unfriendly to artists, Portland is showing an alarming tendency to be unfriendly to small businesses, too, driving a number of them totally out of business or out of the area, into Vancouver and elsewhere. This treatment of these two businesses, the misuse of the making of temporary rules to protect the public despite tests showing it does not seem to be in any need of emergency protection sends notice to other companies considering coming to this town that rules here depend on reaction to hysterical public outcry rather than fair and accurate information. Please refrain from imposing these rules and let these two companies install air scrubbers so that they can get back into production of glasses needed around the world. Beth Williams |
|||
89 | 958 | Chris | Alexander | chrisalex1138@hotmail.com | Alexaxnder Art Glass | Texas |
Both Bullseye and Uroboros glass manufacturers have a history
of responsible operation, and have acted in a concerned and responsive
way to this important environmental issue. Both companies have
made an amazing show of good faith by halting manufacture of
large swaths of their product lines even though there is no legal
compulsion to do so. And regulatory decisions and laws must be based on science, not rampant fear or political issues. Bullseye contends that their furnaces do not produce toxic chromium. It seems clear to me that not enough time, testing, or clear-headed evaluation has occurred to proceed in a way that is safe and fair to all parties. There is a huge community of workers, businessmen, artists and artisans who rely on the production of American-made art glass for their livelihood. I urge you to proceed with more caution and a better tempered vision before enacting restrictions that will drive these companies out of business. |
||
90 | 959 | Chris | Alexander | chrisalex1138@hotmail.com | Alexaxnder Art Glass | Texas |
Both Bullseye and Uroboros glass manufacturers have a history
of responsible operation, and have acted in a concerned and responsive
way to this important environmental issue. Both companies have
made an amazing show of good faith by halting manufacture of
large swaths of their product lines even though there is no legal
compulsion to do so. And regulatory decisions and laws must be based on science, not rampant fear or political issues. Bullseye contends that their furnaces do not produce toxic chromium. It seems clear to me that not enough time, testing, or clear-headed evaluation has occurred to proceed in a way that is safe and fair to all parties. There is a huge community of workers, businessmen, artists and artisans who rely on the production of American-made art glass for their livelihood. I urge you to proceed with more caution and a better tempered vision before enacting restrictions that will drive these companies out of business. |
||
91 | 960 | Robin | Flynn | robinsnestglass@gmail.com | Robins Nest Glass | PA |
Bullseye glass has a long history of responsible operation. I
stand with Bullseye Glass in its efforts to continue operations
as a responsible citizen of the social and business community
of Portland, Oregon. Regulatory decisions must be based on science, not political issues. A leading scientist, Dr. William LaCourse of Alfred University, has said Bullseye's furnaces do not produce toxic chromium. We urge DEQ to rely on science and fact, and not to rush to impose these poorly written and misdirected rules. |
||
92 | 961 | Ashley | McFarland | ammcfarl@gmail.com | PA | I work at an organization that depends heavily on Bullseye glass for their classes and product. I trust in Bullseye and their product. It seems as if the company has been cooperating with the DEQ and EPA to improve their standards and prevent any further possible heath risks. It also seems that there are quite a few possible causes of these environmental pollutants around this area. I believe the company should be given time to comply with these standards without further restricting production. | |||
93 | 962 | Irene | D'Aloisio | Irenejd52@yahoo.com | Self employed glass artist | AZ | I understand the risk of damage to our environment, but I don't believe that has been proven. I am self employed and fusing glass is ,y only source of income. If you take that away from me, I will starve! | ||
94 | 963 | Diana | Chase | dc@dianachase.com | Diana Chase Design | TX | Please do not impose this premature ruling on Bullseye Glass. They are taking all necessary precautions and I depend on their glass production for my livelihood. | ||
95 | 964 | David | Judson | djudson@judsonstudios.com | Judson Studios | CA | As a father and a small business owner, there are two competing feelings regarding this issue. Obviously I would want my local government to do everything it could to protect my family and its environment. As a small business owner I would want my local government to do everything it could to protect and promote my business. My own business is in a residential neighborhood so I am well aware of the sensitivities that are required to operate in a community where families live. To my understanding Bullseye has cooperated fully with local government agencies and is in the process of installing the infamous bag house emissions control systems. They have voluntarily stopped the usage of any materials that may pose a danger. This Temporary Rulemaking is unnecessary and boils down to political showboating. It endangers successful contributors to the local economy, while doing nothing to better the environment, this sounds like a 'lose-lose' solution. Focus your time and efforts on the bigger picture, support the actions Bullseye and Uroboros are making to voluntarily improve their emissions, thus contributing to the success of your city's economy, which through these two companies has a global reach. After researching this issue closely I know my children would be just fine and that the DEQ is working from a place based on fact and science, not false political motivations. | ||
96 | 965 | Christopher | Eykamp | chris@eykamp.com | Oregon |
Dear Commissioners O'Keeffe, Armstrong, Rider, Johnson, and Eden, Thank you for allowing the public to have an opportunity to comment on the DEQ's proposed temporary rules governing the emission of toxic materials by Portland glass makers. I understand this is an unusual step, but I think circumstances require it. * The rules should apply to all emitters of toxic metals, and should include smaller-scale producers. One of my primary concerns is that the rules seem very narrowly tailored to medium-sized art-glass manufacturers, even though the moss data shows there are many more facilities emitting hazardous levels of carcinogenic metals into Portland's air. Please broaden the scope of the rules so that they apply to all emitters, not just those in the glass industry. Furthermore, the minimum size of facility regulated is rather large. I would request that the minimum size be dropped to a single ton of raw materials per year, and that you count cullet and other recycled glass as a raw material for this purpose. * The rules should apply across Oregon. Toxic emissions from uncontrolled sources are not only a problem in Portland, but across the state. Residents of other jurisdictions are as deserving of protection as those in Portland. Please do not restrict these rules to a narrow geographic area. * The rules must prevent emission of hexavalent chromium. Hexavalent chromium is highly carcinogenic. There seems to be confusion about how much hexavalent is emitted while making glass, but I am particularly concerned about hot chromium interfacing with the oxygen-rich atmosphere, which should create conditions conducive to formation of hexavalent chromium. No form of chromium should be allowed in an uncontrolled furnace. * There must be penalties for violation. The proposed rules appear to have no enforceable penalty provision. There needs to be specific, quantifiable penalties for breaking the rules, severe enough to discourage evasion. Rules without penalties become mere guidelines. * Filtration must be backstopped with monitoring. Stack monitoring should be part of any comprehensive emission control system, and should be required on every controlled and uncontrolled furnace. * There must be strict separation between controlled and uncontrolled furnaces. The current proposals do not provide a mechanism for tracking materials used in controlled and uncontrolled furnaces. There needs to be a protocol and documentation to ensure that no hazardous materials are used in an uncontrolled furnace, either by accident, or as a matter of expediency. Thank you, Chris Eykamp |
|||
97 | 966 | Judie | Sims | eyerene@gmail.com | CA | I hope that you will look at this in a nonbiased way and then assess the situation. I feel that right now the DEQ is operating in panic mode and that isn't good for anyone! | |||
98 | 967 | D. | Ikeda |
I concur with the comments of A. Haverland, C. Meiners, Richardson, Klebaum, Northstar Glassworks Inc., the concerned parent, mother, and artist, H. Grimmett, A. Ray, Uroboros Glass, and Bullseye Glass. |
|||||
99 | 968 | Nina | Cambron | nina@ninacambron.com | Nina Cambron | Michigan | Bullseye has already begun the process of installing 99% efficient baghouses on furnaces that melt glasses with chromium. They have made the commitment with the DEQ to test these filtration devices to make certain they operate correctly and safely for the citizens health in Portland. Adopting temporary rules that will shut down Bullseye will do nothing more than seriously affect not only them but the thousands of artists like myself who depend on their product to remain in business. | ||
100 | 969 | Pam | Gordon | bgpg@prozxis.com | Private citizen | Oregon |
Bullseye Glass and Ourobouros Glass manufacturers are an integral
part of the international art glass industry and a precious resource
for glass artists. Not only Portland and the Northwest, but
the entire United States and other parts of the world will be
impacted by the rules and regulations that are established by
the DEQ for these two companies; this is not just a local issue.
Glass will become more expensive, harder to get, restricted
in its value range, and will affect the many artists and hobbyists
that use this glass in their work. Both of these companies are
well established and have been good neighbors and contributed
to the Portland economy for decades. They are not uncaring or
evil in their intent, in fact, they have demonstrated the opposite
characteristics in their business and community interactions.
They do not want to be major sources of toxic air in Portland
and are willing to work for a solution. With this in mind, I
urge the DEQ to be create reasonable rules for regulation that
are based on current scientific knowledge and principles of glass
chemistry. The levels of arsenic, cadmium, and chromium have
already been reduced with the present restrictions. This should
give us time to be deliberative and reasonable so that we in
our admirable rush to protect one group of people do not unduly
harm another. Thank you for your consideration. Pam Gordon |
101 | 970 | Sally | Sawyer | Salsawtim@hotmail.com | Minnesota | Rule is premature, discriminatory and more about PR than protecting public health. | |||
---|---|---|---|---|---|---|---|---|---|
102 | 971 | Lem | Meyers | meyers@gmail.com | OR | I am concerned about the large number of out-of-state customers of Bullseye that have attempted to hijack this comment period for their own purposes. They seem to know little about the regulatory environment in Oregon, and dismiss the very real air quality issues that Oregonians face. These people do not pay the price for lax regulation and dirty air. Please disregard those comments generated by the Bullseye PR machine. | |||
103 | 972 | Pam | Gordon | bgpg@prozxis.com | Private citizen | Oregon |
Bullseye Glass and Ourobouros Glass manufacturers are an integral
part of the international art glass industry and a precious resource
for glass artists. Not only Portland and the Northwest, but
the entire United States and other parts of the world will be
impacted by the rules and regulations that are established by
the DEQ for these two companies; this is not just a local issue.
Glass will become more expensive, harder to get, restricted
in its value range, and will affect the many artists and hobbyists
that use this glass in their work. Both of these companies are
well established and have been good neighbors and contributed
to the Portland economy for decades. They are not uncaring or
evil in their intent, in fact, they have demonstrated the opposite
characteristics in their business and community interactions.
They do not want to be major sources of toxic air in Portland
and are willing to work for a solution. With this in mind, I
urge the DEQ to be create reasonable rules for regulation that
are based on current scientific knowledge and principles of glass
chemistry. The levels of arsenic, cadmium, and chromium have
already been reduced with the present restrictions. This should
give us time to be deliberative and reasonable so that we in
our admirable rush to protect one group of people do not unduly
harm another. Thank you for your consideration. Pam Gordon |
||
104 | 973 | Nichole | O'Neill | oneillartglass@gmail.com | Marynlad | Please do not per-emptively shut down the art glass manufacturing companies while researching the issue of heavy metal contamination. | |||
105 | 974 | Martha | Giberson | marthagiberson@verizon.net | MA |
I don't live in Oregon but I do make my living making glass products.
This proposal is being made without adequate scientific study
to support it. Regulation imposed with research is draconian,
and a response to constituent fear. It does not address long
term damage that can be inflicted on the local community and
the local economy not to mention the national glass art industry.
If you impose controls without the needed expert scientific
research you may well bankrupt two local businesses. The domino
effect of this action is even more severe, these business supply
thousands of small glass art studios in the U.S. alone, plus
many more larger glass businesses. Once this glass is gone,
it's gone. You will also destroy these businesses also and these
are families that will lose their only source of income. Income
that is generated in studios on property in or next to their
homes. Lose their business, lose their homes. Bullseye Glass is installing 99% efficient baghouses on their furnaces. It hasn't been proven that the colored art glass manufacturing facilities are the cause of this contamination. Until you prove this you may well be targeting the wrong two companies in order to "win" the favor of the public. What happens when that doesn't solve the problem? This is not the time to choose the path of least resistance. There is no immediate health risk according to the Oregon Dept. of Public Health, there is no elevated cancer rates in this demographic. DEQ should focus on permanent rules, based on scientific investigation and a thoughtful process to address Portland's air quality issues. |
|||
106 | 975 | Laura | Sutton | laura.sutton@sbcglobal.net | Glass artist | Nevada |
Bullseye glass has a long history of responsible operation. I
stand with Bullseye Glass in its efforts to continue operations
as a responsible citizen of the social and business community
of Portland, Oregon. Regulatory decisions must be based on science, not political issues. A leading scientist, Dr. William LaCourse of Alfred University, has said Bullseye's furnaces do not produce toxic chromium. We urge DEQ to rely on science and fact, and not to rush to impose these poorly written and misdirected rules. Thousands of glass artists rely on the consistent quality of Bullseye glass in their artwork. Limiting Bullseye glass production will limit the creativity of all these artists. We sincerely appreciate any support you can provide right now. |
||
107 | 976 | Bonnie | Celeste | bonnieceleste@comcast.net | OR |
Bullseye Glass has a long history of responsible operation. I stand with Bullseye Glass in its efforts to continue operations as a responsible citizen of the social and business community of Portland, Oregon. As a citizen of Portland and an employee of Bullseye Glass for over 15 years, I remain open minded to science, fact & reason, which must be what determines regulatory decisions - not political issues & fear. I do not support temporary rule making in this case, where there is no immediate health risk. Instead of a hasty and discriminatory temporary rule, DEQ should focus on permanent rules, based on scientific investigation and a thoughtful process to address Portland's air quality issues. New regulations should cover all businesses, not just target minor specific industries. A leading scientist, Dr. William LaCourse of Alfred University, has said Bullseye's furnaces do not produce toxic chromium. I urge DEQ to rely on science and fact, and not to rush to impose these poorly written and misdirected rules. |
|||
108 | 977 | Karla | Murie | krm1313@gmail.com | Concerned citizen | Washington | I am not an Oregon resident, but in following the news I am concerned about a blanket temporary order setting a precedent that could be followed in other states. I want the air we breathe to be safe, but the reality is that our air is not safe; just cars running on a freeway creates an unknown toxic risk. I think putting arbitrary temporary restrictions on businesses to make the public feel safer is irresponsible unless those restrictions have documented merit. Cars emit toxins, but you would not put a temporary restriction on all car use while the matter was taken into consideration. I understand the difficulty of walking the line between keeping people safe and keeping businesses able to produce goods and services. But, a reasonable balance does need to be found. Commerce should never be prohibitively restricted unless there is a known tangible risk to people. Everything I have heard on the news is that air and soil samples are being returned as having no measurable risk. Therefore, I am unclear as to why the drastic temporary restrictions that are scheduled to be implemented. The only benefit I can see in doing this is to appease the people who have been scared by the threat of potential risks that has been on the news for the last 6 weeks, before any real data was available. I am asking you to please consider implementing reasonable restrictions that will keep people safe while allowing businesses to continue to remain viable while the matter is investigated further. Thank you! | ||
109 | 978 | Pauline | Fratantoni | pfrat@comcast.net | NCAAG | MD |
Bullseye glass has a long history of responsible operation. I stand with Bullseye Glass in its efforts to continue operations as a responsible citizen of the social and business community of Portland, Oregon. Regulatory decisions must be based on science, not political issues. A leading scientist, Dr. William LaCourse of Alfred University, has said Bullseye's furnaces do not produce toxic chromium. We urge DEQ to rely on science and fact, and not to rush to impose these poorly written and misdirected rules. We sincerely appreciate any support you can provide right now. |
||
110 | 979 | Marcia | Newren | Marcia Newren Glass | New Mexico |
I am a glass artist and have used BE glass for close to 28 years.
I have been following this discussion from afar and have been
appalled at the sloppy science behind these allegations. If DEQ does indeed institute new emissions controls, I hope they figure out what they are and are not addressing. |
|||
111 | 980 | Jaime | Mitchell | jaimerooni@hotmail.com | Oregon |
I am a local glass artist, and materials from Bullseye glass are
the backbone of my practice. Limiting their production, or running
them out of business, doesn't just hurt the 150 families supported
by Bullseye; it affects me as well as all of those who enjoy
my art. Bullseye glass has a long history of responsible operation. I stand with Bullseye Glass in its efforts to continue operations as a responsible citizen of the social and business community of Portland, Oregon. Regulatory decisions must be based on science, not political issues. A leading scientist, Dr. William LaCourse of Alfred University, has said Bullseye's furnaces do not produce toxic chromium. We urge DEQ to rely on science and fact, and not to rush to impose these poorly written and misdirected rules. Instead of a hasty and discriminatory temporary rule, DEQ should focus on permanent rules, based on scientific investigation and a thoughtful process to address Portland's air quality issues. These rules should give clear directions to businesses and support the safety of the community. New regulations should cover all businesses, not just target minor specific industries. Thank you for carefully considering the scientific facts, and a variety of perspectives from the community. |
|||
112 | 981 | Trisha | Diaz | trishadiaz83@gmail.com | Oregon | I stand with EPAC | |||
113 | 982 | Doug & Vicki | Black | VEBlack@aol.com | UK |
As graduate Chemists of more than 40 years standing we fully endorse
the chemical reasoning within Dr LaCourse's statement In a reducing environment any Chromate or Dichromate VI will be instantly converted to Chromium III Therefore we would support a more measured approach to this issue |
|||
114 | 983 | Patricia | Punykova | punykova@gmail.com | MN |
I believe the proposed temporary DEQ rules are totally unnecessary
since the Oregon Health Authority (OHA) and the Multnomah County
Health Department have stated that there is no immediate health
risk to the communities of Portland's art glass is manufacturers.
I have done business with Bullseye Glass Co. for over 5 years, and use their glass products exclusively. I have visited their factory twice, some years apart, and my recollection was that they were an exemplary business partner in the local community. Their payroll must be in the millions and I can't imagine the local families that would be affected by a partial closure of the manufacturing facility. Imposing these temporary rules will force Bullseye Glass Co. to cut 50% of its glass products causing not only job loss in the immediate community, but affecting the livelihood of thousands of individuals that use those products. I am one of them. Again and again, Bullseye Glass Co. has demonstrated its willingness to roll up its sleeves and solve tough issues. They do it in business, and they are doing it now in the community to prevent any health concerns due to their manufacturing of glass. If there is no immediate threat, why not work closely with these businesses to create preventative measures for ALL area businesses. I think this is the sort of cooperation we would like to see between government and business. It's win-win. Please do not pass these temporary rules. If this passes, it would be devastating to many of us across the nation, and internationally as well. Sincerely, Patricia Punykova (612) 388-7890 |
|||
115 | 984 | Janet | Lipstreu | info@whitneystainedglass.com | Whitney Stained Glass Studio, Inc. | Ohio | As a studio that uses the glass these companies make, we ask that the DEQ reconsider instituting the temporary rules until it can be scientifically proven that these plants are the source of any contamination. As previously stated 'In these situations it is easy to make decisions based on fear and political pressure instead of on scientific evidence. Please read the research, understand the implications before making sweeping decisions (even temporary ones) that will impact people's businesses and lives.' Work WITH these companies to achieve the best solution for the environment - not just put them (as well as others in our industry) out of business. | ||
116 | 985 | Merrilee | Harrigan | merrileeharrigan@yahoo.com | JoyofGlass | DC | letter to DEQ.docx | https://data.oregon.gov/views/trwb-z8xe/files/72ee63d8-8421-4ec6-9248-0553597ab17f | |
117 | 986 | Elizabeth | Braun | lizartglass@gmail.com | Elizabeth's Glassworks, LLC | West Virginia |
Bullseye glass has a long history of responsible operation. I
stand with Bullseye Glass in its efforts to continue operations
as a responsible citizen of the social and business community
of Portland, Oregon. Regulatory decisions must be based on science, not political issues. A leading scientist, Dr. William LaCourse of Alfred University, has said Bullseye's furnaces do not produce toxic chromium. We urge DEQ to rely on science and fact, and not to rush to impose these poorly written and misdirected rules. |
||
118 | 987 | K. Adam | Frazee | afrazee@mnsi.net | Ontario |
To Whom it may concern, Please consider the ramifications knee jerk governing in an election year could have on an entire industry.. Watching from afar the developments that have unfolded in Portland, I have noticed a couple things. The reporting on this has been very biased and alarmist. Also consideration is not being given as to the other industries that may be contributing to air quality and soil quality in the Portland area both historic and current. because of this issue I have acquainted myself with some of Portland's history. Like the fact that it was a large war time manufacturing hub on the west coast. Could any of those historic industries contribute to the heavy metals in your urban soil? Also a google earth search shows that near the uroboros plant there is currently a cement factory and a smelter operation that produces pressurized metal tanks. Could either of these contribute to your high nickel problem? As a glass artist, all I am asking is that government use a responsible, and credible approach to helping these two companies continue to produce fine quality glass cleanly and safely. And not regulate them out of business. These two companies were complying with the current law. Government dropped the ball. To slam the door in there face without helping them adjust would add insult to injury. I can't help but notice that the term"these furnaces "likely" emit these metals is used in the above description I would hope that the state of Oregon and other states institute laws based on fact and not "likely", "possibly" or "maybe" scenarios. These Two companies have benefited the reputation of the Portland community in the past and have helped beautify glass installations the world over. Thank You |
|||
119 | 988 | Darryl | Berry | darryl@darrylberry.com | Darryl Berry Glass Studio | Ohio | I am writing to request you delay your enacting the temporary rules regarding limiting metals emissions from local glass manufacturers. Bullseye Glass has been the model of corporate responsibility in dealing with questions regarding these environmental issues. Too often we have seen companies refuse to address problems without lengthy delays and costly legal procedures. Instead, Bullseye Glass acted immediately to stop production of colors using metals in question. They did not wait for further testing; they demonstrated their concern for the community and acted. Bullseye Glass is making a major investment in their glass production and demonstrating the desire to continue working with the community. The integrity of the company is something I have appreciated and depended on for the last 17 years. Like other artists around the world, we would not work with a company that we thought was harming people and the environment. It was science that brought this matter to the attention of all those involved. I am asking that you please continue to use science as it relates this glass industry before taking action. Thank you. | ||
120 | 989 | Stewart | Martin | stewartdmartin@gmail.com | Oregon |
Bullseye glass has a long history of responsible operation. I
stand with Bullseye Glass in its efforts to continue operations
as a responsible citizen of the social and business community
of Portland, Oregon. Regulatory decisions must be based on science, not political issues. A leading scientist, Dr. William LaCourse of Alfred University, has said Bullseye's furnaces do not produce toxic chromium. We urge DEQ to rely on science and fact, and not to rush to impose these poorly written and misdirected rules. There is no immediate health risk. The recent OHA studies found that there was no increased cancer risk in SE Portland attributed to Bullseye's use of these materials. As the OHA states on its website, 'it is unlikely that the level of metals detected in the air would cause any immediate health problems for people.[1] OHA also concluded that current data shows 'long-term health risks are relatively low.[2] Further, DEQ found no health concerns due to cadmium, arsenic, total chromium or hexavalent chromium in the soil around Bullseye's factory. Soil samples showed soil levels were generally below naturally occurring or 'background levels of heavy metals. Keith Johnson, manager for the DEQ's Northwest Region Cleanup Program, stated, '[o]ngoing emissions from the Bullseye facility are not resulting in harmful impacts to soils around the facility.[3] DEQ's and OHA's own statements provide that the rule is not needed to prevent 'serious prejudice to the public interest. [1] Oregon Health Authority, 'OHA Investigating Metals Emissions in SE and N Portland,. [2] Ibid. [3] Oregon Health Authority, 'New soil, cancer, urine test data show low risk for Portland residents,. |
|||
121 | 990 | Carolyn | Thompson-Rizer | ctr@westerlook.com | Oregon |
I am a retired geologist with both a father and sister who are
glass artists using Bullseye glass. Let's get the science right
BEFORE imposing costly regulations. Bullseye glass has a long
history of responsible operation. I stand with Bullseye Glass
in its efforts to continue operations as a responsible citizen
of the social and business community of Portland, Oregon. Regulatory decisions must be based on science, not political issues. A leading scientist, Dr. William LaCourse of Alfred University, has said Bullseye's furnaces do not produce toxic chromium. We urge DEQ to rely on science and fact, and not to rush to impose these poorly written and misdirected rules. |
|||
122 | 991 | Bryan | Lewis | bryanwlewis@yahoo.com | The Bryan Lewis Studio | MO | To all those charged with the duty of protecting the environment and specifically air quality, thank you for your attention to these matters. I ask that you consider carefully the scientific evidence in these matters of art glass production. It is my understanding that it has been determined that there is no immediate health risk to the community. Furthermore, I understand that these manufacturers are willing to make changes if necessary. Please do not allow harm to come to these companies and the beautiful glass they produce by mandating restrictions based on fear, speculation, or uninformed public pressure. My most successful art glass installations have showcased Bullseye and Uroboros glass. People are very inspired by the unique artistry of these products. | ||
123 | 992 | Gillian | Thompson | magpieartglass@fuse.net | Gillian Thompson Glass | Ohio | As a glass artist whose livelihood is dependent upon the viablity to access art glass material, I support Uroborus and Bullseye in thier efforts to mitigate emissions from thier process. I urge the DEQ to proceed with measured thoughtful steps however, I do not support rushed temporary rulings which may be arbitrary without scientific studies to support. I also understand this is a measure which affects far from the banks of the Willamette. Thank you. | ||
124 | 993 | Elizabeth | Rhodes | ecline@pnca.edu | Ecova | OR | Please choose to enforce these rules. No one should be worried about getting cancer and having health issues just because a small business wants to continue running things they way they have been. We should feel safe breathing the air in our own neighborhoods. | ||
125 | 994 | Jessica | Stark | jessica_stark@msn.com | OR | I would like to urge that the new rules for glassmakers require Method 202 testing for condensable fraction particulate matter as well as Method 5 testing for filterable particulate matter. The effectiveness of control devices should be evaluated for both of these particulate fractions because it is possible that many of the compounds of toxic metals emitted by the high temperature furnaces could be in the condensable PM form at exhaust temps and will not be indicated in a M5 test. 99% reduction of measured M5 + M202 emissions should be required (or the proposed 0.2 lb/ton filterable limit as an option to provide flexibility). | |||
126 | 995 | Katie | Knutsen | knutsenkt@gmail.com | Oregon | As a member of the community here in SE Portland and a student in the field of Community Health, I am requesting that the DEQ provides stricter regulations with Glass Manufacturers as well as the other companies such as Precision Cast Parts who have been emitting heavy metals and other pollutants into the air. I specifically would like to request for the installation of pollution control devices (i.e. baghouse technology) to limit these emissions. I would also like to request changing the regulations to be focused around the actual measured air emissions of these companies, not just the technology to control these emissions. | |||
127 | 996 | Jane | Hartman | janehartman@verizon.net | Maryland |
Follow the Science!! Bullseye glass has a long history of responsible operation. I stand with Bullseye Glass in its efforts to continue operations as a responsible citizen of the social and business community of Portland, Oregon. Regulatory decisions must be based on science, not political issues. A leading scientist, Dr. William LaCourse of Alfred University, has said Bullseye's furnaces do not produce toxic chromium. We urge DEQ to rely on science and fact, and not to rush to impose these poorly written and misdirected rules. |
|||
128 | 997 | Kerry | Ryan | OR | This comment was already shared, but I want to make sure it doesn't get lost in the shuffle: "I am concerned about the large number of out-of-state customers of Bullseye that have attempted to hijack this comment period for their own purposes. They seem to know little about the regulatory environment in Oregon, and dismiss the very real air quality issues that Oregonians face. These people do not pay the price for lax regulation and dirty air. Please disregard those comments generated by the Bullseye PR machine." | ||||
129 | 998 | Leah | Powell | leahslookingglass@gmail.com | Leah's Looking Glass | Pennsylvania |
I am a glass artist and teacher, using Bullseye products and teaching
classes on their use for approximately 20 years. I purchase
these products from local businesses, as well as a wholesale
company in New Jersey. I am personally aware of many more people who are also dependent on availability of Bullseye products to keep their homes and feed our children. When I started fusing glass, Bullseye was the only source of glass for this purpose. With the well-being of so many people at risk due to Bullseye's current severely reduced production, I am requesting that DEQ bring all capability to bear to help expedite whatever solution is determined best for all parties. Expediency is perhaps the one non-controversial action by DEQ that will benefit both Bullseye and Portland residents while helping to rebuild credibility for DEQ. Your handling of this situation can be a guide for other governing bodies to follow: one that is based on scientific evidence used in a timely manner to promote community well-being, for businesses and residents. Respectfully, Leah Powell |
||
130 | 999 | Dianne | Ensign | roughskinnednewt@hotmail.com | OR | I support DEQ's proposed rules prohibiting uncontrolled emissions of hazardous air pollutants from glassmaking facilities. The proposed rules should be strengthened by applying them statewide, not just in Portland. The rules should regulate all heavy metals, and public review should be guaranteed. | |||
131 | 1000 | Terri | Walker | Oregon |
I have been an artist, and have worked some with glass. I'm appalled
at artists who don't value and promote clean air for the environment.
What kind of message is that? ********** DEQ: *********** Please note that a vast influx of anti-EPAC comments are being recruited in a seeming campaign, many from from folks who are not living in the vicinity and quite outnumber the local Portland neighbors who are at risk. Their own communities very likely have stricter regulations over toxics and their own glass factories are held to cleaner standards. The NON-residents' many comments are outnumbering the local neighbors' comments almost 10 to 1. Please take that into consideration when you review the comments. Oregon must not be badgered and 'greenwashed' into producing poorly regulated brightly colored glass for the rest of the nation, even the world, at the expense of local residents' health. DEQ's MUST consider clean air, before profits by industry. I live within a mile of Bullseye and have for 30 years. I STAND with EPAC and their many scientist associates. EPAC has no wish for glass companies to go out of business. EPAC is seeking clean air and health for children and the environment. |
||||
132 | 1001 | Jim | Gibbons | jimgibbons1@gmail.com | OR |
Dear DEQ, As a member of the community here in SE Portland, one who works in the area and is about to raise a family in the area, as well, I am requesting that the DEQ provides stricter regulations with Glass Manufacturers as well as the other companies such as Precision Cast Parts who have been emitting heavy metals and other pollutants into the air. I specifically would like to request for the installation of pollution control devices (i.e. baghouse technology) to limit these emissions. I would also like to request changing the regulations to be focused around the actual measured air emissions of these companies, not just the technology to control these emissions. This is, I believe, part of your civic duty, as it should be for companies that are part of these communities. Thanks for your time. JIM |
|||
133 | 1002 | Renee' | Eaton | freebird002@sbcglobal.net | Stained and Fused glass artist | Texas | I just want to make it known that this does not just impact Oregon. There are artisans all across the United States that will be effected by the operations of these glass manufacturers. | ||
134 | 1003 | Larisa | Palmentere | Se Pdx |
Bullseye Glass has a long history of responsible operation. I
stand with Bullseye Glass in its efforts to continue operations
as a responsible citizen of the social and business community
of Portland, Oregon. Regulatory decisions must be based on science, not political issues. A leading scientist, Dr. LaCourse, has said Bullseye's furnaces do not produce toxic chromium. We urge DEQ to rely on science and fact, and not to rush to impose these poorly written and misdirected rules. We sincerely appreciate any support you can provide right now. |
||||
135 | 1004 | Sally | Oakes | sallyo216@msn.com | Resident of Portland | Oregon | I stand with Eastside Portland Air Coalition, Neighbors for Clean Air and the revisions to the proposed temporary rules submitted by Chris Winter and Mark Riskedahl. | ||
136 | 1005 | Nadania | Idriss | info@berlinglas.org | Berlin Glas e.V. | Berlin, Germany |
I founded a small, non-profit glass studio in 2011. Our focus
is to educate and share with the local community, including offering
free workshops for youths under 18. As a small start-up studio,
with little financial support, we rely on donations to keep us
running, and in 2014, Bullseye gave us a crate of glass from
their European suppliers. Last year, I was fortunate to meet the owners of Bullseye, and was able to tell them that after an artist friend approached me to start a programme for refugees, we dedicated the glass Bullseye had given us expressly for it. Youths and their future, their education, their environment is something that is foremost for Bullseye Glass; and without hesitation, without even asking, we were given a new donation of coloured glass for the refugee programme. It has been painful for us to watch what has unravelled in Portland. Bullseye cares for its neighbours´ well-being, and deserves to be acknowledge with respect for the steps they are taking to solve these issues swiftly, and with the best intentions for everyone in the Portland community. By forcing the glass manufacturers in Portland to stop production, there are not only jobs at stake, but an entire global community of artists, makers and children will suffer a loss. Calming public opinion should not be approached by slamming a hammer down on small businesses, especially not ones that are so civic-minded and humanitarian... |
||
137 | 1006 | Devon | Willis | Willis.devon@gmail.com | Bullseye Glass | Oregon |
I started working at Bullseye Glass Co. almost 6 years ago mainly
because I was impressed by their focus on scientific exploration
and active education. They were a business that obviously cared
about making the world a better place and who were constantly
evolving and improving themselves. Right now as a Bullseye employee I'm terrified but NOT about my health and safety. I'm terrified that the job I love and depend on, and the jobs that many of my friends and thousands of my customers around the country depend on is threatened. I'm frightened because I'm seeing decisions being made by organizations I once trusted based on speculation, conjecture and flat out lies that will affect me personally as well as set a frightening precedence. Right now in the news, many people are discussing the current presidential primary campaign and the use of misinformation and rhetoric to excite the voting base. Many people are laughing at some candidates' blatant disregard for the truth, but there is also real fear that this is going to provide a foothold in our government to turn fear-mongering into law. I'm seeing the same thing happening right here right now in Portland, Oregon where media hype and a group of uninformed and frightened individuals is allowed to influence the decisions my government SHOULD be making based on scientific studies and facts. Progress needs to be made using information from credible sources using empirical evidence not as a reaction towards a public witch hunt that is in actuality delaying progress. I stand with Bullseye as they continue to do the right thing and I hope the DEQ and the EQC will too. Thank you for your consideration, Devon |
||
138 | 1007 | Nancy | Crumpacker | nancycrumpacker@comcast.net | Oregon |
To the Oregon Environmental Quality Commission: The DEQ's proposed rules prohibiting uncontrolled emissions of hazardous air pollutants from glassmaking facilities are a good beginning. The proposed temporary rules are not enough and should be strengthened as follows: STATEWIDE RULE MAKING: The temporary rules must apply to all glass manufacturers and glass makers statewide. All Oregonians deserve to breathe non-toxic air. REGULATE ALL HEAVY METALS: New rules should apply to the full suite of heavy metals utilized by glass manufacturers and glass makers, not just cadmium, arsenic, and chromium VI. ENVIRONMENTAL JUSTICE: The temporary rules are insufficient to protect public and environmental health for the most vulnerable Oregonians. PUBLIC REVIEW GUARANTEED: The public should have a full and fair opportunity to review all air permits issued by the state agency on the DEQ website. There should be no granted authorization to pollute the air other than a permit that is subject to public notice and comment. Thank you for your consideration. |
|||
139 | 1008 | jeffrey | Hunter | jhunter@perkinscoie.com | Perkins Coie LLP | Oregon | See attached comments from Bullseye Glass. | Bullseye Comments on DEQ_s Proposed Temporary Rule_16.03.30.pdf | https://data.oregon.gov/views/trwb-z8xe/files/e8b36852-edb1-4eda-b59b-12ac561be683 |
140 | 1009 | Alexander | Macdonald | alex_macd@yahoo.com | Resident | Oregon |
DEQ, Please maintain and prioritize public comment and public health as you move forward with our evolving, and hopefully improving, air quality standards. You exist to represent us when we are not allowed to represent ourselves. Thank you. |
||
141 | 1010 | Joan | Findlay | jnphl@earthlink.net | Oregon |
My husband and I have lived approximately 1 mile from the Bullseye
Glass Company for 26 1/2 years. I was pregnant in this house
and our son who is 24 now has lived here his entire life. After I read the article in The Mercury, some red flags went off for me concerning health issues in our family. I noticed that some of the toxic metals found to be emitted were known to cause skin cancer, kidney issues, lung issues and I already knew that heavy metals are implicated in neuro-developmental disorders. My son is on the autism spectrum and at one point I noticed that we knew several boys within close proximity who were also affected. My husband has had serious lung issues which were finally determined to be a cough variant asthma. Over the past ten years I have had many tumors and several surgeries due to these tumors, including a radical nephrectomy, radical hysterectomy, bone tumor excision, etc. Some were unusual or unusually presenting tumors, and though all were determined to be benign, the kidney tumor had been bleeding and was in danger of hemorrhage, therefore life-threatening. In addition, I have had skin cancers: a melanoma, 2 squamous cell carcinomas and a basal cell carcinoma. My dermatologist dubbed me ,the queen of odd little things because I have had so many unusual growths. None of my siblings have had similar health issues. I have a friend who has lived in the neighborhood for many years. He had a benign brain tumor a few years ago, a meningioma, that grew large enough to be symptomatic. These are tumors that can go unnoticed as they usually remain quite small. His brain surgeon remarked, at the time, that he wished he knew what was going on, as he had been seeing an extraordinary number of these tumors grow sizable enough to cause trouble. I realize these are anecdotal accounts and that it is possible that there is no correlation to the air quality. My question is whether these other health issues are being tracked or taken into consideration in regards to the safeguarding of the public from air pollutants. I have been aware, for instance, that autism and melanoma rates have been inexplicably high in Oregon and considering the main population base is Portland, I wonder if the poor air quality could be a factor in these high statistics. I heard that decisions were being made after some preliminary looks at cancer rates (though not skin cancers) in very close proximity (a half mile) to the glass factories. My concern is that those who live further from the factories should also be considered, and that the effects of very long term exposure should be taken into account. I wonder whether the rates of not just cancer, but other health issues of the entire city are being compared to other comparably sized cities. I know that Portland and Oregon have serious issues with diesel fumes and other industrial emissions, as well as those from the glass factories. My hope is that after the many decades of poor air quality we have suffered, that we will be able to live up to our green reputation by enforcing some very strict new regulations. sincerely, Joan Findlay 2603 SE 28th Place Portland, OR 97202 |
|||
142 | 1011 | Devon | Willis | Willis.devon@gmail.com | Bullseye Glass | Oregon |
I started working at Bullseye Glass Co. almost 6 years ago mainly
because I was impressed by their focus on scientific exploration
and active education. They were a business that obviously cared
about making the world a better place and who were constantly
evolving and improving themselves. Right now as a Bullseye employee I'm terrified but NOT about my health and safety. I'm terrified that the job I love and depend on, and the jobs that many of my friends and thousands of my customers around the country depend on is threatened. I'm frightened because I'm seeing decisions being made by organizations I once trusted based on speculation, conjecture and flat out lies that will affect me personally as well as set a frightening precedence. Right now in the news, many people are discussing the current presidential primary campaign and the use of misinformation and rhetoric to excite the voting base. Many people are laughing at some candidates' blatant disregard for the truth, but there is also real fear that this is going to provide a foothold in our government to turn fear-mongering into law. I'm seeing the same thing happening right here right now in Portland, Oregon where media hype and a group of uninformed and frightened individuals is allowed to influence the decisions my government SHOULD be making based on scientific studies and facts. Progress needs to be made using information from credible sources using empirical evidence not as a reaction towards a public witch hunt that is in actuality delaying progress. I stand with Bullseye as they continue to do the right thing and I hope the DEQ and the EQC will too. Thank you for your consideration, Devon |
||
143 | 1012 | Todd | Burchett | toddburchett750@yahoo.com | Please do not force this temporary regulation onto the local glass makers. Please focus your attention on a long-term solution instead of this hap-hazard solution. | ||||
144 | 1013 | Stephen | Quirke | Quirke.Stephen@gmail.com | Neighbors for Clean Air | Oregon |
Lynne Saxton, the head of the Oregon Health Authority, says that
the information revealed by the moss study showed Portland is
in a public health emergency. Rep. Blumenauer has already joined
Senators Wyden and Merkley in making the same declaration. I find it unacceptable for the DEQ to focus solely on the two metal sources that have received the most media attention, rather than all the sources which sound scientific research indicates are a threat to public health, and which collectively represent our current emergency. The DEQ itself created the loophole in 2007 that shielded these two glass factories from health-protecting regulation. For the DEQ to simply close this gap in 2016 represents a 9 year anti-climax of breaking even. For the DEQ to regain the public's trust, it needs to go further and show that it is willing to use ALL the information it has at its disposal to protect the public's health. Oregon's temporary rule must cover ALL the areas in Portland experiencing high levels of heavy metals pollution, and require technological changes that produce the maximum reduction in those emissions at their source. This can be done by adapting the LAER standard in the Clean Air Act's NESHAP program. |
||
145 | 1014 | Joseph | Witt | Josephwitt@hotmail.com | Oregon | I stand with EPAC. | |||
146 | 1015 | Jennifer | Benson | jenniferbensonglassart@gmail.com | Jennifer Benson Glass Art | Georgia |
Hi! I appreciate the opportunity to speak into this matter as it affects not only those in the Oregon area, but glass artists around the world who depend upon Bullseye Glass to make their artwork and livelihoods possible. Please do not hastily implement restrictions upon an industry before fully reviewing the scientific findings of recent studies, as well as, speaking with experts in the field of glass science. Do not rush to seemingly fix one issue... only to create more. Please seek solutions that are grounded in truth, fair to all concerned... solutions that will build goodwill and partnerships, and ultimately be beneficial to all concerned. Please seek solutions that allow the people in these glass companies to partner with you for the good of everyone! Let this situation become a model for how careful consideration and mature dialogue can lead to productive problem-solving where the entire community wins! Thank you! Sincerely, Jennifer Benson :) |
Blue Illusion I FinishedFrontViewFISizedBanner.jpg | https://data.oregon.gov/views/trwb-z8xe/files/2a3b7246-335e-45bd-96eb-222a97617f1a |
147 | 1016 | Sarah | Saito | sarahsssaito@gmail.com | Oregon |
I see all these comments from out of state people who obviously
have an economic interest in this glass being produced. A good
friend of mine lives near Bullseye, and her young son, who plays
outside frequently, tested critically high for arsenic. They
have to restrict his diet to make sure he doesn't get further
damaged while they try to heal him. She has health issues that
could very well be related to this contamination being released
into the air near her house for so long, unfiltered, for years
and years and years. It's not a victim-less crime, people! You
can sit in your nice houses far removed from this and talk science,
but there are injured people here! If Bullseye wants to do the
right thing, they should have had the filtering in place without
being made to do it, and not cry about cost now. They got a free
pass for what, 35 years? Maybe they should have set some of that
money aside to make sure this was taken care of. I applaud the
DEQ for taking action and making sure it's not "business
as usual." For you who are saying, no science supports this--
don't forget that the heavy metals present in the moss around
these site was what triggered all this inquiry in the first place.
Would you want that in your backyard soil, and in your air constantly?
Science is being used here! Any company , large or small, should
be required to pay attention to the health and needs of others
around it. It shouldn't be an either/or situation. They should
be willing to do the right thing, not asking their loyal customers
to speak up for them. Why don't you send them money to help them
put in the filtration instead of just whining here? Thanks DEQ for listening and not dragging your feet. I was appalled to read all these comments from insensitive people who don't care about other's health. Those might be precious glass to you, but when you look at them from now on, be aware that people who are getting sick from their own vegetables, and can't play in their own yards without getting poisoned,are also part of this picture. Any other company who is doing the same should also stop. It makes me sick when people try to justify one company's bad behavior by saying that other people are doing the same thing. Such a low bar to hurdle! How about challenging yourself to do better instead? Thanks again, DEQ, for paying attention and making changes. |
|||
148 | 1017 | Morgan | Rotach | hotflashglassnm@aol.com | Hot Flash Glass, Inc | New Mexico |
We are a small art glass business in Albuquerque, NM. The survival of Bullseye glass is vital to our survival as well as many other art glass businesses in the country. Bullseye glass has a long history of responsible operation. I stand with Bullseye Glass in its efforts to continue operations as a responsible citizen of the social and business community of Portland, Oregon. Regulatory decisions must be based on science, not political issues. A leading scientist, Dr. William LaCourse of Alfred University, has said Bullseye's furnaces do not produce toxic chromium. We urge DEQ to rely on science and fact, and not to rush to impose these poorly written and misdirected rules. We appreciate your consideration of the impact this will have on us, and consider all ramifications of a hasty decision that might infact put BULLSEYE GLASS as well as many of us who depend on them, out of business. Sincerely, Morgan Rotach & Karen Conty Hot Flash Glass 2111 San Mateo NE Albuquerque, NM 87110 |
||
149 | 1018 | Johnathon | Turner | jt4turner@hotmail.com | Johnathon Turner Glass | California |
The Oregon DEQ has an opportunity here to both protect the public
and to establish some new measures for that goal by working WITH
both Art Glass manufacturers to provide completely safe melting
procedures that will not curtail the production of the colored
glasses. Tens of thousands of people around the world rely on Bullseye and Uroboros for livelihoods and for the chance to live a better life. The art and craft of the glass that these manufacturers provide for are significant. Artists across the globe utilize the unique products that Bullseye and Uroboros produce. And the craft of glassmaking with these unique products touches and improves the lives of tens, if not hundreds, of thousands of people, ranging from at risk youth to lonely elders. Diminishing or closing these glass factories will have a global reach and increase the possibility for greater environmental degradation as artists and other producers try to fill in the gap -- none of them with even a smidgen of the expertise and health and safety understanding that Bullseye and Uroboros have cultivated over the years. If they were to be shut down, glass and environment quality would both suffer since new and/or smaller manufacturers might be starting from square one since safety equipment may be out of their financial reach. This moment provides a great opportunity to establish guidelines and procedures that will further clean up the small-producer glass industry. Bullseye and Uroboros have been leaders of the glass making industry for many decades -- working WITH both companies to allow their full production while establishing clean and efficient glass melting is clearly the best possible solution. |
||
150 | 1019 | Sherry | Selevan | sherry@sgs1.net | MD |
Having a background in occupational and environmental health (formerly
worked at both NIOSH and EPA), I understand the desire to use
the precautionary principle in your temporary rulemaking to prevent
hypothesized exposure to CrVI (theoretically converted from CrIII
at Bullseye Glass). I have read the summary document prepared
by Dr. William LaCourse of Alfred University (http://www.bullseyeglass.com/about-us/faqs.html#chromium).
His description is reassuring as to the low probability of the
conversion occurring in this setting. Next, I'm speaking as a glass artist. I primarily work with Bullseye Glass. In personal terms, I whole-heartedly support the precautionary principle, but as a glass artist, I am concerned that a response that puts the most stringent rules in place, even temporarily, may drive Bullseye Glass out of business. You will have chosen a direct response, but one, that in the long run, may be a lose-lose resolution. I encourage you to take a more considered approach: take some samples within the actual setting to determine whether Bullseye Glass could be the source of CrVI. Bullseye has producing glass for decades; surely a modest testing period is warranted. |
151 | 1020 | Tamah | Graber | tagraber@yahoo.com | National Capital Art Glass Guild | Maryland |
I urge you to reconsider the proposed regulations before the commission regarding Bullseye glass production. There is no public interest that will be served by this ruling. Accoring to recent OHA studies, there is no increased cancer risk in southeast Portland attributed to Bullseye's use of the materials. On the OHA website, it states that it is unlikely that the level of metals detected in the air would cause any immediate health problems for people and that current data shows that long-term health risks are relatively low. DEQ found no health concerns due to cadmium, arsenic, total chromium or hexavalent chromium in the soil around Bullseye's factor. In fact, soil samples show below naturally occurring levels of heavy metals. Keith Johnson, manager for DEQ's NOrthwest Region Cleanup Program stated that "ongoing emmisions from the Bullseye facility are not resulting in harmful impacts to soils around the facility." Bullseye is certainly willing to cooperate in forming permanent rules based on scientific investigation regarding Portland's air quality issues, but such rules should be given some time to formulate based on exactly that scientific investigation. If Bullseye Glass is forced to stop producing 50% of its glass products for 6 months, not only will I and all other glass artists in the United States and the world suffer the loss of our ability to practice our art, but Bullseye's very survival is at stake. And that includes more than 150 Portland families who will lose their jobs. Craftspeople all over the world depend upon Bullseye products, so this "temporary" ruling will have an enormous impact. Please do not rush to impose misdirected rules. |
||
---|---|---|---|---|---|---|---|---|---|
152 | 1021 | Benjamin | Kawaguchi | ben_kawaguchi@hotmail.com | Local Homeowner | Oregon | DEQ should require all manufactures who are near residential areas to follow strict emissions standards. That a business who is also near a number of schools and daycare centers has been allowed to maintain lax emissions standards does not make any sense to me. I support the comments that EPAC has submitted | ||
153 | 1022 | Sarah | Brostrom | Litna_one@hotmail.com | Portland State University | Oregon | |||
154 | 1023 | Elizabeth | Johnson | orders@elizabethjohnson.com | Elizabeth Johnson Art Glass, LLC | Colorado |
As a consumer of Bullseye and Uroboros Art Glass, I request that
you do not enact the poorly-conceived Temporary Regulations regarding
the colored glass factories in Portland. There is scientific
evidence to prove that the trivalent chromium (also referred
to as Cr(III)) used by these factories does NOT become Hexavalent
Chromium during the glass melting process. If it did, the glass
would be ruined. For more information on this, see this explanation
by Dr. William LaCourse of Alfred University: http://www.bullseyeglass.com/about-us/faqs.html#chromium This knee-jerk banning of the use of all chromium in glass is equivalent to banning the use of all chlorine in food products because, after all, everyone knows that Chlorine is toxic. If you used this type over over-simplified thinking you would ban sodium-chloride (table salt), which is an electrolyte necessary for human metabolism. Oversimplifaction of the chemistry and sweeping bans on whole classes of substances may calm the panic of the ignorant but it won't make them even a bit safer. Instead, you will kill two companies on which I and thousands of other glass sculptors depend for our livelihoods, not to mention the hundreds of families directly employed by those companies. Please stop. Think. Don't be cowed by pressure from the ignorant. Intead of enacting the poorly-crafted Temporary Measures, please instead pay attention to the actual data put before you, and institute good long-term air-quality policies that are based on SCIENCE, not panic. |
||
155 | 1024 | Claire | Palermo | clairempalermo@gmail.com | Oregon | I stand with the suggestions made by the Eastside Portland Air Coalition and the comments outlined in the Chris Winters letter. Please do your job properly and regulate these businesses handling toxic materials. Human lives and health matter more than a few extra dollars spent one time to set up the appropriate safeguards. | |||
156 | 1025 | Felecia | feleciaandthedinosaur@gmail.com | Oregon |
I am a resident of the neighborhood impacted by Bullseye's irresponsible
use of uncontrolled heavy metal emissions. I strongly support
the suggestions made by the Eastside Portland Air Coalition.
Upon reviewing the proposed temporary rules, I would like to
add these comments: Nickel needs to be added to the immediate operating restrictions prior to the emission control installation and approval deadline; Chromium III to chromium VI conversion must be tested in worst case conditions; Additionally chromium III should only be allowed to be melted in controlled furnaces; Every controlled furnace used to melt cadmium, arsenic, chromium, or nickel needs to be source tested to demonstrate compliance; Stiff enforceable penalties need to be added for violators of the temporary rules; These proposed regulations need to be extended to other manufacturers, besides colored art glass manufacturing. Thank you for reviewing these comments on the proposed temporary rule. |
||||
157 | 1026 | Mary | Volm | mevolm@gmail.com | Mary Volm Fine Artist | Oregon |
I am urging the EQC to not adopt the proposed temporary rules
limiting metal emisions for small colored glass for a variety
of reasons. First and foremost is the science, or lack thereof, behind these rules. Q quickly drafted these rules because the spotlight, deservedly so, was shifting from glass manufacturers to DEQ. The science is unproven and and disputed by many in the field of heavy metal heat transformation. The knee-jerk reaction of DEQ is just that, without the science to back it up. Which leads me to my second point, the glass companies themselves. As a glass artist of 15 years, I have the highest regard for Bullseye Glass. As a customer, I have worked with them for as many years, taken countless classes, attended international conferences with artists who have worked in the this field far longer than me, and had many factory tours . Science and chemical actions and reactions is the foundation of this company. They have always been conscious of potential challenges in the creation of art glass and have taught us all very well how to keep ourselves safe in our own studios. Thirdly, there are many of us locally, regionally and internationally who have made huge investments in studios and equipment to work in this medium. Taking colors away will put me out of business immediately. My work is highly saturated color and without it, I can not create my work. I have waited a lifetime to pursue my art and invested everything I have in this medium. Even just a few months without materials will set me back that it is likely I would not be able to recover. Finally, I have worked as communications director for both the State of Oregon and The City of Portland for over 25 years. At the City, I created the Clean Air Fair (recruiting DEQ and other public agencies in the region) to educate citizens on alternative methods to gas powered vehicles and equipment. I have worked tirelessly to encourage people to make good choices. I am asking you to do the same. Bullseye Glass suspended the use of heavy metals immediately after the first findings, went to the research bench as well as the marketplace seeking solutions, which they have already employed, and all the while making glass that isn't sellable in order to keep their employees gainfully employed. Why not allow the tests on the new filtration systems be allowed to be tested and modified if needed in the next few months? It is beyond a reasonable request. I know many of the research staff and education staff at bullseye. I have the highest respect for each and every one of them. They are very much a part of this community and care about the livability of our neighborhoods as I do,proven through my years in public service around these issues. Thank you, Mary Volm |
||
158 | 1027 | Erik | Schmitz | Erik.j.schmitz@gmail.com | Citizen | OR | Please pass the rules to regulate the pollution to protect the health of our citizens, including our children, as well as the natural environment, including bees and birds. Ignoring public health issues for short-term profits is inexcusable. Thank you. | ||
159 | 1028 | Kathy | Grossman | kathy@grossmangizmos.com | self-employed artist | NH | I feel that Bullseye Glass has been working with you to try to find solutions to reduce any air pollutants, has provided science that says that their process does not produce Chromium 6, and is in danger of closing its business completely if this temporary rule is enacted. This temporary rule seems as though it is unfairly targeting Bullseye while allowing other businesses to continue polluting. I am an artist who relies on their excellent quality glass for my fused glass work. Please work with them to figure out long term solutions to the problem rather than temporary stop-gap measures that will not actually deliver cleaner air to Portland. Thank you. | ||
160 | 1029 | Ruzsa | jruzsa@fuse.net | Career Glass Artist for 37 years | Ohio | Further research should be done to reach scientific consensus on this issue. These glassmakers would not willingly endanger thier communities just for these historically important colors necessary for the preservation of a hugely important art form. | |||
161 | 1030 | Dale | Feik | dfeik33@comcast.net | Hillsboro Air & Water a project of Portland Clean Air | Oregon |
To the Oregon Environmental Quality Commission members: After reading the proposed Temporary Rules that apply to the colored-glass manufacturing companies in Portland, I believe that they are necessary to protect the immediate and long-term health of the people who live close to those plants. Even the people who do not live close by will be affected because those toxic emissions, after being diluted by mixing with the air, still linger on. Every toxic emission matters! The goal of the Clean Air Act and the Clean Water Act is to eliminate toxic emissions, not just reduce them. That is why in the Clean Water Act, the EPA and State Environmental Quality Regulatory Agencies have to approve industries' National Pollution Discharge Elimination System (NPDES) permits. Many lobbyists and attorneys representing industries (Association for Oregon Industries – Air Quality Committee co-chaired by Thomas Wood and Mark Morford) have convinced DEQ and you to make decisions that do not seriously prejudice them so that the industries can make huge profits without being held to the strictest environmental emission controls possible. With the hiring of a new Director of DEQ I hope that the DEQ staff will make recommendations to you that are stricter than current Federal rules – rules that DEQ has the authority to make. Specifically, I believe that the Temporary Rules need to be enhanced by: Changing the wording so that they apply to not just Portland but to at least the Portland Metro area – better yet, to all glass manufacturers and glass makers statewide. I requested from the State Fire Marshal in Salem all of the extremely Hazardous Chemicals that Intel had stored onsite in the years 2010 through 2015 in Washington County. Intel manufacturing plants in Hillsboro and Aloha are classified by the State Fire Marshal as Extremely Hazardous Facilities. The very long lists of Flammable, Corrosive, Acute Health Hazard, Combustible, Poisonous Substances, and Chemicals are overwhelming even to Fire Fighter Emergency Response teams. The State Fire Marshal's office administers the 1986 Federal Emergency Planning and Community Right to Know law which has never been implemented well at the Local Emergency Planning Committee County level. Many of those Intel Extremely Hazardous Substances are heavy metals which are also used by the glass manufacturing industry – lead, copper, zinc cadmium, arsenic, chromium and others, and because of propriety laws, are unnamed. The Southwest Organizing Project in New Mexico wrote the book titled Intel Inside, A Case Study of Environmental and Social Injustice. Most of that injustice had to do with politicians/lobbyists blocking effective environmental laws that would have protected the large Latino population who live by Intel's facilities who emit tons, not just pounds, of toxic emissions. Any Temporary Rule in Oregon needs to be sufficient to protect the environmental health of our most vulnerable residents, not just the ones living by the glass manufacturing plants. As you know, I objected to the Temporary Rule that you adopted for six months without public comment so that Intel in Washington County and On-Manufacturing semi-conductor facility in Multnomah County would not have to follow the then current DEQ rule to control greenhouse gases. Toxic air emissions (heavy metals, fluorine related substances) create many health related diseases but greenhouse gas emissions caused by the burning of fossil fuels (coal, oil and natural gas) in the long run will make our planet inhabitable by animal life as we know it. When you decide the details of the Temporary Rule, please consider the statement of the 21 Youth Plaintiffs ages 8 through19 who sued the Federal Government and the Fossil Fuel Industry. I have attached the statements made by those 21 youth – those statements are beside each youth's picture. In summary, colored glass has many interesting features depending on your point of view and qualities of materials used. Many people now wish that public health took precedence over artistic beauty. What good is beauty if you get sick or die from that beauty? Please adopt very strict Temporary Rules and make them Permanent. This time I would be in favor of you doing that. |
Plaintiffs 21 Youth 8 to 19 years in color.docx | https://data.oregon.gov/views/trwb-z8xe/files/cede36f9-b135-4fef-b47b-d0bac45830b5 |
162 | 1031 | Felecia | feleciaandthedinosaur@gmail.com | Oregon |
I am a resident of the neighborhood impacted by Bullseye's irresponsible
use of uncontrolled heavy metal emissions. I strongly support
the suggestions made by the Eastside Portland Air Coalition.
Upon reviewing the proposed temporary rules, I would like to
add these comments: Nickel needs to be added to the immediate operating restrictions prior to the emission control installation and approval deadline; Chromium III to chromium VI conversion must be tested in worst case conditions; Additionally chromium III should only be allowed to be melted in controlled furnaces; Every controlled furnace used to melt cadmium, arsenic, chromium, or nickel needs to be source tested to demonstrate compliance; Stiff enforceable penalties need to be added for violators of the temporary rules; These proposed regulations need to be extended to other manufacturers, besides colored art glass manufacturing. Thank you for reviewing these comments on the proposed temporary rule. |
||||
163 | 1032 | Nancy | Cann | Nancy@hollanderglass.com | Hollander Glass | Georgia | Hollander Glass is a distributed of art glass. We have over 50 employees and sell art glass to hundreds of glass artists throughout the country. We all make our living selling art glass. Please consider the economic impacts when you write new legislation. | ||
164 | 1033 | Dee | Bunge | info@deefuzion.com | deeFuzion limited Fused Glass - small business | Ohio | Please read my attached letter. Thank you. | Ltr to Oregon DEQ.docx | https://data.oregon.gov/views/trwb-z8xe/files/524f8377-19c0-4ceb-83c2-cc258524bba5 |
165 | 1034 | Christopher | Bacher | christopher.bacher.cfe@gmail.com | Oregon | Please see attached letter for comments. | LTR to EQC Mar 30 2016.pdf | https://data.oregon.gov/views/trwb-z8xe/files/ddde268e-b751-49fa-bf70-6893ea0b6db3 | |
166 | 1035 | Roxanne | Leslie | Roxyandrebel@yahoo.com | OR | What do the employees of precision castparts Corp need to do to have the air inside tested as well. Precisions in house tests do not represent the poor air quality that we breathe every day. | |||
167 | 1036 | Susan | Salisbury | ssalisbury48@gmail.com | SE Portland resident and parent of CHS student | Oregon | Bullseye Glass is soliciting comments to this page from their Facebook page, through a document that is highly prejudicial and critical of the proposed temporary rules. Having profited from a giant loophole in federal standards allowing them to emit high levels of heavy metals into the surrounding area for an indeterminate length of time and only implementing long-overdue safeguards after being exposed by the Portland Mercury and the U.S. Forest Service moss studies, I hardly think that Bullseye Glass is in a position to encourage Portland residents to submit comments critical of long-overdue regulatory protections. We can only hope that the proposed temporary rules and recent attention placed on the State's lack of enforcement capabilities will result in some positive impact on the health and well-being of the community. Thank you for finally paying attention. | ||
168 | 1037 | Mary Ellen | Larkins | melarkins@verizon.net | maryellenlarkins.com | Virginia | What I want for this earth is a safe earth for all. We also learn from our mistakes and if Bullseye or any other manufacturer can improve the working environment, wonderful. I am a glass artist and my income depends on using glass that is made at Bullseye. Please give Bullseye a chance to put in a better filter that could emit cleaner air. My lively hood would be eliminated. My life would be worse without enjoying my form of art and creativity. All ruling should be based on the scientific information and not on politics. By all means, I want all people to live in a better place, to be safe and healthy. Thank you very much. | ||
169 | 1038 | Tim | smith | tsmith@gmail.com | OR |
Please do not follow the request of so many Bullseye supporters
to base your decisions on scientific theories gathered from Facebook
or other social media. I hope you will follow real science (and transparently publish your conclusions) when it comes to evaluating the threat posed by using chromium in an unfiltered kiln. --Tim Smith |
|||
170 | 1039 | Kevin | GUMMER | kevingummer@gmail.com | Concerned Citizen, Taxpayer, Voter, & Father thinking about moving out of Oregon. | OR |
Thank you so much for extending the public comment period for
these rules. Hundreds of Portlanders have contributed to feedback, which will be summed up in a formal comment from the Eastside Portland Air Coalition, co-authored with Mark Riskedahl and Chris Winter. I stand by these recommendations, and look forward to seeing these new, revised rules put into action. Thank you! THANK YOU SO MUCH! Our collective public comment is an attached in a PDF. |
EPAC Comments for DEQ.pdf | https://data.oregon.gov/views/trwb-z8xe/files/dd473dc8-206d-490d-8b09-da56a3aefec9 |
171 | 1040 | Paula | Cisternas | Paula.13.cisternas@gmail.com | OR | As a member of the community here in SE Portland, I am requesting that the DEQ provides stricter regulations with Glass Manufacturers as well as the other companies such as Precision Cast Parts who have been emitting heavy metals and other pollutants into the air. I specifically would like to request for the installation of pollution control devices (i.e. baghouse technology) to limit these emissions. I would also like to request changing the regulations to be focused around the actual measured air emissions of these companies, not just the technology to control these emissions. | |||
172 | 1041 | Leticia | Reed | tishreed58@yahoo.com | Texas |
Please do not do this! I have been a Bullseye Glass Customer for
over 10 years and I have known Bullseye Glass Company to have
a long history of responsible operation. I want you to know that I stand with Bullseye Glass in its efforts to continue operations as a responsible citizen of the social and business community of Portland, Oregon. Regulatory decisions must be based on science, not political issues. A leading scientist, Dr. William LaCourse of Alfred University, has said Bullseye's furnaces do not produce toxic chromium. I urge DEQ to rely on science and fact, and not to rush to impose these poorly written and misdirected rules. These rules will not only adversely affect artists who are dependent on Bullseye for their materials, but their families - since many of them are full time artists. It will also affect the Bullseye employees and their families as I am sure this poorly crafted and thought out regulation will affect production/ I know this commission is trying to do what is best for Portland citizens, but adopting a knee jerk reaction is not the answer. Please, please read the science and listen to the facts and consider what this regulation will mean to the company, its employees, their families and many, many artists who rely on Bullseye. Thank you for your consideration. |
|||
173 | 1042 | Marjorie | MartzEmerson | kaytehunt@gmail.com | Pacific Northwest Pollution Prevention Resource Center | Oregon |
Thank you for the opportunity to review and very briefly comment
on the proposed temporary rule for colored art glass manufacturing
facilities. Background. The release of toxic air pollutants is a widespread issue that has been under-addressed in some states. The National Emissions Standards for Hazardous Pollutants (NESHAPs) primarily address larger (major) sources. But not unlike criteria pollutant programs that simply target major sources, there remains an important gap that fails to protect human health and the environment from the impacts of the myriad of smaller sources. These sources, singularly and collectively, have the potential to adversely affect not only the local community but also more distant locations through environmental transport and deposition of toxic and criteria pollutants. Current Situation. The Oregon Ambient Benchmarks for Air Toxics establish protective goals but it is not clear how and when these goals are translated into meaningful and enforceable protective measures. It is my observation that identification of the two small Colored Art Glass Manufacturing (CAGM) facilities in Portland as sources of heavy metal contaminants in their respective neighborhoods is not a unique situation. Many types of smaller sources of toxic air contaminants from currently unregulated industries, businesses, agricultural operations, and transportation exist that have the potential to adversely impact communities and residents across the state. Having to take each of these on individually is neither efficient nor protective. While many toxics programs focus on immediate needs, the potential for buildup of pollutants, especially heavy metals and other persistent toxics substances, is great both within the facility boundaries and in the surrounding environment. Recommendations. While I wholeheartedly agree with taking short-term temporary measures to protect the CAGM affected neighborhoods, it is my request that DEQ develop and implement a broader program for controlling releases from non-NESHAPs regulated sources of toxic air pollutants. There are a number of really good state programs across the country to draw on and simplify the process. In addition, the great work that has already begun on Ambient Benchmarks provides a good starting point. I, therefore, provisionally support a temporary rule with the caveat that it be tied to a high-priority, broader, definitive, and permanent toxic air pollutant rule for all sources of inorganic and organic airborne contaminants with a real potential to affect human health. Thank you. |
||
174 | 1043 | Marjorie | MartzEmerson | kaytehunt@gmail.com | Pacific Northwest Pollution Prevention Resource Center | Oregon representative |
Thank you for the opportunity to review and very briefly comment
on the proposed temporary rule for colored art glass manufacturing
facilities. Background. The release of toxic air pollutants is a widespread issue that has been under-addressed in some states. The National Emissions Standards for Hazardous Pollutants (NESHAPs) primarily address larger (major) sources. But not unlike criteria pollutant programs that simply target major sources, there remains an important gap that fails to protect human health and the environment from the impacts of the myriad of smaller sources. These sources, singularly and collectively, have the potential to adversely affect not only the local community but also more distant locations through environmental transport and deposition of toxic and criteria pollutants. Current Situation. The Oregon Ambient Benchmarks for Air Toxics establish protective goals but it is not clear how and when these goals are translated into meaningful and enforceable protective measures. It is my observation that identification of the two small Colored Art Glass Manufacturing (CAGM) facilities in Portland as sources of heavy metal contaminants in their respective neighborhoods is not a unique situation. Many types of smaller sources of toxic air contaminants from currently unregulated industries, businesses, agricultural operations, and transportation exist that have the potential to adversely impact communities and residents across the state. Having to take each of these on individually is neither efficient nor protective. While many toxics programs focus on immediate needs, the potential for buildup of pollutants, especially heavy metals and other persistent toxics substances, is great both within the facility boundaries and in the surrounding environment. Recommendations. While I wholeheartedly agree with taking short-term temporary measures to protect the CAGM affected neighborhoods, it is my request that DEQ develop and implement a broader program for controlling releases from non-NESHAPs regulated sources of toxic air pollutants. There are a number of really good state programs across the country to draw on and simplify the process. In addition, the great work that has already begun on Ambient Benchmarks provides a good starting point. I, therefore, provisionally support a temporary rule with the caveat that it be tied to a high-priority, broader, definitive, and permanent toxic air pollutant rule for all sources of inorganic and organic airborne contaminants with a real potential to affect human health. Thank you. |
||
175 | 1044 | Scott | Messick | scott.messick59@gmail.com | NM | Given that both OH/ and the County have said there is no risk, I would suggest you suspend these temporary rules until a more thorough, studied approach can be undertaken. | |||
176 | 1045 | Carolyn | Stuart | touchmonk@yahoo.com | OR | Ban their use of toxic chemicals until they've come up with a safe alternative to poisoning us. | |||
177 | 1046 | William | Crawford | williamecrawford@hotmail.com | EPAC | OR |
The proposed rules should apply to all small industries, not just
manufacturers of art glass. Any industry emitting toxic materials
should be regulated by these temporary rules. Metals such as
cadmium and arsenic are equally damaging to health if they are
emitted from a glass maker or from a metal plating shop. The
Forest Service's moss data tells us there are many more uncontrolled
emission sources than there are glass factories, and we feel
all should be covered by the emergency rules. Temporary rules should include both filtration and monitoring – In addition to installing state-of-the-art emission control equipment, there is a need to continuously monitor what is being emitted into the air by these facilities. The cost of monitoring should be considered just another cost of using hazardous materials in an urban setting. The threshold for being covered by these rules should be lowered – The proposed rules only cover facilities using more than 10 tons of raw materials per year, not including recycled glass or cullet. This threshold is far too high, and that the minimum-size facility these rules would apply to should be much smaller. It is unlikely that a hobby glass maker would process even a single ton of material in a year. Recycled cullet should be considered a raw material for the purposes of this rule, to avoid creating an artificially distinction between facilities using recycled glass and those starting from raw materials. All furnaces in facilities processing hazardous materials should be controlled – The proposed rules cover only a small subset of materials of concern, and if a facility has both controlled and uncontrolled furnaces, the potential exists for an operator to, intentionally or not, melt toxic materials in an uncontrolled furnace. Filtering all furnaces would alleviate that doubt. Unmade decisions should default to No – When DEQ receives a notice of intent to construct/modify/change an emission control system, the proposed rules state that by doing nothing, the application will be deemed approved. Instead, if no decision is rendered, the application should be deemed denied. Approval should require an affirmative action by DEQ. Penalties for evading these regulations should be made more severe – Intentionally evading these or other environmental rules should carry a more severe penalty, and should include a private right to action to allow those harmed by such evasion to allow enforcement when DEQ does not act. |
||
178 | 1047 | Chris | Petrauskas | cpetrauskas@mac.com | OR |
Please do not enact the temporary rule. I am a fifteen-year employee of Bullseye Glass. That whole time I have lived in Sellwood-Moreland and walked or biked daily to work. Produce from our garden and fresh eggs from our hens has been a daily part of life all along. Many of my close friends and family members, including numerous children, live near our factory. I have no hesitations in helping them to understand that we are unequivocally not in the midst of a toxic crisis. I am profoundly in support of strong environmental standards. However, the only way those goals can be accomplished is to have legislators work carefully hand-in-hand with evidence-driven science. What we have seen from our regional leadership in these past weeks has fallen tragically short of that. It is a heartbreaking disconnect I witness between the long-time, community-centered, and ecology-conscious company I work for and the environment of fear driven by opportunistic media sensationalism. We, the public, have every right to expect even handed reportage and guidance from our local news organizations and governing bodies but these institutions have failed us. The DEQ now has this opportunity to step-up and provide strong leadership set atop a foundation of rigorous science. To do anything less stands to destroy a world-renowned beacon of American arts and manufacturing while doing nothing to deliver a safer Portland environment. Please do not enact the temporary rule. |
|||
179 | 1048 | Rich | Richards | richrich@mailismagic.com | Oregon | This is a meta-comment for the reviewers who have to sift through all this dreck: Do you find it ironic that many of the out-of-state commenters are asking you to allow something in Oregon that would be illegal in their home jurisdictions? (i.e. allow the use of Cr and other heavy metals in an uncontrolled furnace) | |||
180 | 1049 | Christina | Wolfe | cnochisaki@gmail.com | EPAC | OR | Hey, how about we don't let out of state glassies --who don't do their breathing here-- make the rules for how we should have our air. | ||
181 | 1050 | Bobbi | Vischi | Bbvischi@comcast.net | Bobbi Vischi Art Glass Studio | Colorado | I am very concerned the way the Oregon DEQ is handling their concerns about Bullseye Glass Manufacturing. As a professional glass artist, making my living from my art business, it seems that shutting down Bullseye production 'temporarily' is much too drastic a move, especially since scientists have determined that the amount of chemicals found are not dangerous to humans or plant life. I urge you to consider the thousands of artists (internationally) whose livelihood will be threatened by your hasty, premature move. Please look at the due diligence Bullseye is doing (and has always done the past 23 years that I've been using their product) to help solve the problem in Portland. Your should be proud to have such a professional organization in Oregon. | ||
182 | 1051 | hazel | Love | Gmoo503@yahoo.com | n/a | OR | Clean air is essential for quality life. Oregon can be a leader for our country. | ||
183 | 1052 | Vincent | Miller | vmillermail@gmail.com | Oregon | Please help ensure that Portland has safe levels of hazardous air pollutants and that our safety is sustained for years to come! Please do this ASAP!!! | |||
184 | 1053 | Rob | Markle | rmarke0577@msn.com | Oregon |
I support the immediate adoption of the proposed emergency rule. I live with my wife and two young children approximately 1,300 feet from Bullseye Glass and support emergency rules to control heavy metal emissions in our community and elsewhere. Unregulated sources of these contaminants need to be controlled and any associated costs need to be internalized by the companies as part of their production costs. It is not appropriate to allow these production costs to be exported to the citizens in the surrounding communities. The proposed rules appear reasonable given what we know and don't know about these sources of metal contaminants. In my mind, if you're emitting toxins, controls are warranted. Where an information gap exists (e.g., hexavalent chromium) the prudent approach is one of caution. Therefore, the burden of proof that the trivalent chromium use is not harmful falls on those proposing to use the material. OHA has stated they believe that metal concentrations in area soils and air samples do not pose a short-term risk to community health. However, long-term health risks remain poorly understood beyond the fact that unregulated emissions of heavy metals are a couple orders of magnitude above the established benchmark values and that those risks are additive for each metal. Community residents have already been unwittingly exposed to these contaminants for years. We prefer not to be guinea pigs while OHA determines whether continued exposure should be cause for concern. Consequently, as a starting point, I encourage the immediate adoption of the proposed emergency rule. |
|||
185 | 1054 | Peter | ruplinger | abacjrj50@yahoo.com | Ruplinger Stained Glass | Utah |
This is the United States of America. Not Lenin's Communist Russia. Quit harassing small business. |
||
186 | 1055 | Peter | ruplinger | abacjrj50@yahoo.com | Ruplinger Stained Glass | Utah |
This is the United States of America. Not Lenin's Communist Russia. Quit harassing small business. |
||
187 | 1056 | anne | Sobbota | Artist/Business Owner | Oregon |
While Oregonians are remarkably forward thinking about health
and protecting the environment, we also live in an historic period
that increasingly demonstrates the many ways people rush to extremes
of thought and are motivated to action by fear and media generated
publicity. Extremes of regulation and deregulation have both
been thrust upon businesses and the public for at least the last
three decades in this country; the results are often contradictory
and counterproductive to economic stability and to the "healthy"
end desired by all. After reading the available online documentation, concerning the issues facing Portland and the glass manufacturing community, from both the DEQ and Bullseye Glass, it is not difficult to draw a conclusion that the temporary regulations being suggested are not conclusively warranted and that perhaps a longer, broader, and more in depth approach needs to be considered, before irreversible economic damage is unleashed upon the companies involved and, indeed, on the very wide community of artists and retailers they serve nationally and internationally. |
Glass regulation letter.docx | https://data.oregon.gov/views/trwb-z8xe/files/4e22cc12-227a-4dc8-b0d2-646106863209 | |
188 | 1057 | Darrell | Doke | Darrellportland@gmail.com | Sheet metal workers local 16 | OR | We need air regulation AND enforcement. No one should be breathing poisonous air, especially not children and the elderly. The fact that this happened in today's age is incomprehensible . For the population of our city, this needs to be corrected. | ||
189 | 1058 | Barb | Beckman | barb@barbbeckmanartglass.com | Barb Beckman Art Glass | Illinois |
Bullseye glass has a long history of responsible operation as
evidenced by their recent voluntary suspension of production
of colored glass containing chromium or cadmium in order to evaluate
more safe and thorough ways of dealing with emissions of these
chemicals during the production of this glass. I support Bullseye
Glass in its efforts to continue operations as a responsible
business in the community of Portland, Oregon. Dr. William LaCourse of Alfred University, a leading scientist with over four decades of experience in glass production methods, has said that not only do Bullseye Glass's furnaces NOT produce the more toxic chromium VI, if they did, the colors would change during the production and would not match the colors of the glass that Bullseye was producing. I respectfully request that the DEQ modify their proposal and use more fact-based scientific evidence in the decision-making process and not rush to impose these more poorly written and misdirected rules. Rather than making sweeping judgements and regulations curtailing the production of colored glass for six months, logic indicated more testing to occur immediately after the installation of the 99% effective baghouses on Bullseye's furnaces, this bringing back production of these glasses sooner. By limiting production of the colored glasses for six months, which could conceivably cause the closure of Bullseye, the DEQ will be impacting many families' livelihoods in the Portland area who work at Bullseye as well as others from around the country and around the world, as these limitation will also affect how glass artists are able to make a living when our raw materials are no longer available to us. Please keep in mind that the larger glass factories that produce the green glass used in wine/beer bottles and have been subject to stricter regulations for years (due to the quantities of glass produced), are still producing greater quantities of chrome emissions than were being produced at Bullseye and Uroboros without baghouses on their furnaces. Again, I urge a more thoughtful look, scientifically-based, on all the factors contributing to Portland's air quality issues including all types of pollution and all the businesses that contribute. Any new regulations should be well thought out and should cover all businesses in order to support the safety of the community instead of targeting minor specific industries with hasty, temporary rules which are not supported by scientific facts. If the EQC were to implement this temporary rule, numerous, significant sources of air pollution would remain from many unregulated businesses. Thus, the temporary rule would not effectively protect the public. |
||
190 | 1059 | Bob | Nemhauser | accounting@taglass.com | Trautman Art Glass, Inc. | Oregon | Comments on Temporary Art Glass Manufacturer Rulemaking Proposal attached in detailed letter. | 2016 03-28 March 28 Comment letter final G.docx | https://data.oregon.gov/views/trwb-z8xe/files/d981aa78-115f-41cf-a97c-ee3f517a6858 |
191 | 1060 | Diana | Morrison | dinym8@yahoo.com | TX |
To The Oregon Department of Environmental Quality (DEQ): I am writing in regards to the proposed temporary regulations that the DEQ is planning to impose on small glass companies. I am not from the Portland area, but I am a kilnformed glass instructor in the Dallas area. And being and instructor, the livelihood of Bullseye is my livelihood as well. This is how I make my living! It impacts me, even in the here and now as the glass prices have suddenly shot up to outrageous prices! Both myself and my students use fused glass products from Bullseye and deeply hope that we can continue to do so. I would hope that you have substantiated scientific evidence that Bullseye and other companies have in fact contributed to the Portland area's air quality. I understand that you are concerned that they may be a contributor to the pollutants, but it is my understanding that The Oregon Health Authority (OHA) and the Multnomah County Health Department have stated that there is no immediate health risk to the community. In regards to the chromium III that Bullseye uses and the techniques that they use, that there is little possibility that it can be converted It seems that the DEQ is taking a knee-jerk reaction by creating these temporary rules that aren't necessary in the absence of acute health risks. It seems that Bullseye is moving to correct the issues that may be there to supports new regulations to improve air quality, but the temporary rules will not achieve that goal It would seem that you need to take a little time and give these companies time to make the necessary changes. Also please keep in mind that the Bullseye Company has been and want to always be an active party of the community that they too live and work in. I know this due to the visits I have made to Portland for training. The city of Portland has beautiful glass everywhere due to these glass companies and have worked with many of the city offices to support the beauty of Portland. It would be a shame if the DEQ takes immediate action on these companies without giving them an opportunity to make the necessary changes, if they need to at all, since it is my understanding that the government neglected to test these small companies for years. Test them, let them make the necessary changes if needed. Give them a deadline for compliancy. But don't make rules without the facts. Sincerely, Diana Morrison |
|||
192 | 1061 | Alexandria | Schultz | As.a.writer@gmail.com | Oregon |
Thank you so much for extending the public comment period for
these rules. Hundreds of Portlanders have contributed to feedback, which will be summed up in a formal comment from the Eastside Portland Air Coalition, co-authored with Mark Riskedahl and Chris Winter. I stand by these recommendations, and look forward to seeing these new, revised rules put into action. Thank you! |
|||
193 | 1062 | Mike | Freese | mikefreese@aoi.org | Associated Oregon Industries | Oregon |
Please find attached AOI's Comment Letter. Thank you. |
||
194 | 1063 | Anthony | Onorati | aonorati@mac.com | Onorati Design, Inc. | Oregon |
Bullseye glass has a long history of responsible operation. I
stand with Bullseye Glass in its efforts to continue operations
as a responsible citizen of the social and business community
of Portland, Oregon. Regulatory decisions must be based on science, not political issues. A leading scientist, Dr. William LaCourse of Alfred University, has said Bullseye's furnaces do not produce toxic chromium. We urge DEQ to rely on science and fact, and not to rush to impose these poorly written and misdirected rules. |
||
195 | 1064 | shane | mccoy | shanemccoypdx@gmail.com | OR | Please do something to help regulate these emissions. clean air! | |||
196 | 1065 | Mike | Freese | Associated Oregon Industries | Oregon |
March 30, 2016 Ms. Jane O'Keeffe; Commission Chair Environmental Quality Commission Oregon Department of Environmental Quality 811 SW 6th Avenue Portland, OR 97204 Submitted via Online Subject: AOI Comments on the Proposed Temporary Rules Limiting Metals Emissions from Small Colored Art Glass Manufacturers Dear Chair O'Keeffe: Thank you for the opportunity for Associated Oregon Industries to comment on the proposed temporary rules limiting metals emissions from small colored art glass manufacturers.  Associated Oregon Industries (AOI) is Oregon's largest, statewide, comprehensive business association with more than 1,500 member companies employing 200,000 Oregonians. AOI also represents Oregon's largest group of manufacturers and is the state affiliate of the National Association of Manufacturers. Manufacturing represents nearly 30% of Oregon's GDP and is a critical sector for Oregon's economy. AOI has a long history of working with the Department of Environmental Quality (DEQ), the Environmental Quality Commission (EQC), and other interest groups to address Portland's air toxics concerns and is commenting in light of the regulatory history of the issue before you. As a threshold matter, however, it is important to note that we do not represent any business that is directly targeted by this rulemaking. However, the precedent of avoiding existing regulatory processes, writing detailed rules without adequate scientific information, and confidence in Oregon's regulatory response in this case is concerning to many Oregon manufacturers. We hope to help both the DEQ and EQC with those concerns. AOI opposes the proposed temporary rules because DEQ already has an agreed upon process to address these emissions sources. While AOI appreciates and sympathizes with the human health concerns around the recent developments regarding the potential identification of cadmium and arsenic emission levels from small colored art glass manufacturers, we strongly believe DEQ has an adequate, agreed upon approach to address those concerns without this temporary rule. For instance, there is a process in OAR 340 Division 246 that could have been used to address the issue. The Source Category rules [OAR 340-246-0110] were developed specifically for this situation. The source category to be addressed is Colored Art Glass Manufacturing using batch furnaces. Alternatively, the air toxics safety net program could also address these individual source concerns [OAR 340-246-190]. DEQ should not abandon the Oregon Air Toxics regulations but instead investigate and implement changes within the current rule structure. The same rule structure that industry, DEQ, and environmental groups agreed on. In addition, AOI is troubled that DEQ has not demonstrated the requisite data, evidence or otherwise thorough information necessary to set detailed operating restrictions on emissions from the identified source(s) [proposed rule 340-244-9040]. For example, DEQ has failed to scientifically, with confidence, link the use of chromium III to hexavalent chromium emissions at these sources. As a result, the chromium limits in the proposed rule are too prescriptive given the lack of scientific information to support the requirements. For that reason, the EQC should not adopt the temporary rule because DEQ has not demonstrated that it has adequate science and information on emissions from the source category to write the rule. The rule, as written, is premature and not adequately supported by science. Lastly, AOI is concerned with the precedent this temporary rule could set for future rulemakings and DEQ's intent to abandon current air quality regulations – regulations that our members have invested in and rely on. As previously stated, DEQ has a process in place for regulating these sources. A new, temporary rule of this magnitude is unnecessary. Instead, these individual sources should be subject to the familiar, agreed upon process currently in place. If you have any questions or concerns, please do not hesitate to contact me. Thank you for your time and consideration. Sincerely, Mike Freese Vice President Associated Oregon Industries |
Jane_O'Keeffe_EQC_Proposed_Metals_Rules_3-30-16.pdf | https://data.oregon.gov/views/trwb-z8xe/files/8ab30733-562d-45a3-bc81-1ba1dc26d99f | |
197 | 1066 | Cindy | Young | rocknrollschool@msn.com | EPAC | OR | I stand with EPAC! | ||
198 | 1067 | Cynthia | Gallagher | Cynthia.gallagher@live.com | Maryland | Bullseye Glass has been a responsible business and abides by rules and safety regulations. Please use scientific measures as proof of their safe manufacturing techniques. This is an important US glass manufacturer and they should stay in business . | |||
199 | 1068 | Bob | Jones | robertsenoj@gmail.com | Individual | Florida |
This should be a win, win situation. Government regulators and
the small glass manufacturers are on the same page. The environmental
regulators need to respond to a public concern, and the manufacturers
want to adjust their operations accordingly to keep operating
and stay in business. No one wants to shut down high quality
American manufacturing and everyone wants a healthy environment.
Win Win. thank you. -Bob Jones |
||
200 | 1069 | Bethany | Ostrowski | bethanyrowen@yahoo.com | Colorado | While there is an apparent need to investigate the environmental impact of metals emissions in this area, it appears that you are using these glass manufacturers as a scapegoat. There has been ample evidence that they are not the source of the problems. By instilling this temporary ruling, you are threatening their and countless others livelihood. Develop rules and regulations that protect us all, without putting these small manufacturers out of business while you figure out that they are indeed, not the problem. |
201 | 1070 | Harth | Huffman | harth1@yahoo.com | Oregon | Please pass the rules to protect the quality of our air. Air quality and health are issues that affect all of us, often in ways we do not understand. I understand that implementation of some of these rules may be a financial burden to small business. However, as members of the community, they must take on the responsibility to keep our air as clean as possible. It should be an non-debatable and accepted cost of doing business in their chosen field. Thank you for creating these rules and allowing a comment period. | |||
---|---|---|---|---|---|---|---|---|---|
202 | 1071 | Jennifer | Jones | foerjones@gmail.com | Eastside Portland Air Coalition | Oregon | EPACTempRulesComment.pdf | https://data.oregon.gov/views/trwb-z8xe/files/c5a18fb9-36a6-47a5-b1ef-7192e4ea9af1 | |
203 | 1072 | Robert | Pike | rob.pike42@gmail.com | BC |
I believe that it is a mistake...and possibly illegal to take
action without gathering evidence by an impartial third party.
What happened to "innocent until proven guilty"? Rob Pike |
|||
204 | 1073 | Kevin | Midgley | kevin@tofinoartglass.com | Tofino Art Glass | British Columbia | These newly proposed regulations are based on politics and fear, not science and fact. | ||
205 | 1074 | Mark | Colman | colmanphoto@yahoo.com | OR |
I have numerous concerns over these apparently hastily drafted
rules. I stand with EPAQ. * The wording in the temporary rule seems vague using terms like "will probably install"; and "DEQ and OHA believe to be safe for the public." * There appears to be no enforceable penalty provision. There needs to be specific quantifiable penalties for breaking the rules. This is important because you can make all the rules you want and if there are no penalties, basically no one cares. * Are glassmakers getting the summer off, since no permits would be required until Sept 2016? The requirement should be effective immediately, with a 30-day or similar grace period. * There should be a provision for similar emitters no matter what product they are producing. No loopholes. * The DEQ may be willing to fix one of their mistakes from 2007 loopholes for Bullseye, but if they cannot do so with a transparent process that centers on the communities most at risk and provide them with a seat at the table that allows them to protect their own health, then no one can honestly say that their culture has changed. * We are also concerned that this temporary rule only covers art glass manufactures and not other major polluters in the Portland Metro area. * Also, the rules are so inconsistent when identifying which material is toxic. In one place they mention that the EPA lists 188 HAPs, then they're only concerned about their fave 3, then it's also nickel. There isn't any logic. * How are "fugitive emissions" emissions that don't go up the stack but into the room or open air when doors are open, being monitored and filtered? * How are gaseous emissions being monitored and remediated, such as fluorine? A filter most likely would not capture this. * City of Portland and Multnomah County adopted the precautionary principle in 2004/2006. |
|||
206 | 1075 | stephanie | Gaslin | stephiedg@gmail.com | Portland Resident, PPS parent, Third Rail Repertory Theatre Company Member | Oregon |
Thank you so much for extending the public comment period for
these rules. Hundreds of Portlanders have contributed to feedback, which will be summed up in a formal comment from the Eastside Portland Air Coalition, co-authored with Mark Riskedahl and Chris Winter. I stand by these recommendations, and look forward to seeing these new, revised rules put into action. Thank you! |
EPAC Comments for DEQ (1).pdf | https://data.oregon.gov/views/trwb-z8xe/files/fd11be43-f562-42b7-9742-e70c4aef3e1e |
207 | 1076 | Tami | Covey | tcovey.cst@gmail.com | Texas |
During the last 15 years my family has supported Bullseye through
the purchase of glass. A few years ago, my mother retired in
hopes to develop our family's glass business further. My father
and I both continue to work full time jobs, while helping to
supporting my grandparents and my daughter. But in addition
to our family, we have many people within our community that
have come to know our name and depend on our products. In addition,
recently, we had started teaching an occasional class when the
issues between the DEQ and the glass manufactures began. At this time, we are very concerned about our continued livelihoods within the glass industry, the new costs that will be associated with glass due to long term decreased productions, DEQ environmental protection requirements that may be unnecessary for small business/small glass manufactures, and in general overall public fear that has been placed that we feel can and has hurt not only the glass manufactures but glass artists as well. Media perception has done a job even halfway across the country. It is our hope, that the DEQ can resolve and expedite an action which is non-controversial for both Bullseye and Portland residents, that will minimize the overall cost and public scrutiny. Thank you for your time, Tami Covey |
|||
208 | 1077 | Matthew | Sunderland | msunder89@yahoo.com | Oregon |
Thank you so much for extending the public comment period for
these rules. Hundreds of Portlanders have contributed to feedback, which will be summed up in a formal comment from the Eastside Portland Air Coalition, co-authored with Mark Riskedahl and Chris Winter. I stand by these recommendations, and look forward to seeing these new, revised rules put into action. Thank you! |
|||
209 | 1078 | Frederic | Fravel | ffravel@aol.com | none | Maryland | Your analysis of impacted parties appears not to include the many users of art glass across the country who will be affected if the proposed temporary rules cause the affected firms to drastically reduce or limit output or go out of business entirely. Given that the DEQ does not know the relationship between the amount of Chromium III used and the toxic Chromium IV that may be produced, and that the determination that there is a problem is based on an analysis of moss for which there is no history or standard, it seems hasty and ill-advised to impose an immediate restriction that carries the risk of destroying a noted local industry, when there is no evidence of an immediate threat to public health. Work with the firms to determine what the real health issue is, and what is needed to address it, then issue a notice of proposed rulemaking, take comment, and then impose needed rules. | ||
210 | 1079 | Kammy | Kern-Korot | kammymatt@aol.com | NA | Oregon | I am writing to encourage DEQ to adopt stronger temporary rules that protect public health first and foremost and ensure participation by affected communities in rule-making. The emissions thresholds for colored glass and all other small or large manufacturers in Portland and the state should not exceed DEQ's established ambient benchmarks, including that for chomium 6. Impacts to soil should also be considered. DEQ's emissions rules should apply to all facilities regardless of size and location and should allow for investigation, discovery and regulation by DEQ of ALL identified and yet identified arsenic and other toxic metal pollution sources throughout the city, including SE, N and NE Portland. Thank you for the opportunity to comment. | ||
211 | 1080 | Christopher | Lowe | clowe@igc.org | Oregon | Thank you for taking these comments. I am attaching a letter that explains why I think the proposed regulations are not adequate, because they fail to use health and risk based standards, fail to use already established Oregon benchmarks, are too narrow in their geographical scope and scope of pollutants regulated, and fail to provide adequate public transparency in the permitting process. | DEQ toxics emissions comments Lowe.docx | https://data.oregon.gov/views/trwb-z8xe/files/df84f567-a82f-4669-8817-8069f6a7834e | |
212 | 1081 | Sarah | Livingstone | sarahlivingstone@me.com | EPAC & Neighbors for Clean Air | Oregon |
We live 5 blocks from Bullseye Glass and have been very sick.
Please make clean air and public health your top priority and
not getting toxic businesses back up and running. Thank you, Sarah Livingstone Mother, Resident, Environmentalist |
||
213 | 1082 | Michael | wietecki | mjwietecki@gmail.com | OR | Thank you for the opportunity to comment, please see the attached letter. | Comments to Proposed rule.pdf | https://data.oregon.gov/views/trwb-z8xe/files/ae68f17b-2953-4d54-95bb-01e949b36e73 | |
214 | 1083 | Christopher | Lowe | clowe@igc.org | Portland, Oregon | Please see attached letter, which comments that the proposed rules are inadequate for not using health and risk based standards, for failure to employ existing Oregon benchmarks, for not being statewide, for not covering all toxic emissions, and for not providing adequate public transparency. | DEQ toxics emissions comments Lowe.docx | https://data.oregon.gov/views/trwb-z8xe/files/c9bac078-efa5-4df0-9b2a-9e7fc197531a | |
215 | 1084 | Sarah | Livingstone | sarahlivingstone@me.com | EPAC & Neighbors for Clean Air | Oregon | We live 5 blocks from Bullseye Glass and have been very sick. Please make clean air and public health your top priority before polluter profits. Thank you. | ||
216 | 1085 | Claudia | Lipschultz | lipschuc@gmail.com | (glass artist) | Maryland |
I have worked in various glass mediums and techniques for almost
forty years and have recently retired from a career as a research
biologist. I am very safety aware and chemistry aware. I do not support the proposed temporary rules because of their many adverse impacts. Bullseye glass has a long history of responsible operation. I stand with Bullseye Glass as well as Uroboros Glass in their efforts to continue operations as responsible citizens of the social and business community of Portland, Oregon. Regulatory decisions must be based on science, not political issues. A leading scientist, Dr. William LaCourse of Alfred University, has said Bullseye's furnaces do not produce toxic chromium. We urge DEQ to rely on science and fact, and not to rush to impose these poorly written and misdirected rules. I am very alarmed at ignorance-based legal action, however well-meaning or attempting to address an important issue. Years ago I heard a safety symposium at the Glass Art Society at a conference in Seattle where the representative from King County told the uncomfortable audience that it WAS NOT their intention to close down artists, studios, and sources of materials. BUT RATHER help find good ways to work more safely so we all have longer, healthy, productive lives. Please make those considerations your mandate as well. I am concerned that the proposed temporary rules are more adversarial than helpful. Thank you. |
||
217 | 1086 | Linda | Tesluk | lindatesluk@hotmail.com | Glass artist | Ontario, Canada | As a glass artist in Canada and one of many who rely on the art glass made in the U.S. and in particularly Bullseye, I am very concerned with your temporary rule making. Until absolute scientific facts are produced no government should be able to enforce any restrictions on business! Time must be allowed for all facts and testing to be submitted before any restrictions given. You are not just putting Bullseye employees and business at risk but also my work at risk if I am unable to get glass. Enough of the political posturing!! You are not being fair to anyone including me! | ||
218 | 1087 | Tom | Warren | trw204@gmail.com | self-employed artist | Oregon |
I read the DEQ proposed rules and I have some general comments.
I'm a Portland artist, working with different materials including
fused glass manufactured by Bullseye and Uroboros. As an artist,
I am very disappointed with the response from many glass artists
outside of Portland. Their attacks on the integrity of community
members who are concerned with air pollution are despicable.
I urge the DEQ and the EQC to pay close attention to the input
from local citizens concerned with hazardous pollutants in their
neighborhood. The EQC and the DEQ have an opportunity right now to improve the lives of Oregonians, especially those who live in close proximity to glass production facilities. You can right the wrong that was inflicted on some Portland residents when art glass factories chose to operate without considering the safety of their surroundings. DEQ and EQC should prioritize actions that clean and preserve the environment and promote public health. These are vital to the community we live in and, without this priority, Portland will become an industrial ghost town. A friend of mine who moved to Portland from New Jersey, told me once that New Jersey has better environmental regulations and enforcement than Oregon. This could only happen because industrial profits were prioritized over pollution control. It is unacceptable that New Jersey has better environmental quality control than Oregon. I support EPAC and Neighbors for Clean Air. I agree with EPAC and NCA's proposals regarding the DEQ temporary rules. If art glass production is to continue and thrive in Portland, it must be done safely, in controlled furnaces. We are doing this for the health of our children and our neighborhoods. Thank you, Tom Warren |
||
219 | 1088 | Amy | Bacher | amybacher@hotmail.com | Oregon |
Thank you for allowing time for public feedback and for taking
the time to read these comments. My son attends preschool at CCLC, just around the corner from Bullseye. The health and safety of my son, his classmates and his teachers are reliant on good decisions by the EQC. While I do not want to see Bullseye shut down, I do want the company to be held accountable via the emergency rules and held to their commitment to do right by their neighbors. I hope that in reading the comments provided, EQC will focus on the local and informed commentary, prioritize the impact to public health and remember that, no matter how many times it has been misstated in the threads, facts and science do exist in this realm. There are four indisputable and important facts: 1. DEQ found the levels of toxics in our air were dangerously high. DEQs Ambient Bench Mark Concentrations (ABCs) for cadmium are .6 nanograms per cubic meter (ng/m3) of air and .2 ng/m3 for arsenic. A DEQ Air Quality Data Sheet shows that last October, the monitoring station across the street from Bullseye recorded daily cadmium levels of 132 – 195 ng/m3. That's more than 200 times DEQs safe air goal. Nearly one third of the days tested in October showed arsenic levels at more than 60 ng/m3, one day topping a whopping 101.1 ng/m3. 2. Ceasing usage of the toxics has been effective. Bullseye ceased usage of cadmium, chromium and arsenic in February. Recent data shows the company's cooperation in stopping usage of these toxics improved matters: Arsenic, cadmium and chromium levels from March 1 to March 8 were below 1 ng/m3. OHA and DEQ have stated there is no current health risk to the community with these new numbers. 3. The negative impact of the toxics mentioned above is considerable. The EPA notes that: ,A single acute exposure to high levels of cadmium can result in long-lasting impairment of lung function. We know that these toxics cause cancer, birth defects and breathing issues. We know with certainty that these toxics are bad when inhaled. 4. Filtration devices could help block 99% of the toxics from the air. Knowing those facts, why would we not act accordingly? It would be irresponsible not to. Protecting the public is a proper use temporary rulemaking and is absolutely necessary here to keep all parties accountable. Regarding the specific rules, I stand with EPAC and the feedback from CRAG Law Center. Please adopt the emergency rules, but make sure that the usage of these toxics is not continued until filtration devices are installed. Thank you again for your time. |
|||
220 | 1089 | Jessica | Applegate | applegatebrown@msn.com | Eastside Portland Air Coalition | Oregon | This is submitted on behalf of the over 3,268 members of Eastside Portland Air Coalition and the Hayden Island Hi Nooners Air Group. | EPACTempRulesComment.pdf | https://data.oregon.gov/views/trwb-z8xe/files/7c53535a-37f8-488d-b4c7-04ea68765ba6 |
221 | 1090 | Jennifer | wietecki | jhwietecki@icloud.com | NA | OR - Oregon | I am attaching a letter that provides my comments to the proposed emergency rule. | ||
222 | 1091 | Emily | Blum | emilydblum@gmail.com | Oregon Health & Science University | Oregon |
I stand with EPAC. Please impose immediate permit requirements to regulate emissions to cover not only art glass manufactures, but other polluters in the Portland Metro area and state-wide. Please protect your community. Please add an enforceable penalty provision to force compliance. Provide decisive identifying values for toxic levels. |
||
223 | 1092 | Mike | Conway | michaelconway41688@yahoo.com | voice of the oppressed | Oregon | please act soon. Peoples lives are at risk. children are at risk as well. put people before profits. clean our air! | ||
224 | 1093 | Patricia | Osborne | posborne33@gmail.com | Oregon | I stand with EPAC. | |||
225 | 1094 | Chantal | DeGroat | Mychantal@gmail.com | Third Rail Repertory Theater | Oregon |
Thank you so much for extending the public comment period for
these rules. Hundreds of Portlanders have contributed to feedback, which will be summed up in a formal comment from the Eastside Portland Air Coalition, co-authored with Mark Riskedahl and Chris Winter. I stand by these recommendations, and look forward to seeing these new, revised rules put into action. Thank you! |
||
226 | 1095 | Holly | Nichols | hollydnichols@outlook.com | Oregon | When I moved to Portland in 2014, I carefully considered my choices in locations for my family to live. We wanted to avoid areas with with crime, child molesters, and diesel pollution from the highways. I failed to catch Precision Castparts, just over the county line in Clackamas County. I now feel like I have failed to protect my children from disease and diminished quality of life due to the pollution spewing virtually unchecked from this billion dollar, multinational corporation. What's worse is that I feel like this pollution hotspot is being ignore by the public, the media, and by legislators because people are afraid to make waves when it comes to such an important source of employment and revenue in this city. PCC refuses to entertain comment from the public, demanding that we, the public, be barred from meetings. The city of Portland bows to their whims and allows them to make their own rules. I called the EPA and was told that there were unused monitors that were not being deployed to our location, and they couldn't explain why. This lower middle class neighborhood is being ignored in the name of corporate greed. Please provide monitoring for the Brentwood-Darlington neighborhood immediately. Please reconsider the current laws about air pollution and make sure you are putting the health of the citizens above the bottom line of a corporation. | |||
227 | 1096 | Lynn | Graham | lpsg339@aol.com | The Glass Canyon | California |
Bullseye glass has a long history of responsible operation. I
stand with Bullseye Glass in its efforts to continue operations
as a responsible citizen of the social and business community
of Portland, Oregon. Regulatory decisions must be based on science, not political issues. A leading scientist, Dr. William LaCourse of Alfred University, has said Bullseye's furnaces do not produce toxic chromium. We urge DEQ to rely on science and fact, and not to rush to impose these poorly written and misdirected rules. |
||
228 | 1097 | Christy | Splitt | christy@olcv.org | Oregon League of Conservation Voters | Oregon | The Oregon League of Conservation Voters would like to join and echo the attached comments already provided by CRAG Law Center on behalf of the CRAG Law Center, Northwest Environmental Defense Center, Neighbors for Clean Air, OPAL Environmental Justice, Eastside Portland Air Coalition, Coalition for Communities of Color, Oregon Environmental Council, Oregon Physicians for Social Responsibility, Verde, Beyond Toxics, and the African American Leadership Forum. Thank you. | 3-30-16 - Final Group Comments on Temporary Rule.pdf | https://data.oregon.gov/views/trwb-z8xe/files/a618a2ca-43e9-41c2-8987-59e3a3b0a445 |
229 | 1098 | Graham | Fox | Princelyfox@gmail.com | OH | Please keep making beautiful American opalescent glass. | |||
230 | 1099 | Leo | Bach | tbach.tbach@comcast.net | Taxpayer | Oregon |
As an amateur glass artist living in the Portland area, I have
ready access to some of the finest glass product available in
the world from Bullseye and Uroboros. Over the past couple of
months, I have become very weary of hyper-reactive media coverage
about the dangers of emissions from glass production at both
companies. I stand behind Bullseye, who has followed state DEQ standards in the past and is currently making whatever changes are necessary to conform to new air quality standards. These new regulatory decisions must be based upon science, not political issues. A leading scientist, Dr. LaCourse, has said Bullseye's furnaces do not produce toxic chromium, so I urge DEQ to rely on science and fact, and not to impose poorly written and misdirected rules, even if they are meant to be temporary. From what I see, Bullseye has been forthright in its efforts to solve the emission complaints, by suspending use of Arsenic, Cadmium and Chromium until they have installed and tested a filter system. Imposing impractical, hyper-reactive rules at this time would seem to me to be in poor faith. Please rely on science and fact ; not political issues. Ted Bach Hillsboro, OR tbach.tbach@comcast.net |
||
231 | 1100 | Donald | OR |
This is not a public emergency, soil test, urine test, and air
test are in the green. Take the time and make this fair. Look
at Portland as a whole and do not pick out a single industry.
These rules are poorly written and seem to discriminate against one small industry while other larger polluters continue to operate without bag houses. Do not persecute with no scientific evidence. |
|||||
232 | 1101 | Leo | Bach | tbach.tbach@comcast.net | Taxpayer | Oregon |
As an amateur glass artist living in the Portland area, I have
ready access to some of the finest glass product available in
the world ; from Bullseye and Uroboros. Over the past couple
of months, I have become very weary of hyper-reactive media coverage
about the dangers of emissions from glass production at both
companies. I stand behind Bullseye, who has followed state DEQ standards in the past and is currently making whatever changes are necessary to conform to new air quality standards. These new regulatory decisions must be based upon science, not political issues. A leading scientist, Dr. LaCourse, has said Bullseye's furnaces do not produce toxic chromium, so I urge DEQ to rely on science and fact, and not to impose poorly written and misdirected rules, even if they are meant to be temporary. From what I see, Bullseye has been forthright in its efforts to solve the emission complaints, by suspending use of Arsenic, Cadmium and Chromium until they have installed and tested a filter system. Imposing impractical, hyper-reactive rules at this time would seem to me to be in poor faith. Please rely on science and fact ; not political issues. Ted Bach Hillsboro, OR tbach.tbach@comcast.net |
||
233 | 1102 | Nathan | Cohen | nateinafrica123@gmail.com | OR |
Thank you so much for extending the public comment period for
these rules. Hundreds of Portlanders have contributed to feedback, which will be summed up in a formal comment from the Eastside Portland Air Coalition, co-authored with Mark Riskedahl and Chris Winter. I stand by these recommendations, and look forward to seeing these new, revised rules put into action. Thank you! |
|||
234 | 1103 | Matthew Day | Perez | Matthew.d.perez@gmail.com | Independent Artist | New York |
To whom it may concern I am writing in support of Bullseye Glass and to advocate the DEQ to not impose emergency measures that may irrevocably cripple the supply stream and ultimately the small business I rely on for a great portion of my income. I am a former Fulbright Fellow, NEA scholarship awardee, Lois Roth as well as State Department grant recipient, educator, and art consultant. When I utilize glass either for my own practice or as a teaching tool I turn to Bullseye Glass. It is a trusted material that is well made and produced right here in America. Because of some of my confusion regarding Chromium I reached out to the owners of Angel Gilding. Another company I rely heavily on within my practice, the owners are both scientists. Mike King, co-owner, oxford educated chemist, and I had an extensive conversation mostly regarding allegations that Bullseye may be releasing hexavalent Chromium into the atmosphere when Chromium III is used in their furnaces. This is simply not true and cannot be true. It is true that elements will jump upwards in number when heated, but only in an oxidization atmosphere, this is an atmosphere that is oxygen rich. I have learned, from a trusted source within Bullseye, that when Chromium III is utilized when making richly colored glass a finely tuned reduction atmosphere is utilized. The furnaces at Bullseye glass utilize an Oxy-fuel system. This affords the team at Bullseye Glass an exacting capacity to pinpoint the environment within the furnace. This is unlike other factories that use a forced air system. A fan pushes air from within the studio directly into the furnace. King posed it as such. When you are trying to melt something, like really melt something, such as Iron, you do not want and oxidization flame because it promotes oxidization to occur. When iron oxidizes it rusts, you cannot melt something that is rusting so case in point it is incredibly difficult to melt something with this sort of atmosphere, you would be ruining the end product. While I believe in clean air and the importance of regulation as well as monitoring of factories that utilize potentially harmful materials I do not believe it should be done without the proper information to instigate such a tremendous change. Simultaneously, I have grave concern regarding the impact this temporary emergency regulation will have on the art market both domestically, and abroad. Bullseye glass serves numerous artist working at every level of the art market. Whether a small designer generating dishes or a contemporary sculpture creating public installation, many rely on this product for their lively hood. It is my sincere hope that the DEQ act in a judicious and circumspect manner while dealing with this difficult situation. With gratitude Matthew Day Perez |
||
235 | 1104 | Cindy | Young | rocknrollschool@msn.com | Eastside Portland Air Coalition | OR | Please keep in mind that OHA has not used all data concerning air & soil testing. They claim were all safe and that levels are under bench marks however they sampling techniques are not shared by all NP's or MD"s. OHA said a spot urine test was sufficient and blood test would only be done if the urine test was elevated. But not all MD's and NP's agree with this sampling and say 6 -24 hr urine tests and blood tests are needed for accuracy. OHA uses data from only one lab. Not including test results from other MD's, NP's or other labs making OHA"s data incomplete and inaccurate. Please be mindful that levels could actually be higher than OHA has announced and make sure all emissions from stacks are 100% filtered. If it can't be 100% filtered perhaps that's why other states have made it illegal to manufacture colored glass in their communities. | ||
236 | 1105 | Colin | Price | colinp@oeconline.org | Oregon Environmental Council | Oregon | Please see attached document | OEC_Comments_Temp_Rule-033016.pdf | https://data.oregon.gov/views/trwb-z8xe/files/0799f319-0da0-4903-b3b2-622505981f62 |
237 | 1106 | Albert | Zayha | azayart@live.com | South Portland Air Quality | Oregon | see attached... | AZ 2 DEQ 3-30-16.pdf | https://data.oregon.gov/views/trwb-z8xe/files/a8d603c4-fd01-42c8-98e7-119b86665de6 |
238 | 1107 | Jean | schnadig | jcschnadig@gmail.com | Citizen | Oregon |
The proposed rule is inadequate in addressing the true emergency
and risk to public health. Why are we allowing for emission of chromium 6 at levels 20 times greater than Oregon's established ambient benchmark? DEQ has not advocated for its citizens before, why should we allow DEQ to unilaterally make decisions that affect human health, including for production to recommence, without adequate public involvement? We need measures to sufficiently safeguard against ongoing racial injustice and environmental justice disparities related to toxic air pollution. The poor, disenfranchised have a harder time advocating for themselves and the facilities located in these communities need to be held accountable. |
||
239 | 1108 | Chan | Benicki | c.benicki@gmail.com | Oregon | Please protect the health of Portland residents, especially those who are disabled, chronically ill, children, or pregnant. We deserve clean air to breath. | |||
240 | 1109 | Greg | Haun | cosmo@alum.mit.edu | OR |
I fully support stronger rules for toxic emissions in populated
areas. Note that when my wife tried to submit, the following
displayed: { "error": true, "message": "Internal error", "status": ​500 } |
|||
241 | 1110 | Sheryl | Maloney | sherylmaloney@gmail.com | Resident | OR |
Dear EQC Commissioners, Thank you for allowing public comment both at the last ECQ meeting as well as during this public comment period. As you know this has been a painful process for both residents and the glass manufacturers. Although I truly sympathize with the concern the manufacturers and the global glass artists have about losing jobs and potentially an art form, I am unable to put the priority of their needs above the health of my family and neighbors. The Oregon DEQ is supposed to be the steward of the environment, and our first line of defense against these types of toxic situations. Sadly, the Oregon DEQ has been failing to protect our environment and thus the people living and working in it. I won't rehash all the issues and failures of how the last few months have played out, or focus here on the minutia of the temporary rules, as these items have been outlined in detail in the official EPAC statement and the statements of many others who are in favor of regulation. However, I will urge each of you to remember the original mission statement of the Oregon DEQ as you read through hundreds of comments submitted from those who do not live in our great state. DEQ's mission is to be a leader in restoring, maintaining and enhancing the quality of Oregon's air, land and water. DEQ works collaboratively with Oregonians for a healthy, sustainable environment. Please remember that this issue is first and foremost about Oregon and Oregonians and take great care not to be swayed by those who do not live here, have to breath our air, are vehemently against any regulation and who are so quick to dismiss our very real concerns for our families and homes as hysteria. Despite emotion and concern for my family, I feel that proper data, science and extreme due diligence should now be followed before permanent decisions are made about who, how or what to regulate. The devil is in the accuracy of the details and thus far, as is the case with the improper regulation and handling of metals in glass manufacturing, the DEQ and OHA have yet to demonstrate proper care and respect for the environmental data they are charged with on behalf of the public's health and safety. So, I ask you to carefully review and scrutinize every detail of the temporary rule so that you may find the best possible outcome that protects the environment, the health of the people and paves the way for sustainable industry practices. This is a watershed moment that has the potential to be a catalyst for truly cleaning up the air for Oregon and setting the tone for responsible regulations moving forward. In that spirit, I also urge you to consider other industries in all of Oregon that may be using heavy metals and toxics in your rule-making process. There are so many sources that contribute to our dirty air and simply putting a cap on Bullseyes operation is not a long-term or comprehensive solution that our community will stand by. Our children are the best natural resource to be "Made in Oregon", they are invaluable and their health and safety cannot be equated to glass colors or any other industrialized product. Many Portland children, including my own, attend schools that are ranked in the bottom two percent in the nation for air quality. The time is now to protect our resources and to improve our air rankings as a community, city and state before our children's quality of health suffers beyond repair. Thank You, Sheryl Maloney |
||
242 | 1111 | Charlie | Tellessen | ctellessen@yahoo.com | Bullseye Glass Co. (QC Supervisor), Independant glass studio artist | OR |
I have been an employee for almost 14 years and can honestly say
that the intentions of the company leaders over these years has
always had the health and safety of the employees held to the
highest regard. It has been a shock to everyone, Bullseye and
local community members, to learn of the potential poor air quality
surrounding the glass factory and to have it blindly solely attributed
to one source. I strongly believe that any regulations created for Portland industries should be created using a thoroughly scientific vetted process and not be a quick knee jerk reaction driven by push from politicians or emotional local area residents. I personally have my education in chemical engineering and have studied both environmental laws as well as industrial pollution controls during my studies. Growing up in the oil refining industry I have seen firsthand the potential for pollution but also the desire to control using scientific research. My wife currently is involved with environmental pollution controls and has been involved with stormwater controls for ensuring compliance with EPA and local water quality laws. I have seen the amount of effort that goes into peer reviewed articles, approvals and regulations involved with stormwater and am appalled at DEQs rush to put in place a set of regulations for local air quality before we have any substantial scientific data to back the claims that have been made to date. Should there be new regulations for air quality within the city of Portland for small industrial businesses? Yes, I do believe so. But I think that the DEQ needs to slow down and stop letting the cart get too far in front of the horse when attempting to design these regulations. How does the scientific data line up with the extreme reaction for not only pollution controls but also material usage controls set upon the small glass manufacturers? I have yet to see any peer reviewed documents from the USFS moss study or the initial DEQ air monitoring data from the October tests. How is it that DEQ can justify limiting material usage on materials like Chromium when there is little to no research data on conversion within a furnace like operating at Bullseye? Even with the elevated numbers from Cr in the October data, two of which days Bullseye wasn't in production, there appears to be little to no soil data to back up this regulation. The soil tests around the daycare that DEQ identified as elevated were even stated that the highest numbers were located on the outside of the fence closest to the road, which I can tell you from driving by twice a day is closest to the train yard, semi truck transfer station and a cement transfer silo, all of which are potential sources as well. I hope that the people in charge of creating new regulations will take the time to evaluate all available scientific data when attempting to create a health based regulatory system. I know that there can be very strong emotions involved from concerned citizens, a lot of which is from lack of understanding of what is really happening behind doors, open or closed. Bullseye has been very responsive with working with DEQ from day one of the information being leaked to the media and has continued to try and work to stay in compliance, something they were doing before all of this news broke. Please take the time to work with all industries to ensure that the regulations going forward are made using the best resources possible. |
||
243 | 1112 | Jennifer | Young | jbeayoung@hotmail.com | Oregon | I am concerned about the chromium levels that will still be in excess of any common sense safety levels as well as the continued allowance of lung irritants along a major traffic corridor US 26/Powell Blvd. Do not abdicate responsibility for bag house testing and rely on figures given to you by industry. As a severe asthmatic and living in low income housing which I cannot afford to vacate, I am being forced to live with DEQ's toxic missteps and mistakes. Public input needs to be the default mode in all actions taken by DEQ. DEQ needs to look beyond just the toxic metals and monitor all emissions to ensure clean air and livability in our neighborhoods. | |||
244 | 1113 | Ezekiel | Martin-Brunkhart | ezekiel.martin.brunkhart@gmail.com | Oregon |
I live less than 1/2 from Bullseye Glass. I support strong controls
for healthy air. My husband an I were thrilled to move in to our home last December. We thought it would be a great place for him to heal while he received intensive chemo for his cancer. Chris died Jan 2, 2016. He was 47. I would give anything for to have been able to spend a few more days with him. He was my world; he deserved every chance at survival. He should not have been exposed to toxic air. While still deep in grief, I had my urine tested for cadmium and arsenic. It was found both were elevated. I'm 100% sure that exposure to heavy metals in our neighborhood contributed to my husband's declining health. Bullseye, DEQ: you literally have blood on your hands. |
|||
245 | 1114 | Hanna | Newell | Hnewell@gmail.com | OR | It's critical that we support business in Portland, but not at the expense of human health. Please pass these regulatations and enforce pollution standards that will keep neighbors, children and animals safe. Thank you | |||
246 | 1115 | anne | Trudeau | annet934@yahoo.com | Eastside Portland Air Coalition | OR |
My comments are focused on three areas: Application of the temporary
rule to all industries, best available technology for glass furnace
emissions,Chromium(VI) a highly toxic chemical that i some glass
manufacturers use directly or produce as a result of using Chromium(III).
1. The temporary rule should apply to all Oregon industries, not just two small glass factories. 2. Pollution Controls: Filtering with a baghouse is not enough to control Cr(VI) and other emissions. As much as possible, toxins should not be introduced into the furnace at all. Burner and fuel adjustments have to be made, furnace conditions monitored and remediated as necessary. In addition to baghouses, electrostatic precipitators, and acid scrubbers should be used. The UNECE Best Available Technologies document describes in detail specific measures for glass factories. (UNECE BAT p56-65 see attachment) 3.Please consider all the following data when regulating Chromium. Chromium(VI) toxicity: Cr(VI) is the ninth most toxic chemical on a pound-for-pound basis on the EPA's list of 423 chemicals with inhalation toxicity weights. (EPA) Cr(VI) health effects: When assuming a linear dose-response relationship between exposure to chromium(VI) compounds and lung cancer, no safe level of chromium(VI) can be recommended. (World Health Organization) Eliminating Cr(VI): NIOSH Cr (VI) rules state that the first step to control Cr (VI) in the workplace is eliminate its use. All Cr(VI) compounds are considered to be occupational carcinogens. Cr(VI) is a well-established carcinogen associated with lung, nasal, and sinus cancer. A hierarchy of controls, including elimination, substitution, engineering controls, administrative controls, and the use of personal protective equipment, should be followed to control workplace exposures. Dermal exposure to Cr(VI) should also be prevented to reduce the risk of skin irritation, corrosion, ulcers, sensitization, and allergic contact dermatitis.(NIOSH) Cr(III) and Cr(VI): The stability of Chromium is very dependent on conditions like pH (related to other chemicals being present or not) and temperature. Cr(III) can convert to Cr(VI) under certain conditions and Cr(VI) can reduce to Cr(III). Monitoring challenges: Chromium VI is not a simple thing and requires special filters and careful attention to procedure. This EPA document describes the procedures which include special filter media and refrigeration of samples. The rules should reflect this. Incorrect data in proposed rules: The ambient Cr(VI) level in the proposed rules is twenty times higher than DEQ's own standards. The rules should reflect the correct level. Interpretation of monitoring results: When looking at Cr(VI) monitoring data: it is recommended that you use the maximum measured percentage of Cr(VI) rather than the highest average of the range observed across samples. (World Health Organization) The rules should reflect this. I am happy to provide all the materials I have referenced. I stand with Eastside Portland Air Coalition and call on the DEQ to immediately adopt health-based standards for all Oregon industrial emissions I also call on DEQ to partner with Oregon OSHA and do a complete investigation of Bullseye Glass workplace practices. |
UNECE Heavy Metals BAT 2006.pdf | https://data.oregon.gov/views/trwb-z8xe/files/2f2606b6-48ad-4661-b636-5ae0072863cc |
247 | 1116 | Portland | Resident | lyrikp@yahoo.com | Oregon |
For too long Portland's air has been polluted with industrial
air toxics and particulates. Industry has been given a pass to
use devices without proper emission controls. Other countries
and states have known about the dangers of glass manufactures
not using emission reduction devices. The recent revelations
by the US Forest service moss studies have finally given some
measure of the problem and revealed colored glass manufacturers
as major contributors to the air toxic present in Portland's
air. I understand that this is temporary rule to limit the major
contributors but I would urge DEQ to consider the following:
1) It is presumptuous to single out colored glass manufactures when these rules should apply to any individual or business operating a burning device where potentially toxic metals are burned, melted or shaped. 2) I agree on requiring manufacturers to stop using chromium VI, cadmium and arsenic until they get emission control devices. However this should apply to any burning device and a full list of toxic metals not just those three. Other metals such as manganese and cobalt have been shown to be elevated by the moss study (and are even part of the proposed monitoring). 3) The definition of burning device should be an extensive list of possible devices including the ones used by industrial colored glass manufacturers but should also include others such as smaller scale glass shop operations, or other industrial furnaces. There are smaller hot spots that have not been identified such as the SW Portland (between OHSU and Hillsdale) arsenic hot spot. 4) The regulation limit of 10 tons per year of toxic metals is too high. This should be reduced to 1 ton per year (which is still a staggering amount of potentially toxic metals). 5) The requirements should be enforceable with teeth (fines for violators) as rules without consequences are likely to be skirted by industry and manufacturers. 6) DEQ should also act quickly to set up more air toxic monitoring sites, with real time monitors, throughout the city to get a baseline and monitor their progress in reducing air toxics. 7) Since the moss study was so effective in showing hot spots, the city should be divided into an even finer resolution grid and the moss study repeated. 8) Finally the 350 samples taken at Portland Public School locations that the US Forest service has not worked up the data need to be prioritized and released to the public. I would recommend DEQ act swiftly on these point. Thank you. |
|||
248 | 1117 | Gilda | Lorensen | Gildalorensen@comcast.net | Citizen | Oregon | We are a national laughingstock due to our air pollution tolerance, and cannot weaken our air quality with bad rules. We must have tight standards! | ||
249 | 1118 | Gilda | Lorensen | Gildalorensen@comcast.net | Citizen | Oregon | We are a national laughingstock due to our air pollution tolerance, and cannot weaken our air quality with bad rules. We must have tight standards! | ||
250 | 1119 | Sheryl | Eckrich | Sheryl@SherylEckrich.com | Oregon | I stand with EPAC and Neighbors for Clean Air. |
251 | 1120 | Jen | Davis | Weallneedbees@gmail.com | Bee Friendly Portland | OR | Abe Fleishman owner of Northstar glass has begun filtering his whole factory. Bullseye sells glass globally with millions in profits annually. I stand with EPAC. Latest science shows even incremental exposures to air toxics can harm children like mine who has asthma and a debilitating nerve disorder which can be caused by, or at the least exacerbated by, the high arsenic, cadmium, lead and other toxins emitted regularly by Bullseye. Children should not suffer for others profits. I support lead, chromium and manganese testing as well, and all the stipulations of Attorney Cecilia Young's and EPACs statements. | ||
---|---|---|---|---|---|---|---|---|---|
252 | 1121 | West Supply | Illinois |
West Supply LLC in Chicago has been a loyal client of Bullseye
Glass Co. for 5 years. We are an artisan manufacturing business
in the Midwest employing 35 glass and metalwork artisans in the
making of fine art and designer furnishings and sculpture. It is with great concern that we've been following the various media stories on the possibility of severely limiting the output and livelihood of Bullseye and its team. The effect of such a motion could choke our glassworking business, as we currently use only Bullseye glass - due to its quality and the incredible collaboration we have with their team from a technical and logistics POV. The artist and designer clients we work with span domestic and international domains. Many are small business entrepreneurs themselves, and they rely heavily on our highly custom handmade productions - many of which they have sampled and placed showroom models of products we make in locations from Miami to Toronto to Hong Kong. To disable one or two glass supplier companies in Portland has far-reaching consequences on a personal and business level than just the footprint of that city. To be clear, this is not to diminish the paramount importance of personal health of anyone living or working in the vicinity of Bullseye. Looking over public health reports from the Oregon Health Authority it has been deemed in the short-term "unlikely that the level of metals detected in the air would cause any immediate health problems for people." Considering this, it seems only fair to allow these glass companies time to honor the alert and make careful appropriate changes in concert and collaboration with their valued neighbors and community. The precedent these actions and any new regulations set will be critical far beyond Oregon. In this vein, we hope decision makers will consider the haste at which these temporary rules are being pushed and look instead to methodically gather facts, measure the impact of potential regulations on the very special business Bullseye is and the incredible vast network of artists and creatives around the world that it supports. We are very proud to be a loyal customer of Bullseye Glass and have only the best things to say about the integrity and professionalism of the ownership and staff - the beautiful and highly technically developed product notwithstanding. With concern and support, Angie West + the West Supply family of makers in Chicago, IL |
|||||
253 | 1122 | Patrick | Blythe | patrickblythe@msn.com | Sculptor | CA |
I understand the public concern and your need to address those
concerns. However, I hope you will avoid reacting to the public
outcry whipped up by media-fearmongering and rely solely on science
as you consider new rules. Many artists around the world are
dependent on a supply of high-quality glass, and we are counting
on you to make a science-based decision that protects jobs and
public safety. This issue is too important to simply accept conjecture as your guide. |
||
254 | 1123 | Linus & Corliss | Carleton | jewelGlass@frontier.com | JewelGlass, LLC | Oregon |
Having read the available material, we believe the premise behind
the proposed Temporary Rule Making concerning the regulation
of glass making facilities are unjustified and that a longer
period for reasonable consideration would not only better protect
the health of Oregon children and families, but also conserve
the jobs of Oregon citizens. The temporary Rule Making is based upon the stated premise that immediate action is necessary is to prevent risk to the health of all people situated near two glass manufacturing facilities in Mutlnomah County. The justification to the Rule Making states: "Now that DEQ has verified monitoring and inspection data to show that the facilities have uncontrolled furnace emissions that can significantly increase the risk of cancer and other diseases." However, studies made by the Oregon Health Authority (OHA) indicate that no increased incidence of cancer has been shown in either the Southeast or North Portland areas from 2009 through 2013, despite the fact that the two facilities have been operating there for more than 35 years. And, despite the initial fear that soil contamination has resulted from the operations of these two facilities, on March 22, 2016, the OHA formally rescinded its original recommendation for citizens residing in the areas to avoid consuming backyard produce. David Farrier, a toxicologist in the OHA Public Health Division's Environmental Public Health Section stated: "Our dose and risk calculations for arsenic and chromium 6 indicate that metals in the soil are too low to harm the health of people living and working in the area, including children attending the day care center." Rushed and potentially inappropriate regulations are rarely the answer to not yet fully understood environmental conditions. The standards which the regulations are purported to protect relate to 24-hour public exposure over a lifetime. Given the lack of demonstrated harm that has occurred from the controlled use of these chemicals over the last third of a century, it is unnecessary to impose regulations not based upon thorough scientific study and analysis, since those regulations may make it impossible for the businesses in question to remain in operations. It is far better to delay a few months further and produce rules that are sound and fully justified. The rules proposed will mean that the two facilities in question will only be able to remain in operation after September 1, 2016 if suitable protective measures for their furnaces can be approved by the DEQ and installed timely by the companies. With the lack of available research, the assumption that the DEQ can even make a scientifically sound determination of suitability in time is a real stretch of the imagination. Even if this is achieved, the ability of the two glass works to purchase and install the approved equipment by September 1st is exceptionally unlikely. More likely, additional months or years will be needed for all to fall into place. If the two facilities are forced to close, the specialized jobs of their employees will be lost and thousands of artists across the country and around the world will be deprived of material on which their art and livelihood are based. Finally, these regulations are imposed upon only one very small industry;one which it has not been proven without a doubt is the only cause of the pollution that has been discovered. Does DEQ intend to regulate each potential pollution source one industry at a time? Better to take the necessary time to provide more inclusive rules by which all small polluting industries can abide. JewelGlass is a small but exclusive user of Bullseye glass for our small business; others in the world have a far greater than we. While we fully understand and agree with the desire of DEQ to protect the public from possible harm, we fail to see the credibility of rushing into rules which are not scientifically based and not fully thought-through. We urge time and reasonable deliberation, and utilization of the promised active cooperation of the regulated facilities (and others) before inappropriate and harmful rules are imposed. |
||
255 | 1124 | Jen | Davis | Weallneedbees@gmail.com | OR | See attached | Blank 136.pdf | https://data.oregon.gov/views/trwb-z8xe/files/c4067357-81bb-40f3-9ca5-94204df9b0a1 | |
256 | 1125 | andrew | Nemec | anemec@outlook.com | OR |
Thank you for taking action to protect the communities impacted
by the toxic releases from these glass manufacturers. I would like the proposed regulation to address the following: * Address all toxic hotspots impacting residential communities, not just speciality glass manufacturers. * It should not allow for the emission of chromium 6 at levels 20 times less protective than Oregon's established ambient benchmark. * Allow for sustained air and soil monitoring (inc on-site monitoring of smoke stack emissions) and human health monitoring over a period of years to gauge the health impacts of toxic emissions on the nearby community. Ideally, this could include a health registry which allows any nearby citizen to log health issues and which allows any concerned citizen to query such reports to better judge personal health risk. * Allow for prompt shutdown and stiff penalties should a regulated entity fail to comply. * Allow for citizen involvement in policy making over time. DEQ should not enact regulations without public input. |
|||
257 | 1126 | Heather | Berry | berryh555@hotmail.com | OR |
will allow unexplainably for the emission of chromium 6 at levels
20 times less protective than Oregon's established ambient benchmark; will allow DEQ to unilaterally make decisions that affect human health, including for production to recommence, without adequate public involvement; will not sufficiently safeguard against ongoing racial injustice and environmental justice disparities caused by toxic air pollution, by too narrowly limiting which facilities will be subject to this rule. |
|||
258 | 1127 | anne | Trudeau | annet934@yahoo.com | Eastside Portland Air Coaltion | OR |
https://www3.epa.gov/ttnamti1/files/ambient/airtox/hexavalent-chromium-paper-06.pdf In my previous comment I referenced this EPA document which describes the procedures which include special filter media and refrigeration of samples. Please add this to my comment. |
||
259 | 1128 | Michelle | Kurtis Cole | michellekurtiscole@gmail.com | Michelle Kurtis Cole Studios | California | There are so many things that people don't know about the Bullseye family. I've being buying their glass since the 80's. I make my living from it. I'm an environmentalist and I too was concerned by the claims about their emissions before I read the facts. But I also know Bullseye's people personally, so I knew whatever the problem was that they would address it immediately and without being forced to do so by some authority. I know in my heart and head that they would never do anything knowingly to hurt the environment. Case in point, I work on cleaning and preserving coral reefs. I've been working with Scripps Institution of Oceanography to determine ways for coral reefs to thrive, regenerate and survive. My project is to create glass sculptures to provide a cleaner, more stable substrate for corals to naturally recruit to, live on and grow. Bullseye's owners heard about this project and voluntarily donated many cases of glass for the project. Due to their donations I can now afford to make tiles for other coral restoration projects around the world. Bullseye asked for nothing in return, nor did they advertise this to promote themselves. This is just one case, my project is not the only one where they have done this. There is no doubt in my mind that when it comes to the current environmental controversy, they will do the right thing. | ||
260 | 1129 | linn | keller | jeksac@earthlink.net | TX | For years Bullseye Glass has been and continues to be a responsible, active and involved community member, hiring a local workforce and creating a product used by artists around the world. I would urge the DEQ to create rules based on environmental testing and scientific evidence. There is no current information that emissions cause acute health risks or long-term danger. Nor is there evidence that these proposed rules for Bullseye will contribute to improvement in Portland air quality. I would encourage DEG and Bullseye to work together to develop a plan that will actually achieve appropriate goals for emissions and testing and allow both sides to have input and adjustments as time goes on. Good rules should the aim, not over-reaction, using scientific evidence, testing and fair process. Thank you. | |||
261 | 1130 | Jen | Davis | Weallneedbees@gmail.com | OR | Document to accompany previous comment | Soil:plant metals concern.pdf | https://data.oregon.gov/views/trwb-z8xe/files/cef21aa2-2db8-4c02-99fc-3f1196ea878a | |
262 | 1131 | Dean | Philipp | dmphilipp42@yahoo.com | OR |
As a Portland resident*, Sierra Club member*, chemist/physicist,
glass hobbyist, cancer patient*, and generally concerned human
being, I feel that I am especially obligated to comment here. Air quality is just one of many environmental issues on which public policy has been lax, and for which much more will need to be done. However, now that it has come to light that metal emissions look to be an air quality problem, it is important to not respond to hysteria, anger, and fear with knee-jerk responses that seem to be more for show. What is done going forward needs to be based on scientific evidence and facts, and needs to be effective in addressing the actual problems without being extraneous and/or excessive. In particular, though admittedly not within my specialty, it is implausible that trivalent chromium converts to hexavalent chromium within the glass furnaces without oxidants, which would ruin the glass color. It is important to continue working WITH companies that have been responsible in doing what has been required of them to this point, and that seem willing to take measures to correct these oversights, as long as they are deemed essential and efficacious. It would be a shame to lose iconic companies known worldwide, and that have been so instrumental to glass art. One thing to keep in mind throughout all of this is that EVERYONE needs to do more to protect the environment. This includes government, corporations, and citizens, all of whom will need to be informed with facts from reputable sources (and not propaganda), not give in to anger and fear, be willing to share the costs and efforts, and most of all be willing to work together. Remember, there is no "us" and "them" here - only "us" and "us". Our welfare and the welfare of generations to come depend upon all of "us". *I have been a Portland resident for over 14 years, a Sierra Club member for over 15 years, and my cancer is a slow-growing cancer that has not been shown to necessarily correlate with any particular risk factors and had been symptomatic for me long before moving to Portland. |
|||
263 | 1132 | hummingbirdzoo@yahoo.com | n/a | Oregon |
Please do everything possible to reduce the toxic pollution in
Portland's air, and as quickly as possible. Companies need to
properly filter emissions. If they need help buying filters or
equipment, then some funds need to be made available for this.
Independent air monitoring needs to be done regularly in the city, and done without prior warning being given regarding when the monitoring will be done. It is easy for a company to not spew out poisons for a few days or weeks during monitoring. DEQ needs to stop being so cozy with polluting industries, and instead must look out for the health of the environment and the people. DEQ needs to focus a whole lot more on diesel emissions and it must get things cleaned up like CA and WA has. Much more attention needs to be given to the toxic emissions coming from oil re-refineries and oil refineries. There is such a scary cocktail of poisons being released into the air, and even although recycling oil is being heralded as being Green, when it poisons people like it does, it is a menace and needs to be stopped until corrective measures are made. Thank you. |
||||
264 | 1133 | Roger | Cole, PhD | rogerjcole@gmail.com | California |
Seven reasons why it would be a huge mistake to adopt the proposed
rules. 1. No urgent risk. Bullseye has shut down all production that uses the metals in question. There are zero emissions of these metals from this facility. The premise that Bullseye's current operations pose an immediate threat to the health of people nearby is entirely false. 2. Problem is being handled. Bullseye is already in the process implementing a state-of-the-art filtering system designed to bring emissions far below levels that might be of any concern. Once it is operational, this entire issue will be moot. 3. No credible evidence of past risk. There is a claim that glass furnaces could, theoretically emit certain metals in unsafe amounts, but no actual measurement showing they have ever done so. The recent ad hoc inspections are no substitute for properly controlled scientific investigation. Since there is no immediate risk, there is plenty of time to soberly study the issues and get the facts right. Only then, and only if necessary, should new rules be drafted. 4. Responsible company. Bullseye is a well-established local company with a sterling record of social responsibility. Its owners and many employees are environmentalists. Its own workforce, including owners, scientists and top management, are daily exposed to any emissions that might come from their facility. Many of their families live in the neighborhood. Bullseye's people have a greater stake in this than anyone, so they can be trusted to do what it takes to operate safely. 5. Harm to local families and economy. Bullseye is a major local employer. Needlessly shutting down their facility would do far more harm than good. 6. Worldwide harm. Bullseye supplies most of the world's supply of color-compatible art glass. Shutting them down would cripple an entire art form across the globe. 7. Setting a precedent. This situation presents a rare, low-risk opportunity to demonstrate how government, business and community can set aside name-calling and coercion and instead work together with good will to resolve an environmental issue. |
|||
265 | 1134 | Matt | Minnick | Mwminnick@gmail.com | The people | Oregon | No more allowances wether temporary or permanent. Oregon and especially the Pacific Northwest rainforest is not a playground for any industrial pollutants. The people and the ecosystems of the Pacific Northwest are not the lab rats for these untested and known dangerous pollutants. We have some of the most fertile, food producing, oxygen sequestering soils which are rapidly disappearing due to industrial indiscretions and rapid development which are short lived, fossil fuel dependent destructions to the very things in which we ALL depend on to survive. "I stand with EPAC" | ||
266 | 1135 | Any business emitting chemicals or heavy metals should have the proper emission filters to safeguard the public against exposure and should also be required to declare the amount and type of material it is using. Notice of that declaration should be presented to everyone in proximity annually . | |||||||
267 | 1136 | Misha | Whisenand | eugenerain@gmail.com | Eugene Rain | CA | I am a glass artist, and very concerned about the future of art glass should these temporary rules become effective. Regulatory decisions must be based on science, not political issues. A leading scientist, Dr. William LaCourse of Alfred University, has said Bullseye's furnaces do not produce toxic chromium. We urge DEQ to rely on science and fact, and not to rush to impose these poorly written and misdirected rules. Thank You | ||
268 | 1137 | Debra | Philpot | glassqueen.dp@gmail.com | Philpot Designs | Oregon | I understand there are some big differences between big gas furnaces and small electric ones, and shouldn't the DEQ be going after big polluters, like Precision Castparts, and not small companies - especially when the soil tests come back with normal levels? And what about the other industries in the vicinity of Bullseye? | ||
269 | 1138 | Linda | Nettekoven | linda@lnettekoven.com | Oregon | DEQ Letter 3:30:16.pages | https://data.oregon.gov/views/trwb-z8xe/files/bc939493-be25-45e3-8c00-17b6324789f6 | ||
270 | 1139 | John | Wasiutynski | john.wasiutynski@multco.us | Multnomah County Office of Sustainability | Oregon |
Multnomah County supports temporary rules for the Colored Art
Glass Manufacturing (CAGM) industry. Indeed, regulation limiting
the emissions of hazardous air pollutants is long overdue. Recent
revelations that CAGM are a significant source of heavy metal
contamination in Portland neighborhoods has been a cause for
serious concern. It is the County's position that the State must
exercise statutory authority to protect public health by regulating
stationary sources of hazardous air pollutants. While the county supports these rules, specific aspects of the rules should be strengthened to help build trust with the community and ensure that human health is adequately protected. Mandate best available emissions control technology: The rules should require the use of best available emission control technology on any furnace that uses heavy metals (or recycled glass containing heavy metals) in the manufacturing process. In addition to arsenic, cadmium, chromium and nickel the rule should also cover lead, selenium and any other heavy metal that is toxic to human health. Do not allow exceptions for chromium: The temporary rules allow for the emission of chromium VI so long as the ambient concentrations of chromium VI do not exceed 1.6 ng/m3 at DEQ monitoring stations. This standard is insufficiently protective of public health and any ambient emission standard set in rule should be consistent with the Ambient Benchmark Concentration set by DEQ's Air Toxics Scientific Advisory Committee. Chromium use should be prohibited unless best available emission control technology is in place. Include all art glass and glass manufacturers in the rule: The temporary rule as written only applies to CAGM that "[m]anufacture 10 tons per year or more of colored glass using raw materials that contain metal compounds."This threshold would exclude CAGM that produce less than 10 tons of colored glass or glass manufacturers that use metals in their production process but don't produce art glass. The facilities that are not covered by this rule, it is reasonable to assume, may also be sources of heavy metal air pollution, particularly in communities adjacent to those facilities. Although we agree with the assessment that hobbyists should be exempt from the rules, the 10 ton threshold is too high and we ask that the threshold be lowered to capture all CAGMs. Similarly, any glass manufacturer that uses metals in the production process should also be covered by these rules. |
||
271 | 1140 | Carol | Carson | carsonglass@me.com | Oregon |
I ask the DEQ to NOT ask the EQC to adopt the proposed temporary
rules limiting emissions from small colored art glass manufacturers
until the rule is written properly using thorough scientific
research to back up claims that the small colored art glass manufacturers
are the only ones emitting metals into the air in southeast Portland.
The entire southeast area including businesses such as Precision
Castparts, the railyard project with the large toxic land berm
and the daycare center that used to be a recycling center should
all be tested and taken into account for possibly emitting toxins
into the air. To choose to impose these temporary rules on Bullseye Glass and not the surrounding businesses comes a place of emotion and hysteria, not scientific findings. Comprehensive testing done by an impartial third party not the; should be done of the entire southeast Portland area. There is no immediate threat to the area and pushing through this temporary rule without clear scientific data can put Bullseye Glass out of business. A company that has and is continuing to comply with the DEQ and has always put people before profit. The DEQ has, by trying to rush through this temporary rule, caused tremendous hardship on not only the employees of Bullseye and their families, but of the people who live in southeast Portland by striking fear and hysteria in them. This rule should be rewritten completely and not until thorough research has been done. |
|||
272 | 1141 | Barbara | Bader | barboglass@yahoo.com | n/a | Oregon |
My husband, pets, and most of my friends live in southeast Portland.
It's clear that DEQ's proposed temporary rules were issued in
haste and without due diligence that requires some basic research.
This lack of fact-based information was on display to the dozens
& dozens of citizens who attended the DEQ hearing on the
temp. rules. Several of the supposedly knowledgeable people who helped create the document, which they planned to vote on that day and implement the following day, responded to commissioners' questions with a version of, "I don't know." If you don't know important information, you find out the answers BEFORE you slam regulations on small businesses that may or may not be the source of the pollution. Don't really know whether the furnace conditions at Uroboros and Bullseye convert harmless C-III to C-VI? Find out! Basic science is out there. Meanwhile Uroboros and Bullseye, the two small glass manufacturers singled out for the temp. regulations, immediately and voluntarily ceased production that used the heavy metals in question. In other words, they totally want to make sure their factories are safe from dangerous pollutants. Both have ceased production of about half of all their glass products until everyone agrees that they're safe. Both are spending tons of cash in areas such as environmental consultants, engineers, and having their baghouses built & installed. Employees have been laid off and, if the temp. rules are approved, one or both of these companies may go out of business completely. That's what very well may happen ... just because DEQ crumbled under pressure and issued rules that punish two small businesses when many of the people of Portland decide that some of the so-called newspaper journalists write truly wild stories that call out facts --- when they are not science-based facts; write about the 2 companies, especially Bullseye's, actions -- some of which never happened, and others without correct (or any) context. These journalists and their editors (if there are any editors left on their staffs) do no service to the citizens of Portland, by whipping up an understandable frenzy of fear with such lousy and reporting. Even their choice of words reveal animosity toward Bullseye, in particular. They should be fired. But that's how newspapers operate nowadays. Bullseye is already installing a pilot baghouse. Uroboros also is in the baghouse process. If the companies can prove, and they can do so, that C-III will not convert to C-VI in their furnaces, there is absolute no danger or reason to force them to stop manufacturing those glass colors for 6 months. DEQ's temp. rules are flawed, yet DEQ is eager implement them anyway. Portland's pollution problems are far greater than these 2 small companies. PLEASE take your time, do your due diligence, research, and apply appropriate rules across the board to businesses large & small that emit toxics. Why aren't those companies shut down while rules etc. are investigated? Politics, power, money. Most obvious example is, of course, Precision Cast Parts. |
||
273 | 1142 | Janet and Alastair | Roxburgh | hummingbirdzoo@yahoo.com | Private citizen | Oregon |
Please do everything possible to reduce the toxic pollution in
Portland's air, and as quickly as possible. Companies need to
properly filter emissions. If they need help buying filters or
equipment, then some funds need to be made available for this.
Independent air monitoring needs to be done regularly in the city, and done without prior warning being given regarding when the monitoring will be done. It is easy for a company to not spew out poisons for a few days or weeks during monitoring. DEQ needs to stop being so cozy with polluting industries, and instead must look out for the health of the environment and the people. DEQ needs to focus a whole lot more on diesel emissions and it must get things cleaned up like CA and WA has. Much more attention needs to be given to the toxic emissions coming from oil re-refineries and oil refineries. There is such a scary cocktail of poisons being released into the air, and even although recycling oil is being heralded as being Green, when it poisons people like it does, it is a menace and needs to be stopped until corrective measures are made. Thank you. |
||
274 | 1143 | Henry | Leonard | hleon@gmail.com | OR | I am concerned that the 99% filtration limit in the proposed temporary rules will still permit emissions of toxic metals at levels higher than health standards permit. Please clarify in the final temporary rules how we can verify that emission levels do not exceed pre-existing health standards. | |||
275 | 1144 | Misha | Whisenand | eugenerain@gmail.com | Eugene Rain | CA |
there are some big differences between big gas furnaces and small
electric ones, and shouldn't the DEQ be going after big polluters,
like Precision Castparts, and not small companies - especially
when the soil tests come back with normal levels? And what about
the other industries in the vicinity of Bullseye? Laws, rules, and regulations need to be based on science. |
||
276 | 1145 | John | Maloney | jfmaloney@gmail.com | OR | I stand with EPAC. All companies currently non-exempt from filtering the use of heavy metals that can impact our airshed should be required to do so to protect the environment and human health. | |||
277 | 1146 | Silas | Haun | Silas.haun@gmail.com | Oregon | I stand with EPAC. I live near Bullseye, I am 15, and I wake up with a sore throat everyday. | |||
278 | 1147 | Ryan | Malia | ryanmalia@gmail.com | OR - Oregon | I stand with EPAC. Businesses need to conform to pollution control standards. | |||
279 | 1148 | Susan | Longini | slongini1@gmail.com | Independent Artist | CA | My understanding is that Bullseye is currently installing emissions apparatus that will collect the metals emissions in question. Also, chromium III does not convert to Chromium VI when the glass it is used for (green) is produced. To put this small business under such onerous rules would punish the manufacturer, its workers and their families and many artists throughout the world. If the emissions bags work, there is no reason to require elimination of these metals from its production. | ||
280 | 1149 | Rich | Richards | richrich@mailismagic.com | OR | Almost at the end of the list of stuff to review! Good job! | |||
281 | 1150 | Ariel | Malia | arielmalia@gmail.com | Oregon | I stand with EPAC. Businesses need to conform to pollution control standards. | |||
282 | 1151 | M. | Andre | n/a | OR |
DEQ must provide safety for the health of our communities by preventing
toxic exposures to those who work, live, play, garden, grow up,
recover, or travel at and around toxic emitters. If a temporary
rule fails to include a toxic emission, such as hexavalent chromium,
the rule needs to be changed to include all chromiums (which
can, in combination, become more toxic than in isolation. will allow unexplainably for the emission of chromium 6 at levels 20 times less protective than Oregon's established ambient benchmark; will allow DEQ to unilaterally make decisions that affect human health, including for production to recommence, without adequate public involvement; will not sufficiently safeguard against ongoing racial injustice and environmental justice disparities caused by toxic air pollution, by too narrowly limiting which facilities will be subject to this rule. We urge you to submit comments to the DEQ online comment site, encourage DEQ to adopt stronger temporary rules that protect public health and ensure public participation. |
|||
283 | 1152 | sharon | Dunham | dunhamsw@frontier.com | Oregon | As a mother concerned about the health and safety of my own and all children, I understand the concern! As a health care provider at a local regional hospital for almost 30 years, I also understand these concerns! Having said that, I would hope that decisions will be made based on science and evidence over and above a more emotional reactionary response. The local glass industry has moved forward to do the right thing toward mitigating what most likely goes beyond their factories. Please consider tempering the process and look in to questions, such as that posed by Paul McNulty, before leveling these "temporary rules". Thank you! | |||
284 | 1153 | charles | Norona | cenorona@yahoo.com | self | California |
My opinion on the temporary restrictions on colored glass production by Bullseye Glass is that the actions of the Oregon Department of Environmental Quality (DEQ) are reactionary and not based on proper evidence. The DEQ has been provided with scientific evidence by established experts in the field, so I will not repeat those here. The DEQ should provide a consistent, public accounting of their justifications for extreme actions. This is especially because, by all accounts, Bullseye Glass has conducted its operations within previous guidelines. Supposedly, this whole chain of events began with one air quality test in the area of Bullseye Glass that was not definitively tied to Bullseye Glass operations, and with the assumption that Bullseye Glass was responsible without proper investigation of other possible sources of contamination. Implementation of temporary measures is irresponsible because it gives the impression that the Oregon DEQ is taking positive steps to handle a problem when, in fact, there is just as much evidence that Bullseye Glass operations were not solely or in part responsible, and other possible sources of contamination are not even being explored. Sincerely, Charles Noroña Menlo Park, California |
||
285 | 1154 | Melissa | Williams | Sfec@live.com | Oregon | The State's concern that hexavalent chromium could be produced in Bullseye Glass' furnace is moot. They use only chrome III, which is harmless to public health, and with every run in their furnaces they have visual feedback via the color produced by incorporating chrome III. If chrome VI were present they would know it instantly by the characteristic color that would result from the presence of chrome VI. Temp regulations to curtail operations are valid only when backed by actual scientific data. | |||
286 | 1155 | John | Wasiutynski | john.wasiutynski@multco.us | Multnomah County | Oregon | See attached file | Comments - DEQ Temporary CAGM Rules.pdf | https://data.oregon.gov/views/trwb-z8xe/files/964901e2-a986-4bab-ba3d-25b5fe0ae4b9 |
287 | 1156 | Jane | Elliot | 2janeelliot@gmail.com | SE Portland Neightbor, EPAC | OR | I stand with Hosford-Abernethy Neighborhood Association, Northwest Environmental Defense Center (NEDC), Neighbors for Clean Air (NCA), OPAL Environmental Justice, Eastside Portland Air Coalition (EPAC), Coalition for Communities of Color, Oregon Environmental Council, Oregon Physicians for Social Responsibility, Verde, Beyond Toxics, and the Portland African American Leadership Forum., in calling for clean air for all of Portland, and all of Oregon. This current climate of Industry First, before Public Health cannot stand any longer. For the past 42 years, Bullseye has polluted with a long list of hazardous materials, unmitigated by any proper filtration. I have lived in my 1925 era SE Portland home for the last 23 years, not knowing the DEQ has not protected us, by allowing this toxic air to proliferate. Only through enormous public pressure, Bullseye has decided to belatedly filter ONE of 19 furnaces, all the while calling on out-of-state glass industry supporters, and high priced PR people to spin the news their way. This is unacceptable and sickening. Bullseye, Intel, Precision Castparts, and every other polluter in Oregon needs a wake up call, tough standards and oversight is needed that put our public health first over their manufacturing. This is not the Middle Ages, we know better about toxic materials! | ||
288 | 1157 | AKIHIKO | KAWAMOTO | glass-kawamoto@rio.odn.ne.jp | JAPAN | SHIZUOKA |
I'm Akihiko Kawamoto, stained glass studio's owner in Japan. And I'm a SGAA ( Stained Glass Association of America ) member. My studio has over one hundred stained glass class students and many stained glass customers. We use many Bullseye and Uroboros glass every day. If we can not use these glass, we can't do business. Stained glass business company in Japan all feeling same manace for this a disturbance. Plese help our glass user and excellent Portland glass companys. We love Oregon glass sheets. Plese accept our acute request. Thank You |
||
289 | 1158 | Scott | sell | scott.sell.oregon@gmail.com | none | Oregon | I live 8 blocks from bullseye glass. These rules are inadequate because they allow for the emission of heavy metals at too high a level. The rules should set a level of emissions commiserate with the degree of alarm caused by the past 40 years of pollution. You job as a rule maker is, in part, to make the residents of my neighborhood feel safe. These rules are not stringent enough to do that. Don't forget that some of the damage done here was damage to the residents' perception of their safety. Stronger rules would help remedy that damage. People deserve to feel safe in thier homes. Please help us feel safe in our homes. | ||
290 | 1159 | Amy | siwik | amysiwik52@yahoo.com | Oregon | I support the comments outlined in the Chris Winters letter, written on behalf of the Eastside Portland Air Coalition | |||
291 | 1160 | Roxanne | Leslie | Roxyandrebel@yahoo.com | OR | What do the employees of precision castparts Corp need to do to have the air inside tested as well. Precisions in house tests do not represent the poor air quality that we breathe every day. |