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 2 Andy Haverland andy@yaquinaboat.com Yaquina Boat Equipment OR - Oregon It is my hope that the DEQ would do its very best to ensure that the supposed environmental issues raised by the recent discovery of elevated levels of toxic metals in the air, are treated as delicately as possible. People's jobs are at stake, and its easy to assess fees and require copious amounts of red tape just fro a small business to function. It is my hope that you would regulate without an agenda, either left or right.
3 3 Sara Meissner sarameissner21@hotmail.com   OR Please pass the proposed rules to stop glass factories from using arsenic, cadmium, chromium, and nickel. I work across the street from Bullseye, and as a mother who was pregnant two years ago here, learning there are potential health issues/risks to my son or myself is alarming.
4 4 Portland resident         I am very worried about its effect on our health and the duration of our exposure to these toxic materials. I am definitely in support of rules that would help prevent these toxic materials from compromising our air quality.
5 5 Callie Meiners photocallie@gmail.com   OR Please, do not support the Air Quality 2016 Temporary Rules. These onerous rules put an unnecessary and unsustainable burden on local manufacturers. The rules do not address the real air quality problems facing Portland. Instead they target small businesses that do not produce large tax revenues. Bullseye and Uroboros are known around the world as businesses that make quality glass, ethically and locally. These rules are focused only on these small local business and not large producers of chemicals which there is such sudden concern over, such as any number of other glass manufacturers (consider alcohol bottling?). Lest we forget the incredibly high levels of car and truck exhaust inhaled daily, but this is not a concern for the DEQ-but art glass-that's where we draw the line now?




These onerous new rules come less than a week after the DEQ found NO evidence that heavy metal emissions were causing harm. The DEQ found NO evidence of harmful levels of arsenic, chromium or cadmium in schools. It appears these rules are being introduced merely to calm public opinion. These companies have made beautiful glass in Portland for forty years. I'm afraid that if these rules will drive them out of business. Certainly their employees locally will be harmed and the ripple of these changes will be felt by the art glass community around the world.




I don't understand. I thought Oregon supported the arts. I thought Portland supported local businesses and workers. I have never been more disappointed to call Portland home.
6 6 Grey Byrd pkreisberg@spiritone.com individual resident of Portland OR I don't understand why it is not patent that no business, big or small, or any individual be allowed to emit toxic substances into our atmosphere. I am sure the technology exists and is affordable, to mitigate chromium, cadmium, cobalt, arsenic, nickel, what have you! Why you need more time to figure this out is beyond me.
7 7 Christina Thompson thompson.portland@gmail.com   OR Please include hexavalent Chromium to the concern list.    
8 8   Richardson current@gorge.net n/a Oregon
To whom it may concern,

I welcome DEQ's actions to reduce harmful emissions of certain heavy metals from some art glass facilities -- but I disagree with the notion that closing this regulatory loophole is sufficient. DEQ seems to believe that investigations of impairments to our air, water and soil aren't really worth bothering about; and that since the public is alarmed at this one particular instance -- art glass manufacturers in Portland -- a very specific patch on existing regulations is all that's needed. This would completely miss the point.

The public needs a more vigorous DEQ and a Department director more zealous for the health of the public and of our natural resources. We need an agency that actively seeks out impairments that compromise our environment and human health, and then acts with resolve to alleviate them.

As an Oregonian living near a railroad company's creosote-emitting tie plant, I see, smell and feel (have headaches) the impacts of impaired air quality on a regular basis. DEQ has done nothing substantial to support my community's health or environmental integrity. So it comes unfortunately as no surprise that the agency was so lax in seeking out heavy metal contamination in Portland neighborhoods. The human beings in my community, as in the Portland neighborhoods near the glass manufacturers, just don't seem to matter to DEQ. It should not take front-page news articles to motivate DEQ employees and leaders to do their jobs!

I strongly urge DEQ officials to reform their agency into one that stands up to polluters, and stands up for the health of Oregonians first and foremost. I ask DEQ not to begin regulating a few heavy metals from a specialized manufacturing sector in Portland, but rather to strengthen all harmful heavy metals emitted by all industries -- indeed, by any sources -- in all Oregon cities and towns.

Respectfully, Dan Richardson
The Dalles, Oregon
9 9 Marc Rose marcrose.b@gmail.com   Oregon I understand the need/desire to protect local businesses, but not particularly when local businesses refuse to even acknowledge that their business practices have been a problem in the past. To date, Bullseye has been arrogant and shown no contrition. The company refuses to even accept that the emissions measured are coming from their factory, despite the evidence. I would contrast Bullseye to Urorburos, which reached an agreement with DEQ to limit emissions voluntarily. I sincerely hope that we do not now see a watered down version of rules that have been bent to Bullseye's wants. Please do not put business interests over public health and safety.
10 10 Regina Loos 503regina@gmail.com   Oregon It is absolutely critical that toxic elements not be released into our air, water or land. I support your temporary rules but would like to see them broad enough to include protection from the next potential polluter.

My family has lived about 10 blocks from Bullseye Glass for the past 28 years. Well over a year ago my doctor found some metals in my system. Mercury was finally gone but the cadmium persisted. "What do I need to change? Where is it coming from?" I asked my doctor. "The environment. Food. It's hard to tell," he answered.

Next to hit our family was the threat of prostate cancer and cadmium is a very high common denominator.

And I will always be wondering about my good friend and neighbor (who lived here for 30 years) and recently died of kidney cancer. He was in his 50's.

Thank you for working on this toxics issue with all due haste. This is not just a matter of statistics. Every day that passes has an effect on the health and well-being of great numbers of real people.
11 11 Sandra Ihrig Sandra_ihrig@yahoo.com   Oregon Why are these rules temporary? What about other air pollution not in the news? One example being The Dalles Amerities? Of you only address Portland and only Portland what about the other hot spots?
12 12 Pamela Klebaum klebaumpp@gmail.com   California I urge the DEQ to evaluate the scientific evidence in this matter and not get tied up in the sensationalism stirred up by some members of the press. Bullseye is an environmentally conscious company and has always been stellar in its obligations to the public's health.
13 13 Grey Byrd pkreisberg@spiritone.com   OR Please explain how someone from California can sing the praises of a company polluting the air in Portland, Oregon.  
14 14 Annie La Rue mrs.annielarue@gmail.com   Oregon The proposed rule changes lack quantifiable and enforceable violation definitions and monetary penalties. The lack of monetary penalties is a non-deterrent to industry emitters. The proposed rules lack even rudimentary mandatory public notification standards if a violation should occur. The proposed rules lack specific mandated and continuous science-based air quality monitoring requirements that are as stringent as or more stringent than the standards used by the EPA. The proposed rules should require any emission control devices to be properly maintained and inspected, and all records produced as a result of these inspections to be made public records. The proposed rules should give DEQ emergency authority to act prior to consulting with OHA to limit CAGM’s use of metals of concern.
15 15 Matthew Preusch mpreusch@kellerrohrback.com Keller Rohrback L.L.P. California   KRPublic Comment CAGM.pdf https://data.oregon.gov/views/trwb-z8xe/files/bb64fa56-3bbe-4dbd-8745-a57a85883230
16 16 Robert LeChevallier rlc@buckley-law.com attorney for Northstar GlassWorks, Inc. Oregon See attached testimony of Abe Fleischman, president of Northstar Glassworks, Inc. Northstar Glassworks, Inc testimony.docx https://data.oregon.gov/views/trwb-z8xe/files/184a7331-e35a-4d78-b24e-591cbf8348f1
17 17 Shawn Ingersoll Shawnwingersoll@gmail.com   Oregon It is my sincere opinion that the metals listed on this temporary rule are lacking. It is highly important that all toxic metals (or materials that we do not yet know their impact, include the precautionary principle here) used at these facilities be known to EQC and DEQ and that they are added to this list. In addition, any new metals in the future that have not been used in the past or currently should also be reviewed for inclusion when and if that time comes. They may be able to install a bag on one furnace, make the glass with the limited defined metals at this furnace, and still use other unfiltered furnaces on other toxic metals that were never included. Allowing for continued human and environmental damage despite this ruling.

Questions related to this concern:
What if they increase production of other metals like Lead?
18 18 Concerned Parent voiceofathena@yahoo.com   Oregon I support Clean Air AND Bullseye & Uroboros — Glass Makers are NOT the Enemy

I am a SE Portland native, an artist, and a mother. I care deeply about these issues, and support a rational fact based approach to reducing air toxics that does NOT target and destroy the art glass world.

I advocate for the State, Regulators, and City of Portland to stop feeding the “glass crisis� media blitz, and work cooperatively with ALL industrial source points equally and rationally in a way that improves air quality AND protects the lively hood of employees and artists.

Hasty regulations, made in reaction to fear and misinformation, which are dominating public discourse, do not protect public health.

The EPA has standards. Part of the current misinformation is that nothing is known about glass manufacturing emissions. When in truth quantitative standards have already been created. Part of the controversy lies in that “periodic or pot furnaces are not part of the source category. The final rule applies only to glass manufacturing plants that operate continuous furnaces and use one or more of the glass manufacturing metal HAP as raw materials.� and therefore these standards have never been applied to the artisan glassmakers in Portland.

But the formulas and acceptable levels already exist. pg 5 – “The Glass Manufacturing area source category was listed for regulation under section 112(c)(3) for its contribution of the following urban HAP: arsenic, cadmium, chromium, lead, manganese, and nickel. The glass manufacturing final rule requires each new or existing affected furnace to comply with a PM emission limit of 0.1 gram per kilogram (g/kg) (0.2 pound per ton (lb/ton)) of glass produced or an equivalent metal HAP emission limit of 0.01 g/kg (0.02 lb/ton) of glass produced.�

What would make more sense, and seem reasonable for all sides, is that with the lack of DEQ standards, they not scramble to reinvent the wheel, and fall back on using EPA standards to calculate the allowable usage of these metals, allow Bullseye Glass and Uroboros to resume operations within this usage while continuing to report raw materials consumption and monitor ambient air. In addition, DEQ should continue to work with these glass companies, which have been more than willing to cooperate, to make improvements that would reduce overall emissions in a fact based and scientific way, allowing them to remain financially viable employers while investing in filtration and control technology that will improve the industry as a whole and ensure public health. These standards are available here: https://www3.epa.gov/ttn/atw/area/fr26de07.pdf

As I have followed the unfolding of this story, and watched neighbors griped with fear turn away from civil discourse and solutions, instead embracing misinformation and anger to attack and suppress any dissent to their narrative, going so far as to personally attack, slander and threaten – I have been afraid to speak out in dissent, and that is a terrifying thing in a democracy. The loudest voice is not always the most accurate, it takes all of us to make this city what it is — we need to stop letting fear divide us and focus on facts and whole truths.

Sincerely,
A Concerned Portlander, Mother, and Artist
19 19 Henry Grimmett Ghanalytical@gmail.com GH Analytical Labs OR After a review of the literature and the epa study I find the response by both the public and the legislature to be hysterical. Certainly we want to protect the publics health and keep cadimum and other heavy metals out of the environment but theses rules probably do neither. First, the glass companies have general been good neighbors providing jobs, spending money with other local companies and supporting various non profits. They have all keep emissions within legal limits. If you elect to change those limits it should be across all industries not just 5 or 6 glassmakers, some of whom are very small. Second, the rules need to have a phase in which has been the historical norm, not a do it now or close. Finally, there needs to be a rational for demanding these extraordinary expenses, it can't be because some neighbors are on a crusade. One glass plant, located only in an arsenic hot spot actually uses no arsenic but is located next fodoor to a Styrofoam melting facility and across the street from an asphalt recycling plant, the most probable source. To close them down or require them to invest $500,000 won't make an iota of difference for the health of the neighborhood but would eliminate 20 good jobs. Now's not a good time to use a hammer even if it would get a few members of the public of your back.
20 20 Robin Denburg robin@realtyrobin.com self Oregon I would like to request the following changes to the proposed rules:

o lower the amount of emissions triggering the required baghouse from 10 tons (a massive amount!) to 1 ton.

Reason- if I live next door to an entity emitting 9.9 tons of a heavy metal I'm going to trigger the same emergency situation. 10 tons was arbitrarily chosen and is much too high.

o include all heavy metals, not the limited list as currently drafted by DEQ staff.

Reason- scientific evidence is clear that metals like, for one example, nickel is a significant health risk. It is not currently included in the rule language. Additionally the cost to a glass maker is not significant to install either a combo or additional baghouse for additional heavy metals.

o have the rules apply statewide, not just the Portland area

Reason- other cities also have citizens living in proximity to glass makers and other non-glass maker heavy metal emitters. They are also being exposed to an increase in cancer especially if they are in close proximity to a manufacturer.

o This rule really should address heavy metal emitters that are not just glass facilities. So my specific request is that it not be limited to glass makers. Realizing that is unlikely I would request a different emergency rule making session for non-glass maker emitters.

Reason - there is ample evidence in the Forest Service study that non-glass makers are ALSO emitting heavy metals. They need to be addressed just as urgently as the glass makers.

o Direct DEQ in conjunction with the Forest Service to do another round of moss testing in Portland and a first round in various other Oregon cities. And to expand the type of heavy metals being tested.

o Have penalties for violators. The proposed rules have no penalty for violators. This needs to be a component. It needs to be strong enough that someone questioning doing this realizes it's better to install a relatively inexpensive baghouse.

I would suggest a fine of $50,000 per violation.

o Add third party monitoring language, paid for by the emitter. There is no language addressing testing pre or post installation of a capture system. This should be part of the permit fees and the work should be independently done, by someone like EPA or Linda George.

o Direct DEQ staff to study in detail California air quality standards. This should be both for glass makers as well as all heavy metal emissions.

Reason- there is no need to reinvent the wheel and California has a process and regulations that work and work effectively. They are recognize by the federal government as largely best in class standards.

Thank you in advance for your evaluation of my comments.

I would also like to have DEQ staff specifically respond to:

o Why was 10 tons chosen as the limit? Was it an arbitrary number? If so why is it just a massively high amount?

o Why are the rules not addressing the entire state?

o How were the type of heavy metals included in the language chosen? Why, specifically, were other heavy metals like nickel excluded?
21 21 Annie Ray 2annieray@gmail.com n/a OR Yes small manufacturing should be regulated. Kudos for gathering actual field data! Now for the big manufacturing, the elephant in the room is Precision Castparts. The public must demand the same standards of real time air & soil monitoring along the Johnson Creek locations. The public has the right to know the volume of toxic air releases that are allowable by DEQ permit. The public has the right to know the tonnages of heavy metals & the long term consequences of living near by the most toxic polluter of Portland. Also all the subsequent smelters throughout the area that work in conjunction w/ Precision Castparts need monitoring & no doubt contribute to the heavy metal toxic load that Portland suffers from. The relationship of DEQ & public health has to be taken into account around all these issues!
Please equip the DEQ monitoring station on SE Lafayette with toxics monitoring equipment.
thank you for your attention
Sincerely, Annie Ray
5806 SE Rhone St
PS We have pregnant daughter living close to Precision Cast Parts & have 2 special needs grandchildren with neurological problems.
22 22 katherine saunders katefsaunders@gmail.com lewis creek glassworks Oregon I am writing concerning the recent Oregon Environmental Quality Commission’s meeting to discuss Administrative Rules Chapter 340, regarding changing air quality rules in light of recent air quality issues in Portland.
It is clear that some regulations need to be changed concerning air quality and manufacturers of colored glass in Oregon, but I think that any regulatory decisions must come from sound scientific study and are not hastily made reactions due to public pressure and speculation.
Bullseye has recently concluded, after careful scientific research, that their use of chromium III is safe. Chromium III does not turn into chromium VI in their factory. To change the current air quality regulations to prohibit Bullseye from using chromium III is not based on any scientific data and will have a serious, perhaps fatal, impact on the ability of Bullseye to continue in business.
Bullseye has already begun the process of installing better air quality systems and should be applauded for its immediate response to the air quality situation.
Bullseye has been a conscientious and responsible business in Portland for many, many years. It employs a lot of people. Bullseye is recognized worldwide for its highest quality fusible glass, which it spent years developing. As a glass artist, I have already felt the impact of their voluntary suspension of certain glass colors. It will have a worldwide impact on many, many people.
DEQ has a responsibility to both the citizens of Oregon and to the businesses that lie within the state. It will be possible to satisfy both groups if the process of making sound legal and science based decisions are followed. More time and input on the facts needs to happen, and judgement made only after all the scientific data is studied.
Thank you for your time and consideration on this important issue.
Kate Saunders
Lewis Creek Glassworks
P.O. Box 1007
Neskowin, Oregon 97149
23 23 Julie Carrico Jakcarrico@gmail.com   Oregon These rules will put an extreme hardship on all glass manufacturers when there is no scientific reasoning to suggest that such a hardship is necessary. After initial soil results came back as very low risk, it should have necessitated more in depth research into what is needed. Bullseye and other glass manufacturers are working towards installing filters, which will further reduce risk. These temporary rules are overly burdensome and not needed.
24 24 Nancy Sala Kaleidoglass@gmail.com   NM The DEQ needs to make decisions based on scientific findings, and not on political motivated opinions. The rules the DEQ is proposing will affect a company that has followed all regulations, will affect their employees, and most of all, will affect artists from all over the world. Do do this for political reasons.
25 25 Paul Ruscher ruscherp@lanecc.edu Lane Community College Oregon I am writing as an atmospheric scientist who has taught graduate level atmospheric chemistry before. I am writing in support of the need for new requirements for monitoring and modeling with respect to the possibility of heavy metal air contamination near manufacturing facilities that are involved in production of colored art glass. Such contaminants are demonstrated health hazards and even though EPA has not yet necessarily established federal guidelines for minimum acceptable risk for all of these contaminants, it does not mean that they are not harmful. Public health studies on the risk of hexavalent chromium and cadmium in particular, are numerous, and DEQ's proposed rule is a good start to address them. There are over 6,000 studies on cadmium and other heavy metals in the literature just since 2012, and over 800 on hexavalent chromium.

My primary concerns with the proposed rule is the lack of specificity as to the monitoring and modeling requirements imposed on the manufacturers and the lack of specification as to filtration. There is a great burden on DEQ to use best practices here with respect to each of these items, and there is also uncertainty as to what will be acceptable. For example, atmospheric stability and wind direction and speed will all have a bearing on the resultant plume for any escaping contaminant from any source. Under stagnant flow conditions, so common in the Pacific northwest, concentrations can be quite localized to the facility and quite intense. Dilution will naturally occur when ventilating winds and mixing occurs under less stable conditions, perhaps reducing the risk near the facility, but broadening the plume. The proposed rule could be strengthened if some details as to appropriate modeling and monitoring procedures are specified. Both mobile and fixed sampling should be contemplated for known large sources.

In addition, I am concerned about the apparent restriction that the rule defines with respect to two facilities in Portland. Are there other facilities in the state which should also be required to follow the rule? What if new facilities are started in other areas? The rule should be clarified to indicate that any facility that uses these materials, and perhaps not just in the quantities mentioned, should be subject to the rule.

Finally, there may be motivation here by people in the Portland metropolitan area to create a regional or county air pollution authority. This makes some sense in the context of an airshed, which does not respect county boundaries. If there were a true regional approach here, it would have to involve multiple counties in the Portland area, including those north of the Columbia River.

My comments are not designed to be representative of those of my employer or my professional affiliation with the A. M. S.

Paul Ruscher, PhD, Fellow, American Meteorological Society (A. M. S.)
Dean, Science Division, Lane Community College
26 26 Paul Ruscher ruscherp@lanecc.edu Lane Community College Oregon I am writing as an atmospheric scientist who has taught graduate level atmospheric chemistry before. I am writing in support of the need for new requirements for monitoring and modeling with respect to the possibility of heavy metal air contamination near manufacturing facilities that are involved in production of colored art glass. Such contaminants are demonstrated health hazards and even though EPA has not yet necessarily established federal guidelines for minimum acceptable risk for all of these contaminants, it does not mean that they are not harmful. Public health studies on the risk of hexavalent chromium and cadmium in particular, are numerous, and DEQ's proposed rule is a good start to address them. There are over 6,000 studies on cadmium and other heavy metals in the literature just since 2012, and over 800 on hexavalent chromium.

My primary concerns with the proposed rule is the lack of specificity as to the monitoring and modeling requirements imposed on the manufacturers and the lack of specification as to filtration. There is a great burden on DEQ to use best practices here with respect to each of these items, and there is also uncertainty as to what will be acceptable. For example, atmospheric stability and wind direction and speed will all have a bearing on the resultant plume for any escaping contaminant from any source. Under stagnant flow conditions, so common in the Pacific northwest, concentrations can be quite localized to the facility and quite intense. Dilution will naturally occur when ventilating winds and mixing occurs under less stable conditions, perhaps reducing the risk near the facility, but broadening the plume. The proposed rule could be strengthened if some details as to appropriate modeling and monitoring procedures are specified. Both mobile and fixed sampling should be contemplated for known large sources.

In addition, I am concerned about the apparent restriction that the rule defines with respect to two facilities in Portland. Are there other facilities in the state which should also be required to follow the rule? What if new facilities are started in other areas? The rule should be clarified to indicate that any facility that uses these materials, and perhaps not just in the quantities mentioned, should be subject to the rule.

Finally, there may be motivation here by people in the Portland metropolitan area to create a regional or county air pollution authority. This makes some sense in the context of an airshed, which does not respect county boundaries. If there were a true regional approach here, it would have to involve multiple counties in the Portland area, including those north of the Columbia River.

My comments are not designed to be representative of those of my employer or my professional affiliation with the A. M. S.

Paul Ruscher, PhD, Fellow, American Meteorological Society (A. M. S.)
Dean, Science Division, Lane Community College
27 27 Paul Ruscher ruscherp@lanecc.edu Lane Community College Oregon I am writing as an atmospheric scientist who has taught graduate level atmospheric chemistry before. I am writing in support of the need for new requirements for monitoring and modeling with respect to the possibility of heavy metal air contamination near manufacturing facilities that are involved in production of colored art glass. Such contaminants are demonstrated health hazards and even though EPA has not yet necessarily established federal guidelines for minimum acceptable risk for all of these contaminants, it does not mean that they are not harmful. Public health studies on the risk of hexavalent chromium and cadmium in particular, are numerous, and DEQ's proposed rule is a good start to address them. There are over 6,000 studies on cadmium and other heavy metals in the literature just since 2012, and over 800 on hexavalent chromium.

My primary concerns with the proposed rule is the lack of specificity as to the monitoring and modeling requirements imposed on the manufacturers and the lack of specification as to filtration. There is a great burden on DEQ to use best practices here with respect to each of these items, and there is also uncertainty as to what will be acceptable. For example, atmospheric stability and wind direction and speed will all have a bearing on the resultant plume for any escaping contaminant from any source. Under stagnant flow conditions, so common in the Pacific northwest, concentrations can be quite localized to the facility and quite intense. Dilution will naturally occur when ventilating winds and mixing occurs under less stable conditions, perhaps reducing the risk near the facility, but broadening the plume. The proposed rule could be strengthened if some details as to appropriate modeling and monitoring procedures are specified. Both mobile and fixed sampling should be contemplated for known large sources.

In addition, I am concerned about the apparent restriction that the rule defines with respect to two facilities in Portland. Are there other facilities in the state which should also be required to follow the rule? What if new facilities are started in other areas? The rule should be clarified to indicate that any facility that uses these materials, and perhaps not just in the quantities mentioned, should be subject to the rule.

Finally, there may be motivation here by people in the Portland metropolitan area to create a regional or county air pollution authority. This makes some sense in the context of an airshed, which does not respect county boundaries. If there were a true regional approach here, it would have to involve multiple counties in the Portland area, including those north of the Columbia River.

My comments are not designed to be representative of those of my employer or my professional affiliation with the A. M. S.

Paul Ruscher, PhD, Fellow, American Meteorological Society (A. M. S.)
Dean, Science Division, Lane Community College
28 28 Paul Ruscher ruscherp@lanecc.edu Lane Community College Oregon please see attached. deq-art-glass.docx https://data.oregon.gov/views/trwb-z8xe/files/16326f11-46a9-45ae-a929-0da3afb8813b
29 29 Debbi Elmer Debbi@timberidgeglassworks.com Timberidge Glassworks Texas It is alarming to me that the DEQ would consider implementing the proposed overreaching regulations on the glass manufacturers there in Oregon. Bullseye Glass has been an upstanding business in the Portland community and has quickly begun to take actions by installing filters to ensure safe operation. To enact hasty regulation does nothing but hurt the glass industry worldwide...especially when scientific analysis has shown that no harm has been done. The regulations will have far reaching effects. Already, we are experiencing shortages of glass colors. Business impacts are huge on the small business owner. For Bullseye employees, this could impact their livelihoods and families. Safety is paramount. However, no one has yet proven that any damage has been done. Please do not regulate unnecessarily. Thank you.
30 30 Rob Wilcox porteavant@gmail.com none Oregon The document does not specify how and where the ambient concentration limit of metals is to be measured.

Is it an instantaneous measurement? Does the equipment need to gather a volume over time to compute an average? Are the averages broken into time buckets where the ambient measurement cannot exceed the limit? Is there a specific piece of equipment operated a certain way that determines the implementation of the limit? Are you referencing a published standard for measuring from another agency?

It will be important to provide references used to set the ambient air concentration numbers, and explain them to all of the stakeholders.

Thank you for your quick work on this project, looking forward to the long term rulemaking and best regards.
31 31 Martha Wittstruck witt44@charter.net Normandale Community College MN I urge you to look at the science and not the headlines when you make your decision about limiting the use of certain metals used by the Bullseye glass company. Bullseye is a respected leader in glass production for kiln glass artists. Regulations that would severely limit Bullseye's ability to produce glass would have a catastrophic world-wide effect on glass artists, educators, craft business, and the entire glass industry.
Please do not destroy an amazing company.
I believe Bullseye Glass to be good steward of the environment and that claims about pollution are exaggerated and inflammatory. Bullseye is not a bad actor but a responsible community oriented company. Singling out Bullseye and other glass manufactures for punishment without regard to facts and other sources of possible pollution is not only unfair but solves nothing.
32 32 Bob Leatherbarrow bob.leatherbarrow@gmail.com Leatherbarrow Glass Studio British Columbia, Canada Bullseye is the world leader in suppliers of glass and related products for kilnformed glass. I believe they have acted in a responsible manner in light of the Feb 4 report on toxic emissions, and I trust that they are genuine in their commitment to reduce future emissions. Mt main comment is that every effort should be made to enable Bullseye and other glass manufacturers to enable them to continue creating glass for the worldwide market. Please use science and environmentally sound practices in your decision making.
33 33 Jessica Applegate applegatebrown@msn.com Eastside Portland Air Coalition OR * 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.
* City of Portland and Multnomah County adopted the precautionary principle in 2004/2006. Please be reminded of that commitment. http://www.sehn.org/pdf/portland.pdf
34 34 Jessica Applegate applegatebrown@msn.com Concerned parent Oregon * 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.
* City of Portland and Multnomah County adopted the precautionary principle in 2004/2006. Please be reminded of that commitment. http://www.sehn.org/pdf/portland.pdf
35 35 Maeghan Culver mculver@nwim.org Northwest Integrative Medicine OR To Whom It May Concern,
I appreciate the care the DEQ is taking in finding the cause of the heavy metal exposure to the Portland area citizens and environment. As a physician with extensive training in environmental medicine and treatment of toxicity, it is imperative that we address sources of possible exposure, such as those found near Bullseye and Uroboros glass manufacturing plants. However, based on recent OHA findings, the data suggests that the actual short-term risk to citizens is negligible, suggesting that we have time to take corrective action.
Furthermore, as is mentioned in the summation on the DEQ website, the DEQ has previously recognized that the level of risk is proportionate to production size. From previous legislation, it seems that both of these companies were following the permitted processes, yet these companies have been targeted by the media as companies poisoning their neighborhood. Large glass production companies will need to adjust their production methods to control for heavy metals, but the application of these methods should be proportionate to the risk they pose to the public, just as it has been.
I am concerned that by acting drastically in response to the sensationalism of the news, this current emergency measures may jeopardize the well being of local businesses and the job positions they provide in my community. As a policy is developed, tiered requirements should be proposed, based on the level of risk of exposure (ie quantity of harmful materials use). It would also be beneficial to allow time to implement changes, especially considering that there is no proposed short-term harm from the current levels of exposures.
I greatly appreciate your time and consideration of this and trust that the DEQ will work to find a solution that takes all parties, citizens and small businesses, into consideration.

Sincerely,
Dr. Maeghan Culver
36 36 Juanita Remien jmremien@gmail.com   Oregon I support setting operation standards for glass maker manufacturers to require best available filtering technology installed. I support making these rules permanent. Additionally I would like Oregon to adopt comparable standards for air quality to California and Washington, including barring diesel engines.
37 37 Ronald Parvin Winecg@yahoo.com Glass artist Oregon The electrical furnances used to produce borosilicate colored glass are much different than furnances fueled by gases. There is not the turbulence during the batching process or during the actual melt process with electric furnances. They also operate on a smaller scale in volume.
38 38 Blake Peterson BlakeGPeterson@gmail.com   Oregon There is no immediate health risk. The recent Oregon Healthy Authority (“OHAâ€�) 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.â€� OHA also concluded that current data shows “long-term health risks are relatively low.â€�

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.�

DEQ’s and OHA’s own statements provide that the rule is not needed to prevent “serious prejudice to the public interest.�
39 39 Anthony Longo aclongo@verizon.net RAINBOW ART GLASS, INC. NEW JERSEY We sincerely hope that no "knee-jerk" reactions will take place and initiate economic crushing rules to our small industry. I have 20 employees who rely on the products that Bullseye manufactures in order to meet mortgages and rent. Shouldn't common sense regulations that are based in scientific proof be put into place that protects all citizens while also looking out for those same citizens who rely on Bullseye to survive? I am a family man also and worry about my children's health all the time, but have to be mindful of the truth, not subjective views from other non-experts, when responding to concerns. I hope these temporary rules are reviewed again to take into account the actual test results in the area and corresponding scientific models. Thank you.
40 40 Marjorie Wippel gwippel@dlartglass.com D&L Art Glass Supply CO I feel these temporary regulations are made in haste out of fear and panic without the scientific evidence to support these restrictions. The survival of two of the most important glass manufacturers in the country, let alone the world, are at stake! Please, please take a closer look at the situation and reconsider such extreme action at this time pending further research on this subject!
41 41   Bonig Nancy@bonig.com Nancy Bonig Glass Studio Colorado 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. I will go out of business if you close this factory because I use only their product. My friends in the glass industry will also have to close their doors, the friends I have at Bullseye will lose their jobs and all because of undocumented speculation. Please consider the economic impact on the immediate community and the larger art glass community.
42 42 Diane Miller dianemillertx@sbcglobal.net   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. LaCourse, 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.

Unreasonable fears should not trump reason-based solutions. The health and safety of the community can be achieved without forcing these businesses to close.
Instead of a hasty and discriminatory temporary rule, DEQ’s should focus on permanent rules, based on scientific investigation and a thoughtful process to address Portland’s air quality issues.

Please don't make the glass companies scapegoats for unsubstianciated health risks, and wait until all the data collection and studies are completed rather than imposing temporary rules.
43 43 Karen Young kareneyoung@yahoo.com   California Regulatory decisions must be based on science, not political issues.

The Oregon Environmental Quality Commission should only consider a temporary rule when credible evidence demonstrates a rule is needed to prevent “serious prejudice to the public interest.� This is not the case here.
44 44 Paul McNulty mcpaulty@yahoo.com Bullseye Glass Co (R&E) Oregon My employer quoted scientific evidence of Dr. LaCourse as proof that Cr (III) doesn't convert to Cr (VI) in the 'Glass melting process'. BUT - the report fails to mention any form of Chrome bypassing the melt due to being a very fine particulate. Can non-glass bound (raw?) Cr (III) become Cr VI? It is all assumptions at this point. I highly recommend the following test to prove/disapprove prior to the new temporary rules:

Run 1%-1.5% Cr (III) batch from non cullet source.

Collect 12 hour exhaust as per:

EPA Method 0061 (Hexavalent Chromium (Cr+6) in Stack Gas Emissions)

Analytical proof ~ rather than a report from a board professor.

Thanks,

-P
45 45 Abigail Spring abi@abispring.com Abi Spring OR I am confused by the DEQ's desire to make a temporary ruling regarding the use of Chromium 3 in their glass. From my understanding this kind of ruling is only appropriate when there is an immediate threat to public health. The OHA has not found this to be the case.

Further, your motives seem extremely political rather than science or public interest based when you look at the fact that in 2013 when Precision Castparts was found to be the number ONE toxic air polluter in the country and nothing was done to them, no temporary ruling was passed, at that time.

I am an artist. And yes I do work with glass, but Bullseye's survival wouldn't have much of an effect on me since I get the bulk of my glass from other sources. What does affect me is that our states DEQ and EQC seem to be operating with little knowledge of what they are making decisions about. At a recent DEQ EQC meeting, correct me if I am wrong but the EQC commissioner did not know what baghouse filtration was. As a member of the general public, not someone making decisions about environmental regulations, I know what is.
46 46 Sally Alferink Tez Sallytez@yahoo.com Bullseye neighbor Oregon In addition to arsenic, chromium, and cadmium, please also set a temporary rule for the regulation of other toxic materials used such as lead which was elevated in the air monitoring done in October 2015.
Please ensure that Bullseye uses the best possible technology for any filter installation and pays for this to essentially close the 2007 exemption it got.
47 47 Leah Busch leah@brazeestreetstudios.com Brazee Street Studios Ohio Please do the proper research before limiting production of Bullseye Glass. I run a business that relies on Bullseye, and if their production is cut, so is my job and that of 10 others. Bullseye has gone above and beyond to keep their glass "green". Please let them continue to improve their factory processes as they have been doing for 30 years.

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.

Please consider your actions and the people (and families) they will harm.

Leah Busch
48 48 Lataya Dailey daileytay@hotmail.com   OR First, thank you for forming these temporary rules to stop the exposure of toxic emissions from Bullseye and Uroboros Glass. As well as to address other glass-making companies.

There are a few points I hope will be changed before the rules are approved. Below are my concerns.

--Please prohibit chromium III as well if the glass-making furnaces are not equipt with emission controls since it produces chromium IV when heated.

“If DEQ does not deny or approve the Notice of Intent to Construct within 10 days after receiving the Notice, the Notice will be deemed to be approved.� ---Please hire enough staff at DEQ to review all notices of Intent to Construct.

“Each CAGM must perform the following source testing on at least one controlled glass-making furnace.�
--Please have all glass-making furnaces tested to insure all are operating within guidelines.


“(1) CAGMs may not use arsenic, cadmium or chromium VI in raw materials in any glass-making furnace that is not controlled by an emission control device DEQ approved.�
--Please add chromium III since it produces Chromium IV when heated.

“For the purpose of establishing a maximum allowable chromium III usage rate, the following are required:
(a) Performing a source test in an uncontrolled furnace or at the inlet of an emission control device as specified below:
(B) Test while making a glass that DEQ agrees is made under the most oxidizing combustion conditions and that contains a high percentage of chromium III as compared to other formulas the CAGM uses;�
--Please alert the public in the surrounding area to the date of this test since the furnace will be uncontrolled at time of test.

--Please have a DEQ staff member preform all tests not company employee.

--Please set fines for non-compliance
--Please make sure all glass-making furnaces are required to have emission control units.

Thank you,
Lataya Dailey
49 49 Amy Ferber Amyferber@bullseyeglass.com Bullseye OR Glad I can comment, buy glass!    
50 50 Eric Swanson eric@ericswanson.com Eric Swanson Photography NM As a consumer of Bullseye Glass products I have found this company to be responsible and concerned with the manufacture and sales of their product. I believe that this hearing needs to be based on actual air quality monitoring standards and real unbiased scientific study. 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.
51 51 Chasity Logan cglogan@ilstu.edu     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.
52 52 Janet Brocklehurst janetbrocklehurst@gmail.com Sweet Harmony Jewelry Design Vermont I use Bullseye glass almost exclusively for my business. Please allow more testing for permanent rules to be scientifically based, not these temporary rules which seem unfair and not based on scientific evidence.
53 53 Roger Nachman Roger@nachmanglass.com Nachman Studios LLC WA 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.
54 54 Stephen Edwards glassman@alfred.edu Professor Emeritus Alfred University New York I am a emeritus professor of glass art and engineering at Alfred University.
There is absolutely no evidence of a threat to public health by Bullseye and Urobos glass plants in Portland. They provide valuable jobs and resources to the region that will be threatened if these regulations are put in place. These chrome bearing glasses and cadmium selenium glasses are perfectly safe to melt !!!!!
55 55 Sarah Lundin Sarah.lundin@gmail.com   Oregon As a glass artist and lifelong resident of the Portland Metro Area, I strongly beseech your department to proceed with careful, calculated, science-based consideration of the long-term goals of improved air quality in regards to the glass manufacturing industry. Any impromptu or speculative measures taken at this point in time, against reasonable and concrete validation of actual risks of harmful pollution will have damaging consequences on many levels. Hasty, ill -conceived measures have a nasty habit of setting irrevocable precedent.
56 56 Sam Grillmeier rengls@att.net Renaissance Glass Studio Ohio Having read all the pertinent information on these temporary rules I believe they are in haste and would due more harm than good. Scientific evidence does not support the need for these. Co-operation between all entities involved should continue until a just solution is found. Knee jerk laws are hast and counter productive.
57 57 Sara Dolph CPA sara@saradolphcpa.com Wilson Design Studio Tennessee Bullseye has always been one of the most publicly responsible companies in the United States.

Are you people unaware of the scientific evidence that supports Bullseye's position? You should base your decisions on science rather than some ill-founded biased positions of selected persons.

I would think that Bullseye is an important and contributing member of your business community and you would want to work with them to solve any problems, rather than try to drive them out of business. You must also be completely oblivious to how many persons they employ and how many families you would impact by driving them out of business, not to mention the thousands of us glass artists that depend upon their products.

I stand with Bullseye Glass in its efforts to continue operations as a responsible citizen of the social and business community of Portland, Oregon.
58 58 D Germana djgermana@yahoo.com   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.
59 59 John Mckinley 217682LR@hotmail.com Glass House Oregon These glass companies make so much money and have hundreds of products to sell, not having greens or a few other colors will not greatly impact their operation. They will suffer a little less profits but the public will have piece of mind that they are not being poisoned.
60 60 Joey Fisher Joey_t77@hotmail.com   VA Please do not prevent Bullseye from continuing to mfg glass. It would eliminate half of their product line and cause serious issues in the stained glass and fused glass industry.
61 61 TERRY LITTLE tlittlehhord2@yahoo.com buyer of bullseyes glass n/a Agree the environment and the health of people are important. That the health of the public and the workers at Bullseye is also important.

The problem is temporary rules tend to just lay there and de facto become "law". I do not support this temporary ruling. I would support a third party of experts to set out a .program for confirming if there is a problem from wherever it is coming from and how to fix it.

Thank you for your kind attention and consideration of my personal and independent opinion. Terry Little
62 62 Nancy Oudegeest Business@oudegeest.com   California Before putting large numbers out of work and small businesses out of business do your homework. Let the facts and science determine your moves not fear.
63 63 Ann Bauman Annbauman@sbcglobal.net   California It appears that DEQ is initiating this temporary rule-making in response to news articles that show DEQ in a negative light. It also disregards the fact that Bullseye is a good corporate citizen and has demonstrated its willingness to work with DEQ. Hastily adopting temporary rules make it appear that the agency is being proactive, but these rules do not protect the public, and makes Bullseye a scapegoat. There is no evidence that emissions from the facility pose any acute health risk nor that Bullseye is fully responsible for the emissions, nor 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.
64 64 Peggy O'Hara Pegleg7240@gmail.com Pegleg's Treasures NY I am a glass artist who will be directly affected by your decisions. I sell a Celtic knot bowl made specifically with Bullseye green glass.
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.
65 65 Janis Capraro jcapraro@verizon.net Mountain Wave Studio 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.
66 66 Joan Kraus jnskraus@cox.net   CA Your attack on glass production is irrational! Bullseye does not endanger air quality, and your attack will cause a loss of jobs and probably a company. I am an environmentalist, but this is crazy!
67 67 Michael Miro michael@miroglass.com Miro Glass Art Studio New Mexico I understand there is some temporary regulations directed at the Bullseye Glass facilities. I know that Bullseye are extremely conscientious and their research and development is front and foremost in their production of glass. I think they know more about what they are doing than those who are not in the industry. I hope actions will not be taken by uninformed fears and suggest that regulators not unnecessarily restrict and work closely with Bullseye Glass and others in the industry.
68 68 Michael Miro michael@miroglass.com Miro Glass Art Studio New Mexico I understand there is some temporary regulations directed at the Bullseye Glass facilities. I know that Bullseye are extremely conscientious and their research and development is front and foremost in their production of glass. I think they know more about what they are doing than those who are not in the industry. I hope actions will not be taken by uninformed fears and suggest that regulators not unnecessarily restrict and work closely with Bullseye Glass and others in the industry.
69 69 Maura Allen mauraallen@mac.com Artist CO Science trumps politics. Science -- not conjecture -- should be the driver on decisions relating to environmental and health issues. Better regulations may be needed, but the temporary ones are not. The consequences on small business (including loss of jobs and loss materials to artists worldwide) are severe and unnecessary. Bullseye glass has a long history of responsible operation. The culture of the organization is exemplary--everything they do, from education to production is above and beyond industry standards. I stand with Bullseye Glass in its efforts to continue operations as a responsible citizen of the social and business community of Portland, Oregon.

I strongly urge DEQ to rely on science and fact, and not to rush to impose these temporary rules.
70 70 Valerie Larson-Lohr larsonlohr@me.com Fire and Glass Design Texas Please make your decision concerning the two glass manufacturers based on scientific fact, not political pressure or fear. The science is there is solid evidence that the manufacture of the glass does not put the population at 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.�

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.�

DEQ’s and OHA’s own statements provide that the rule is not needed to prevent “serious prejudice to the public interest.�
71 71 Karla Fears kpfears@gmail.com search site Virginia Science before emotion. This country already lives in an environment of fear. Please do not add to that by hair trigger reactions. Let someone who is unbiased do testing to ensure the folks at Bullseye and other glass making industries don't have to go out of business. Many artists, like myself, depend on them. Livelihoods will be destroyed based on an environment of fear and that's not what built the United States.

Karla Fears (no one or nothing)
72 72 judy luther judyl13@q.com The Glass House (business) Oregon Historically (ancient, Egyption) glass has been important to civilization. This interest alone makes me a glass advocate. Oregon (coastal artisans/businesses) piqued my interest in this medium. Scientific laboratory chemical production of glass mirroring God's plentiful supply of silicon (sandy beaches) make it a natural product. We need this cottage industry in Oregon. It is a 'clean' industry. The I-5 Corridor is NOT a clean industry...make that your priority...not Bullseye Glass.
73 73 judy Fisher Judy@seejudyfisher.com Ju-Ro Glass Creations South Carolina I am retired and supplement my in me with my fused glass creations. Already my business has been adversely affected by the stoppage of red glasses until an environ,eo tally safe solution is in place. Now, as I understand it, you are suggesting temporary cessation of green glass unti,such t,e as, who - you?, determine IF ther is even an issue with the Che,is try I'm green glass. ?????


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.
74 74 Karen Reece beadkrap@yahoo.com beadKRap Colorado 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.

Thank you for your consideration.
75 75 Manon (Nonnie) Lyketsos nonlyketsos@gmail.com Radiant Glass Studio MD Please do not restrict Bullseye's ability to produce glass until you have solid evidence of danger to people and the environment. I make my living using Bullseye glass and unnecessary restrictions for the sake of appeasement rather than fact would unfairly harm my product line, and therefore my income.
76 76 wendy hahn wkhahn@yahoo.com Retired Materials Scientist, Los Alamos National Laboratory New Mexico 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.
77 77 Daniel White white.daniel0284@yahoo.com   VA The DEQ should only make rules based upon FACTUAL scientific evidence. The soil tested around the facility of Bullseye glass wad found to have NORMAL levels of all heavy metals. Also, your own report didn't show evidence that Cr(III) EVER changed into Cr(Vi), SO NO TOXIC EMISSIONS FROM THESE SMALL GLASS MANUFACTURERS. No temporary rules are needed, but instead do ACTUAL SCIENTIFIC WORK BASED UPON EVIDENCE AND RESEARCH to come up with permanent rules. Your paragraph above is misleading and factually erroneous, and I stand behind companies that have safely operated for half a century, not politically motivated individuals who can't conduct evidence based scientific research. Get your FACTS and THEN make a permanent set of rules.
78 78 Leslie Johnson Adreamaday@q.com   WA Decisions should be based on factual evidence not hasty restrictions made to pacify the public. The ones who are making these rash rules even temporarily should at the very least be given crash courses in glass production and chemistry. By making this unprecedented judgement it shows the DEQ is lacking in both areas. Many rely on Bullseye for jobs, other sources of income and some just the joy of creating. Also why is Bullseye being restricted when they are not the only glass manufacturer? Clearly someone needs to step in and rethink this approach to this situation and find a solution that is realistic. Thank you for your consideration of my opinion
79 79 Steven Stelz stelz@embarqmail.com Stelz Studios NEW JERSEY To Whom it may concern:
I am against a temporary restriction that may be imposed on the Bullseye Glass company for the use of Chromium to produce the green glass pigments found in over 50% of their product line.
It would seriously effect my business here in New Jersey and I would no longer be able to produce ANY of my glass paintings as well as some of my stained glass works. Without the various shades of green coloration to the glass, it would be impossible to produce any kind of significant art piece in glass and I would probably go out of business.
Steven Stelz
Stelz Studios
Flemington, New Jersey
80 80 anne mcelhinney anne3mac@yahoo.com   hawaii 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.
Since there is no immediate threat to community safety, please consider more longterm solution.
81 81 Kuno Egger kuno@retailsoftware.com Salt Spring Gallery British Columbia We depend heavily on Bullseye glass for production of gift ware and a switch to Uroboros glass would require scrapping all our current designs and starting over.

Considering how long Bullseye has been in production may we encourage you not to precipitously shut down big chunks of their product line.
82 82 Luciana Proaño Lucianaproano@msn.com   OR I hace been a client Of Bullseye Glass for almost 18 years and consider myself responsible towards the environment. I think this temporary measure is not supported by enough scientific data and mostly political. It will be too harmful to the livelihood of not only the employees that will have to be laid off but to the many artists and others that survive by using this glass as prime matter. Bullseye is being responsible by conducting research along with authorities and should be given opportunity to survive. It has been there 40 years!
I stand by Bullseye.
Thanks for listening
Luciana Priaño
83 83 Susan Hobbs trcat12@aol.com   Oregon Please take the necessary time to study this issue ... do not race to decide something that probably is making you look foolish ... please don't let hysteria rule the day ... I am a fused glass artist and I do not believe that putting either company out of business is in the best interests of anyone ... please think carefully before you make any decisions
84 84 Pam Stransky Pamskii@hotmail.com Re: Bullseye Glass WA Re: temporary and egregious, overly harsh rules not based on science, will cause extreme hardship to 2 small local business as well as to thousands of glass artisans like myself. There is no justification for such a politically based set of rules. I expect you to reconsider, and after full research cpleted, enact appropriate safeguards rather than business-crushing and draconian rules. Thank you. Pam Stransky
85 85 Linda Bennett lindabennett427@gmail.com The Glass Attic Studio Ontario Canada As a glass artist that has used Bullseye products for over twenty years, I have been following this situation as have many others that depend on Bullseye and Uroboros
After researching various other probable sources of pollution in the Portland area I feel that the temporary rules you are considering are based more on politics and sensational headlines than fact based scientific conclusions.
I find it unconscionable that Bullseye who has been in business for 42 years and has been a responsible corporate citizen ( and who voluntarily shut down production as soon as the "problem" was brought to their attention) should be put it the position of becoming a scapegoat so that the general public is appeased without due consideration to all sources that may be contributing to the air quality problem .
Regulatory decisions should be based on science, not politics. Imposing poorly written and misdirected rules only serves the short term and will affect not only the employees of Bullseye, but tens of thousands of Glass artists, teachers , craftspeople and retailers worldwide. I personally would lose more than half my income if production was stopped for 6 months.
I urge you to reconsider what would appear to be a hasty decision and allow Bullseye to work with the relevant organizations to ensure a viable lasting solution that will be in everyones best interest.
sincerely
Linda Bennett
86 86 Sherry Ann Boyd-Yost sherry_yost@lostartoriginals.com Lost Art Originals WA I am a warm glass artist and am concerned that the cutting of production of Bullseye Glass would hinder my business as I use they're produce in a major amount of my art works.
If the levels of metals are not of concern-able amounts, and a bag house is being installed to prevent the metals getting into the air? It seems very much over kill to keep them from producing much of there line of products, and Possibly putting them out of business. And UN-employing some very fine talent and important research in our industry.
Bullseye has been a very progressive and evolving glass product company, always concerned with safety in there teaching and creating their fine glass product.. From my point of view. This would be a devastating loss. Please look into a reconsideration of these actions. Respectfully, Sherry Boyd-Yost
SBYpsw.2015.doc https://data.oregon.gov/views/trwb-z8xe/files/6fe80c7a-e241-4529-9787-ff1929ccf7bc
87 87 Tamara Coatsworth tami@tlcglass.com TLC Glass Design Idaho I am a professional artist and I have been working with Bullseye products for 25 years. 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.
Oregon should be grateful and supportive to companies that are responsible. I'm sure China would love to step in and take more american jobs.
88 88 Fay Bright fsbright@bellsouth.net Individual Louisiana It seems to me that this temporary ruling may do irreparable harm to the small colored glass manufacturers. Why not let them install their baghouses then test to see if they are causing any metal contamination? Bullseye Glass has been in business for decades. Let them continue in business while this issue is resolved. Causing them to lose 50% of their business for 6 months seems ludicrous and an over reach of the regulators. Is there no common sense to this issue?
I am a customer of Bullseye Glass. Thousands of artists use their products and many others purchase work which they commission.
I hope you will rescind this temporary ruling immediately.
Fay Bright
89 89 Fay Bright fsbright@bellsouth.net Individual Louisiana It seems to me that this temporary ruling may do irreparable harm to the small colored glass manufacturers. Why not let them install their baghouses then test to see if they are causing any metal contamination? Bullseye Glass has been in business for decades. Let them continue in business while this issue is resolved. Causing them to lose 50% of their business for 6 months seems ludicrous and an over reach of the regulators. Is there no common sense to this issue?
I am a customer of Bullseye Glass. Thousands of artists use their products and many others purchase work which they commission.
I hope you will rescind this temporary ruling immediately.
Fay Bright
90 90 Martha Keane     Oregon I urge the DEQ to base their decisions on science and fact, not the fears of the public. It is DEQ and EQC's responsibility to know the science and wait for the results to come back from a wide range of testing instead of making hasty decisions and implementing rules that will have real and lasting impacts on families and communities. I urge you to slow down and take the time to make informed decisions. As a glass artist, I stand with Bullseye and Urobos. As an Oregonian, I am alarmed by what I have seen in the news from my fellow community members and the hasty, uninformed response of the DEQ. As an educated environmentalist, I am confident that a reasonable solution exists that will protect both air quality and businesses, should those in charge choose to seek such a solution.
91 91 Becky Ratliff rbc@ratbone.net Glass artist Montana I am appalled at the proposed knee jerk temporary regs. We all want things environmentally well done.... but not on non scientific rash actions that impact our lively hood, jobs and risk company reputations. Get your facts and then act accordingly but stop the rush to act without facts!
92 92 Debbi savage glassydeb@aol.com Texas Glass Artists Assoc. TX 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.
93 93 Phyllis Crawley pgcrawley@hotmail.com 1410 Fahrenheit - a glass artist Indiana Hello. As a professional glass artist, I would like to say that I don't think you are being responsible about Bullseye Glass Co I'm not sure who is causing this revolt, but I suggest you use your head to look over the scientific information you have been provided. If you close Bullseye down even for 4 weeks, you not only put the producers out of work, you put tens of thousands of artists out of work as well. This would have a huge impact on the economy. Not only in the US,but also across the world. Please think of this logically. Thank you.
94 94 Christine Burris ctburris@aol.com NA District of Columbia I am a fused glass artist working in the Washington, DC area. My work depends on the availability of colored glass in all colors, such as produced by Bullseye. Your state is very fortunate to have this art glass factory producing such high quality glass. Your proposed rules would be be deleterious to Bullseye and perhaps even close their business, all because of emissions which MAY be harmful to humans. Bullseye states that they support "permanent rules, based on scientific investigation and a thoughtful process to address Portland’s air quality issues. Bullseye will support that effort. 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." Any temporary rules should put into place an agreement such as this, guaranteeing that in the future Bullseye must comply in a timely manner with new scientific evidence regarding emissions and public health.

It is my understanding that If Bullseye Glass is forced to stop producing 50% of its glass products for 6 months, without regard to ongoing test results or added emission controls, Bullseye’s survival is at risk. Bullseye supports an agreement that is similar to the temporary rules, but unlike the temporary rules, also allows DEQ and Bullseye to respond promptly to new factual information.

Thank you for this opportunity to address this issue, critical to my artistic endeavors. Christine Burris, Washington, DC
95 95 Joanne Merrick sculpturedlife@gmail.com Winds of Art Studio Oregon Bullseye glass has been doing business responsibly for many, many years. It has been serving the art community and has supplied necessary product to bring about much joy and beauty into our communities and lives. Any changes should be made upon facts, nothing less. There should be NO temporary change nor change at all, without substantial proof of facts. NO wild cannon decisions made on off the cuff information. Provide facts or back off. There is no room for strong arm tactics here. We are watching and we are listening. We are standing against irrational decisions.

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.
96 96 Jessica Wesolek jessica@cre8it.com WOW! Gallery NM One of the things that hurts support of environmental agencies is their constant tendency to go overboard, and act without gathering all the science. This restriction would greatly harm or destroy two companies, eliminate jobs in those companies and also adversely affect the livelihood of thousands of glass artists around the country. Before going off half-cocked for political reasons, try working with these companies to get the true facts and resolve the problem, which they are very willing to do.
97 97 William Grix wgrix@mac.com Wm Grix Art Glass hawaii Hello
The neighborhoods in these areas and the affected families and jobs of the people who work for these companies.should all be considered in these temporary rules. As adopting.these rules even though said temporary. the impact would not be,.I would suggest a monitoring program however frequent to address and discover what is real and what is perhaps only feared. I am sure that the companies in question would not intentionally want harm to come to anybody, not the public or their own employees. This approach would serve all.
Thank you
William Grix .
98 98 Phyllis Crawley pgcrawley@hotmail.com 1410 Fahrenheit Indiana After further investigation of your files, I have determined that you are not paying attention to your own findings. In your reports, it has been determined that there is absolutely no health issue from Bullseye Glass Co. What are you doing? Read your own DEQ reports.
99 99 Melinda Bryden melinda@redfernconsultants.com Redfern-Designs Washington 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.

My livelihood and many other artists will be negatively by harsh unrealistic standards.
100 100 Alice Gebhart alicearts@verizon.net Heritage Art Gallery & Glass Studio RI I am a professional glass artist who makes my living as such. ALL the glass I purchase to make my fused glass art comes from and is made by Bullseye Glass and Uroboros Glass companies. I would be put out of business if your temporary action were to be put into effect. If it were proven that the air quality is harmful or that the current production of glass were harmful, I would understand the restriction but that is not the case. It has been said that "it MAY be harmful" if certain conditions existed, but that is also not the case. There is no evidence to support any kind of restriction.
101 101 Melody Roth mroth97@msn.com   OR his is an improper use of temporary rule making. The Oregon Environmental Quality Commission should only consider a temporary rule when credible evidence demonstrates a rule is needed to prevent “serious prejudice to the public interest.â€� This is not the case here.

Hastily adopting temporary rules make it appear that agencies are being proactive, but these rules do not protect the public, and makes Bullseye a scapegoat. There is no evidence that emissions from the facility pose any acute health risk nor that Bullseye is fully responsible for the emissions, nor 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.

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.�

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. Bullseye will support that effort. 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.

With minor changes to correct scientific errors and omissions in the currently proposed rule, Bullseye Glass is willing to sign an agreement that achieves all of DEQ’s goals and allows DEQ and Bullseye to respond promptly to new factual information.

The haste to adopt technically flawed temporary rules makes it appear that Oregon is repressive to manufacturing businesses and does not care about jobs.

Oregon agencies should strive for proper and fair treatment of all parties, based on law, rather than responding to public concern resulting from sensational blog posts and test results with partial data and no peer review.

The health and safety of the community can be achieved without forcing these businesses to close.

If Bullseye Glass is forced to stop producing 50% of its glass products for 6 months, without regard to ongoing test results or added emission controls, Bullseye’s survival is at risk. We support an agreement that is similar to the temporary rules, but unlike the temporary rules, also allows DEQ and Bullseye to respond promptly to new factual information.

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

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.
102 102 Jocie Braaksma jocie100@yahoo.com Artist 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.
103 103 Marsha Trawick Marsha.trawick@gmail.com Artist studio Texas Bullseye glass supplies thousands of independent artist. We depend on them for our lively hood. This will only push another industry off shore resulting in lost jobs and opportunity in the US. We all want the best environment possible but there has to be some common sense. This should be fully studied before you destroy an entire industry. Have you shut down all bottling companies that use that product? There must be away to come to terms before you destroy so many people.
104 104 Elzbieta Gerla Betty@elzbeads.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.
105 105 Scott Jenkins tsjenkins@mac.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.

We sincerely appreciate any support you can provide right now.
106 106 stephanie nyman stephnyman@gmail.com   Idaho please see the attached letter. Thank you for your time and consideration be glass or deq.docx https://data.oregon.gov/views/trwb-z8xe/files/1d5ee5f6-ed11-40bf-83cc-837bc9a945e8
107 107 Carolyn Ratliff cratliff1957@bellsouth.net self Alabama 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.

Science, not political issues should govern regulatory decisions. According to a leading scientist, Dr. William LaCourse of Alfred University, Bullseye’s furnaces do not produce toxic chromium. I strongly urge DEQ to depend on science and fact, and not to rush to impose poorly written and misdirected rules.
108 108 Matt Vinci mvinci72@gmail.com   CA To whom it may concern,

It strikes me that Bullseye Glass has been there for 40 years. Without rancor I say this: If there are dangerous emmissions from the glass manufacturing process, with certainty you must have a mountain of evidence of the harm it has done to the local population. If you don't have that evidence then isn't the role of your agency to inform the public of that fact, rather than shudder Bullseye?

After 40 years there would have to be a lot of unambiguous material evidence of environmental harm and a long standing surge in health problems related to the compounds in question. Again, Isay this without rancor. I'm not trying to goad anyone there. However, after 40 years, the evidence wouldn't be subtle. It would be a screaming mountian. If that is not there, then enacting rules that would put these glass manufacturers out of business is just wrong. Additionally, not informing the public of the obvious fact that there is no large scale, long standing surge in very dire health problems is irresponsible here.

My two cents.

Sincerely,
Matthew Vinci
Glass Artist
109 109 Bonnie Hinz bonniehinz@gmail.com   MN Bullseye glass supplies colored glass to thousands of independent artists, including myself. We depend on them for our livelihood. We all want the best environment possible but there has to be some common sense. These rules will put an extreme hardship on the glass manufacturers and artists when there is NO scientific reasoning to suggest that such a hardship is necessary. Regulatory decisions must be based on science, not political issues. 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. 
 
110 110 Cheryl Sattler cherylsattler@yahoo.com   Florida Please see attached file. Bullseye environmental letter.docx https://data.oregon.gov/views/trwb-z8xe/files/36c34608-d790-43c1-807e-b50e14e9efc2
111 111 David Colton dhcnic@comcast.net   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 in the social and business community of Portland, Oregon. I support Bullseye Glass because I am a member of the glass art community and because our family has a son who resides in Portland. This issue affects the economic health of Bullseye Glass, a Portland business.

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.

I appreciate any support you can provide at this time.
112 112 Sheri Marshall boeingbabe@gmail.com   MS 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.
113 113 Delores Taylor Pdvgirl@gmail.com   WA I'm disappointed that an entire industry has been placed under attack without scientific support that the glass industry is the cause of pollution without addressing all other industries that are worse polluters. Science should have been done first then meetings with all industries doing their bit to clean up the air not isolating one industry and turning a blind eye to other industries. Also unduly making this about public reaction rather than how science can make Portland a better place to live with all businesses not just two businesses being singled out. The point should be to provide clear and accurate directions that is fair to all.
114 114 Lori Hudson lori.hudson@superiorfarms.com Superior Farms California I feel it is imperative that the decision to limit usage of stated minerals and metal is based on actual scientific data not on speculation. I have read a summary of the results on study done by the OHA taken earlier in the year in Portland. This study stated that minimal emission were documented and levels of hazardous materials emitted were well under hazardous levels. Adopting temporary rules are not the solution. By doing so you are targeting two small companies unfairly. These controls seem technically flawed and are not likely to improve the air quality of Portland. From what I know both of these companies are for improvement of air quality, but these temporary rules will not accomplish this goal.
Both the DEQ and EPA have acknowledged there is not clear evidence of acute or chronic health risks based on the usage of Cr(III). There is no proof that CR(III) will change into a more toxic for of chromium - Cr(VI). Scientific evidence clearly indicates that furnaces heat won't turn Cr(III) into Cr(VI). Do not adopt policies that are not ground in good science.
115 115 Michael Beaman mb@beamanarch.com Beaman Architecture Ltd. Oregon The State of Oregon should be working to find relative common ground in complex issues where public safety is involved and where forthright businesses are concerned. Please accept these comments in support of Bullseye Glass's position:

1. This is an improper use of temporary rule making. The Oregon Environmental Quality Commission should only consider a temporary rule when credible evidence demonstrates a rule is needed to prevent “serious prejudice to the public interest.� This is not the case here.

Hastily adopting temporary rules make it appear that agencies are being proactive, but these rules do not protect the public, and makes Bullseye a scapegoat. There is no evidence that emissions from the facility pose any acute health risk nor that Bullseye is fully responsible for the emissions, nor 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.


2. 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.�

3. 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. Bullseye will support that effort. 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.


4. With minor changes to correct scientific errors and omissions in the currently proposed rule, Bullseye Glass is willing to sign an agreement that achieves all of DEQ’s goals and allows DEQ and Bullseye to respond promptly to new factual information.


5. The haste to adopt technically flawed temporary rules makes it appear that Oregon is repressive to manufacturing businesses and does not care about jobs.


6. Oregon agencies should strive for proper and fair treatment of all parties, based on law, rather than responding to public concern resulting from sensational blog posts and test results with partial data and no peer review.


7. The health and safety of the community can be achieved without forcing these businesses to close.


8. If Bullseye Glass is forced to stop producing 50% of its glass products for 6 months, without regard to ongoing test results or added emission controls, Bullseye’s survival is at risk. We support an agreement that is similar to the temporary rules, but unlike the temporary rules, also allows DEQ and Bullseye to respond promptly to new factual information.


9. 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.
116 116 Guy Whittaker ge.whittaker@gmail.com Retired materials science teacher Oregon This proposal is very flawed. There is no scientific reason to implement this. Bullseye is quite willing to work to correct third issue, working to install necessary bag filtration. Additional restrictions that would effectively cause undue hardship on this company and it's employees is poor judgement on DEQ's part. This proposal should not be implemented.
117 117 Jennifer Higgins mjhiggins143@yahoo.com Higgins Glass Studio Alabama 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.

Not only do your decisions affect your community, but hundreds of thousands of glass artists around the world. This decision could cripple all of us. YOU MUST consider all the facts before making a decision based on scare tactics and politics alone. Test what Bullseye is telling you about their processes before you make more governmental rules that kill our businesses. Find ways of compliance instead of making blanket policies that have long reaching consequences that you haven't considered.
I applaud everyone who truly looks into this objectively and bases their decisions on facts.
118 118 Philippa Rubell psrubell@gmail.com Glass artist California I live in California, as you can see, but have visited Portland on several occasions to take classes offered by Bullseye, and have also visited the Uroborus factory. The glass center, including its factory has always struck me by its meticulous concern about health and safety, with all facilities being carefully vented, waste appropriately disposed of, and a concern for environmental issues in general. While, of course, dangerous by-products should not be allowed to be emitted, Bullseye seems to be anxious to commit to creating whatever new filtering systems are requested, and to comply with all scientifically documented information on the subject.
The issue regarding chromium seems to be scientifically invalid, as the chemistry of the glass manufacture depends on the chromium remaining in its non-toxic form, and there is nothing in the process to engender the formation of the dangerous chromium isotope, in fact processes are in place to prevent its formation. Punishing the the company on the basis of a gut reaction, rather than scientific evidence is unfair, especially in the light of the pollution we are all subjected to on a daily basis by larger enterprises, and a restriction on the use of chromium, which could quite likely close down Bullseye, and the glass art world in general would be tragic. Portland is truly the glass art center of the world now, and this is something to be very proud of. The loss of jobs, a thriving and benevolent company, and an art form would impact the population of Portland, and people like myself who love the products, and need them to continue with our art.
In conclusion, I think it is obviously of benefit to everyone to provide the best filtering processes available, but the banning of the use of chromium, which would make the manufacture of much of the glass palette impossible, is an unproven knee-jerk response. One might as well say let's ban eggs because they contain sulfur. I entreat you to not pass hasty judgement on a company which, while small in the general scheme of things, is huge in the world of art-glass, and irreplaceable. (Or will be once more have to turn to China).
119 119 Lydia Piper lapiper@comcast.net Grand Mesa Studios New Mexico As a glass artist who is a customer of Bullseye Glass, I am dismayed to see the implementation of temporary rules that are targeted to specific companies based on such limited information. The imposition of these rules will greatly impact businesses and individuals around the world, that depend on Bullseye and Uroboros glass production. Therefore, I urge you to do further investigation and work with these companies to find a solution to this problem based on scientific fact, and not react to the emotional responses from the media and public. Your own technicians state that there is no public health concern based on recent testing. Therefore, putting a business at risk by implementing rules that are not based on fact, when so many people depend on it for their livelihood, is irresponsible. I urge you to reconsider these temporary rules.
120 120 Karen Caldwell caldwell877@comcast.net Sundlower Glass Studio NEW JERSEY Please find a way to allow Bullseye to resume production of chromium glass while trying to resolve tis issue. I, along with thousand of other artist will be ourt of business not being able to obtain glass to create our art. I beg you to try to come up with a solution for all of us to survive and maintain our jobs. In the research that I have studied, I do not see the environmental impact which the DEQ has put upon Bullseye Glass. Please do not hold up production for six months. I will have to close my business after 39 years if this happens. Please come up with an agreeable solution soon!
121 121 Teri Shamlian tshamlian@hotmail.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.

Bullseye is willing to make the changes needed to improve air quality, these rules aren't needed. It would be silly to have a rainbow with colors missing. Small glass companies are not the target.

We sincerely appreciate any support you can provide right now.
122 122 Carol Conway handmedownlions@msn.com   Colorado 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.
123 123 Denise Mullen dmullen@ocac.edu Oregon College of Art and Craft 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.
124 124 Denise Mullen dmullen@ocac.edu Oregon College of Art and Craft 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. This rush to unfounded action is disturbing and unprofessional, and makes Oregon look unorganized and ineffective.

I strongly urge the powers that be to act responsibly, on proven science and to not make knee jerk reactions that cause more harm than good and adversely affect another group of innocent people.
Bullseye glass .docx https://data.oregon.gov/views/trwb-z8xe/files/31f47897-ba81-4831-80ad-e54ffca457a2
125 125 Renato Foti renatofoti@gmail.com trio design glass on I use bullseye glass exclusively for my livelihood. I did read the letter re CR 3 , i would ask that you allow Bullseye glass time & ability to allow for modifications or prove the safety of CR3 since it is a critical element in the making of glass used for 100's of raisins globally.
126 126 Lia Howe lia.glass.dream@xplornet.ca Lia's Glass Dreams re:Bullseye Glass Canada I am an artist using Bullseye glass. I have been using it for over 20 years. I have followed the company and its workings for a very long time. I find it very sad to hear that a government agency is choosing to impose " temporary" rules when there is NO scientific proof that this is the source of the areas problems. The science actually shows the opposite is true, please read the work of Dr. William LaCource of Alfred University. By using Bullseye as your scapegoat you are not dealing with the real problem, you are just looking for the easy out. Use some of your government money to study ALL businesses in the area, I am sure you will find another source. Thank You Lia Howe
127 127 kathleen walbridge   KMW Glass Art CA why did it take so long after all these years to inform them. it does not seem fair the way it is being handled?  
128 128 Deanna Muir tanddmuir@bendbroadband.com   OR I am writing this letter in regard to the proposed temporary regulations by DEQ that will severely curtail production by Bullseye Glass co.I am a lifelong Oregonian and have run my own small business in OR for nearly 25 years.
I am strongly against the improper use of temporary regulations by DEQ to control the manufacturing process that does not produce any serious prejudice to the public interest. There is no proven immediate health risk according to DEQs and OHAs own reports. The DEQ should focus on permanent rules based on scientific facts that pertain to all businesses, not targeted specific industries.
Our state agencies must deal with safety for all, but it must be done judiciously and fairly. we need to factor in the importance of employment and income to the state. Bullseye Glass has a long standing reputation as a manufacturer of a quality product and dependable employer in the state. we need more businesses as dedicated as they are to their product and their employees.
129 129 Tara Sawyer taranisan@gmail.com   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.
130 130 Ernest sugden ernestsugden@hotmail.com retired Oregon Please take time to listen to what the studies are showing.    
131 131 Louise Erskine erskine.real.estate@juno.com self MA I disagree with the temporary rules limiting metals emissions for your art class community. They have been good neighbors and provide a valuable service to both Oregon and the world wide art community. As with any scientific endeavor the data should be obtained before any effective plan of progress is begun. Please consider my request. Thank you for the time.
132 132 Margery Gjerstad mgjerstad@msn.com Artist Washington I am a glass artist who uses Bullseye Glass and would be severely hampered by the changes in rules limiting metals emissions from small colored art glass manufacturers. 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.

Please reconsider your actions.
133 133 Mary Weigand mary_weigand@yahoo.com Citizen of Oregon since1954 Oregon WE NEED RESPONCIBLE SCIENTIFIC PROVEN DEQ ENVIORNMENT CHANGES - NOT PANIC DRIVEN WITHOUT SUBSTANTIAL EVIDENCE CHANGES:
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 rule
134 134 Theodore Rips Tedrips@gmail.com Individual CA 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.
135 135 betsy smith betsybirth@gmail.com   WA 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.
136 136 Eduardo Prado eduardoasprado@icloud.com Artist from Brazil Sao Paulo I am a glass artist from Brazil and for more then 25 years I use only glass from Bullseye. I use Bullseye for their tecnology, quality and respect for their clients and workers. I am 100% sure that they are not doing anything illegal.
137 137 Carol Routh Carol@hevanet.com Beadsongs Oregon I began working in colored glass in 1994, which is when I met Dan and Lani. In these 22 years I have known them to be deeply dedicated to ethical business practices and environmental safety. I have been studying all the information available on the current situation regarding heavy metals being discharged due to glass production. From what I can tell, the temporary regulations are based on politics, public perception due to newspaper reports, and not the facts of the situation. Oregon can and should do better than this.The DEQ should be working cooperatively with Bullseye to establish The facts of what needs to be done. Bull's-eye appears to be in complete agreement that safety is of the highest concern, and completely willing to do what it takes. It sounds to me like the temporary rules will seriously damage your relationship with them, and other businesses trust of the DEQ, in the viability of that company as well as the artists who depend on their products. For myself, Green is integral to everything I do, in my livelihood will be seriously damaged without that source of green glass. please slow down and rethink the temporary rules. Focus on permit rules based on scientific fact. Thank you.
138 138 Alberto Romañach   The Ohio State University Ohio Bullseye Glass is telling me that they are completely willing to sign an agreement that achieves ALL of DEQ's goals and allows both parties to "respond promptly to new factual information." If it were up to me, instead of making "temporary" policies based on a few samples, I would be directly communicating with a professional from Bullseye Glass and taking MANY more samples, samples you can both agree on.

I'm just a student who's only interacted with Bullseye once or twice, but from the concern they've expressed, I firmly believe that after enough research and with a lot of scientific background on the matter, Bullseye would be more than happy to implement new company policies to promote your goals, but only if it's directly based on the evidence that you find together. That's the key to cooperation. You both have to WORK TOGETHER before making any kind of decision, temporary or permanent.
139 139 Dalene Reese haciendadelsol@q.com Hacienda del Sol Stained Glass N.M. There are many issues to consider. Please let DEQ and the Environmental Quality Commission know whether you agree with the points below, and let them know how you would be affected by the temporary or permanent loss of Bullseye’s products.
1.This is an improper use of temporary rule making. The Oregon Environmental Quality Commission should only consider a temporary rule when credible evidence demonstrates a rule is needed to prevent “serious prejudice to the public interest.� This is not the case here.

Hastily adopting temporary rules make it appear that agencies are being proactive, but these rules do not protect the public, and makes Bullseye a scapegoat. There is no evidence that emissions from the facility pose any acute health risk nor that Bullseye is fully responsible for the emissions, nor 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.

2.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.�

3.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. Bullseye will support that effort. 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.

4.With minor changes to correct scientific errors and omissions in the currently proposed rule, Bullseye Glass is willing to sign an agreement that achieves all of DEQ’s goals and allows DEQ and Bullseye to respond promptly to new factual information.

5.The haste to adopt technically flawed temporary rules makes it appear that Oregon is repressive to manufacturing businesses and does not care about jobs.

6.Oregon agencies should strive for proper and fair treatment of all parties, based on law, rather than responding to public concern resulting from sensational blog posts and test results with partial data and no peer review.

7.The health and safety of the community can be achieved without forcing these businesses to close.

8.If Bullseye Glass is forced to stop producing 50% of its glass products for 6 months, without regard to ongoing test results or added emission controls, Bullseye’s survival is at risk. We support an agreement that is similar to the temporary rules, but unlike the temporary rules, also allows DEQ and Bullseye to respond promptly to new factual information.

9.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.
140 140 Nicole Burdette nburdette@colton.com Garden Glass Oregon Please do not allow political expediency to influence rules for any small businesses. Environmental rules should be based on clear scientific evidence and should be applied as necessary for public safety. Rules that unnecessarily harm small businesses harm all of us. Politics should never set public policy!
141 141 Gina Szulkowski Gszulkowski@gmail.com none Illinois I take environmental concerns very seriously, but rushing to quick judgement on the glass companies will not benefit the people of Portland. Both Bullseye and Urbros have worked within all the laws and codes that existed. They have been good neighbors, and are working to continue to be good neighbors. Please consider the entire picture before making your decision. Theses are two small companies who have made considerable impact to the arts community by employing artists, teachers, and artisans. They have brought students and buyers to to Portland just for their glass.
142 142 Christopher Bailey chrisbailey.oregon@gmail.com Private citizen Oregon Please do not subject Bullseye Glass to temporary rules that will likely cause job loss and adversely affect Bullseye's position in the glass making industry. Until clear scientific evidence proves that heavy metal pollution in and around Bullseye's manufacturing plant is directly linked to Bullseye, temporary rules forcing Bullseye to halt use of certain products would be arbitrary and unfair.

Create an agreement with Bullseye to halt production immediately if clear scientific evidence directly links use of chemicals at Bullseye to contamination in the surrounding communities.
143 143 Kim Hagan kim@fhighlanderdesigns.com F. Highlander Designs OK 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.

I would be greatly impacted if Bullseye Glass is unable to product 50% of it's glass.
144 144 Anne D Harris annespan@suddenlink.net   CA 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.

I have taken glass classes at Bullseye and first and foremost are safety concerns for participants. I believe Bullseye will do all that is necessary to produce a safe environment for the production of their glass as well. Please do not be hasty in restricting this company without thorough scientific investigation of the specific production process as it applies to this company.
Thank you.
145 145 Helen Balagot helen.balagot@comcast.net n/a Washington I urge legislators to please work with the manufacturers on a fair long term solution that will not put them out of business. Please don't create rules that hurt small businesses, hurt local employment and end up sending jobs overseas. I use art glass as a hobby and would be very sad to see yet another American-made product become unavailable while overseas manufactures, who pollute our earth so much more, only get more business because of it.
Thank you,
Helen Balagot
146 146 Phillip Harris newlifeglass@frontier.com   WA I have been working with glass for 46 years. I have been using Bullseye Glass for 40 years. 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. Please reconsider your actions.

Thank you,
Phillip Harris
NewLife Glass
147 147 Rene Ellis reneellis101@gmail.com Rene Ellis Studio Minnesota It makes no sense to shut down, even temporarily, 2 small glass makers because it is "likely they will produce more pollutants" than other manufacturers in the area. This proposal is not based on sound analysis, is grossly discriminative against small business, and has the appearance of political grand standing, not problem solving. I am a working glass artist in Saint Paul, Minnesota. I have been paying my bills through sale of my glass art using Bulleye products for over 16 years. I consider my art as "Green Art". I have always been proud of the company’s ethics, standards, and quality. I spend thousands of dollars on their products because I know that they are consciences of environmental, manufacturing, and safety processes. They are right now in the process, voluntarily, to ensure even higher standards of manufacturing. Bullseye Glass has been, and continues to be a business that is responsible to the environment, its staff, its community in Portland, and all the glass artists across the country that depend on Bullseye Glass for their lively hood. I urge DEQ to rely on science and fact, and not to rush to impose these poorly written and misdirected rules.
What motive is there in forcing them out of business? You put them out of business, you put me, and thousands of other artists across the country out of business. You also put the small businesses that the glass artists depend on in their own communities out of business. We have only 2, here in Saint Paul, MN and our entire community depends on them for Bullseye Glass.
148 148 Julie Seavy julie.seavy@gmail.com Alchemy Fine Glass LLC Colorado I am a glass artist who uses glass produced by Bullseye Glass Co. There is no alternative in all the world to the glass produced by Bullseye. Without it, I – and thousands like me – will no longer be able to produce my work in the same manner. I am also an attorney who has handled environmental litigation. So I understand the difficulty inherent in the situation in Portland. However, I urge the DEQ to be thoughtful in issuing temporary regulations. While everyone involved wants to protect human health and the environment, even temporary regulations must be designed to alleviate actual concerns supported by the facts and by science. Your own studies show there is no immediate health risk. Further, Bullseye has been completely cooperative and continues to be willing to sign an agreement that achieves all of DEQ’s goals. Therefore, please continue working with Bullseye on final rules that address all environmental concerns, but allow it to remain in full business.
149 149 Daniel Head danielhead@savoystudios.com Savoy Studios Oregon I strongly support Bullseye and Uroboros's ability to create the colored art glass that we use in our studio. Unrealistic limitations based on fear and not science will only harm artists working with their products.
150 150 Lin McJunkin mcjunkin@wavecable.com   Washington I have been a loyal customer of Bullseye Glass Co. in Portland, OR since the 1970s, when they were making sheet glass from recycled beverage bottles in an effort to reduce solid wastes in landfills. For the past 45 years, I have found them to be consistent in their environmental concerns.
Please do not make a temporary rule targeting this one small industry. Please consider a rule ONLY when credible evidence demonstrates a rule is needed to prevent “serious prejudice to the public interest.� This is not the case here. You need to use science and facts BEFORE you issue a rule, not AFTER.
I am an avid and active environmentalist, concerned with clean air and water. I am also an active glass sculptor who relies on a full palette of colors from Bullseye. I would be willing to subsume my professional needs to those PROVEN to be detrimental to the environment, but that is not the case here. If you issue a ruling without the proper science to back it up, I could lose my business for lack of a full palette of glass colors to offer my clients. I could by glass in my home state of Washington, but it is of vastly inferior quality, and I would hope that the Washington DEQ would also limit these factories' productions due to the presence of CrIII in the air. Please proceed with great caution and skill before you malign or even force out of business this fine company. Thank you. -Lin McJunkin
151 151 Debora Seaver deboraseaver@gmail.com   Idaho I am asking that Oregon DEQ does more research before setting rules temporarily or permanently. DEQ needs to understand how these companies produce their products before implementing restrictions. It is my understanding that both glass making facilities have been cooperative with DEQ and I would hope that DEQ reciprocates.
152 152 Russann Royce russannroyce@gmail.com 1952 OR Do not impose environmental sanctions on this business until a study has been done. They did everything as requested by DEW. They are a fine business who cares about the environment. Please save this business, until more study is done.
153 153 Jerry Melvin crickit246@comcast.net Retired Federal Planner Oregon With the train yard next door to glass co. its really unfair to say one company is causing more harm than the other, you have to inspect the many trucks, trains and even the cars to really know who caused the problem going back many years so if you stopped the trains and cars then checked I'm sure you would see better results also. Let's clean up the entire problem not just a small company problem and say that will clean up everything, that's unfair to target only the small companies that have already began to install a better exhaust system that will take care of problem, according to many experts. After all .this problem should have been prevented by city inspectors many years ago.
154 154 Dawn Petricevic Nwmxmom@gmail.com   Oregon 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. Bullseye will support that effort. 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.
155 155 Leng Hunter jeh32@msn.com Chan Leng Geok Hunter Inc Houston Bullseye is responsible for the development of Studio Art in USA & probably also round the world. Thus It is responsible for putting Portland on the International map. As an Architect, sculptor and a glass lover, I try to attend the conferences whenever one was held & I take the chance to visit the city's beloved bookshop, seafood and stash up on the hazelnuts as well. The Owners have also been very supportive of many of the artists that are now considered masters in the art and worked tirelessly to promote young artists (a renown group now from Australia) and develop the possibilities for glass.
I understand that they have also been regularly giving art pieces to the Portland Museum & the Corning Museum. From my years of 'knowing' (meeting at the Conferences) them I recognized the Owners of Bullseye as people who do good work and not ask for praise.
Air quality is important but I hope DEQ work with Bullseye to come to a viable workable solution, bearing in mind that there are also no conclusive cause that Bullseye cause the emissions. Cutting off certain production that will ruin their busibess is drastic.
Do not let a great American institution like Bullseye bite the dust because because it may be causing the noxious emissions. That wll be a sad end for Portland, for the US and the world. Glass is one of the oldest medium dating back to antquity & I hope DEQ appreciates what a great institution Bullseye is and work with it. To every problem is a solution - the question is only how long it takes and how much. Sounds like Bullseye is already doing its part to work with you. PLEASE work with them.
Gratefully, Leng Hunter
156 156 frances squillari gla1720@hotmail.com 1950 Florida bulleye' glass furnaces do not produce chromium,rely on scientific facts  
157 157 Doncella Marquess Doncella49@comcast.net none Oregon Please do not support the 2016 temporary rules. You need to listen to the scientists that are better qualified to to form an opinion. Oregon can't afford to lose jobs which could be a result of all the new regulations. Bullseye has always worked extremely hard to insure safety and they will do everything they can to address this problem.
158 158 John Emery jpreston43@cfl.rr.com PRESTON STUDIOS Florida Like many other stained glass artists I am VERY concerned about the possible loss of a major national treasure like Bullseye. The glass arts have been dealt a severe blow nationally and internationally by the Great Recession. Losing Bullseye would only add the decline in this uniquely AMERICAN tradition - where art glass is not just for churches, but for people to live with in their homes and daily lives:
http://www.prestonstudios.com
159 159 Kym Textor Kym.textor@bigpond.com blossom & blue QLD Australia 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.
160 160 Josephine Geiger josephine@jageigerstudio.com J A GEIGER STUDIO, LLC MN Please, when considering the new regulations, please, please, use facts and not speculation. As a self-emplowed glass arist, I depend upon the fabulous art glass produced from art glass manufacturers across the country, like Uroboros, Bullseye, Spectrum, Kokomo, Youghegheny, Wissmach, etc.
Please use the facts not fear inspired commentary in determining the regulations these small companies have to inplement, because those costs will trickle down and impact my, and countless other artists, livlihoods as well.
161 161 Melody Lynch dmlynch2468@gmail.com The Craft Guild of Dallas 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. This has far reaching impact and is not a decision that should be taken lightly or without due diligence.

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.

Making such quick decisions without all the facts effects not only the numerous families who work for Bullseye but also thousands of artists across the country who rely on Bullseye glass, ALL colors of glass, to make their glass art which provides their livelihood and that of their families.
162 162 Melody Lynch dmlynch2468@gmail.com The Craft Guild of Dallas 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. This has far reaching impact and is not a decision that should be taken lightly or without due diligence.

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.

Making such quick decisions without all the facts effects not only the numerous families who work for Bullseye but also thousands of artists across the country who rely on Bullseye glass, ALL of the glass, to make their glass art which provides their livelihood and that of their families.
163 163 Mary James maryjames20@gmail.com   Washington I have purchased and used glass from Bullseye for 15 years. I am horrified my use of pleasure, art glass has affected the families in the area. I really would have assumed it had been investigated.
164 164 Laurie Fossier-Mills Beachgecko@mac.com BeachGecko Glass Art Studio Australia 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.
165 165 Carol Bishop carol@bishopcards.com   OR I am of course concerned about the high pollution levels of metals as first reported but have also realized that later testing has shown lower levels. There seems to be confusion and/or conflicting measurements done. Before forcing these glass companies to make major outlays on equipment, I do think the science must be done and confirmed, including showing that those facilities are the ones that produce the metals emissions. We don't want the companies to have to close down if there are other ways to limit such pollution, and we do need to ascertain they are indeed the source of such emissions. Take your time and do the investigation thoroughly before making decisions.
166 166 Tadd Leggate tkleggate@gmail.com Glass artist AR I completely understand the concern over the emissions from the Bullseye glass plant. It's my understanding they were following the limitations allowed under their legally issued permit. It is also my understanding the company has already voluntarily contracted to install filters to remove the potentially harmful emissions. Bullseye is a responsible company and does not deserve to be hindered and potentially ruined due to poorly thought out knee jerk regulations. They are a gem in your community and should be worked with rather than worked against.
167 167 wendy Rogers wrogers1@nbnet.nb.ca   Canada Science does not support the need for any temporary rules. Please don't hobble a successful business for no good reason! The public is safe.
168 168 Cathy Wheeler catsglassart@gmail.com   Alabama 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.

I am a glass artist in Birmingham using Bullseye glass for my fused glass artwork. These stringent rules will not only affect the business of Bullseye Glass but mtpy business and the businesses of many, many of my fellow artists.
169 169 Laurie Matthews Laurie.r.matthews@gmail.com   Oregon I disagree that a temporary rule is the right path forward. A permanent solution that is based on more reliable research needs to be the focus. This is clearly a politically motivated solution, not a real one.
170 170 Kathy Littman kathbass@yahoo.com   CA please allow Bullseye glass to continue to make the wonderful product that makes my contribution to my Local Marketplace, a store that sells only North Bay, California local artist's products to the public. This small and wonderful business supports sustainable businesses and families at the most basic level and is in direct competition with businesses that only care about the bottom line and are not contributing to the quality of our local environment and the environment of the world.
171 171 Eileen Radigan Eradigan@rochester.rr.com   NY From everything I am reading, there is no danger here. The levels are lower than required. Jumping into temporary rules that are largely ineffective and cause companies and their employees to loose their jobs doesn't make sense. First you need proof that damage is being done. First things first.
172 172 David Schuster dsf@davidfschuster.com Artist, owner New Mexico 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.
173 173 Portland Concerned Citizen sueflah@yahoo.com   Oregon Please adopt and enforce these important emission control regulations as soon as possible to protect Portland residents from toxic substances.Thank you.
174 174 Abby Robinson abbymoranrobinson@gmail.com   Ohio I'd think a state that was interested in the welfare of ALL it's citizens, economically as well as medically, could find a way to definitely measure whether these airborne pollutants were really caused by two small glass facilities.

"More likely than not does not seem to me to be a compelling reason to put people out of work in your state, deny glass artists in the ability to make a living in many other states, an risk the complete closing of a business.

Why not wait for something more definitive?

Sincerely,
Abby
175 175 Leslie Simonds Lbsimonds55@gmail.com Vista Glass Pennsylvania Bullseye glass is an invaluable resource for glass artist all over the U.S. The proposed sanctions and ensuing production cuts would have a very grave impact. The company is willing to work with regulators to find solutions to satisfy all concerned. Don't put politics before science!
176 176 Nancee Hiffmann Nhoffmann4@verizon.net Sunshine & Rainbiws TX Please do not enact temporary or permanent laws that will negatively impact the livelihood for so many people. At least don't do this without working with the Bullseye reps to draft a reasonable solution to the issue. Thank you so much!!!
177 177 Cynthia Rose Weaver rosietko@gmail.com   CA Please work with the glass companies to help protect the environment. Monitor all the local businesses instead of finger pointing at a few well established small companies.
Give Bullseye time to correct any problems and focus on fact instead of hysteria. Check out all the manufacturing in the area and get it right for Portland, it;s people and the community.
It saddens me to think sucha wonderful glass company could be harming the environment. I support their work and desire to make theier omissions right.
On a more logical point. Get al the manufacturing out of the city. Make sure they all put filters on their exhausts. Stop pointing the finger until you have the facts. And get it right .
178 178   Jackson eejackson77@hotmail.com   CA I am a glass artist that relies on glass produced by Bullseye Glass which is a responsible company. The Air Quality Temporary Rules are not based on science but on politics. I ask that you reconsider adopting them as they will not solve any environmental concerns and will adversely affect many employees and artists. Thank you.
179 179   Jackson eejackson77@hotmail.com   CA I am a glass artist that relies on glass produced by Bullseye Glass which is a responsible company. The Air Quality Temporary Rules are not based on science but on politics. I ask that you reconsider adopting them as they will not solve any environmental concerns and will adversely affect many employees and artists. Thank you.
180 180 Cyndy Later cyanaurora50@gmail.com   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.
181 181 Sandra Feder sandy_feder@hotmail.com Art by Fire CA There is NO scientific evidence that these small glass manufacturers are causing harmful emissions. Until studies are done that show harmful emissions, it is unfair to target these 2 manufacturers and potentially ruin their businesses and the business of the buyers or their products. Since the studies have not been done,it would be prudent to initiate studies to see what emissions come from these colored glass manufacturers. Then, and only then, can decisions be made regarding the manufacturing process and its emissions. To adopt temporary rules that limit the manufacturing, is premature and harmful to the industry. This adoption of temporary rules would be like telling jewelry makers that they can't make jewelry because certain metals might be emitted into the atmosphere. A much better choice would be to run tests to see exactly what emissions come from the process and then let scientists determine if these emissions cause a problem. Prof S H Feder, Sacramento City College, Sacramento, CA
182 182 Linda Norris linda@linda-norris.com Artist UK As an UK based artist and fervent environmentalist I have been following the recent toxic air emissions revelations closely. I understand that Bullseye has always been 100% compliant with State emissions regulations and has voluntarily temporarily halted use of Chromium, Cadmium and Arsenic in their production following the recent toxic air emissions revelations and is currently installing a 'bagging' system which will be 99% efficient in terms of preventing toxic air emissions from its furnaces in the future. As a responsible company have also employed an environmental consultancy to overhaul all their processes and advise them on the most effective way to proceed to protect their neighborhood and employees.

Bullseye Glass is fundamental to my practice as an artist working with hard-to-reach children and vulnerable adults in my own community. The fabulous range of fully compatible colours has enabled me to draw in people who are marginalised and have limited communication skills, as well as allowing me as an artist in my own right to develop my own artistic expression. There is no replacement for this material as no other company has invested so much expertise, time and experience into developing a truly remarkable palette of colours. The impact of Bullseye Glass on the development of studio glass globally can not be underestimated, and the support and encouragement given to artists and communities by the company through their competitions, prizes and sponsorship represents a massive contribution to glass art on a worldwide scale. Examples of work made with Bullseye Glass are in internationally important collections across the world, such as the V&A Museum, London.

Nothing should take precedence over environmental health, but decisions concerning the use of Chromium and other heavy metals in the factory should be based on proven science, and it concerns me that calls for a temporary ban on the use of these materials are being based on sensationalised press reports and emotive reaction, rather than the bare science. I understand that the proposed restrictions could put the future of the company at risk and could cost the jobs of many employees in Portland and elsewhere across the USA, it would necessarily have a knock on effect on suppliers and artists globally.

Given the fact that latest soil tests show no increased prescence of toxins in the vicinity, and the attempts that Bullseye are making to ensure their toxin emissions falls far below the required minimum level, I would ask that the company be allowed to resume production and safeguard the jobs of their employees, while the state undertake scientific monitoring of emissions and avail themselves of the expertise required to protect the citizens of Oregon from all industrial environmental impact, not just that from two small factories with over 40 years manufacturing experience who contribute so much to glass art and opportunites for marginalised people in communities across the globe.
image001.jpg https://data.oregon.gov/views/trwb-z8xe/files/4961cda5-ef2d-4d4f-b743-6bbf4d38e34d
183 183 Lynn Lloyd lynn_lloyd@comcast.net   Washington The Art & Science of glass making has been in existence for at least 5000 years. The ancient Egyptians made glass to decorate their sacred objects and travel into the afterlife. The Romans made glass and modern glass makers inhabit the Island of Murano Italy, off the coast of Venice. In such an island composed of little commerce but glass making, don't you think that if the environment had been poisoned over the last few hundred years, that we'd have heard about it? The environmentalist do NOT have their facts straight. Companies like Bullseye are environmentally conscientious and would never do anything to endanger the Earth. Until such time that the environmentalist can PROVE their case beyond a shadow of a doubt, the local and state governments should not interfere. "Temporary Laws" tend to become permanent and as such, difficult to abolish. Politicians rarely admit mistakes. Yes, you'll shut up the critics, but at what cost? Remember the environmentalist do not have the FACTS on their side. Do NOT initiate this Slippery Slope of "Temporary Laws" and remember you work for ALL of the people, not just the ignorant loud-mouths.
184 184 Becky Wills becky@yellowdogglass.co.uk Yellow Dog Glass UK 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. Ill judged knee-jerk reactions could result in the loss of many jobs and a situation from which the art glass companies of Portland can never recover. The loss of their product will have a devastating knock on effect in the world of art glass. Please consider any further actions only based on scientific fact not scare mongering fiction.
185 185 Renee Farr rfarr01@comcast.net   FL As a firm supporter of Bullseye Glass, please use responsible decision making when determining the use/non-use of Chromium III. Bullseye Glass has been, and hopes to continue to be, a member of the social and business community of Portland, Oregon. Please do not rush to a decision that isn’t based on science and facts. There is scientific evidence showing that the use of Chromium III by Bullseye Glass does not produce any toxic emissions, nor does the use of Chromium III result in a change to Chromium VI within their furnaces.

I urge you to review all the scientific facts before making a ruling.
186 186 David Hopper dghopperart@gmail.com Independent Artist California I am not in favor of this temporary ruling. The proposed rules to fill a regulatory air toxic gap is an action to a non existent or unproven condition. This knee jerk ruling by the DEQ exhibits how agencies are swayed by unscientific opinions and public comments. It is only fair that you work with these small glass companies through scientific reporting and analysis. I have known the owners of the two sheet glass manufacturing companies for over 40 years and at no time have they been irresponsible in protecting the health of their employees and environment. As a fellow manufacturer, you taking the action of establishing this Temporary Ruling would be unscientific, illogical and open your agency to a damages lawsuit. "The proposed rules would fill a regulatory gap by setting operation standards for the smaller art glass businesses that emit air toxics and potentially cause serious health effects." This statement from the proposed ruling is enough to fill a lawsuit against the DEQ. The DEQ has not proven "smaller art glass business emit air toxics."
187 187 Diane Ziegman       This company, Bullseye, is trying to comply with the law to run their business by installing proper equipment for purification. Unfounded regulations like this are what drives companies to move operations to other countries (e.g. China) who will welcome them with open arms. Do not force them to move with these frivolous claims.
188 188 Ann Nash anash@manzanodayschool.org Manzano Day School New Mexico 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.
189 189 Erinn Dady     IL While I am concerned about the environmental impact regarding this decision, my hope is that the ruling will be based on actual facts, not merely the likelihood of emissions.
190 190 Vikki Stacey staceycolourdiva@hotmail.co.uk Glass artist Buckinghamshire 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. I am a self employed glass artist and recently visited the beautiful city and surroundings of Portland, so understand that you want to keep it healthy. This is not the way and will only cause more city wide social problems as well. Please rethink and research before you act. Thank you Vikki. UK
191 191 Debra Joseph djoseph@sssnet.com Concerned Citizen and Customer of the businesses you are trying to destroy Ohio This is an improper use of temporary rule making. The Oregon Environmental Quality Commission should only consider a temporary rule when credible evidence demonstrates a rule is needed to prevent “serious prejudice to the public interest.� This is not the case here.

Hastily adopting temporary rules make it appear that agencies are being proactive, but these rules do not protect the public, and makes Bullseye a scapegoat. There is no evidence that emissions from the facility pose any acute health risk nor that Bullseye is fully responsible for the emissions, nor 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.

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.�

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. Bullseye will support that effort. 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.

With minor changes to correct scientific errors and omissions in the currently proposed rule, Bullseye Glass is willing to sign an agreement that achieves all of DEQ’s goals and allows DEQ and Bullseye to respond promptly to new factual information.

The haste to adopt technically flawed temporary rules makes it appear that Oregon is repressive to manufacturing businesses and does not care about jobs.

Oregon agencies should strive for proper and fair treatment of all parties, based on law, rather than responding to public concern resulting from sensational blog posts and test results with partial data and no peer review.

The health and safety of the community can be achieved without forcing these businesses to close.

If Bullseye Glass is forced to stop producing 50% of its glass products for 6 months, without regard to ongoing test results or added emission controls, Bullseye’s survival is at risk. We support an agreement that is similar to the temporary rules, but unlike the temporary rules, also allows DEQ and Bullseye to respond promptly to new factual information.

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.

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.
192 192 Christine O'Connor oconnor.chris@verizon.net   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.

We sincerely appreciate any support you can provide right now.
193 193 James Coon jim_em@ameritech.net jim and em stained glass Michigan I hope the issues with bullseye glass does not result in layoffs and possible closure of the plant. All over the US we rely on Bullseye glass for our business. The hope is that the facts are legit and not just supposing there is a problem. We all want clean air and hope that Bullseye's efforts to have clean are are sufficient. Thank you
194 194 Lori Love duncansue@verizon.net   MD I am a glass artist - there are thousands of us worldwide that rely on Bullseye Glass products. 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.

You are not only threatening our creative endeavors and in many cases our livelihood by these proposed draft regulatory decisions, but you are also impacting the many employees of Bullseye Glass and their familys by hastily drafted regulations that can not be supported by the available science. 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.
195 195 Denise Hovda wildprairieartglass@hotmail.com Wild Prairie Art Glass ND Please base your ruling on scientific facts instead of the "possiblity" that the glass manufacturing process is the cause. Your decision will affect more people across the US than you can fathom at this point. Peoples livelyhood and careers are at stake at this point.
196 196     oags@cfl.rr.com Glass Artisian Florida If you are really concerned, check out the glass manufacturers in Germany, Italy, Poland to name a few that have been creating some of the most sought after art glass in the world. Family generations after generations and THEY LIVE REALLY LONG lives. Get off your HighHorses folks. Get a life.
197 197 Margaret Greene margaret42@tds.net   Oregon 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.
198 198 Shannon Gill deva2101@yahoo.com Golden Cricket Studio Florida 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.
199 199 edna brown booedna.barown@yahoo.com   Michigan I don't quit understand the path you are taking with the glass factories, if you found 5 site that contained high levels and only two are near glass factories, what is near the other 3 and why are we not notified what is near those spots that are responsible for those areas. Why are we just ruling out glass factories.
200 200 Donald Croxton croxdon@aol.com hobbist Florida It is time that legislation be determined by scientific fact not gut reaction misinformation.  
201 201 Daniel Seffinger Dannyseffinger@yahoo.com Ashlandglassact Oregon I oppose the rules limiting metals that would effect glass production at bullseye glass. This would have devastating effects both for bullseye and hundreds of glass craftmen effects the lilyhood of many artists . Please do not do this. Dan seffinger
202 202 kathleen White kathleenwhite101@gmail.com   CA I am a glass artist, and very concerned about the future of art glass should these temporary rules become effective. 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.
Thank You
Kathleen White
203 203 Ken Goodrich goodrichk@yahoo.com K & L Crafts/Gifts MD Innocent until proven guilty.
As a glass artist I rely on Bullseye Glass Co for much of my supply. I care about the issue but understand that the company is taking steps to correct the problems.. Allow the company to take steps to correct the issues without enacting strict rules that puts the business at risk of closing.
Thank you.
Ken Goodrich
204 204 Diane Routt droutt@tds.net   WA As a glass hobbyist I have been following the events in the news regarding two of Portland’s glass companies, Bullseye and Uroboros, with great interest.

I have just learned about DEQ’s attempt to impose a temporary regulation that is based on judgement not scientific evidence. Two other agencies, Oregon Health Authority (OHA) and the Multnomah County Heath Department have stated there is no immediate health risk to the Portland Community.

Portland is known worldwide as ‘Glass City’. Many artisans have relocated to the south west region of Oregon and Washington to be closer to their sources. Many artisans have come to Portland to be able to learn how to work with glass at the Bullseye Resource Center. I might add Glass conventions have been held in Portland since it is known as the glass hub of the United States.

I have taken classes from Bullseye for the past 10 years from fusing to lampworking. They have always stressed safety in working with glass and components that we add to the glass for a final product. Bullseye offers compatibility options with their glass products that no other glass supply markets.

I recently took a 3-day class with Bullseye and we were taken on a tour through the factory. I was so impressed with the process and what it takes to make glass. I know they have taken every precaution to abide by the regulations that have been required since they went into production, this is discussed in the classes they offer.
I am just a hobbyist but I know many people make their living making products from glass. The decision not only impacts Bullseye and Uroboros but this temporary rule will impact more than the areas around the factories but people’s source of income.

Has DEQ bothered to communicate with OHA and Multnomah County Health Department about their findings? Has DEQ attempted to understand what is involved in making glass and the years of research Bullseye and Uroboros has invested? Has DEQ bothered to look at the big picture of their decision, it goes beyond Portland?

DEQ needs to understand before they start making rushed decisions.

Glass making has been an art for centuries….
205 205 David Aavang quinch9000@gmail.com     I would like to voice my support for Bullseye Glass in Oregon. they supply glass to many small business, in addition to being a small business themselves.
I have read the scientific analysis of their production of green glass by Dr. LaCourse and the reports by local health authorities that find bullseye glass is not creating a hazardous byproduct during the production of green glass.
I would hope that the DEQ and EPA would not put into effect knee-jerk temporary regulations that have a permanent, damaging result to small business and the people they employ.
206 206 Jean Fernandes   University of Texas Arlington, Sinaca Studios, Creative Arts Center of Dallas TX Please understand that these are small businesses that your regulations will be affecting. These businesses provide thousands of jobs, support a very large community that makes their living from these materials, and are an asset to the local, national, and international economy. If these small businesses shut down as a result of these "temporary" regulations, it would collapse an entire community of people.
If there is specific scientific evidence that shows a large contamination/pollution problem as a direct result of the companies’ manufacturing of art glass, I would completely understand these regulations being implemented, but this does not seem to be the case. If these regulations are imposed on these companies, there will be protests and significant uproar as a result of the unfair discrimination against these two small glass companies. As of now, there is scientific proof online that shows that the furnaces do not turn Cr(III) into Cr(VI), which is the primary concern of the DEQ. Both, DEQ and EPA have acknowledged there is no clear evidence of acute or chronic health risks based on Bullseye’s use of Cr(III). Bullseye Glass has started to take steps to use baghouses to cut any possible emissions and I think that this is important because it shows the company’s concern about the environment as well as their willingness to comply with the public’s concerns.
As of now, the risk of implementing these regulations on Cr(III) on top of the current suspension of cadmium glass production would cut the glass product line by 50%. This would be detrimental for the growth of these companies, the jobs they provide and the glass community that they support. The DEQ needs to take into consideration that scientific evidence currently does not support the regulations that they are planning to implement.
207 207 Emelie Rogers emrogers@ix.netcom.com emrogers designs CA As a glass artist, environmentalist, I am concerned with the lack of reliable, supported scientific data regarding your constraints on glass furnace use in art glass facilities. Work with the entities involved to arrive at a reasonable well-supported remediation.
208 208 Virginis Rigney Vnarts@aol.com none CA Bulls eye glass is essential to hundreds of artists. They known as a quality company that offers quality product and as a company that supports the community of artisans in many ways.
Please give careful thought and process to any regulation that will impact the service they provide
209 209 Felicidad P Morgan chicamima@msn.com chicamima designs California while i am an out of state glass artist, your decisionaffects my modest income significantly. I agree we need controls. in order for Uroboros and Bullseye, to be able to implement the controls in a cost effective manner, perhaps a rebate or subsidy like those given for solar energy would accomplish the goal quickly with a smaller impact. these are two USA manuafacturers we sure would ot see resort to exporting production plants etc. We need to support our USA small/medium businesses and our USA craft industries. many from other countries marvel at what we as Americans craft and we who do craft hand crafted American glass etc support our local businesses. this affects not only the glass industry but the other businesses that go hand in hand such as metals, gemstones, etc. This will affect the local Oregon economy as well as affect out of state commerce benefitting Oregon. If it must be done to protect our help, the least that could be offered is some type of subsidy or rebate to soften the blow for all of us and still accomplish the goals desired.
210 210 Heike Brachlow Heike.brachlow@network.rca.ac.uk Self employed artist UK Rather than effectively shutting down the small scale coloured glass businesses (which millions of artists all over the world rely on for their glass, and who have a significant number of employees who would likely loose their jobs), why not give them time to improve their systems? They have been operating for decades - a few months extra is not going to make a huge difference. Unless it can be scientifically proven that their emissions are so dangerous for the environment that there is no other choice, of course.
211 211 William Goldsmith corgisnk@bgproductions.com Bill Goldsmith Productions PA To Whom it may concern:
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 !
212 212 Audrey Morrell Audreka.m@gmail.com   Ohio 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.

These rules would have a negative impact not only for the companies involved, but for numerous small businesses and glass artists that rely on the products these companies all over the US and worldwide produce to make a living. We urge you to consider reason and facts. Thank you.
213 213 Eugenia Olson rnpcn@comcast.net   Washington There is no urgency. There has not been enough time taken for a complete and comprehensive study. There are toxic metals used in the production of some glasses but a knee-jerk response is not warranted at this time. Further studies and a comprehensive plan of action by both the glass companies and the agencies involved is a better plan for both the public and the economics involved in the issue. Thank you for your consideration.
214 214 TERRY Rothwell tsrothwell@gmail.com Mr. New Mexico Any and all decisions should be made based on proven science only. Irate and hysterical citizens do not override the reality of that science.
215 215 Deb Fritz Debfritzdesign@gmail.com Fritzfires Maryland As a glass artist, I have prided myself on selecting Bullseye glass for its long history of responsible operation. I stand with them in its efforts to continue operations as a responsible citizen of the social and business community of Portland, Oregon.

Regulatory decisions should 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 misdirected rules.
216 216 Deb Fritz Debfritzdesign@gmail.com Fritzfires Maryland As a glass artist, I have prided myself on selecting Bullseye glass for its long history of responsible operation. I stand with them in its efforts to continue operations as a responsible citizen of the social and business community of Portland, Oregon.

Regulatory decisions should 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 misdirected rules.
217 217 Markus Klein markus.klein@inspiration-for-glass.com   Germany 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.
218 218 Cassandra Koslen ckoslen@gmail.com   Oregon The phrasing "likely emit" is troubling. It implies a lot of missing information. Instead of a temporary restrictions on small manufacturers, let's spend time and resources determining the true source(s) of the air toxics and then create regulations based on fact that will have long term effect.
219 219 Susan McWilliam susanmcwilliam@yahoo.com Adventures In Glass New Mexico I stand with Bullseye and their comments regarding these regulations which should not be motivated by politics but by scientific study. Putting so many people out of work and we the artists who need the glass should not happen for a "maybe" something might happen. Bullseye is a responsible company. The DEQ must prove without a doubt scientifically before attaching regulations on Bullseye.
220 220 Laura Brownfield Laura@glassplay.co Glass Play OR and AZ I have been a customer of Bullseye Glass for over 10 years and have toured their facility several times including the furnace rooms and all production areas. I was profoundly pleased with the level of “green� methods they used and attention to safety for their employees and customers. The manufacture is a fixture in the neighborhood, and a global leader in the industry. They promote green environmental issues and lifestyles.

The recent news that they may not be in compliance with air safety issues seems, at minimum, greatly exaggerated. They are expanding their practices to add additional safety filters and should be given the short time it needs to accomplish the installation. There is contradictory scientific evidence about possible issues. Hundreds, if not thousands, of livelihoods are dependent on their glass production, including mine. I travel from our southern Oregon home to Portland each year to purchase the glass that I use for my work.

I agree and support the statement from Bullseye that 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.

Laura Brownfield
Glass Play
221 221 Kay McCann Kayja32@aol.com self Oregon In response to DEQ putting temporary restrictions on Bullseye Glass manufacturing I believe this is yet another example of social media and a handful of people complaining and spreading unsubstantiated rumors to thwart Bullseye's glass production. I would expect you to show scientific evidence behind your decision and not give in to public pressure which could destroy an industry and put many out of work. It's unfortunate that the government cannot be trusted to follow the law but instead have a few people seemingly dictate their decision making.
222 222 Tiffany Spahn Devilspahn@hotmail.com   Oregon I live and work in the Brooklyn neighborhood of Portland, not far from Bullseye Glass. Bullseye Glass is a quality small business which enriches Portland as a whole, and has a long history of responsible operation. It would be a huge misfortune if ill considered regulations forced them out of business and caused the loss of jobs and a unique Portland business.
I urge DEQ to rely on science and fact, and not to rush to impose these poorly written and misdirected rules.
223 223 Denise Bohart Brown artsydenise@icloud.com independent glass artist Colorado I have been involved in the art glass industry as an artist for 15 years, and in my experience and knowledge, Bullseye glass has a long history of responsible and environmentally-conscious operation. I support Bullseye Glass in its efforts to continue operations as a responsible citizen of the social and business community of Portland, Oregon.

Regulatory decisions should not be rushed in a knee-jerk reaction to a situation that “sounds� as though it might be toxic, scary, poisonous, hazardous, etc. Such decisions must not be reactionary, but must be based on science (not politics), and in order to be fair to all involved they must be based on a thorough examination of the facts and evidence.

DEQ’s apparent desire to rush into being these poorly written and misdirected rules unfairly affects not only a specific industry (without affecting other neighboring businesses that may share the blame, but will not currently share the dire results of these restrictive regulations), but also the myriad of businesses and individuals like myself that rely on Bullseye to supply us with the tools of our trade.

While I understand the necessity of DEQ’s investigation and subsequent thorough understanding of the situation, this is something that has manifested over time - over years, perhaps decades. The OHA has stated that there is no immediate health risk to the community. I urge you to take the time needed for your due diligence and then, and only then, relying on science and fact, implement new regulations that can be borne fairly by all industries and will positively impact the lives and health of the people of Portland.
224 224 Leslie Wallace lesliew@sonic.net small business owner California I have worked with Bullseye Glass for over 10 years. I use their product exclusively in my home based buisness. If their glass becomes scarce, prices will rise. I can afford neither a scarcity of my glass or a significant rise in cost. I will be put out of business as soon as my supply is depleted. I cannot substitute another supplier, my inventory is exclusively Bullseye for technical reasons. You cannot mix glass. It scientifically does not work. I use their product because of it is constant quality control. I have the same product now that I did ten years ago. Bullseye glass has a long history of responsible operation. I have visited the Portland facility many times. 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.

Not only does your decision affect the Portland facility, it's repercussions will be felt Globally. So many artists depend on Bullseye Glass. California has managed to chase many businesses away with ill thought legislation. Please think carefully before you lose a valuable and unique business. Portland is a hub for creative thinking, a reason that I visit as often as I can. I can tell you that Bullseye is a major reason to visit, my trips would be curtailed if they are no longer there as a source. Who is spearheading this hate? You have scientific documentation to back a business, yet you obviously are choosing to bend an ear to someone crying wolf. Please think carefully before you act, the ripples of your decisions will spread further than you can see at this moment.
225 225 Regina Seamann reginadon@live.com Stain Glass By Nana Iowa Please do not make them comply as larger companies, as mall business have a hard time making it as it is due to all the regulations. Small mom and pop organizations/ businesses cannot stay in business and keep prices low so us who are also trying to survive on a limited income can afford to buy raw goods ( such as sheets of glass.) Please do not force them to comply as it will shut down one more American dream of owning there own business, which in turn help others to enjoy the healing therapy of doing stain glass on a small scale.
Thank you for listening and taking thus in consideration.
226 226 John Svenson svenson@extremedreams.com Extreme Dreams Fine Arts Gallery Alaska Please consider basing your decisions concerning the Bullseye glass Co. on hard science. They are THE coveted premier glass co. in the world. We are under contract with the State of Alaska to produce large glass murals for new schools, all Bullseye, so even we, as well as many others are indirectly impacted by your decisions. Tens of thousands of people as well as many millions of dollars are at stake. Thank you
John Svenson
227 227 Francine Lofrano ftblote@sbcglobal.net   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 San Francisco, California.

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.

This ruling would be devastating to Bullseye Glass, their employees and their customers - please, you must reconsider and review the science!
228 228 Mary d'Autremont marydautrey@comcast.net     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.
229 229 Laura Parham LauraGoffParham@gmail.com Laura Goff Designs TN I urge you to look at science and not sensational headlines in making the decision to limit production at Bullseye and Uroboros glass. These two companies are world class leaders in the stained glass field. The quality of their product line is unmatched by any company. Their products are used by artists worldwide! Your decision will have a detrimental impact on ALL colored sheet glass manufacturers in America. I have been a professional stained glass artist for 30 years. I have installed thousands of stained glass windows in hundreds of churches. Why? People want stained glass windows. They want new stained glass windows and they want their old stained glass repaired. Your decision may hinder professional craftsmen ability to repair stained glass windows in churches. I, and my staff, depend on being able to purchase colored sheet glass. Temporary regulations made in haste out of fear without the scientific evidence to support these restrictions are knee-jerk political maneuvers. Regulations should be based in scientific proof and put into place to protect all citizens while also looking out for those same citizens who rely on Bullseye to survive.
230 230 Johanna C.   Portland Resident   Please do not make rules hastily based on public panic. New rules should be based on sound scientific evidence.  
231 231 Arlene Dean aglassbash@comcast.net   WA Let's not use jump to conclusions. Let's take the time to look into what is really happening and NOT ruin a business before we know the full facts.
232 232 Kevin O'Brien kevin@obrienstainedglass.com O'Brien Stained Glass, Co., Inc. Minnesota Re Bullseye Glass: Please understand that the availability of these glass from the Oregon locations is very important to the artwork of related industries. Since there has been no demonstrated level of hazard from these operations..we urge that the state allow these products to be made while Bullseye does its part with the state to assure reasonable safeguards. Sincerely
233 233 Warren Weiss wiweiss@verizon.net   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.
234 234 Jacque Rowland jac_pt@yahoo.com   NM Scientific evidence clearly indicates these furnaces won’t turn Cr(III) into Cr(VI). If they did, the glass would be ruined. I am really bothered by the idea that the state doesn't really look at the evidence but yet they cause much worse things on their watch for instance the water and severe damage to people from the lead pipes in Michigan.
235 235 Nancy LiVolsi mathtea@gmail.com   NY Keep Bullseye open. Let them prove themselves to make production clean. They are responsible people, they want to do right by the people. Let them!
236 236 Morio Toyoshima supermorio@aol.com   OR I believe the health of the public of Oregon comes first, period... And I am not a Bullseye user.. But I have been to Bullseye for the tours inside their factory more than a few times... they showed us everything.. Is there any factory shows you everything while they are in full production mode if they are doing anything illegal... They have been a very friendly and an open-minded manufacturer.. If their emission level is under the current regulation.. then look for other possible emitters around.. If you want them to improve their emission system, then give them some time to install better equipments... provide some financial or/and logistical help to improve their system, because they (Company, employees and users) have been paying great amount of tax to the State for a long time.. they deserve governmental assists from the State and Federal institutions... Wrong if you punish them hastily based on insufficient research results or sensational media reports... Work with them... Don't try to kill them... Remember, they are not a big company with tons of assets to resist or endure the hardship.. They are the small businesses which the State of Oregon have tried hard to nourish and grow in the past..
237 237 Barbara Dutton Redcj5@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. As a long time glass fused, I've used Bullseye glass and while I appreciate the concerns for public safety, I don't believe this temporary action is the best path to take.
238 238 David Kingman david@kingmanarts.com Kingman Arts Oregon Do not make temporary rules based on guesses. Determine toxic levels of metals involved and make permanent rules.  
239 239 Gregory Bell flatlatex@yahoo.com Edenwind Studios OR I have worked w/ Bullseye Glass for well over a decade. They have exhibited nothing but prudence and responsibility in regards to employee, customer and public safety. I trust that the ownership will do everything possible to cooperate w/ officials and install/implement new systems/technology to make their processes safe for everyone. Temporary rules may make for good news sound bites, but they will have very real, very lasting effects on many people's lives. Please take the long view - let Bullseye get filtration in place that addresses the real problem, not a bandaid media fix. NO to Temporary Rules that feel good yet don't actually fix a problem and have a negative impact on so many lives. Think!
240 240 Jan smith Magpiemoonglass@gmail.com     Dear Governor Kate Brown,

The DEQ appears to be in the process of making temporary rules not entirely based on science and driven by the press, eager for headlines to sell their publications, as well as ambulance chasing lawyers and citizens who lack the knowledge to make sound decisions, to restrict the ability for Oregon art glass manufacturers to conduct their businesses. Unsound decisions appear to have been made more to appease the public and protect the DEQ in advance of scientific analysis is examined to determine what levels of toxins these factories emit and what actual threat is presented to thephysical areas around these factories. Your temporary regulations will financially devastate not only these businesses, but the businesses of 1000's of glass artists across the United States. In addition, Spectrum Glass in Washington state will be harmed because much of their warm colors are made by Uroboros. The science in these temporary rules makes claims of emissions that if are precluded by the nature of the glass. Bullseye has made every effort to be transparent and cooperative. They have posted their intent to make improvements. Your DEQ site has listed a study showing minimal heavy metal residue in the area and this is after the presence of glass manufacturing in those areas for many years. These temporary rules will not produce instant change and harms many more people. The DEQ should wait, determine exactly what heavy metal emissions actually are and make permanent rules based on science and deliberation and consideration of all involved, not act out of unproved fears. These glass factories are a part of your economy and have paid taxes for their representation. Please honor them with the consideration any citizen of Oregon should expect. Thank You.

Sincerely,
Jan Smith
241 241 Beth Tierney Beth@seafocus.com See through sand Dorset As I work with glass it is in my interest to see that production at these companies continues unimpeded. However, as a professional diver, I also have a strong focus on the environment and agree that ANY company releasing toxins into our environments should be responsible.

The issue here seems to be that although there is proof that the long-term effects of these processes are minimal (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.�) there is a lack of understanding about the issue at large.

Surely, it would make more sense for the local authorities to work WITH the glass manufacturers to ensure safety standards are increased, that research into effects is increased and to inform everyone on the results of this research?
242 242 Nanette Thrush artsgrl67@hotmail.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.
243 243 Lisa Barnett inthemiddleofnowhere123@yahoo.com   Oregon Please do NOT pass this temporary rule. This ruling is not based on scientific evidence, and will seriously damage the business of Bullseye glass as well as its thousands of employees. I want environmental safety but do not want hastily prepared "fixes" that cause unnecessary hardship for our citizens. Please don't act so hastily and take the time to make a rule after getting in all the facts.

Thank you,
Lisa Barnett
244 244 Rebecca Derby barwickbecky@yahoo.com   NC 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.
245 245 John Sweet Bikegatestudio@bendbroadband.com BikeGateStudio Oregon Until further testing is done and Bullseye has their new filtration system up and running, it would be unfair to the artists that use their product and the employees that make it. It is my option that the DEQ is stepping the guidelines set up for a temporary shut down. Please don't go forward with this shut down. This sounds like a knee jerk reaction that Donald Trump might come up with!
246 246 Lori Blessing Loribless@gmail.com D"Verre Kilnformed Art Glass Idaho I am a glass artist in Idaho. I feel that
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
247 247 Emily Carlson mle@solsticeartsource.com   Illinois Open the document to see the effects of the process 12916101_606737696144139_8805361366631670536_o-1.jpg https://data.oregon.gov/views/trwb-z8xe/files/3aaba488-0717-46a6-8357-e42927a1d5b6
248 248 Ann Rosendahl anlaglas@anlaglas.com Anla Glas A/S Denmark
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.
249 249 Ann Rosendahl anlaglas@anlaglas.com Anla Glas A/S Denmark
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.
250 250 Michele Schuster micki@davidfschuster.com   New Mexico 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.
251 251 Jean Dougherty jeancaindougherty@hotmail.com Individual WA Unless the Oregon DEQ can prove that air and soil levels are contaminated there should be no rules applied to the colored glass industry. Stained glass industries are beloved by many people over the centuries.
252 252 Paula Radke paularadke@gmail.com Paula Rasked Dichroics,Inc CA - California This will put me, a 62 year old woman who has been making a living using Bullseye Glass out of a job. What can I do at 62? I am not qualified to do anything else and I am too old to enter the force force. Please savey business and handle this issue fairly with no chips on anyone's shouldets.
253 253 Nathalie Joel nat.jojo@virgin.net Nathalie Joel Glass Design United Kingdom I do not object to Bullseye and Uroboros having to upgrade their furnaces if the scientific tests on pollution are proven conclusive but I urge you not to rush into making them stop production of glass. The interested parties are not only the public and the 2 manufacturers as you state in your document, this will also affect tens of thousand of glass artists across the world who make a living by using the raw materials produced in Portland. Please make sure your decisions are based on scientifically proven facts rather than on assumptions and political pressure. Your decisions are going to have a huge economical effect much further afield than the Portland area. You could literally starve and kill the art glass world community. I know it will directly affect me and I do not live in Portland as I need those materials to be able to work and bring up my family, without them I might as well close down, it is that simple. Art glass was found in Pompeii, French cathedrals have stained glass dating from the Middle Age, please realize the consequences of your actions in the wider world not just in Portland. Art glass is part of Humanity, Bullseye and Uroboros are 2 of the very few art glass manufacturers in the world. Please realize this.
254 254 Barbara Simon bbbsimon@comcast.net   FL 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. B Simon
255 255 Jerre Davidson jerredavidson@gmail.com Jerre Davidson Glass 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.
256 256 Russell Gilman-Hunt rgilmanhunt@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.
257 257 Pat Kane mpkane@comcast.net   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.
258 258 Lisa Hilquist lhilquist@gmail.com self CA Please do not destroy two small businesses by over-compensating the flaws in your laws. If the regulations were for much larger glass manufacturers, and these levels met, by smaller companies, are the laws not flawed? Why should smaller companies be penalized. Get the facts about furnace emissions instead of reacting to inflamed public ignorance. Don't you think the employees would be dropping like flies if the emissions were so hazardous as perceived?
259 259 Suzanne Townsend Suzanne@agreementswork.com   Oregon I am very concerned that the temporary rules you are considering are not based on actual science. The State should not risk the loss of important small glass makers based only on fear. DEQ should not react to past oversight problems by imposing restrictions that are not well thought through. Thank you.
260 260 Marceen bloom marce@effectnet.com private - artist   This is over-the-top for regulation....Please have facts that this is a problem. Focus on the big corporations and the rivers, and the big companies. There is no proof of massive contamination.....Play right. This is an art community.
261 261 Michelle Stewart topspin1418@gmail.com Stain glass Artist Georgia
Bullseye glass has a long history of responsible operation. I stand with Bullseye Glass in its efforts to continue operations as a stain glass artist that rely s on Bullseye for my glass needs.

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.

With all due respect I hope your making the right decision to only target this one type of Manufacture. Have the other businesses in your wonder state not also effecting the air quality too? Thank you for you time with my message.
262 262 ruth Parvin ruthnilea@yahoo.com SE Portland neighborhood OR It breaks my heart to see what is happening around Bullseye glass. I can't imagine the fear that the parents and people who live in this area feel. And I just hate what is happening to Bullseye who, as I understand it, have been operating within the law. The temporary rules being proposed appear, however, to be due to public fears that are not based on science. They appear to be a way to appease the fears of the people based on fear no science. I am a long time potter and have studied the chemistry of making glazes, a type of glass. It seems to me that there is a real lack of understanding of the chemical processes that happen inside the kiln and fear mongering based on the lack of this understanding. Please do not do something hasty and political that will destroy this portland based small business. Know your FACTS first.
263 263 Deborah Anglin tangoexpat@yahoo.com   TX There are enough scientifically proven, serious problems that deserve your attention. As such, please leave this company alone. I used this product for years without any ill effects.

Sincerely, Deborah
264 264 Joe Leggiero lafarge04@hotmail.com Savannah Glasswork Canada Just begging you guy to re-evaluete any negative issues on this matter. As a glass artist for many years ( and many to come) I hope for a well tough legislastion. We breath metals, poisons... We eat metals, poisons...I don't feel now that any arguments against my favourite glass Company are fare. The future I see is the deat for my craftmanship. What about controlling glass manufactured in Cina and the letal contenents in it? PLEASE PLEASE PLEASE BE WISE IN YOUR DECISIONS. Best regards
265 265 Jean Scholtz jean.scholtz@mindspring.com   Oregon I urge DEQ to not impose temporary restrictions on the rules limiting metals emissions from the processes of art glass manufactures. The science shows that their current processes are adequate or being addressed at this time. DEQ should focus on finding a policy that is scientifically supported to put into place permanently. A temporary order will actually not be temporary and will most likely eliminate two companies and many jobs in the Portland area.
266 266 Jean Scholtz jean.scholtz@mindspring.com   Oregon I just read the majority of the 14+ pages of comments. It is very obvious that passing this temporary order will adversely impact citizens across the world. You need to conduct some thorough studies to determine what impacts if any the current processes are have on the environment and work with the glass companies (as well as other polluters in Portland) to come up with regulations that work for all concerned.
267 267 Jim Piercey jpstudios@aol.com J. PIERCEY STUDIOS, INC FL Environmental regulation based on accepted scientific guidelines is an imperative - unwarranted regulation based on emotion,
voodoo science, or hysteria, is not.
There has to be a logical separation between fact and fiction. If it can be proven that either of these two companies are responsible
for the release of any heavy metals into the environment, then they should forced to comply to the new regs.
I'm from Florida. Recently I visited the beautiful state of Oregon - a standard bearer for the environment. If there was any other state
I would want to live it, it would be Oregon, not only for its beauty but because the people there seem to really care about the place.
If in fact, there are increased levels of heavy metals in the soils around Uroboros and/or Bullseye, who is to say that they are the
responsible parties? Many industries near these glass factories probably use heavy metals (tanneries, paint manufacturers, electro-
plating plants, some types of ceramic manufacturers, cement manufacturers, wood preservation plants). Both of these glass
manufacturers appear to be located in areas that have historically been industrial. If contamination is found in these areas, who can
say how long it has been there or from where it originated?
Just the term "heavy metals" cause consternation among people. As for Cr III, it is a naturally occurring form of chromium. It is is many
foods and is a necessary micronutrient - it is necessary for some protein structures and certain enzymatic actions. I would venture that
many of the people that are supporting the the DEQ proposal are the same ones that buy from the health food store, then swallow
chromium picolinate (Cr III)
Cr VI us altogether a different matter. If it can be proven (using SCIENCE) that either companies furnaces are converting III to VI,
and it is being released into the air, then it is a problem that should be addressed.
These companies make beautiful glass. I use it in my business. If these Oregon factories (as well as the few other glass factories
still located in the USA ) are forced out of business because of arbitrary and unnecessary regulation, then I will in turn have to buy
my materials from overseas sources. It would seem to me (remember, I'm a Floridian) that EPA and DEQ would work together with these
companies to determine the actual source of these pollutants, then work towards eliminating the source.
This past year, the Stained Glass Association of America held their annual conference in Portland. We did so because it is the home
of both Uroboros and Bullseye which are famous around the world. I feel totally confident that both companies
operate with a very high degree of integrity and ethics and are totally dedicated to the environmental wellness of the area.
268 268 Phillip Johnson-Tuwaletstiwa philhopi@gmail.com retired New Mexico   Comments on the Proposed Temporary Rule specifically directed at small colored glass manufactures.docx https://data.oregon.gov/views/trwb-z8xe/files/9394979c-de91-4933-9e2e-4ed9a403e6bf
269 269 Jon Orloff jon.orloff@mindspring.com Professor Emeritus, Department of Electrical and Computer Engineering, University of Maryland Oregon This proposed rule is ill-considered at best. Study the science, listen to those who have studied how the generation of Cr-6 can be prevented and base your rules on rational analysis. "Feel good" regulations that play to ignorant hysteria are a poor way to go; they will do nothing for the environment and cause economic harm to the state. Use only evidence based reasoning.
270 270 Susan Green segpdx@yahoo.com Bullseye Glass OR Greetings- I am writing to you as an almost 21 year employee of Bullseye Glass. Of course, I and everyone at Bullseye is concerned about the environment. We have always been progressive in the way we deal with environmental concerns- meeting and/or exceeding goals and limits that were given to us.

The issue here is that we were not informed of these new benchmarks before the information was leaked to the press. And, benchmarks are just that- goals to work TOWARDS. We are happy to do, and have already begun work on new systems.

My immediate concern is that the proposed temporary rule regarding chromium SEVERELY limits our production. Chromium as we use it is not a hazard, and there is no proof that it can or will be one. There is only proof that it is NOT a health concern. The proposed rules are supposed to be for emergency situations. This is not an emergency. Soil levels tested fine. Air quality is improving and will continue to do so now that we have knowledge and are installing filtration systems. The rule will not make anything better, and will only serve to harm small business. Also, no other small business that uses chrome is in the cross hairs. If this is such a danger, why aren't other businesses that use chrome being targeted in this rule as well? It's simply not well thought out, or executed, and will only harm the community in that many people may be put out of work.

Please CAREFULLY consider this rule- it's bad science, will solve nothing, and will possibly harm hundreds of local families, not to mention tens of thousands of people around the world that rely on Bullseye's products for their livelihoods.

Thank you for your consideration-
Susan Green
271 271 Mark Ditzler mark@markditzler.com Mark Ditzler Glass Studio Washington Please allow Bullseye and Uroboros Glass companies to correct air quality problems without curtailing their production. Bullseye and Uroboros are responsible companies who will do the right thing if given the chance. Also, my glass business depends on a reliable and affordable supply of their glass products to stay in business. Please work with these companies to achieve acceptable air quality standards without harming the art glass industry. Thank you
272 272 Bert Weiss bert@customartglass.com Bert Weiss Art Glass NH Bullseye Glass Company is working hard to be a responsible community member while manufacturing a world class product. Please work with them to verify that their emissions are not harming the community.
273 273 Jack Whitworth jack@whitworthstainedglass.com Whitworth Stained Glass Texas I fully support Bullseye and Uroborous companies and their effort to comply with existing guidelines. Their willingness to modify their process in order to secure a safer environment is evident. I find it wrong that processes could be changed (even temporarily) before factual data and guidelines are obtained and implemented. I implore the resistance of the DEQ to submit to media and political bias and pressure. Multiple visits to both Bullseye and Uroborous indicate responsible and responsive community members. The stained glass studio industry depends on these and all stained glass manufacturers for beautiful and high-quality stained glass.
Thank you.
274 274 Kathy Monti glassykathy@yahoo.com Prairie Light Art Glass Studio LLC ND Dear Jill, We, in the glass industry are depending on you to make decisions based on science, our livelihood depends on it. Thank you, Kathy Monti
275 275 brianna ortega bo2@pdx.edu portland state Oregon I want to know what is going on with our air and water. I have high arsenic in my urine from living near woodstock and cesar chavez. I want to know that Portland wants to protect its people that care so much about health and the enviornment. I want to know what is going on and why my health is deteriorating at such a young age.
276 276 Phyllis Williams phyllis.w@comcast.com Fused Glass Artist CA Hello,

I understand the anxiety of Portland’s residents who live in the vicinity of Bullseye and Urborous Glass manufacturing facilities.

I believe the Proposed Temporary Rule for Colored Glass Manufacturer Emissions goes too far and is based on fear and a lack of understanding of their manufacturing process.

A leading glass scientist from Alfred University, Williams LaCourse, PhD states to obtain the desired colors for Bullseye and Urborous glass, it is not possible for their furnaces to produce toxic chromium.

Many small arts and crafts businesses use Bullseye and Urborous Glass to make their living. This temporary bill will cause harm to small independent artist who rely on their glass without scientific evidence it would make Portland’s and our environment safer.

Thank you for your consideration.
LaCourse letter.pdf https://data.oregon.gov/views/trwb-z8xe/files/0910a5ab-0b64-4276-915f-1c74bdecaff3
277 277 junya tsugita j.tsugita@gmail.com     To us is I need a glass of bullseye. Glass artists in the world you need a glass of the bullseye. Please do not let stop the production of the bullseye glass .
278 278 Kari Russell-Pool kari@karirussell-pool.com Petrovic Glass LLC Ohio I am an artist and educator located in Ohio who makes work tied to Bullseye’s product. I am also an engaged and caring steward of our planet’s air, water and environment.

My wish would be that the governing authorities would focus on permanent rules, based on scientific investigation to address Portland’s air quality issues. Rules that could give clear directions to businesses and support the safety of the community. My further hope is these rules and regulations would cover all businesses, and not just target specific industries. Understanding that there is no evidence that emissions from the Bullseye facility pose any acute health risk, if the EQC were to implement the proposed 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 and put our livelihoods in danger.

My impression has been that the haste to adopt technically flawed temporary rules makes Oregon appear responsive to fears over reason-based solutions that protect both the health and safety of the community and the important USA based manufacturing business and jobs both locally and globally.
Sincerely Kari Russell-Pool
279 279 Marc Petrovic mtpetrovic@cia.edu Cleveland Institute of Art Ohio I am an artists and educator located in Ohio who makes work tied to Bullseye’s product. I am also an engaged and caring steward of our planet’s air, water and environment.

My wish would be that the governing authorities would focus on permanent rules, based on scientific investigation to address Portland’s air quality issues. Rules that could give clear directions to businesses and support the safety of the community. My further hope is these rules and regulations would cover all businesses, and not just target specific industries. Understanding that there is no evidence that emissions from the Bullseye facility pose any acute health risk, if the EQC were to implement the proposed 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 and put my livelihood in danger.

My impression has been that the haste to adopt technically flawed temporary rules makes Oregon appear responsive to fears over reason-based solutions that protect both the health and safety of the community and the important USA based manufacturing business and jobs both locally and globally.

Sincerely,
Marc Petrovic
280 280 Nancy Wilcox nwilcox95@comcast.net   OR The recent OHA studies found that there was no increased cancer risk in SE Portland attributed to Bullseye’s use of trivalent chromium. Evidence clearly indicated the furnaces won’t turn Cr(III) into Cr(VI). In this light the glass making companies should not be subjected to a crippling temporary rule before they can get finish installing more efficient processing measures. At this point they have been following all the state regulations and are being singled out based on politics and public fear rather than scientific facts.
281 281 Bob Jones robertsenoj@gmail.com Individual Florida I have used Uroboros and Bullseye glass for years. Both make exceptionally fine art glass that is highly regarded world wide. Both forms are run by good people that are highly skilled and knowledgeable. I encourage you to work with these small manufacturers to enhance environmental standards while keeping their businesses open and viable. It would be a shame if these individuals were forced to take their specialized and advanced technical skills to other countries.
282 282 debbie James starfishdj@aol.com   Texas I can't believe you guys are squashing another american industry. This time it affects me. It's one thing to protect the public but quite another to overprotect at the expense of a lot of people's jobs. I guess you don't care because you got a cushy government job. What are you going to do when you destroy all those who support the government through taxes? Hello those taxes pay your salary. We are the producers and the money makers. You have become the destroyers.
283 283 Jim Vermeer jvermeer@q.com Vermeer Glass Art Iowa Dear Regulators: The DEQ is in the process of making temporary rules not entirely based on science and with hysterical fingerpointing by the press to restrict Oregon art glass makers before they have all the facts on just what levels of metals used in glass are harmful. They propose to limit these job creators and Oregon ambassadors based on consumption of metals when the majority of what metals these factories consume does not pose a health risk because it is sealed in glass. Basing a rule on consumption and not emissions is just onerous rule making not based on facts. The DEQ should wait, determine what toxic levels are and make permanent rules based on science not hyteria and fine the factories for exeding those levels. Yes, we are from Iowa and yes we care about the environment; however, before over reacting, I hope you realize the impact of your actions for many individual businesses across the country. You are impacting the lives outside of Portland as well. Please move forward cautiously, as your decisions impact many lives both in Oregan and across the country and internationally. Thank You.

Sincerely,
David Kingman
284 284 Kathy Monti glassykathy@yahoo.com Prairie Light Art Glass Studio LLC ND I urge you to use science as a basis for your decisions regarding glass manufacturers. Many rely on the glass industry for their livelihood. Thank you, Kathy Monti
285 285 Donald Burt dburt_mail@yahoo.com Liberty Mutual Insurance Ohio I appreciate the rational and measured approach that the DEQ is taking towards this issue. Please do the right thing. If there is health danger, take prompt action to mitigate it. If there is not evidence of an immediate danger, then please consider the importance of these small businesses to people of Portland and to the many people all over the world who use their products. Small scale manufacturing of something as unique and enriching to our quality of life as this artists' media is something a city should treasure. Give the companies a chance. Help the companies do the right thing so that they can survive and continue to add to the rich quality of life in Portland.
286 286 Min-Yi chen michael@vetri.com.tw Vetri glass art company 台灣 I use Uroborus fusing glass only. I will also out of business if this company closed. I wish this company continuing manufacture and supply fusing glass to my company in the codition of environmental frendly.
287 287 Belinda Schearf bkschearf53@aol.com Glass Art by MSM Missouri As a glass artist who is a customer of Bullseye Glass, I am dismayed to see the implementation of temporary rules that are targeted to specific companies based on such limited information. The imposition of these rules will greatly impact businesses and individuals around the world, that depend on Bullseye and Uroboros glass production. Therefore, I urge you to do further investigation and work with these companies to find a solution to this problem based on scientific fact, and not react to the emotional responses from the media and public. Your own technicians state that there is no public health concern based on recent testing. Therefore, putting a business at risk by implementing rules that are not based on fact, when so many people depend on it for their livelihood, is irresponsible. I urge you to reconsider these temporary rules.
288 288 Raoul Stepakoff skipoff@comcast.net self-employed CA 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. Forcing Bullseye to curtail production of certain of its glasses will deeply effect the ability of tens of thousands of glass artists throughout the world from creating their art and harm the families of employess and suppliers of Bullseye. This is a small business and the rules could potentially put it out of business, for the sake of political expediancy.
289 289 Edward Sawyer wishputty@hotmail.com   Oregon A temporary rule is appropriate in the instance in which there is an immediate threat to the public good. Contrary to the claims made on the DEQ website, there is not an immediate threat from these facilities, and this is supported by the Oregon Health Authority and Multnomah County Department of Health as well as independent members of the scientific community. The claims made on the DEQ website and in the full text of the rule are not supported by science - no evidence is cited to support claims made. Please do not pass this temporary rule. It is not based in science, but rather in fear. It will hurt responsible businesses made up of responsible people who are working to do the right thing.
290 290 Mike Rerick mike@dragonglassworks.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.

If Bullseye Glass is forced to go out of business, you will affect me as an artist as well as thyousands of other people world-wide. You could be responsible for destroying an entire art form.

Why don't you investigate the real pollutants that make our air bad - commercial diesel engines in trucks, buses and ships. There have been numerous studies showing that they are the number one contributor to air pollution.
291 291 Kathy Engholm comment@indigocrow.co   Oregon Of course, the physical health and safety of our community should be a top priority. Economic health is a lower priority, but should not be sacrificed unnecessarily. The proposed rules under consideration are not properly crafted to solve the overall problem of toxic chemical pollutants in the Portland area, but instead appear to place unjustified limitations on two small, locally-owned businesses while ignoring other industries with greater emissions.
Uroboros and Bullseye were both founded in Portland over 40 years ago and have been part of our community through thick and thin. They sell their products world-wide and bring that revenue back to Portland in the form of jobs, taxes, education, and support of the arts. Flint, Michigan has lead in their water because they lost their manufacturing jobs, had to cut costs, and made bad decisions. Don't gut a Portland industry "just in case", especially when they have been long-term good citizens and are eager to work together with the rest of the community to research and resolve this issue.
292 292 Patricia Nelson pnelson1@aol.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.
293 293 Jerry De Wald Studio-66@midco.net Studio 66 Custom Design Stained Glass South Dakota Please do not constrain the abilities of either Bullseye or Uroboros from producing glass without using thoroughly vetted scientific studies that prove without a doubt that their proccesses do in fact endanger the public. We have used their products for over 16 years and have suffered no ill effects. Their Glass is essential for the continuation of our business and livelihood!
294 294 Jo Tricker jtglass@xtra.co.nz Jo Tricker GLass New Zealand I fully agree with all 9 points that bullseye has presented in regards to air quality, which I have attached in a word document, and I fully support its efforts to operate as a legitimate company in the business/social community of Portland Oregon.

Bullseye glass has been in operation for 42 years. It is highly respected - not only in America but also worldwide - as the forefather of kilnformed glass manufacturing and art glass education

Given that a leading scientist, Dr. William LaCourse of Alfred University, has said Bullseye’s furnaces do not produce toxic chromium, I am appalled as to why DEQ would favour politics and poorly written rules over and above factual science. If the production of Bullseye glass were to be curtailed or completely shut down, this would set a trend for all the other glass art manufactures in America such as Uroboros in Oregon, Spectrum in Washington, System 96 in Washington, Kokomo in Indiana, Wissmarch in Virginia, Creation is Messy in Seattle, Northstar in Oregon, Youghiogheny glass in Pennsylvania, and Armstrong Glass in Georgia (to name a few…) to also be curtailed. Thousands and thousands of people worldwide who have art glass businesses would also have to shut down resulting in loss of jobs worldwide. The consequences of actions need to be carefully considered!
BE air admissions https://data.oregon.gov/views/trwb-z8xe/files/4bbdb606-340d-45c4-ac2f-924b08a68173
295 295 Shuichi Ogata booshu1@yo.rim.or.jp Artist Osaka Japan If can not make glass . We can not fix before art works .    
296 296 David Taylor micromelt01@gmail.com Anla Glas Denmark Bullseye Glass maybe a small business measured against others but it is a world class company and the world is watching how the DEQ behaves. Of course we in Europe see to our consternation every day how some american politicians spout rubbish in order to garner the whoops and votes of the people.
I hope that the DEQ , politicians and opinion makers in Portland will not use public fears and emotions to gain short term popularity and votes but will act responsibly and follow the wisdoms of science and technolgy to assess and amend if required. There is no evidence to instigate drastic 'firefighting' measures which will probably result in the loss of many jobs worlwide except in China.
297 297 Kurumi Tokushige   Glass artist JAPAN I have used these glasses for long time. These glass companies support glass artists all over the world.  
298 298 Bob Stevens bstevens@blendedsystems.com Glassting Impressions GA "More likely than not..." is no grounds for such a ruling. Get you facts then act.  
299 299 Maria Gracia Cabanilla geneandmaria@comcast.net   Oregon I have been an employee at Bullseye Glass for 21 years. I work and live in the communities affected, and it is obvious that we all want clean Air – I strongly support our local government to push for better environmental standards. But, I’m worried that Bullseye Glass has become the scapegoat of a much larger issue.

The DEQ and EPA have announced that there is no evidence of health risks – so, why are they pushing for a sweeping temporary regulations that will put our jobs at risk?
This temporary regulation will not protect the public – it will only harm Bullseye and all its employees.

Please take a second look at this temporary regulations and please make a decision that is based on science and not politics. Not allowing us to use Cr(III) will have a huge economic impact to the workers of Bullseye Glass.

I urge to work on regulations that make sense – regulations that aim to protect all. I urge you to strive for fair treatment of all parties, based on law and science.

I hope my voice also matters.

Maria Gracia Cabanilla
300 300 María Aragon maricruzaragon@gmail.com Independent Mexico I know that Bullseye art glass manufacturer follows all the rules that science says. I use this glass from your country and it is a shame that you even think in closing it. Think where the pollution problems really are, and please if you believe on science, follow what is saying.
301 301 Linda Meadows lmeadowsgm@gmail.com   Alabama 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.

The proposed new regulations will severely impact the local business area as well as the larger community of glass artists worldwide. Both DEQ and EPA have acknowledged there is no clear evidence of acute or chronic health risks based on Bullseye’s use of Cr(III). Cr(III) is essential to the production the glass. Scientific evidence shows the use of the compound is not harmful. Nevertheless, DEQ wants to restrict Bullseye from using Cr(III) for an extended period of time. They are essentially basing these rules on an assumption of guilt without any proper supporting scientific or factual evidence. Bullseye understands the public interest and supports stronger environmental standards for our industry. To that effect, the company has already begun the process of installing 99% efficient baghouses on furnaces that melt glasses with chromium. Bullseye Glass and DEQ will test these filtration devices to make certain they operate correctly.

Please delay this ruling until all the facts have been collected and reviewed.

Thank you,
302 302 Linda Meadows lmeadowsgm@gmail.com   Alabama 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.

The proposed new regulations will severely impact the local business area as well as the larger community of glass artists worldwide. Both DEQ and EPA have acknowledged there is no clear evidence of acute or chronic health risks based on Bullseye’s use of Cr(III). Cr(III) is essential to the production the glass. Scientific evidence shows the use of the compound is not harmful. Nevertheless, DEQ wants to restrict Bullseye from using Cr(III) for an extended period of time. They are essentially basing these rules on an assumption of guilt without any proper supporting scientific or factual evidence. Bullseye understands the public interest and supports stronger environmental standards for our industry. To that effect, the company has already begun the process of installing 99% efficient baghouses on furnaces that melt glasses with chromium. Bullseye Glass and DEQ will test these filtration devices to make certain they operate correctly.

Please delay this ruling until all the facts have been collected and reviewed.

Thank you,
303 303 Robert Seitz Harmonyartglass@sbcglobal.net Harmony Art Glass Company Illnois we believe that the amount of metal oxides is very limited , and can be further controlled. It is the rich history of stained glass that makes our country strong. This art proved the highest cultural advancements in our American society.
304 304 Ralph Shuping ryshuping3@gmail.com   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.
305 305 Claire Zevnik glassylady57@yahoo.com     As a customer and constant user of their glass, I stand with Bullseye Glass in its efforts to continue operations as a responsible citizen of the social and business community of Portland, Oregon. This company has a long history of responsible operation and environmental safety.
I believe that all 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 strongly urge DEQ to rely on science and fact, and not to rush to impose these poorly written and misdirected rules.
306 306 Tina Dodge tdodge6@yahoo.com n/a VA 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.
307 307 David Roberts dsr@ihsstudios.com IHS Studios Inc Texas My studio designs and installs stained glass windows in Texas and the surrounding states, although we do have several projects nationwide, including the Pentagon. We have done business with Bullseye for decades and have found their facility to be the cleanest glass manufacturing facility nationwide. I have no doubt that Bullseye operates with the utmost regard for the environment and public safety. When these safety concerns were brought to their attention, they voluntarily suspended their production of red glass pending modification of their equipment.

This voluntary suspension unquestionably creates a hardship on their operations, a hardship on my company, and risks placing a hardship on Bullseye employees and the communities in which they live. It appears that these "temporary" rules which will prohibit the creation of green glass, cutting Bullseye's sales down to 50%, will unquestionably lead to job losses in the very community being protected.

A leading scientist, Dr. William LaCourse of Alfred University, has said Bulleeye's furnaces do not produce toxic chromium. I would hope that the DEQ will act responsibly, as Bullseye does, and base their proposed rules on science rather than trying to gain publicity for "doing something" which may not solve the problem, and certainly would create unemployment.
308 308 Concerned Artisan     New York I am not in favor of implementing these temporary rules! The stained glass industry as a whole will suffer. Stained glass may seem like a small niche but it employs a lot of people. I am in favor of clean air but this seems arbitrary and puts a huge burden on small glass manufacturers. In the bigger picture it will effect ALL stained glass artisans. Could not your efforts be put to better use like targeting chemical manufacturers or large companies the pollute far more?
309 309 sharon genasci sgenasci@spiritone.com NWDA Air Quality Committee Oregon Draft Written Testimony from NWDA Air Quality Committee to the EQC on Air Toxics Temporary Rulemaking for Small Colored Glass Manufacturers, 3.22.16

Thank you for the opportunity to send written comments from the NWDA Air Quality Committee, to offer our views of your proposed temporary rules limiting metals emissions from small art glass manufacturers.

First, we would like to remind the EQC that our group, formerly the NWDA Health & Environment Committee, worked closely with ODEQ from 1997 through 2001, when Dr. Robert Amundson, our consultant worked with our NW Portland neighbors to gather VOC data using bucket monitors during strong industrial odor events. Later he put DEQ beakers on neighbors’ porches to gather dust falling through the air near ESCO Corporation, a multinational foundry on the edge of the neighborhood built in 1913. The particulates in the dust were analyzed for heavy metals.

These monitoring projects over the years provided evidence of lead, manganese, cadmium, arsenic, chrome Vl at dangerous levels for the public health of nearby residents.

Four years ago ODEQ was present during negotiations with ESCO for a Good Neighbor Agreement (GNA) that would reduce ESCO’s emissions by 20 per cent, but with no agreement to monitor the three plants to assure the neighbors that new controls were in fact reducing emissions even that amount.

In all those years of working with ODEQ there was no attempt at any rule making to reduce heavy metals in our public airshed. We welcome ODEQ’s belated concern, but the proposed temporary rules only for glass manufacturers is clearly not enough – not nearly enough.

Now is the time to write rules that apply to all industrial polluters emitting dangerous, heavy metals statewide. Please step up and give us the protection we need for our children and ourselves in Oregon. California and Washington state both have much better air regulations to protect public health. We are asking ODEQ to lead the way now to a higher standard for controls of heavy metals than Washington & California.

Sharon Genasci, Chair, NWDA Air Quality Committee
310 310 Pamela Richarde peacecoach@me.com   Oregon In our community governmental system, we must be sure when we make decisions that put 'rules' or restrictions around anything, that these decisions are based on clear, solid evidence. 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.

This feels much like a political action unfortunately. The impact of random changes based on fear is NOT what our Oregon green community stands for. 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. Take the time for due diligence and work WITH the community, the business and the people that are involved. If it is clearly determined that changes are needed, then partnering with Bullseye and other small glass manufacturers is the highest pathway, rather than 'doing' something to them without better research. It is our culture to partner. Please consider an integrated approach to this challenge.

Thank you
311 311 Russell Glenn Glenn813@gmail.com Concerned citizen FL How can you justify putting a business at rusk of clising and many losing their jobs. On a whim. I feel more investagation is needed Bullseye is cooperative.
312 312 Jeff smith jgs@archstglassinc.com Architectural Stained Glass, Inc. TX As both owner of a stained glass studio and a committed environmentalist, I hope you will allow me to present my perspective on the pending Temporary Regulations that will affect Bullseye Glass Company and Uroboros Glass, both in Portland. Since 1977, my studio has relied on the high quality and full palette of glass produced at Bullseye Glass Company and Uroboros Glass. I hope you’ll bear with me – I’ll try to avoid re-hashing details of which you are much more conversant than I.

Whenever there is an obvious environmental threat to a community, I am sure we all are in full support of aggressive actions to alleviate the threat. However, recent studies by the Oregon Health Authority and the Multnomah County Health Department with oversight by the OEQC have revealed no threatening levels of heavy metals in the air, soil or water in the vicinity of these companies. It therefore appears that the Temporary Regulations OEQC is considering do not address real threats to the long- or short-term health of citizens, but, instead threaten responsible/responsive manufacturers due to a loose, “broad-brush� approach. To curtail or threaten these corporate citizens’ viability without a clearly delineated threat, would force an unnecessary hardship upon them, their workforces and the local economy, not to mention their customers around the world – all with no apparent benefit to the environment.

I trust that the ultimate outcome of the discussion of these Temporary Regulations will be, not their enactment, but a realistic assessment of actual environmental threats. I am assured by both Bullseye Glass Company and Uroboros Glass that they stand ready and willing to make their workplaces and surroundings even safer than they are today in response to accurate scientific assessments. After such testing, should heavy metal contamination be revealed, a reliable science-based strategy can then be devised for the ongoing mitigation of heavy metals from the pristine environment for which Oregon is famous.

I trust you will be able to avoid throwing babies (such as Bullseye and Uroboros) out with the bath water. Best wishes in your important work!

Sincerely, Jeff Smith
313 313 Robert Amundson r.amundson@comcast.net public Oregon see attached PDF document Toxicshearing1.pdf https://data.oregon.gov/views/trwb-z8xe/files/3e4fb2d2-834f-4fbc-a96e-f19eeb29dffa
314 314 Barbara Vanderhoff barbara@vanderhoffstudios.com VanDerHoff Studios WI It is our hope as well that the DEQ would do its very best to ensure that the supposed environmental issues raised by the recent discovery of elevated levels of toxic metals in the air, are treated as delicately as possible. Please find ways to filter the air or other protective filtration requirements before banning it completely. People's jobs and businesses are at stake, and its hard enough already to restore these Historic Cathedrals that adorn all of our towns and cities in a respectful and correct way without banning the materials that are needed to complete the job. This is not going to only affect a craft that many people do in their homes, schools and small business such as lamp and lighting industries, small art glass business and major historic restoration companies like ours. It is our hope that you would regulate without an agenda, either left or right and visit all filtration options before banning the substance that creates one of if not the most popular color glass that is in high demand. Please reach out to University of Arizona Industrial Engineering school to figure out a filtration system to safeguard any legit findings that you have to protect the communities around these glass making plants if the need is there as the health and safety of all of us are of utmost concern but not even trying to filter before you make a move to destroy so may jobs and business in this country is not in the best interest of all. Thank you for your consideration.
315 315 Janet smith janet@lightimagesglass.com elf-employed artist VA The proposed rules are not based on science, and would severely compromise both the manufacturers involved as well as hundreds of small businesses around the country, including my own.
316 316 Morgan Madison     WA Bullseye glass has a long history of responsible operation. I know this personally as a former long-term employee. 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 hastily written and misdirected rules. Additionally, as further testing comes in, it appears to indicate that adverse effects from the emissions detected in the initial moss studies are likely minimal to non-existent.

There are many jobs at stake, both in Portland and around the world. As an artist now working with Bullseye Glass products, my livelihood and ability to contribute to my community is at risk if these rules, that are not based on sound science, are haphazardly imposed. Please don’t let fear and agitation drive policy when a sound and rational approach can be taken that protects both the health and safety of the community and the livelihoods of numerous small businesses and independent artists.

Thank you for your consideration.
317 317 Joseph Cavalieri cavaglass@gmail.com Independent Artist New York I use these products and see the amount of emissions to be very small compared to larger manufacturers. I would suggest a more detailed and controlled long term study of the emissions and the options, and effects on the people working in this industry.
318 318 Geraldine Ensminger   McKeever Studios 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.

Another example of believing media hysteria as opposed to intelligent research done by scientists.
319 319 Glen Albig imagesinglassinc@yahoo.com Images in Glass, Inc. New York We do not agree with the DEQ's stance on this issue.
According to OHA scientific info there is no hard evidence that the emissions from these stained glass manufactories pose a serious health risk, especially if said manufactories add safe-guards (which we understand they are doing). It is also noted that soil samples from around the plant(s) show no heavy or above normal levels of the toxins dealt with here.
Apparently DEQ"s and OHA's own statements say that temporary regulation is not needed to present "serious prejudice to the public interest".
If these plants (and probably many others across the country) are forced to limit the color of glass they produce, our business would be severely impacted. We make and restore stained glass windows (many considered to be artistic treasures in our Buffalo, New York area). The unavailability of all colors of stained glass would make repair of older windows impossible, not to mention the problems creating new windows with a limited color pallet.
Please consider long and hard before restricting the stained glass trade. Our livelihood depends on it.
320 320 David Coup turdherder02@yahoo.com Bubble Squeeze A fused glass studio Florida I appreciate the opportunity to comment on this issue. I retired from an environmental engineering company after 22 years and formed a small glass studio and checked into glass making companies and found Bullseye Glass to be very concerned about their impact on the environment in Portland. I began purchasing the glass from bullseye and found it to be the most beautiful and high quality . I am currently working on several projects now and would be disappointed along with my customers if I am not able to obtain the glass I require to finish the projects and continue winning new work on the product I rely on so heavily. I am used to working with local State, and Federal environmental agencies and have contributed to promulgating rules and support protecting our environment. I have seen where temporary rules are being considered and were detriment to the community because they weren't thoroughly considered and after a short period were withdrawn while further study could be done. I believe unless there is not an imminent danger to health and safety of the community that Bullseye and DEQ work in a cooperative manner to resolve any issues to benefit not only the community but the employees of Bullseye whom are apart of the community as well and rely on the jobs Bullseye provides. My interactions with the associates at Bullseye have always been positive they project professionalism, pride in their community and I believe represent your community well. As a customer I know that I will not be able to find quality glass and am not sure what the future would hold for my new business. Thank you for your time Sincerely, David Coup
321 321         OR Air quality is important and affects us all. My hope is that the environmental impact of harmful toxins released into the air is taken seriously. I also hope that the economic impact of unnecessarily limiting glass production with no scientific evidence of environmental harm is taken seriously. We should not invoke the temporary rules that could put small businesses OUT of business. We should be working with them and providing scientific evidence and reasoning to support DEQ proposed actions. It sounds like a witch hunt to blame the most visible parties for recent discoveries instead of scientific risk evaluation.
322 322 Leah Wingfield acmeartglass@gmail.com Acme Art Glass 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. Please review these findings here: http://www.bullseyeglass.com/about-us/faqs.html#chromium

Bullseye Glass is an Oregon company that truly has a global impact, creating critical materials used by artists around the world. Bullseye has generously supported artists, created programs, resource centers and been a leader in the glass art world. They have also been an example of an honestly, carefully grown business. To cripple this business based on the understandable emotions of a misinformed public will have a worldwide ripple effect. Ironically, they have been innovative precisely because they are a very careful scientific leader in developing new materials and techniques. Please approach your assessment the same way.


Acme Art Glass Inc.
Steve Clements- President
Leah Wingfield - Vice President

Jacksonville, OR
323 323 thierry sommer thierrysommer1@gmail.com Citizen Tennessee small businesses are the key to our economy over regulationa nd restrictions cause more financail harm then the the emmissions produced. Making businesses aware of your research and having them find solutions to the problem is more profiatble the community then shutting them down.
324 324 Suzie Geyer suziegeyer@carolinastainedglass.com Carolina Stained Glass North Carolina As a Bullseye Kiln Glass Resource Center and fuser, I have been following the environmental impact investigation and know that 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.

These misdirected rules and reaction to fear rather than science will impact those not only in your community but in the country and world at large. It will cause loss of revenue and jobs. PLEASE MAKE YOUR DECISIONS BASED ON SCIENCE rather than fear and political pressure.
325 325 Bonnie Hammes gbjjj@juno.com   WI It is our hope as well that the DEQ would do its very best to ensure that the supposed environmental issues raised by the recent discovery of elevated levels of toxic metals in the air, are treated as delicately as possible. Please find ways to filter the air or other protective filtration requirements before banning it completely. People's jobs and businesses are at stake, and its hard enough already to restore these Historic Cathedrals that adorn all of our towns and cities in a respectful and correct way without banning the materials that are needed to complete the job. This is not going to only affect a craft that many people do in their homes, schools and small business such as lamp and lighting industries, small art glass business and major historic restoration companies like ours. Look around at the windows in a church the amount of green that is used. It is our hope that you would regulate without an agenda, either left or right and visit all filtration options before banning the substance that creates one of if not the most popular color glass that is in high demand. Please reach out to University of Arizona Industrial Engineering school to figure out a filtration system to safeguard any legit findings that you have to protect the communities around these glass making plants if the need is there as the health and safety of all of us are of utmost concern but not even trying to filter before you make a move to destroy so may jobs and business in this country is not in the best interest of all. Thank you for your consideration.
326 326 Kristina Miller millerkl@bendbroadband.com   Oregon Bullseye glass has been in operation for over 42 years manufacturing colored glass without causing health issues in the community and I believe will continue in putting practices in place to ensure everyone's health . 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.
327 327 Bradley Butterfield bradleyab@hotmail.com private person Oregon Please be more careful in the writing of your temporary rule. These proposed regulations are overkill, and may harm local glass manufacturers and their customers. Both DEQ and EPA have acknowledged there is no clear evidence of acute or chronic health risks based on manufacturers' use of Cr(III). Scientific evidence clearly indicates the glass manufacturers' furnaces won’t turn Cr(III) into Cr(VI). 99% efficient baghouses on furnaces that melt glasses with chromium should be sufficient. These rules go far beyond what is really necessary. Please scale the rules back.

Sincerely,

Brad and Lana Butterfield
328 328 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.
329 329 Julie Harroun julie_harroun@msn.com neighborhood resident Portland I am against this temporary rule. It is unnecessary, punitive and not based on science. Additionally the companies targeted are actively working with the DEQ to install new filtration systems to meet even higher standards.
330 330 Cindy Young rocknrollschool@msn.com   OR I would like significantly stiffer fines with enforceable regulations and policies around them to ensure accountability.
When it's easier for industry to just pay fines instead of fixing the problem fines are not high enough.
331 331 Tim Carey tcarey@judsonstudios.com Judson Studios CA I am a designer and glass artist working for a large Stained Glass studio in Los Angeles. Our studio is currently working on an exciting project, the largest Stained Glass window in the world, all using Bullseye glass.

We strongly support Bullseye on this matter. In our dealings with their team, we have seen nothing but the utmost diligence and thoughtfulness on all matters, but especially on matters of safety. In the glass industry today, there is no other company with Bullseye's commitment in it's attention to detail regarding issues of safety. It's clear from the moment one steps into their facility.

It is apparent that there is NO evidence that supports a danger to the public, and rather there is clear evidence against it after reading Dr. LaCourse's report at http://www.bullseyeglass.com/about-us/dr-lacourse-chromium-statement.html . It would have a huge impact not only on the large number of families that depend on Bullseye for their employment, but on a Global industry, one that brings light, color, and joy to so many-- it's sad that there would even be a possiblity of losing this craft based on a fearful campaign that is not backed by any evidence.

Please do not impose these regulations on Bullseye or other glass manufacturers hastily. I support a thorough investigation of glass practices in all facilities across the country- one that returns a clear result based on evidence, not a hasty temporary band-aid solution with terrible unintended consequences.
332 332 Douglas Royse doug.orc@comcast.net   OR This increased restriction on law abiding businesses in order to appease citizens that have been stirred into a frenzy by an overzealous media, is unlawful. To force small businesses to drastically add to their costs, placing the business and many jobs at risk, based on hypothesis, or hearsay is irresponsible. Government entities represent business as well as individual citizens; which are really one and the same, accept one is a group of citizens trying to provide for many families instead of one person. Restrictions that clearly place a financial burden on anyone or any business, are sometimes necessary for the good of the many. However, such rules must be backed up by indisputable proof and facts, not guesses and whims. The powers that be are clearly choosing to take the easy way out in order to appease, rather than research the actual impacts and react accordingly. Businesses aka., groups of citizens, deserve the same protection as any one individual. If it is found, and proven, of course increased restrictions are necessary, but then and only then should rules be changed.
333 333 andrew Young ayoung@pearlriverglass.com Pearl River Glass Studio MS I am writing this letter in support of the art glass manufacturing industry in Oregon. Our company, Pearl River Glass Studio, has been in business for over 40 years. The art glass that my company buys from both Uroboros and Bullseye Glass has been an important part of the artistic success of what we make and do for our customers.

I am urging the Department of Environmental Quality to not unduly regulate this small but important industry in Oregon. I was in Portland last summer for the annual conference of the Stained Glass Association of America. Our group toured both the Uroboros and Bullseye glass factories. My impression was that both companies were very worker and environmentally conscious. Their facilities were well maintained, orderly, and clean. In order to produce the beautiful material I use in making art it would have to be. Both companies have been vital parts of the Portland social and economic climate for decades. It is not in their best interest to be anything but the best possible corporate citizen.

I further request the DEQ be very circumspect in its deliberations considering the science behind its decisions. As manufacturers of glass, a very exacting process to guarantee reproducible results in the making of colors, they know the science of the chemicals that they use every day. My firsthand experience is that these companies run environmentally conscious operations because they work there every day and live with their families in the community. Placing unwarranted and premature restrictions on their operations puts an entire industry at risk.

This affects me directly as an artist working in glass. I have a company of 18 people in Jackson, Mississippi. Our annual payroll is $500,000.00. The product made by Uroboros and Bullseye is used every day by these artists and craftsman. Recently our state celebrated the year of the creative economy. The glass manufacturers in Portland are a vital part of this creative economy not only here but across the entire United States and the world.

My company is currently underway in manufacturing a Holocaust Memorial for a local synagogue. If these manufacturer’s operations are unduly interrupted then I cannot finish this very important project.

Thank you very much for considering my opinion in this matter.

Sincerely yours,

Andrew Cary Young, President,
Pearl River Glass Studio, Inc.
334 334 Richard Mackin richmackin@gmail.com     Given the dangers caused up until negative publicity led to some modicum of self-policing, I believe the industry should be tightly regulated. Speaking as an artist myself, art glass is a low priority compared to public health and ability for people to chose the risks they are exposed to.
335 335 Rev. CarrieAnn Therese Paxsong1@aol.com Soul Fusion Arts LLC AZ I SUPPORT BULLSEYE GLASS COMPANY in feeling that thesexdecisions have been made hastily and without proper evidence. In fact Bullseye has acted responsibly from the start, with cateful attention to to the chemical processes in the glasses because if they did in fact do what they are accused of, their beautiful glasses would be ruined. Years of study and expense and artistic tradition have gone into the practice of creating these glasses in a way that is not harmful to the glass nor to the leople creating them, using them, nor residing near them. I fear this is a politically driven agenda and unfortunately have seen this happen too many times over the years. I have worked for environmental groups and speak here both as someone who has lobbied in Washington for Sierra Club in the past as well as someone who is a glass artist; and looking at this situation I feel the glass companies are being unfairly targeted here and thec repercussions could be disastrous to many. Nobody wants unsafe living or working conditions. I don't believe that's the case here. They need to re examine the studies.
336 336 Frank Spillers Frank@experiencedynamics.con Neighbors for Clean Air Oregon Protect the citizens first and foremost. Place aggressive monitoring and prevent pollution as a matter of urgency.  
337 337 Ginny Farmer farmer.ginny@gmail.com n/a OR I live and work in the immediate vicinity of Bullseye Glass. I have friends and family that work for the company.

I do NOT support these temporary rules, which are technically flawed, discriminate against two small companies unfairly, won’t improve Portland’s air quality, and aren’t necessary in the absence of acute health risks. Bullseye supports new regulations to improve air quality, but the temporary rules will not achieve that goal. These newly proposed regulations are based on politics and fear, not science and fact.

If Bullseye is restricted from using Cr(III), which does NOT turn into Cr(VI) in their furnaces or facility, they will be forced to eliminate half their product line, causing layoffs and potentially closure of the business.

The haste to adopt technically flawed temporary rules makes it appear that Oregon is repressive to manufacturing businesses and does not care about jobs.

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.

Thank you for the opportunity to comment.

Ginny Farmer
338 338 Gabrielle Derrico Gab@derrico.net GJD Organic Designs MA 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. I urge you - DEQ to rely on science and fact, and not to rush to impose these poorly written and misdirected rules.
As many other glass artisans in the industry, you must realize that this will not only affect the local economy of Oregon but the industry across the US. You will put most of use out of business! This is my livelihood. it is unconscionable of you to act on misinformation so you look good! Think before you act as this impacts us all. Humbly yours, Gabrielle J D'Errico
339 339 Emma         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.
340 340 Elizabeth Johnston lisajo.johnston@gmail.com   Oregon I had been a glass artist from about 1996-2014 and used Bullseye and other manufacturer's glass color rods for torch-forming beads and marbles. My studio was located across the street from the Bullseye factory at 2020 SE Bush for the last 1.5 years of that time period. I spent 7-8 hours a day working there on most weekdays. Although I knew there were some metals such as Cadmium used in the color, I was under the impression that the components of the glass I was using were fairly inert within the glass rods. Just to be safe though, I kept the windows open and circulated air from outside with a fan. I transitioned out of the glass business after I heard that some of the lustering colors I had been using were not safe. I thought I was limiting my exposure and assumed that there were air quality standards that the Bullseye factory was adhering too. I was shocked when I found out how high the levels of cadmium and arsenic were in the area, especially since I had already made a career change based on my own, much lower estimates of my exposure. I feel very strongly that there should be strict limits on toxic factory emissions for any factory size or zone. Many people, including the past and current employees of Bullseye and Uroboros as well as people who have been using their products or lived in the affected areas for years, have already had long-term exposure and will not be able to decrease their own biological accumulations of toxins if the emission of those toxins are allowed to continue.
341 341 Janet Pitcher janetpitcher@gmail.com Dream Visions Studio CA 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.
342 342 Marshall Hammond marshall@floathq.com   OR I live in the Brooklyn neighborhood near bullseye glass and have friends who work there. I humbly request that you review the steps Bullseye has taken to ensure that their facility controls emissions, and to weigh all scientific evidence before subjecting them to rules that will endanger their business. My understanding is that Bullseye will is in the process of installing bag filters on their furnaces which will effectively limit their emissions of dangerous metals to safe levels.
It is also my understanding that the proposal to ban the type of Chromium (CRIII) Bullseye uses is based on an incorrect assumption that it might turn into a different form of Chromium (CRVI).
In general I support rules that are designed to protect the environment, but I ask you to reconsider whether the proposed rules are necessary are both necessary and scientifically valid before endangering the jobs of my friends and neighbors.
343 343 Marshall Hammond marshall@floathq.com   OR I live in the Brooklyn neighborhood near bullseye glass and have friends who work there. I humbly request that you review the steps Bullseye has taken to ensure that their facility controls emissions, and to weigh all scientific evidence before subjecting them to rules that will endanger their business. My understanding is that Bullseye will is in the process of installing bag filters on their furnaces which will effectively limit their emissions of dangerous metals to safe levels.
It is also my understanding that the proposal to ban the type of Chromium (CRIII) Bullseye uses is based on an incorrect assumption that it might turn into a different form of Chromium (CRVI).
In general I support rules that are designed to protect the environment, but I ask you to reconsider whether the proposed rules are necessary are both necessary and scientifically valid before endangering the jobs of my friends and neighbors.
344 344 Martin Stone marty@rockyland.net   Minnesota https://www.pca.state.mn.us/news/new-data-confirms-poor-air-quality-north-minneapolis

I would suggest a closer look at your metal recyclers in the Portland area as a source of air quality pollution. the link above is just one example from Minnesota. Please complete your due diligence before taking the easy way out and targeting just one of many LIKELY sources.
345 345 Bernard Huebner contact@stoneridgeglass.com Stone Ridge Glass, LLC Maine Our studio urges the Oregon DEQ not to adopt temporary rules governing the furnace emissions of BullsEye or Uroboros.
True scientific data should determine what course is required to protect the public, not politically motivated speculation.
346 346 Cindy Young rocknrollschool@msn.com   OR Please be thorough in your investigations concerning all toxics emitted from industry. Long term exposure has not been addressed. How could these toxics be good for anyone at any level? I urge you to gather the right data. OHA has only gathered data from one lab. Communities have been tested by NP's who have used other labs. Please be mindful that the data used by OHA is incomplete and far from accurate. Please don't make your decisions on policy with skewed data. We have to make sure that all decisions and policy's concerning pollution and industry are health based.
347 347 Damian Kilby damiankilby@gmail.com   OR - Oregon Please, please close all loopholes and limit emissions to safe guard the health of our children and all of us. It's absurd to endanger thousands and thousands of people and consign some to a life time of painful health issues and possible death for the sake of colored glass!!!!!!
348 348 Judith Trebelhorn Trebsmom@yahoo.com   Oregon We've had our home in the area of bullseye for almost fifty years and are very concerned that this has gone on so long without any mention to neighbors and business in our area. I want my grandchildren not to worry in the future that we weren't concerned enough to take care of this problem. I hope DEQ does the right thing for us and future generations.
349 349 Judith Trebelhorn Trebsmom@yahoo.com   Oregon We've had our home in the area of bullseye for almost fifty years and are very concerned that this has gone on so long without any mention to neighbors and business in our area. I want my grandchildren not to worry in the future that we weren't concerned enough to take care of this problem. I hope DEQ does the right thing for us and future generations.
350 350 Harriette Hyde hydehj@yahoo.com USA citizen Oregon An alert has been sounded.
No damage has been proven to have occured.
New regulations, if needed, after a proper study are fine.
No, these temporary rules are flawed and achieve nothing.
This is an unreasonable response putting at risk a quality, reliable company in our community.
351 351 Lisa Arkin larkin@beyondtoxics.org   Oregon The temporary rules must apply to all glass manufacturers and glass makers statewide. Any Oregon resident living near a glass manufacturing facility could be at risk for exposure to heavy metals. Why only protect people living in certain Portland neighborhoods? All Oregonians deserve to be protected from uncontrolled emissions of cadmium, arsenic, and chromium VI. In fact, the temporary rules are insufficient to protect public and environmental health for the most vulnerable Oregonians. The DEQ knows these risks of heavy metal exposure affect other neighborhoods, not only neighborhoods near two Portland glass manufacturers. Yet the agency is proposing rules that do not address those risks. The DEQ’s own research shows that low-income neighborhoods and communities of color are most likely to be harmed by air toxics. DEQ is legally obligated to regulate air pollution through its obligations under HB 420, Oregon’s environmental justice statutes, and Title VI of the Civil Rights Act.
352 352 Margery Slate Margie8002000@yahoo.com   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, OR.
Regulatory decisions must be based on science, not politics and fear. 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 temporary rules.
353 353 Meghan Murray megara128@gmail.com Glass Artist - Bluebird Glass Studio VA Reducing the use of these metals would deal a significant blow to the art glass industry. With these regulations, it would be possible that stained glass, blown glass, fused glass, and mosaics would go without red, yellow, orange, amber, brown, and green glasses just to name a few. The amounts of chemicals being produced are not large amounts and these colors of glass are not run every day in these facilities. Our industry needs these colors or the art of glass manipulation will surely become something of the past. Please take this into account as you think about this decision. A world without glass art would be a world with less joy. Just imagine churches without stained glass windows. This is an old and treasured art form that we should not lose.
Thank You
354 354 Harry Tompkin studio@palaceglass.com The Palace Glass Co. Nebraska As an artist with nearly forty years of glass work in the public domain, churches, private homes and businesses, I find it difficult to believe that Bullseye Glass would not try to resolve any issue with air or water quality given time and careful study of factual scientific findings. Though a small niche in the artistic fiber of the United States, art glass significantly influences public spaces. Bullseye Glass is the leader in contemporary uses for glass and its investigation of glass properties and abilities. The situation deserves further investigation but immediate implementation of rules to curtail the production in Bullseye or Uroboros will certainly have an effect economically and artistically in the United States.
355 355 Kristina DiPaola kris@environmentalcapitalgroup.com Neighbors for Clean Air OR The era of public risk for private profit must come to an end. There are real, quantifiable costs associated with toxic and carcinogenic emissions, and these are borne by the public and especially the unfortunate individuals who live near the emitters. All toxic emissions should stop as soon as possible - with a hard deadline negotiated upfront - and until then, absolute best scrubbing technologies must be put in place for the protection of the public. In addition, an ongoing campaign for third-party monitoring of emissions and regular reviews and implementation of improved scrubbing technologies should be paid for by emitters. Anything less is criminal and these actions are long overdue. Thank you for your immediate attention to this urgent matter.
356 356 Scott Kimball scott.nicole.k@charter.net self WA see uploaded word file. Bullseye OR DEQ-CSK.docx https://data.oregon.gov/views/trwb-z8xe/files/0180ce64-f9ef-4687-abd7-8892598f63a1
357 357 Carmen Vetter Carmenvetter@gmail.com Citizen of SE Portland, glass artist Oregon I am an artist living and working in Portland Oregon. I exclusively use bull's-eye glass as the material for my work. I earn a living of approximately $50,000 a year on which I pay taxes to the city of Portland and the state of Oregon. My livelihood along with those of many artists covering the entire globe could be severely affected by this temporary order.

Bullseye Glass has proven over many years of operation to be a responsible business. I am a citizen who is very concerned about the environment and I place my votes in that direction. If I felt for one minute that Bullseye Glass was unscrupulous in any way I would not be purchasing and using their products. They are a local company with integrity who care about environmental issues deeply and are investing a great deal in working to improve this situation.

I am very opposed to the temporary ruling. Regulatory decisions should be based on science, not political issues. I strongly urge the DEQ to rely on science and fact, please do not rush to impose these poorly written and misdirected rules.

Sincerely,

Carmen Vetter
358 358 Teresa Frederick terryfrederick4thebirds@gmail.com   OR - Oregon Please adopt the temporary rules. Although the glass companies should be commended for suspending their use of metals in production of colored glass, there are currently no regulations in place to protect the public if they should chose to start using toxic metals once again. As a local resident, I am concerned for the health of my family, including my child. We grow backyard vegetables and are particularly susceptible.

No company, large or small, should be allowed to emit substances that are toxic to human health.
359 359 Mark Brody brodyarts@gmail.com Glass artist and school teacher OR Hello-
My name is Mark Brody, and I am a glass mosaic artist and I have been teaching mosaic arts in schools throughout Portland for the past 14 years. I have worked with well over 5,000 students using Bullseye Glass to create legacy projects that remain in schools for decades, and create lasting memories for these children as they grow older. Many of these projects are made using donated glass from Bullseye Glass Co., and if the temporary rules were hastily put in place in early April, this would have a direct effect on a project I have scheduled with the Chinese Immersion program at Woodstock Elementary. We were planning on creating a rendition of the Tilikum Bridge in the style of traditional Chinese scroll paintings. I plan to work with (80) 5th grade students. Bullseye Glass has a long history of responsible operation, and has been a supporter of community education.
Below is a version of the TIlikum Bridge I did with the 8th grade students of Beverly Cleary School in 2015. This glass was leftover materials donated by Bullseye from the Tri-Met Orange light-rail station installations.





Bullseye Glass has been my primary supplier of stained glass for my school as well as my professional work. In 2015, the Portland garden publisher Timber Press published my how-to book entitled Mosaic Garden Projects, which has 25 different designs for outdoor locations. This book has been a huge seller in the US, Canada and England, and in it I name Bullseye Glass as my only resource for buying glass. Finally, I will be teaching a Fountain mosaic class next week at the SAMA Mosaic Arts International conference in San Diego. I will be taking Bullseye Glass with me for these projects. So my appreciation for Bullseye Glass reaches well beyond the grade school students I teach.




I came to the DEQ session on March 15 to learn more about the current situation. What I found most striking was the OHA’s report stating that the soil and air quality tested “did not show harmful impacts� on the nearby neighborhoods, where I myself live. If there is no immediate health risks, then how can the DEQ take drastic actions which will harm this business, artists and citizens whom benefit from their work?
I strongly urge you to work with Bullseye Glass and come up with a solution that does not curtail their responsible practices. They are currently placing large baghouse filters on their chimneys to control emissions. They are taking the right steps. Please use science to decide policy, and not public fear.

Thank you,
Mark Brody
http://markbrodyart.com


http://www.timberpress.com
http://www.timberpress.com/books/mosaic_garden_projects/brody/9781604694871
http://americanmosaics.org
Mark's book cover pic.jpg https://data.oregon.gov/views/trwb-z8xe/files/f9c536bf-638e-476e-b3ff-2bb2a510b6e2
360 360 Steve Klein dksk@earthlink.net Steve Klein WA 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.

My business and my family's financial stability depend on my work. My work depends on Bullseye Glass. Again, I join Bullseye and all concerned citizens in wanting a safe environment. However panic and reacting to unsubstantiated and unscientific data hurts many innocent people. Please take the time to gather accreted data before imposing regulations.
361 361 cher church   Talented Lady CA I do not feel that these temporary measures are necessary. Please do not enforce them.  
362 362 Jennifer Cheng jenccheng39@yahoo.com n/a CA 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.

1.This is an improper use of temporary rule making. The Oregon Environmental Quality Commission should only consider a temporary rule when credible evidence demonstrates a rule is needed to prevent “serious prejudice to the public interest.� This is not the case here.

Hastily adopting temporary rules make it appear that agencies are being proactive, but these rules do not protect the public, and makes Bullseye a scapegoat. There is no evidence that emissions from the facility pose any acute health risk nor that Bullseye is fully responsible for the emissions, nor 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.

2.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.�

3.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.

4.The haste to adopt technically flawed temporary rules makes it appear that Oregon is repressive to manufacturing businesses and does not care about jobs.

5.Oregon agencies should strive for proper and fair treatment of all parties, based on law, rather than responding to public concern resulting from sensational blog posts and test results with partial data and no peer review.

6.The health and safety of the community can be achieved without forcing these businesses to close.

If Bullseye Glass is forced to stop producing 50% of its glass products for 6 months, without regard to ongoing test results or added emission controls, Bullseye’s survival is at risk. 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 (including me) and the world depend upon Bullseye products. Please stop the madness - do not adopt these temporary rules.
363 363 Lee Pritchard lee_pritch@yahoo.com Eastmoreland Heights/Woodstock Neighbor Oregon Thank you for your thorough and expeditious efforts in regulating the emissions of Portland glass producers. These efforts will undoubtedly make a healthier Portland.
I look forward to similar efforts being made to regulate Precision Castparts Corporation. It is unclear why one industry has received regulatory priority over the other, when the DEQ has been aware of the toxic emissions caused by PCC for some time. If the DEQ can act quickly to regulate the Portland glass industry on a temporary basis, there is no reason why it can not take similar action to regulate PCC. The failure to do anything to monitor or regulate PCC suggests that there are factors, other than a ensuring a healthy environment for surrounding residents, at play.
I ask that, as an agency, you be equitable in your rule making efforts and begin the process of regulating Precision Castparts, and similar industry, immediately.
Sincerely,
Lee Pritchard
364 364 Caroline Skinner caro4321@earthlink.net   Oregon I live in St Johns now but for many years lived near a large source of pollution Esco (foundry) in NW Portland. I am hopeful that DEQ will be more proactive to protect human health by sharing info about specific toxins found in the environment and by playing a more active role in limiting the toxic emissions from industry as well as from wood stoves and vehicles. I now live one block off North Lombard, a heavy diesel truck route, and I am bothered often by diesel exhaust at my home. We know diesel particulate is ultra-fine in size and harmful to human health. In addition to needing cleaner trucks, there is an urgent need to control metals emissions from small colored art glass manufacturing facilities. Uncontrolled glass furnaces processing colored glass to which arsenic, cadmium, chromium and nickel are added likely emit these metals at levels that can pose an immediate threat to the health of people nearby. This is not acceptable. The proposed rules would fill a regulatory gap by setting operation standards for the smaller art glass businesses that emit air toxics and potentially cause serious health effects. I hope the new rules are put in place soon and our health is protected better than it has been.
365 365 Bruce Pussell bpussell@bigpond.net.au Sally Robinson Art & Design NSW Australia More likely than not is not scientific evidence of harm. You should delay this decision, which will have a severe impact on us the users of coloured glass, until you have firm scientific evidence of harmful pollutants. Personally I have metal hip replacements and my blood chromium levels have been elevated for 10 years without harm so far. So, when a company is threatened by new rules, it must be based on good evidence before compliance is required.
366 366 Sarah Dionne info@sarahdionne.com Warm Glass Artist Ontario, Canada This is an improper use of temporary rule making. The Oregon Environmental Quality Commission should only consider a temporary rule when credible evidence demonstrates a rule is needed to prevent “serious prejudice to the public interest.� This is not the case here.

Hastily adopting temporary rules make it appear that agencies are being proactive, but these rules do not protect the public, and makes Bullseye a scapegoat. There is no evidence that emissions from the facility pose any acute health risk nor that Bullseye is fully responsible for the emissions, nor 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.

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. Bullseye will support that effort. 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.

The health and safety of the community can be achieved without forcing these businesses to close.

If Bullseye Glass is forced to stop producing 50% of its glass products for 6 months, without regard to ongoing test results or added emission controls, Bullseye’s survival is at risk. I support an agreement that is similar to the temporary rules, but unlike the temporary rules, also allows DEQ and Bullseye to respond promptly to new factual information.

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.

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.
367 367 Dave Sabo desert.dawg.art@gmail.com   NM Please use best available science in making your decisions. Any rules whether temporary or permanent have far reaching consequences. Bullseye glass has been a good neighbor and should not be penalized based on "assumptions" `regarding environmental impacts. As a former resident of Oregon I well understand how easy it is to get over-reactions from the public on issues which shouldn't really get the type attention that they do. Please be reasonable in your decision making and ensure that you do not overreact to unsubstantiated rhetoric.
368 368 Alex Krebs portlandalex@gmail.com   Oregon We had our kids tested for cadmium and arsenic. Both showed elevated levels and our 6 year old showed above normal levels. We are distraught that we have been doing everything possible to keep our kids healthy, and that they have (and continue to be) exposed to toxic metals that are beyond our control.
369 369 Thomas Benke trbenke@env-compliance.com The Environmental Compliance Organization LLC Oregon ODEQ has wrongly assumed that controlling particulate will reduce or eliminate heavy metal emissions from the Bullseye and Uroboros facilities. This "temporary" rule provides only political cover for the Department while doing nothing meaningful to protect people living in the surrounding neighborhood. The onus needs to be on Bullseye and Uroboros, before receiving permission to operate, to prove through stack tests, dispersion modeling, and proper risk assessments that its activities do not pose a threat to human health and the environment. "Put a baghouse on it" is not the answer to controlling metals emissions from glass-making facilities. ECOCommentsGlassRule.pdf https://data.oregon.gov/views/trwb-z8xe/files/37adaa9f-053d-4cab-bf8e-6a478b301972
370 370 Terri Walker terri.pdx@gmail.com   Oregon Please support the Arts and the artists, and the health of these artists, neighbors, customers by doing the right thing. As private vehicles are regulated, so industry must do its part to deserve Oregon's 'green' reputation. The public needs a transparent and accountable DEQ and a Department director who champions the Precautionary Principle as adopted by our city and county in 2006. http://www.sehn.org/pdf/portland.pdf March 28 2016 Letter to EQC Re Proposed Rules Small Glass Factories.doc https://data.oregon.gov/views/trwb-z8xe/files/4910e9e0-ace8-4718-ab23-082573a7ab25
371 371 Deborah LeDonne debbieledonne@gmail.com Engineer and Glass Artist Pennsylvania Please reconsider the "temporary" rule until further investigation has been done.
I am an Engineer and a glass artist in Pittsburgh. I have seen the elimination of the steel industry in this area from regulations and many communities have not recovered financially from these closures. These regulations started the same as the "temporary" rules proposed here and continued to a swift decline in the industry.
This also impacts the Engineering aspect of my job of trying to find USA sourced steel for contracts is prohibitively expensive to win these bids.
As a glass artist, I am extremely proud to advertise that my end product is entirely sourced and made in the USA. With these proposed bans and possible shuttering of the Portland glass businesses, the sourcing of the raw materials will be inconsistent in pricing and location and may drive some glass artists out of business also.
Please wait until the businesses have time to react to the proposed "temporary" rule and re-test the environment before acting.
372 372 Catherine Strand cjstrand@sbcglobal.net GlasRat Art Glass California I am a sole proprietor glass studio and a Bullseye customer since 2003. 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.

A leading scientist, Dr. William LaCourse of Alfred University, has said Bullseye’s furnaces do not produce toxic chromium. I urge DEQ not to rush to impose these proposed rules without considering the cost/benefit outcome based on scientific evidence.
373 373 Joseph Janczak joetexas@aol.com Sam Houston Window Texas If you find no clear evidence finding or linking to large amounts of metals in the area, then the investigation must be dropped at that point. Additionally, any metals found may have been there previous to the glass company and that must be proven. Some soils have natural amounts of lead, mercury, etc.
374 374 Melissa Barclay mbarclay0398@yahoo.com personal California Please do not adopt temporary rules targeted to affect only one specific industry – the colored art glass industry.This could set a precedent that could affect every other colored glass manufacturer in the United States, as well as employment opportunities in the affected areas. Please wait until these issues have been addressed & determined by the EPA and other relevant agencies.
375 375 Holli Lewis holli_l@hotmail.com   Indiana Please use facts in your ruling and don't just assume that small glass companies are the problem. Many glass artist rely on the colored glass that is made in our own country for both hobby and business. To force us to buy else where prohibits many people from the art and will make business fold because the will have to raise their prices.
376 376 DON FERGUSON donferguson46@gmail.com Laura Goff Designs Tennessee Public health and safety are of paramount importance. Concerns about the heavy metals that are part of the glass making process are important and appropriate.
However, I hope the concerns and emotions surrounding this issue do not cloud the real time data that is being collected as part of the evaluation of the colored glass industry, both in Oregon and across the country. Hopefully, that data and the available filtering technology will allow these industries to continue to produce the unique and amazing glass products which are used world wide. Thank you.
377 377 Elizabeth Broten lisabroten@comcast.net Citizen Oregon I want leaders to make sure the citizens of Oregon, are protected from the gross negligence of manufacturers and in this case colored glass manufacturers to keep our air, water and soil clean and free from dangerous contaminants. There are many more businesses who fall through the cracks and the DEQ turns a blind eye or knows the loop holes but does nothing as that is the nature of politics and money, but this needs to stop. Please pass this bill and keep us safe.
378 378 Joe Rowe ojoe22@gmail.com   Oregon All DEQ permits for all industry must meet the same standard. If your house or day care center is not safe to be next door to the permit holder, then the permit should NEVER be issued to ANYONE. Shut down the pollution or install expensive equipment to keep the pollution inside the building of the permit applicant. It's really simple. If jobs go away, they were jobs created at the expense of human lives. The glass companies can just triple their prices and pay to keep the pollution in their buildings.
379 379 Eric Mayhew emayhew@ymail.com Collective Light Studio OR / CO Please do not pass reactionary laws without using factual science to determine levels of toxicity. This effects thousands of people around the world and most importantly, Portland. I myself, can't make a living without the glass they produce.
380 380 doris cultraro dcstudios@msn.com DC Studios LLC New York I rely almost exclusively on the glass produced at bullseye and uroborus for my stained glass business for both new work and restoration work (ex: church windows, historic windows etc..) I am all for temporary measures for safety, however until all the facts are in place, limiting the production of glass that is needed for my business will severely impact it - and possibly force me out of business in the near future. While the investigation is ongoing, and the bullseye and uroborus co. are making efforts to add additional safeguards, they should not be required to halt their production. I understand that they have voluntarily halted some of their colors glass production using cadmium, during this time... but if they are making every effort to make the improvements requested, and while the final determination is still not made, they should be allowed to continue producing their fine product and keep their staff employed. If they are now asked to stop using chromium which is a major ingredient in their green toned glass pallet, then about 1/2 of their product line will be halted and unavailable to our studios using their materials, and may force us to limit our business and possibly layout our workers if we can't produce the work with the materials our clients have selected. The small glass art industry has been in the US for the past century plus, - and if not for those companies supplying their unique specialty glass - many of the major art works we value today would not be around for the public to enjoy and for our skill craftsmen in our industry to make, create and preserve.
381 381 Kim Fitzpatrick kim@tsglass.com.au tradition stained glass pty ltd Western Australia As an International purchaser of the fine products supplied by your local company Bullseye and Uroborus glass, I do hope that a scientific and factual assessment will be concluded to make a true and just decision on what limitation one might impose on these local company's, I am sure that many compnays such as mine would be very concerned if the colored glass currently on offer was to stop in production, and I am sure the exports coming out of Oregon would be sorely missed by the community at large. Please insure accurate and scientific results are used to facilitate an action plan to keep this fine business in Business.
382 382 Randy Miller rjaymiller@gmail.com Citizen OR Bullseye Glass has been operating in the same location for 40 years and 130 families depend upon their employment there. There is no immediate health risk. The recent Oregon Healthy Authority (“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.�

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. Bullseye will support that effort. 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.

If Bullseye Glass is forced to stop producing 50% of its glass products for 6 months, without regard to ongoing test results or added emission controls, Bullseye’s survival is at risk. We support an agreement that is similar to the temporary rules, but unlike the temporary rules, also allows DEQ and Bullseye to respond promptly to new factual information.

The haste to adopt technically flawed temporary rules makes it appear that Oregon is repressive to manufacturing businesses and does not care about jobs.

Oregon agencies should strive for proper and fair treatment of all parties, based on law, rather than responding to public panic resulting from sensational blog posts and test results with partial data and no peer review.

Unreasonable fears should not trump reason-based solutions. The health and safety of the community can be achieved without forcing these businesses to close.

Thank you,
383 383 Natalie Bennon nataliepdx@gmail.com   Oregon I want all facilities using any sort of heavy metals to have filters installed that remove the heavy metals before they are emitted into the air. I repeat: all facilities using heavy metals need to cap all of the stacks that use heavy metals -- or any other dangerous pollutant. Thank you.
384 384 Sally Riley sallyenberg@hotmail.com   Oregon The DEQ needs to have an outside, unbiased watchdog agency partner with it in order to monitor and regulate the air quality of Portland. The DEQ has not been open with the public or protective of the health of the public. It has systematically overlooked and misreported the amount of unfiltered and toxic emissions that these companies have been emitting for years at the expense of the children and families in the neighborhood.
These companies must be required to install proper filtration systems so that they have no toxins poisoning our air, soil, food and bodies. If they don't cooperate with the clean air requirements, they will need to lose their permits to operate in this state.
Please make a stand to protect our children and families.
Thank you,
Sally Riley, mother of two and concerned teacher in the local schools.
385 385 Dan Packard dan.packard@gmail.com   WA Hi,

I am very concerned about the harmful air emissions that some industries in Portland are sending into the environment. For 15 years, I lived within a half mile directly downwind of the Bullseye glass factory. Our family experienced numerous severe health problems of cancer, abnormal growths, rashes, vomiting, diarrhea, headaches, nausea and fatigue, most likely due to the toxic heavy metals this factory has been releasing into the air.

I recall riding by the Bullseye factory periodically by bicycle and smelling obnoxious and repellent odors coming from an open area at the south side of the building on SE Bush street.
Since moving away from Portland, the unhealthy symptoms I experienced have slowly subsided.

I think it is extremely important that DEQ monitor more aggressively the toxins that industrial factories such as Bullseye, are emitting into the air. Other problem areas, are emissions coming from the ESCO factory in NW Portland (terrible burnt brake lining smell in Portland's downtown and Pearl district areas when winds blow from the Northwest and this factory location). Another unhealthy air shed is in the vicinity of the Graphic Packaging / Sun Chemical corporation in North Portland, near I-5, the Expo Center and Delta Park.

These companies are required by law to report the toxins they are pumping into the air we breath. Why isn’t DEQ connecting the dots and monitoring the air in these unhealthy areas to protect our health and welfare? Why today, does the State of Oregon allow businesses to continue to release toxic chemicals and metals into the air without any regulatory oversight?

Finally, it IS possible to operate successfully without polluting the air to such a drastic degree. A case in point is the glass factory in the Seattle area, regulated by the Washington Department of Ecology, with baghouses limiting noxious air emissions (source, The Portland Mercury, Daniel Forbes, March 4, 2016 writing about Spectrum Glass, Woodinville, WA, and in the company website, http://www.spectrumglass.com/stained-glass/CleanAirEfforts.asp).

Monitoring, disclosing, and eliminating harmful air emissions in Portland, and Oregon should be DEQ’s number one priority. The lively health and safety for everyone is paramount. I hope no one has to go through the unnecessary agony our family has experienced breathing unhealthy air full of toxic metals and the resulting detrimental health consequences caused by this. These are important questions and points that should be addressed promptly by policy makers, health officials, and quite frankly, the polluting industries themselves.
386 386 Carrie Puterbaugh missmkdirector@aol.com   Oregon If you are going to change laws you need to prove there are unsafe air qualities, not more likely than not... It is unfair to put these smaller business under restrictions when you have not proven the air standards are definitely unsafe.
387 387 Jennifer Brightbill Jbrightbill@mac.com   OR Please do not enact new rules without scientific data to back it up. All the recent media postings are saying that the air and soil are safe and a bag house filter is being put on Bullseyes Furnace(s). You could easily find data from other cities that have glass manufacturers, such as Seattle, to learn more about CRIII and under what circumstances it can turn into CRVI. Please use facts and scientific evidence to make your decision, not hearsay and knee jerk reactions.
388 388 Rex Bosse rexarino@gmail.com Private citizen OR I have worked in industries with elevated levels of dangerous chemicals. I support safety for the workers through personal safety gear, but I also don't like the tendency to exclude or hamstring small industries because of over-hyped perceptions of "safety concerns". I feel this particular issue is small enough to not require re-writing laws and/or imposing unusual sanctions. I would prefer that authorities encourage the glass manufacturers to increase their filtration/capture of chemicals, but allow the companies time to institute change and experiment with various solutions. You don't solve a problem by forcing a company out of business, or bullying them. The two affected glass manufacturers are a necessary resource for hundreds of small businesses that will falter or fail should the DEQ impose excessive restrictions.
389 389 Rex Bosse rexarino@gmail.com Private citizen OR I have worked in industries with elevated levels of dangerous chemicals. I support safety for the workers through personal safety gear, but I also don't like the tendency to exclude or hamstring small industries because of over-hyped perceptions of "safety concerns". I feel this particular issue is small enough to not require re-writing laws and/or imposing unusual sanctions. I would prefer that authorities encourage the glass manufacturers to increase their filtration/capture of chemicals, but allow the companies time to institute change and experiment with various solutions. You don't solve a problem by forcing a company out of business, or bullying them. The two affected glass manufacturers are a necessary resource for hundreds of small businesses that will falter or fail should the DEQ impose excessive restrictions.
390 390 Josephine Geiger jageiger.studio@comcast.net   Minnesota Please don't eliminate an entire niche industry by proposing regulations based on anecdotal hypothesis rather than actual facts. Shutting down (or even limiting production) these specialty glass manufacturers not only impacts their business, it also is crippling my business. I am an artist and active member of the Stained Glass Association of America (SGAA) and I depend upon the glass produced by Bullseye and Uroboros for about 85-90% of my materials. Curtailing production of half of their color palette will destroy my business, sooner rather than later.
I'm all for protecting the environment, but not with news/bloggers sensationalized hypothesis as to either cause or effect.
I implore the DEQ to use scientific facts and not conjecture and assumptions to determine the proper regulations necessary.
391 391 Josephine Geiger jageiger.studio@comcast.net   Minnesota Please don't eliminate an entire niche industry by proposing regulations based on anecdotal hypothesis rather than actual facts. Shutting down (or even limiting production) these specialty glass manufacturers not only impacts their business, it also is crippling my business. I am an artist and active member of the Stained Glass Association of America (SGAA) and I depend upon the glass produced by Bullseye and Uroboros for about 85-90% of my materials. Curtailing production of half of their color palette will destroy my business, sooner rather than later.
I'm all for protecting the environment, but not with news/bloggers sensationalized hypothesis as to either cause or effect.
I implore the DEQ to use scientific facts and not conjecture and assumptions to determine the proper regulations necessary.
392 392 Vivian Christensen vivianchristensen@earthlink.net   Oregon I am writing to encourage the DEQ to take the necessary action to ensure that air pollution reform in Oregon includes meaningful regulations for both large and small industrial polluters. As you are aware, Oregon lags behind California and Washington in enforceable air quality standards. It is my hope that future environmental health regulations in Oregon will require glass manufacturers to conduct comprehensive individual risk assessments. Oregon lawmakers and the DEQ can no longer deny that our state must implement a comprehensive set of rigorous health-based emissions regulations. Relying on the Clean Air Act’s Emissions Standards for Hazard Air Pollutants (NESHAPS), which regulates point sources of air toxics (including heavy metals) only when a single industrial source has total annual emissions exceeding 10 tons of each air toxin (or 25 tons per year of aggregated toxic emissions) from a single source does not and will not protect the public from the harmful effects of toxins that are emitted into neighboring communities from industrial polluters.
393 393 Chris Andrews chris.p.andrews@gmail.com   OR   airtoxic_comment_chris_andrews https://data.oregon.gov/views/trwb-z8xe/files/ba90eee3-3b0f-4239-9369-c29079e0cd0a
394 394 Andrea Tembreull temfam3@yahoo.com Native Waters Art North Dakota I understand the need for proper emissions controls, but please scientifically prove there is a problem before indiscriminately restricting the use of any chemical utilized to make colored glass. Thank you.
395 395 Helen Dennis ferretkeeper@btopenworld.com Private individual UK Your approach and handling of this situation has been entirely flawed. You have pinpointed two glass manufacturers as the source of all the harmful emissions picked up in tests with no concrete evidence to back up your claims. Thay have been vilified by local people, despite following your guidelines all along. They have taken drastic voluntary measures in suspending production, spending a lot of money installing filters, costing not just money but jobs. And you now want to impose more rules, with yet more untested theories? You should be supporting these businesses and looking to your own organisation to find out how this situation even arose. I would like to see a far more thorough investigation into ALL the businesses in the wider area, which I understand to be a highly industrialised part of the city. And if you really are doing this for the health and well being of all concerned, check your facts before leaping to conclusions and causing such major and unnecessary upset to all involved.
396 396 William Roberson billr5787@aol.com SGAA SC There is no scientific evidence to support these "temporary rules" This is just a scare tactic. Further proof should be required before you essentially shut down the stained glass industry in America.
397 397 Julieana Gill Bigglassart@icloud.com Big Glass Art art studio Alabama 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.
398 398 Harry & Erna Sowersby info@creative-glass.com Creative Glass AG Switzerland We are distressed about the news which we get from Portland Oregon with regard to the planned temporary rules issued by the DEQ. Our company is based in Switzerland and we have been customers of Bullseye Glass for over 35 years and to a lesser degree also of Uroboros Glass. In this time we have known both factories to be very serious and environmentally conscientious manufacturers as well as good business people.

What concerns us about the proposed temporary rules is a lack of scientific facts on the factories’ exhaust fumes. The DEQ’s approach seems to be entirely based on fears expressed by the factory’s neighbourhood. According to test results published in early March, the soil around the Bullseye factory is normal for Portland and there is no cause for public concern. There is also no evidence of any increased cancer risk according this same study. Despite these findings Bullseye are putting in additional filtration.

If the proposed temporary rules become operational Bullseye Glass would have to reduce their product pallet by about 50% for a duration of 180 days, which could threaten their survival. This potentially means that over 100 families in Portland would loose their livelihood. The Bullseye products are essential supplies for many other companies and their artisan customers, thousands of jobs in US and around the world would be at risk. In our own small company 30 jobs would be at risk.

Bullseye glass products are used in glass art, architecture and artisans’ products. Both Bullseye and Uroboros and many artisans’ studios have established Portland as an acknowledged centre for glass art worldwide. In particular, the energy Bullseye Glass brought forward led to a new movement in contemporary glass art with new forms of expression and application. There is a distinctive risk that this movement would lose momentum, which would mean a big loss in the cultural life of Portland, the US and many places in the world.

Over the last 35 years we have travelled to Portland Oregon on a yearly basis, mostly to visit the factories but also to attend Becon, the biannual glass art conference organized by Bullseye and visited by hundreds of artists, architects and educators. Portland has always appeared to be a very open and energetic city with a dynamic environment for small and middle sized businesses, a great cultural programme as well as a strong feeling of opportunity.

We strongly believe that DEQ’s temporary rules could endanger a unique glass movement which has brought Portland into the vocabulary of glass artists worldwide. This arbitrary action (without any scientific proof) could evoke a negative perception of how local government agencies operate.
We think that the good name of Portland deserves better than this.
399 399 Corley Marsalis cmarsalis@bellsouth.net   Mississippi Please use actual facts and not speculation before closing down the glass factories. Was wondering if the government could help fund the changes needed to the furnaces to expedite the conversion to the new requirements?
400 400 Peggy Myers ehrhartstainedglass@hotmail.com Ehrhart Stained Glass Inc. PA Please do not make rules before you have all the scientific facts. You haven't actually linked the air quality problems to the Bullseye or Uroboros glass companies. When you make new rules, these companies should have time to comply. They are responsible companies and are willing to work with you. Do the same for them.
401 401 Dana Boyko dana@danaboyko.com Fused Glass Creations CA I urge DEQ to rely on science and fact, and not to rush to impose poorly written and misdirected rules. We all care about protecting the envitonment while continuing to provide for our families. Please realize many of us support ourselves and our families on our craft and results of working with a full line of colors and products we purchase from the glass suppliers. These rules have a long term impact on many, many people and implications that go far and wide. Please see the big picture when enforcing rules and regulations. Thank you.
402 402 Kathy Perry chickadeeglass@gmail.com Chickadee Glass Studio, LLC Missouri I believe this would be fair IF you had definitive, qualitative proof in the form of measurements of the various metals directly from the stacks. Without scientific proof, and operating from speculation, I believe the temporary rule should not be made. However, I do agree that the "baghouse" emissions systems should be on each batch furnace. The companies should be allowed to continue operating normally, while installing these systems.

Imposing this rule on these companies before they have time to address the issue could eliminate them. I would certainly hate to see that when the solution to any pollution issues are just over the horizon.

Thank you.
403 403 Lisa Myers Lisa372@gmail.com Private party OR I lived in this neighborhood fir 17 years and ha e been plagued with health problems ever since I left the neighborhood. High levels of arsenic in my blood...daughter had thyroid cancer and had to have thyroid removed. We want compensated for the ills we face having lived by what was then Brooklyn grade school. Something needs to be done!!!!
404 404 Jane Bruce jbruce99ny@aol.com Artist/Eduator New York Having worked with the Bullseye Glass Company as an artist and an educator/teacher, I know from experience that they are a responsible and caring company and would NOT do anything to endanger their immediate environment. They have a long history of responsible operation and I stand with them, as do many others world wide, in their efforts to continue operations as a responsible citizen of the social and business community of Portland, Oregon.

If Bullseye Glass is forced to stop producing 50% of its glass products for 6 months, without regard to ongoing test results or added emission controls, Bullseye’s survival is at risk as is the future of all who rely on the company either directly as employees or indirectly as artists and educators through the use of their glass.

I support an agreement that is similar to the temporary rules, but unlike the temporary rules, also allows DEQ and Bullseye to respond promptly to new factual information. 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.

Thank You.

Jane Bruce
405 405 Mark Schoem markschoem@gmail.com Ancient Arts California Stained glass windows are part of the world's cultural, religious and artistic heritage for a thousand years. Any perceived need for changes in the procedures or safeguards for stained glass production should take this into account.
Oregon is known for its intelligence and creativity. I believe a solution can be found without causing a big disruption to the creation and restoration of stained glass windows, if you approach this challenge in a thoughtful manner.
406 406 Pamala Enberg pamenberg@hotmail.com Private citizen Oregon We live within a half mile of Bullseye Glass and are terribly dismayed to learn that we have been breathing toxic air for the last 10 years! My husband and I moved here to help take care of our young grandsons who also live in the neighborhood. It is our greatest desire that our grandsons grow up to be healthy and strong. We feel that the toxic emissions coming from Bullseye threaten the health of our whole neighborhood and especially the health of all the young children who run and play outside every day. Please change the regulations regarding toxic emissions by smaller art glass businesses such as Bullseye in order to protect all of us in the neighborhood. Thank you!
407 407 stewart craig Enberg nelsjoyroy@hotmail.com neighbor of bullseye glass Oregon I have been confident that Bullseye Glass will permanently change its manufacturing procedures to insure the health of our neighborhood. I hope that this confidence will prove to be well founded.
I went to the public event at Cleveland High School. The young man from DEQ in charge of permits did not inspire confidence. He needs someone more experienced to help him.
408 408 Laura Cruz y Celis Lauracyc@verizon.net Craft Guild of Dallas -student artist Texas Produce and share the specific scientific quantitative data to back up things that you suspect are happening. As stated by Proffessor LaCourse The production of green glass with Cr III is not the source of Cr VI .. Therefore, anaylize real data and real facts that are backed up with evidence research before you make Bullseye stop using a basic ingredient in green glass. Sciences can be replicated..... The do so, replicate results and corroborrate the source of the toxic elemenst, jot just assign them to the most probable cause in your eyes. We are knowleadgeable people who rely in chemical analysis and controlled complex engeneer processes that generate consistent products. Do the same, produce the data and find the real source of the problem. Do not harm our source of consistent well produced glass in the meantime. Bullseye is seeeking the be environmentally conscious and responsible as they has voluntarily agreed to build the baghouses, even without formal data on being responsible for toxic elements in the air. Use reliable methods to produce the data to support your suspiction before you negatively impact Bullseye as a bussines, source of employment and their world wide consumers.
409 409 Joseph Ring joe@jringglass.com J Ring Glass Studio Inc. Minnesota J Ring Glass Studio Inc. would like to voice its support of the position that Bullseye Glass Company, Uroboros Glass Company and the Stained Glass Association of America have taken in regards to the proposed temporary EPA rules which would stop production of 50% of the art glass colors available. These actions need to be based on science and proven fact.
I do believe that the proposed temporary EPA rules threaten the very existence of the supply of art glass used for the restoration and repair of tens of thousands of historic buildings, public as well as private. I believe this would be in violation of the U.S. National Preservation Act 1966. Under this law a Section 106 should be convened before any action can be taken.
J Ring Glass Studio Position 3-29-2016.docx https://data.oregon.gov/views/trwb-z8xe/files/8b9ca721-5fbc-4f0d-b6c8-fbab996e081a
410 410 Cindy Young rocknrollschool@msn.com EPAC OR I have heard many complaints that there is no scientific proof that toxics used by glass company's are harmful to health.I disagree. I would like to remind you that long term exposure has not been studied and that in 20 yrs we will regret anything but the most strict guidelines on this issue. Please protect us from industry poisoning make your decisions based on health and not money.
411 411 Rebekah Santiago rebasantiago@gmail.com Creative Escape Glass LLC Missouri Bullseye Glass has operated their business responsibly for many years. They have been operating within the guidelines set by their community for safety of their employee and their community based on the known science when the guidelines were set. As new information and newer technology raises new issues, they are willing to work within new guidelines. However, these guidelines need to be based on scientific fact not politics, not fear mongering, not unproven conjecture. Putting temporary rules in effect that are not based on scientific fact will cause an unfair burden and hardship on Bullseye, other art glass manufacturers, and the artists and businesses that are dependent on their products.
As a new, small business in Springfield, Missouri, if I am unable to get sufficient quantities of glass from Bullseye I will literally go out of business and my 4 employees will lose their livelihoods. The very nature of glass fusion means that I need glass that is compatible so I use Bullseye glass in my studio.
I know the proposed regulations are not targeted only at Bullseye, but they are targeted at the very niche art glass industry that is dependent on glass produced primarily in the Portland, Oregon, area. Creating an environment that endangers your art glass industry will have a broader negative impact on your region than you may anticipate. Besides the ripples this would create throughout the US in glass studios from coast to coast that are dependent on the art glass produced in your town.
I understand that recently discovered safety concerns must be addressed, but since there is no imminent danger, please do your due diligence and not rush to regulate. Make sure that any new regulations are necessary, aimed at the correct industry and are implemented in a timely fashion that will not cripple our industry.
DEQ-Bullseye Letter.docx https://data.oregon.gov/views/trwb-z8xe/files/c96524ec-e1a7-4eea-8d46-c52176f15abb
412 412 Rebekah Santiago rebasantiago@gmail.com Creative Escape Glass LLC Missouri Bullseye Glass has operated their business responsibly for many years. They have been operating within the guidelines set by their community for safety of their employee and their community based on the known science when the guidelines were set. As new information and newer technology raises new issues, they are willing to work within new guidelines. However, these guidelines need to be based on scientific fact not politics, not fear mongering, not unproven conjecture. Putting temporary rules in effect that are not based on scientific fact will cause an unfair burden and hardship on Bullseye, other art glass manufacturers, and the artists and businesses that are dependent on their products.
As a new, small business in Springfield, Missouri, if I am unable to get sufficient quantities of glass from Bullseye I will literally go out of business and my 4 employees will lose their livelihoods. The very nature of glass fusion means that I need glass that is compatible so I use Bullseye glass in my studio.
I know the proposed regulations are not targeted only at Bullseye, but they are targeted at the very niche art glass industry that is dependent on glass produced primarily in the Portland, Oregon, area. Creating an environment that endangers your art glass industry will have a broader negative impact on your region than you may anticipate. Besides the ripples this would create throughout the US in glass studios from coast to coast that are dependent on the art glass produced in your town.
I understand that recently discovered safety concerns must be addressed, but since there is no imminent danger, please do your due diligence and not rush to regulate. Make sure that any new regulations are necessary, aimed at the correct industry and are implemented in a timely fashion that will not cripple our industry.
413 413 andrew Kinman andrew.kinman@gmail.com   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.
414 414 Sandra Gross sandragrossart@gmail.com Brazee Street Studios Ohio I write to give you a few glimpse of what I know as Bullseye Glass Company. I view this company from multiple perspectives: an artist, customer, teacher and as a friend.

Artist: Bullseye Glass is one of the most beautiful and carefully manufactured materials I have worked with. I have worked with paper, bronze and glass in my tenure as a professional artist. Of all of those materials, the consistency and quality of the product is of the utmost importance. I remember the first time I went to the factory and realized they tested every 10th sheet and studied its quality with a high-powered polariscope. That was very impressive to me as an artist who relied on this product to make a living.

Customer: There are many times Bullseye has completely impressed me with customer service and they still answer the phone!!! One of the most important times they answered the phone was about 6 years ago. I was working on a mural for the Ronald McDonald House and the glass had to go into the kiln to stay on schedule for the install. I had to go out for a week to teach somewhere else. I instructed my husband to just fire the kiln with the last program. I figured he is a professional in another field (medicine) so he can figure this out. He got nervous so he called Bullseye Glass. Now, we had not bought the kiln from Bullseye. That did not matter. A person from the Research and Development Department got on the phone and very kindly talked my husband through the kiln firing process.

Teacher: I teach very young children- 3 years and up. For the past 12 years, I have had the privilege to teach 1000s of children Art (all aspects) and other subjects (Literature, Science, some Math) using Bullseye Glass. I don’t know if it is the beauty, permanence, transformative qualities or all of this but it has a power that no other material has. It allows children to fail (try things that may not work)) and succeed by giving children the power to experiment and play. It allows children to work with a beautiful and permanent material. It allows children to be as transformed as the material every time you put it into the kiln. I have always seen how children feel empowered when using the material but most recently I saw it on a very acute level. I teach in a subsidized housing community in an enrichment program that is based on the Montessori Method. I have the materials out on the shelf like any other material in a classroom. Children can choose it if they wish and the lessons on the shelf have various themes- color, line, etc. One of the children in the class has a receptive language delay so she finds it hard to express herself verbally as well as following multiple step directives. The children have all been given the lesson: which includes safety, multiple step process with each material (Montessori lesson plans have many steps) and a place to store their finished work to go into the kiln. This child carries out each lesson, helps others and artistically has one of the most distinct voices I have ever seen. Her work always has the same feel and rhythm like voice has. You know it is her work. We have given her an opportunity to speak and work on developing her voice- the language of glass.

Friend: I have been fortunate to spend some time at the owner of Bullseyes home. We spent countless hours discussing the ins and outs of education, children and making a difference. I also had the opportunity to travel with one of the owners when doing an installation with children in Santa Fe, New Mexico. Again, many hours of conversation on education and helping children. These are kind, genuine people who deeply care about artists, children, and the environment.

My hope is that from these brief glimpses, you will see the importance of Bullseye glass not only as material but also as a company. Please allow them to modernize their machinery and place the necessary filters so that glass production can begin again.


Respectfully yours,

Sandra Gross

M.Ed., Montessori Education, Xavier University
M.F.A., Sculpture. Miami University

Brazee Street Studios
4426 Brazee Street
Cincinnati, Ohio 45243
AutoRecovery save of BE letter.docx https://data.oregon.gov/views/trwb-z8xe/files/76cc6442-5dfb-42ad-a92a-2ad99c0d39b7
415 415 Katie Niles Nileskatie@wavecable.com   WA I travel to Portland twice a year to purchase glass. Though I am not a Portland resident I have an interest in how you handle this situation. Please use scientific proof and specific testing before asking businesses to change their practices.
416 416 Mitch Miller rmitchellmiller@yahoo.com   OR The inordinate amount of scrutiny and public outrage aimed at Bullseye Glass and Uroboros Glass, in particular, from citizens, from the press, from Governor Brown, compared to the actual air quality problems that exist in Portland, is quite ridiculous. This shows that there is very little interest in actually addressing the root of the problem. This is about punishing those parties that received the most attention in the media.

Do not adopt rules that could potentially cause a venerable Portland institution like Bullseye Glass to lay off workers or go out of business.
Bullseye has been cooperative with DEQ and has enacted voluntary suspensions of use of certain metals since the initial editorials were posted in early February on the Portland Mercury’s “Blogtown� website. Please work with Bullseye rather than enforcing a set of hastily written rules created by people with an extremely limited and haphazard understanding of the science behind the manufacturing process.

Mitch Miller
SE Portland resident
417 417 Saul Goodman   NA OR I live above the bluff in North Portland. The toxic smells along Willammette are often extremely strong. Anyone who bikes or jogs here can attest. Neighbors started whatsinourair.org but weren't able to get any traction. We've submitted countless complaints to the DEQ. It's not just the glass factories. We demand real change and accountability. All beings deserve clean air. No business has the right to jeopardize our health. If a business model can't support environmentally and socially responsible behaviors then it isn't a viable business. There are plenty of opportunities which do not harm others. Absolutely disgusted. Please do the right thing.
418 418 Linda Ostman laostman@verizon.net Wild Hair Art Glass Studio Texas I am in support of Bullseye and Urboros in this situation. It is very sad that the EQC are basing their decisions on people and the media who have not done any research before becoming the hysterical naysayers. If the EQC uses what they think is a solution to the problem (that scientifically isn't a problem) to "temporially" put rules and laws into effect then what is stopping any government agency from following suite till they kill all the small businesses that help the economy. The decision of the EQC will have such a ripple effect in the economy across the world. I know as a artist that relies on the products of Bullseye it would greatly effect my business and thousands of businesses world wide. Bullseye is willing to do what is necessary to work to fix the problem. Please make wise decisions that will help, not hinder the livelihoods of people not just in Portland but around the world. Bullseye is not out to harm anyone. They are a company that works hard to keep people safe. Please base your decisions on SCIENTIFIC PROOF and not the hysterics the media is so good at producing. I would welcome Bullseye to produce glass in Texas any day!
419 419 Cara DiMassimo Carazen@yahoo.com The Glass Palette VA Testing of emissions, air and soil quality have shown that the levels around the glass manufacturing facilities are no higher than found naturally occurring in other areas, and are not at a toxic level. To shut down production of art glass by the two companies in Portland, even temporarily, would have the potential to put many small businesses as well as individual artists out of business across the country. As a small, family owned business the current strain has already been impacting our ability to function. Due to the pause in manufacturing of many colors of glass, the cost of replacing those colors has doubled, and many colors have become completely unavailable. My livelihood depends upon the ability to obtain the full spectrum of glass colors and provide them to my customers at a reasonable cost, something I am barely able to do under the current circumstances and which will become impossible with this "temporary" ruling.
I speak for the many small businesses across the country and for the artists trying hard to make a living through their work - this temporary measure will put many of us out of business. There is no alternative source, these small businesses supply the world with their glass color and without them our businesses will close, not temporarily but permanently.
420 420 Leslie Speicher Chicagoglasscollective@hmail.com Chicago Glass Collective IL 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.

Sincerely,
Leslie Speicher, Owner
Chicago Glass Collective
421 421 Cindy Cox sybill99@aol.com   NC 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.
422 422 Susan Stuckman stuckman1848@gmail.com     I work at the Fred Meyer facility on 22nd Street just across the street from Bulls Eye Glass. All tests done inside our facility were shown to be at recommended levels. I do think that continued testing should be done regarding the air quality in the neighborhood. However, I do not think immediate changes should be made to the law or policy without further testing.
I heard that there was a previous air problem when the crematory was still in use. Does the other location of Bulls Eye also have a crematory or other manufacturing near its facility that could be part or all of the problem?
423 423 Paulette Erde paulette.bernd@me.com   NY Do NOT limit Bullseye's ability to use Cr III. There is no evidence that it is converted to a dangerous form in the processing of glass. This is one of the few companies in the country providing glass of high quality and variety. The loss of this company would have a huge impact on the art community as well as others.
424 424 Sarah Pick sarahpick648@gmail.com citizen/artist Maryland   Bullseye doc.docx https://data.oregon.gov/views/trwb-z8xe/files/ec9d28d3-7e44-40b5-8d41-b329c482e50b
425 425 Joan Schaumburg Joans49@gmail.com Sun City Anthem Fused Glass Clob 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.
Respectfully yours,
Joan Schaumburg
426 426 Lawrence Jacobsen LarryJ@colourdeverre.com Colour de Verre Oregon I am one of the founders of Colour de Verre, www.colourdeverre.com. Our company makes molds for glass casting. People fill our molds with frit - crushed glass - to produce art objects. This frit is produced almost exclusively by Uroboros and Bullseye. Our company is small, but we directly create a dozen or more living wage production and logistic jobs in the Portland area. To these people and Colour de Verre, it is very important that DEQ work with Uroboros and Bullseye to quickly define and solve the emission issues.

Furthermore, we would remind the State and the City how often they spend money to entice jobs to the area. Perhaps similar money could be found to help Uroboros and Bullseye keep jobs in the area.
427 427 TERRY Bushnell tbushnell@arcomnet.com   Utah I purchase glass from Bullseye in Portland and understand certain metals need to be used to make certain colors. My understanding of articles written is there is a gap in the regulations currently; however, it has not been proven that in Bullseye's production they are currently in violation. The gap in the regulations is not the fault of the business but DEQ and Bullseye should not be accountable for this DEQ error. Bullseye has not been in violation of the regulations. The people living around the facility are also to be blamed. They moved in knowing that there was a facility producing glass. This is not something they were not aware of and if they were they didn't research the neighborhood before moving into it. From what I have seen a lot of the homes are run down and not kept up.
As the production of the glass has not been found to be in violations of the current regulations, they should not held at fault. The DEC/EQC should work with the facility to come to an agreement on how and in what time frame any problems can be corrected without financially crippling the facility. I believe the temporary rules for the small glass companies should not go into affect until they are found at fault for violating the regulations. Just because it may doesn't mean it will and any effects won't be discovered until years from now. Let's all work together and not cripple business on something that has not yet been proven beyond a shadow of a doubt. Remember innocent until proven guilty and they have not been. Potentially doesn't mean it will happen.
428 428 Kasia Stahancyk kasiaannastudio@gmail.com Kasia Anna Studio Washington 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.
429 429 Kerry Ryan kerrysilvaryan@gmail.com   OR Thank you so much for extending the public comment period for these rules!

Our entire neighborhood has 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!
430 430 John Poole jlpoole56@gmail.com   California Dear Commissioner Members,

California has driven so many industries out of state all under the mantra of improving the environment. There has been no working with industry. But the well-intentioned movers and shakers have thrown the baby out with the bathwater and I think the general population is starting to realize it, we have lost so many industries. Try to find a place to cast metal work? No dice, you have to go out of state because the air quality regulations shut down foundry work. Of course, the politicians in Sacramento will never agree that is the case lest it reflect poorly on their predecessors decision or alarm the ever so intense feeling about the environment. There are social costs that never get measured or show up on the balance sheet, except on a manufacture's sheet where it might cost monies to mitigate. This is where government drops the ball.

You have a very special industry in your state: art glass. If I thought they could have a chance moving production to California at this time, I would urge you to move forward so they would relocate in California. People do not realize what they have lost until after it is too late. Please do not make that mistake. There has to be some way for Oregon's air quality to work with industry to keep industry and the excellence of this unusual product going. Perhaps making decisions on "likelies", as in " are added likely emit these metals at levels" of your notice above in this form, should be be postponed until you have facts. When you get the facts, then make your decision, but keep in mind what government can do to work with industry and finding ways to mitigate potential problems.

Perhaps having government share the burden of mitigating hazards defined under new legislation should be considered. There is no right to pollute, but as society increases its awareness of hazards, it ought to look at the entire picture and consider mitigation as an expense everyone should bear. Show California what California failed to do by working with the art glass manufacturers.
431 431 Johanna Wiseman 456@spamex.com Akamai Art Supply hawaii 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. 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.
432 432 debbie Hansen Dhansen55@msn.com D S Designed Arizona I am a glass artist and my income helps support my family. I count on Bullseye Glass for the glass I use for my art. Your decision regarding the use of chromium at the Bullseye factory will directly effect me as an artist. I sit here in disbelief that you would even consider requiring Bullseye to discontinue the use of chromium based on flawed data. There is no evidence that the chromium used by Bullseye causes any danger. If they are forced to discontinue the use of chromium, even temporarily, the impact will be felt worldwide. The economic impact in Portland alone would be significant as Bullseye lays off employees or, heaven forbid, they have to close their doors for good. Please set politics aside and look at the data before you. Do not force Bullseye to discontinue the use of chromium.
433 433 Amanda Taylor mcbridea@rochester.rr.com Oatka Glass New York 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 facts.
434 434 sc Marshall boeingbabe@gmail.com   MS Do not put additional restrictions on Bullseye Glass emissions. Bullseye is committed environmentally to safe manufacturing practices. If you hassle them unfairly it will have a unnecessary economic impact on the company, artisans around the world (including myself) who rely on Bullseye as an art glass supplier and on employees of the company. Also, a new environmental requirement may push Bullseye out of the state to an area where regulations are less stringent and more stimulating to the bottom line. Do you want to force a change that is detrimental in the long run to the tax base and economy?
435 435 Andrea Alpine aea600@aol.com   CA 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.
436 436 Barbara Wells barbwired_6@hotmail.com   OR Hello,

I am a neighbor of Bullseye glass. I live only about 3 miles from them and I am not concerned about toxicity. I am also a glass artist and hope to start a business this year. I feel VERY fortunate to live in a city with such a vibrant glass community.

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.

Please do due diligence before imposing more restrictions which could even put Bullseye out of business and damage a thriving artistic community. Indeed, it would effect glass artists around the world. Just asking for proper testing first.
Thank you,
Barbara Wells
437 437 Rance Masheck rance@investage.com Artist California I am very sensitive to environmental issue. I have looked into this matter. Please DO NOT block everything for small issue that does not effect every production of glass.
The processing the is used by Bullseye glass is not of the temps that would cause the conversion of metals into the toxic form you are trying to protect. This measure would be throwing the baby out with the bath water.
The actions of companies to address emissions should be strongly considered.
This is a strong move that will impact not only companies in your state but resellers and artist across the country.
Please do not block more than is needed to address the issue.
We need to address environmental issue. But going overboard in the "protections" creates more resistance and resentment from companies and individuals. As a country (on world) we have a hard road ahead to solve the global issues. Making the road harder to travel than is needed is going to make it harder for people to take the needed steps.
438 438 Bonnie Quintanilla blazingstararts@gmail.com Blazing Star Arts California Good day,
I am an avid, proactive environmentalist. And, where scientific evidence proves changes are needed, I will be one of the loudest proponents of change. I am also a small business owner working in fused glass art. The proposed restrictions here, which I do not believe are based on sound evidence, are punitive and have the potential to put me and tens of thousands of artists, stores, teaching studios, and shows that rely on art glass out of business. We will not survive if we cannot get glass. Period. Already, we are forced to deal with less than 50% of the supply which has driven prices through the roof. To eliminate more will be devastating. I urge the DEQ to wait until further testing is complete, to be realistic about proposed changes, and to take into account the enormous domino effect of this decision on the lives and livelihoods of people around the world. This is not just an issue for Oregon.

Respectfully,
Bonnie Quintanilla
439 439 Cindy Sweeny cindy.sweeny@gmail.com   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.
440 440 Nancy Becker nb.nbs@icloud.com Nancy Becker Studio, LLC Mississippi Uroboros Glass and Bullseye Glass have a long history of responsible operation. I stand with Bullseye Glass and 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. 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 are many may artists and businesses who rely on the glasses made from these two factories. Your hasty decisions will affect businesses all over the world. Please do not stop their production. Please do the due diligence required.
441 441 Lorri Krisman lorri.kris@yahoo.com   OK Please consider the hundreds of lives that will be impacted by the temporary rule. Please take a hard look at all companies in the area not just the two glass companies that you are impacting. Please drop all agendas and do what is right for the small businesses in Portland.
442 442 charles mcsweeney chasmcsweeney@yahoo.com pinecone books, etc Oregon please keep our air clean don't let anyone put hazardous poisons in our breathing air! it's all our breathing air. which poisons do you personally prefer?now take a deep breath........can you catch a wiff of mercury? or chromium......................................................always support life don't suppress it!
443 443 Nick Allen gallery@nick-allen.co.uk Nick Allen Consultancy West Sussex UK 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 have worked with Bullseye glass for years , and their knowledge and determination to act responsibly and environmentally has been a beacon within the UAS and far beyond , any disruption to their production would have far reaching consequences , and would in our opinion be based on erroneous precepts .
Yours sincerely, nick Allen . CEO
444 444 Kathy Bankston kathy@kathybankston.com   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.
445 445 Alaina Oremen mintleafbeads@live.com Alaina Oremen CA As I was speaking to a glass store owner here in CA, buying Bullseye glass for my own business use on 3/26/16, I found out that his grandfather lives two blocks away from the factory. His grandfather is 85 years old and on top if this has a vegetable garden. He has lived there many years.

Based on this information alone, if the poisons you say, arsenic for example, are in the air and affecting everyone why is he still alive? Arsenic is a known poison that kills us after enough has entered our systems. An 85 year old has had at least 40 years of exposure should not be alive.

Now you are assuming that a different form of chromium chemical is produced prior to even running tests. I think this is quite biased for a government agency to take a stand on.

I stand by Bullseye as a business and support them. They have currently stopped using cadmium and arsenic and actually care about the community of Portland, Oregon. In this day and age that is very rare in 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.

If you impose rules, prior to scientfic proof, which cause Bullseye to cease operations you will be taking away employment in many locations within the United States, not just the factory. This will trickle down to all businesses that use Bullseye glass. Please so what is correct and run scientific tests prior to imposing unfair rules.
446 446 Heather Oakley facetiousfeline@yahoo.com   Colorado 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.

It would be a travesty to the art world, and affect thousands of businesses, both large and small across the world, to stop production of Bullseye glass. It would be even worse if Bullseye had to permanently close their doors over this. The colorful world of glass art would turn dull and gray.
447 447 Nicole Gladwin theheppriestess@gmail.com   OR - 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.pdf https://data.oregon.gov/views/trwb-z8xe/files/cf0732b2-0ce9-44d5-89ef-aadf6168cc7d
448 448 Elizabeth Girod elizabethgirod@gmail.com Artist - Fire & Fibers GA I am an artist from GA, who has visited the Bullseye glass factory and uses their products exclusively in my designs for the past 15 years. I believe Bullseye has a long history of responsible operation to Oregon and all other states or countries where their products are used. I stand with Bullseye Glass and hope you will too.

These DEQ hastily written rules will have a more far reaching impact than just the community of Portland. It will greatly effect my ability to continue my business here in Georgia. Without raw materials from Bullseye to use in my art these rules will have the potential to kill my business.

Regulatory decisions must be based on science, not political, emotional issues. A leading scientist, Dr. William LaCourse of Alfred University, has said Bullseye’s furnaces do not produce toxic chromium. The DEQ decisions should be held to rely on science and facts.

This is a very serious matter for me and my future business, please take the time to understand their process of making the glass. Listen to the facts from experts in the field, not emotional opinions not based on science facts.
449 449 Michael Green mgreen.portland@outlook.com Portland home owner Oregon I do not believe that there is sufficient scientific evidence to support imposing the proposed temporary rules. Taking this action would materially impact many Portland jobs. It may be necessary to implement additional rules or law related to emissions from glass manufacturing facilities, but doing so must be based on clear evidence that there is a public risk.
450 450 Joellen Sweeney joellensweeney@comcast.net Northwest Children's Theatre 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!
451 451 Kerry CORDOVA KERRY83815@YAHOO.COM crafts Idaho I find it unreasonable when the DEQ can go around state regulations that already exist and put rules into effect that are not justified. It is time for the state to step forward and shut the DEQ down until the harm can actually be found and then give the company time to fix what is wrong, Bullseye Glass is a viable company that employs many people. DEQ take a step back and do this the right way - not the way you are attacking this,
452 452 James Harrison mail@jamesmharrison.com Artist Oregon I'm an artist living in Portland, I've built many projects using Bullseye glass, and my son lives within 1 mile of the factory. I urge you to not implement rules that will limit Bullseye's ability to make colored glass for the sake of political expediency. I know the factory is working diligently on finding the best solutions to this issue, but shutting them down is not the answer. On the issue of trivalent chromium, I understand they have submitted evidence that scientifically addresses the health concerns.

It is clear to me that you have an example of a business that will go the full distance to ensure public safety. I see the owners and employees working hard in good faith to address the public's rightful concerns. My own son lives nearby. I would rather see the level of cooperation that I'm seeing than a one sided approach that shuts down a portion of their business. Please continue to work with them to set a standard. Thank you for hearing my concerns. Yours,
James Harrison
453 453 Kathy Richardson kathy@krtile.com Kathy Richardson Designs CA It seems completely unfair to suddenly decide after 36+ years that one needs to reduce emissions from these glass furnaces to zero, TODAY. Typical environmental rules have a lead time that allow motivated companies to meet the emission targets. If Bullseye is totally in compliance and willing to make changes to meet stricter standards, then the DEQ should be working with then to make that happen.

Shutting down the art glass factories will hugely impact the companies, their employees, and thousands of artist that rely on their glass for their livelihood as well.

If DEQ doesn't work with companies to improve the environment, companies will not locate in Oregon, will abandon facilities on Oregon, and lack of jobs will have a huge impact on the area.
Please work with the glass companies, measure emissions from their actual smoke stacks, and improve air quality.
454 454 Ryan Mooney mooney.ryanm@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!
455 455 Taylor Rezvani taymo@hotmail.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!
456 456 Pinn Crawford pinn.s.crawford@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!
457 457 Lourdes Zenobi mlzenobi@yahoo.con    
Bullseye glass has a long history of responsible operation. I stand with Bullseye Glass in its efforts to continue operations as a responsable company of Portland.
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.
458 458 Jessica Friedt jessy.friedt@gmail.com Oregon Children's Theatre 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!
459 459 Deborah Nelson arch0922@gmail.com   WA      
460 460 Bob Heath bob@arttouch.com none Oregon My name is Bob Heath. I am a Portland area glass artist, but I am not employed by any glass company nor have I ever been. I attended the hearing on March 15, 2016 where the DEQ presented its request for granting of a temporary rule restricting the use by Colored Art Glass Manufacturers (CAGMs) of Arsenic, Cadmium, Chromium and Nickle to the EQC.
I felt at the time that the temporary rule was unjustified based on the available evidence and the fact that the two largest glass manufacturers in Portland had already voluntarily stopped using the metals in question. Two days after that hearing, the DEQ announced results of its more recent air monitoring which showed that levels of those metals had dropped dramatically, thereby confirming the effectiveness of the glass companies’ voluntary actions.
The DEQ recommendation to the EQC requesting adoption of the temporary rules was based on the premise that “failure to act promptly would result in serious prejudice to the public interest or the interests of the parties concerned�.
Following the release of the most recent air monitoring results, The Oregon Health Authority stated, “None of the sampling results were higher than the Oregon 24-hour screening levels, meaning that there is no immediate or urgent health risk related to these new results, according to an Oregon Health Authority (OHA) toxicologist.�
Given this statement from the OHA, it is clear that the case for taking the extreme action of adopting a temporary rule no longer exists, if it ever did. The voluntary actions taken by the CAGMs have quite clearly mitigated any immediate risk, even before the DEQ request for adoption of the temporary rule. Considering what the data have shown, it would be truly inappropriate for the DEQ to repeat the request for the same temporary rule that it made previously.
The CAGMs do not pose a threat to the community. They have shown good will and achieved excellent results as they work to improve their systems for cleaner air. The new filtering systems represent a huge investment for these glass companies, at a time when their income is dramatically reduced due to their voluntary production cuts. Time is of the essence for these companies. They must get their pollution controls installed and operating as quickly as possible or risk going out of business entirely. If that were to happen, it would be a loss not only for their employees and local glass artists like me, but for thousands of glass artists and glass art businesses world-wide that depend on these Portland companies for their unique type of glass. I’m not exaggerating when I say that the entire world art glass community is watching what happens here and hoping that fear based reporting and local politics do not destroy their livelihood and possibly an entire art form.
The DEQ will need to approve plans, then test and verify the effectiveness of CAGM pollution controls as they are implemented. The DEQ can set an example as an effective agency that values the health of both the community and the businesses that the community depends on by expediting its actions with respect to that planning and testing.
The imposition of additional regulations on the CAGMs at this time, after they have been shown to be unnecessary, would not result in cleaner air, but might very well have dire consequences for these companies and the many people that depend on them.
461 461 Larry Stuckman stuckman1848@gmail.com     please see attached document "20160329 Bulls Eye Glass regulations,docx 20160329 Bulls Eye Glass regulations.docx https://data.oregon.gov/views/trwb-z8xe/files/8d8fd24d-a41f-401e-bcc1-4b014da1ad67
462 462 George McIlvaine Georgmcil@msn.com   Arkansas I am an ardent admirer of Oregon's environmental stands, and a recent transplant from Oregon to Arkansas. The "Natural State" has much to learn from Oregon and Portland environmental policy, especially in the area of recycling, management of used paint and tires, and urban composting. These areas show what can be accomplished by proactive leadership with vision. The issue with toxic metals in moss and Bullseye Glass is an opportunity for Portland's leaders to also demonstrate that they have an understanding that rule-making can have unintended consequences. Bullseye has been a conscientious steward of its property and has helped foster Portland's reputation as progressive community with a motivated and interesting corporate citizenry. The proposed hasty rules will punish one of Portland's few truly public-minded small corporations with a national customer base. Portland is not Flint. Don't let fear influence a decision that should base on data, science and community.
463 463 Jody Welch jeepinwelch@yahoo.com none Colorado Bullseye Glass has been following EPA guidelines and complying with all environmental regulations that exist; and after scientific evidence was presented have willingly ceased production on several glass colors while taking steps to boost clean air systems. Without actual scientific proof that the glass manufacturing industry is emitting further harmful pollutants, including Cr(VI), I believe the temporary ruling is just a knee jerk reaction from a group of political fear mongers to further their own agenda's. I believe this temporary rule would do more harm than good by setting a precedence for governments to act on hearsay rather than facts. The proposed temporary rule directed at small glass manufactures will effect many peoples jobs, lives and family welfare without facts to base this decision on.
464 464 Mary McDonald-Lewis mary@marymac.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!
465 465 Elisabeth Marier elisabeth.marier@gmail.com Artist Nouveau-Brunswick The entire glass community would be affected by that political decision. Personnaly, I only work with Bullseye Glass and cannot change because my stocks would be incompatible with the result of my researches since twenty years. 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.
466 466 stephanie Cordell stephanie@octc.org   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!
467 467 Stanton Girod stantongirod@gmail.com   GA To Whom it may Concern;

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.

Thank You,

Stanton Girod
468 468 Barbara Boals mojoglassworks@gmail.com   Idaho It has been shown that Bullseye glass does not emit the changed chromium that is the worry in this decision.. If you shut them down, not only will the local employees suffer but all glass artists everywhere.. I personally would lose my livelihood
469 469 Michelle Galli Galli.michelle@att.net   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.
470 470 Erin Grant     Oregon Please take the time to ensure that the regulations you intend to put in place are based in scientific fact rather than fear. If these rules are passed, many artists such as myself will not be able to create art and many Oregonians will lose their jobs. As I understand, Bullseye Glass has done a great deal of research to insure the safety of their employees, neighbors, and customers.
471 471 Diana Owyang owyangd@sbcglobal.net   California I like to think of myself as an environmentalist. As such, I'm careful of the products that I use in my artwork. Should the OHA declare Bullseye to be out of compliance with health regulations then they should be prohibited from making those glasses. However, until that time, Bullseye is showing a willingness to work with OHA and DEQ to find a solution to the perceived problem. Any hasty action or temporary rules will unnecessarily affect the lives of many Oregonians. I urge you to give more time and effort to finding a solution to this problem.
472 472 Camille Smicker camillesmicker@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!
473 473 maya arb firewomanart@yahoo.com   KENTUCKY The science does not support this legislation. There is no public safety issue with Bullseye glass production. If there were they would not be able to produce the consistently beautiful glasses they do. Furthermore glass artists across the United States would be losing an amazing resource, and be forced to purchase lower quality materials from foreign suppliers as Bullseye is one of the few glass makers in the United States. Please do not force this closure temporarily or for any duration. We need American made!
474 474 George McIlvaine Georgmcil@msn.com   Arkansas I am an ardent admirer of Oregon's environmental stands, and a recent transplant from Oregon to Arkansas. The "Natural State" has much to learn from Oregon and Portland environmental policy, especially in the area of recycling, management of used paint and tires, and urban composting. These areas show what can be accomplished by proactive leadership with vision. The issue with toxic metals in moss and Bullseye Glass is an opportunity for Portland's leaders to also demonstrate that they have an understanding that rule-making can have unintended consequences. Bullseye has been a conscientious steward of its property and has helped foster Portland's reputation as progressive community with a motivated and interesting corporate citizenry. The proposed hasty rules will punish one of Portland's few truly public-minded small corporations with a national customer base. Portland is not Flint. Don't let fear influence a decision that should base on data, science and community.
475 475 Scott Yarbrough okieboy1969@hotmail.com Third Rail Repertory Theatre 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!
476 476 David Landau dpland@mac.com SE resident 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
477 477 Zoe Rudman zoe@octc.org     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!
478 478 Blaine Palmer blainepalmer@stanfordalumni.org SE Portland Resident Oregon I appreciate your extending the public comment period for these
rules. A formal comment from the Eastside Portland Air
Coalition will sum up the comments of hundreds of Portlanders I stand
by these recommendations, co-authored with Mark Riskedahl and Chris Winter.and look forward to seeing these new,
revised rules put into action. Thank you!
479 479 Amy Frankel Amybethfrankel@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!
480 480 judy sanseri js3022@msn.com none Oregon Stand with EPAC.    
481 481     rgalbick@gmail.com   OR I am calling/writing because it is time to make air quality a priority in Portland, but that means we need local solutions for local problems. 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.
482 482 gerard Sala gerard.sala@wanadoo.fr cornaline-vitrail france dear Sir
I'm a bit far from a very well known state of Oregon but I'm astonish to learn that the Bulleyes company could stop their production . it's very important to find a solution to resolves this problem .
sorry for my bad English but I'm a French glass artist very fan user of their goods
sincerely your's
483 483 Catharine Newell catharine.newell@comcast.net Catharine Newell Studio OR I stand with Bullseye Glass in its efforts to continue operations as a responsible citizen of the business and social community of Portland, Oregon.
As a longtime Portland artist, gratefully using Bullseye glass materials, I understand that a progressive studio practice is never centered around inexperience, haste and ignorance. Rather, studio work is a progressive and detailed conversation about what actually is, where it can be taken and how best to move forward to a successful resolution.
As a Portland community member, I consider our conversation to be the same.
DEQ’s push for a temporary rule is misguided and dangerous. Rather than supporting the safety of our community and offering clear guidance to local businesses, the DEQ is offering the opposite – unfounded placation and hasty supposition. My neighbors and I are considering the future with trepidation. If the temporary rule were to prevail, Portlanders would be faced with a patchwork of legislative approaches that would likely put Bullseye Glass out of business and still not address Portland’s air quality issues in an efficient and appropriate manner.
The Oregon Health Authority and the Multnomah County Health Department have stated that there is no immediate health risk to our community. Excellent. Instead of instituting a discriminatory and improperly posited temporary rule, DEQ now has the time to focus upon creating permanent and effective rules, based on scientific investigation and thoughtful process.
Bullseye Glass is already doing just that. In addition to proactive action involving emission controls, Bullseye is, in fact (with minor corrections to scientific errors and omissions in the currently proposed rule), willing to sign an agreement that fulfills all of DEQ’s goals and allows both entities to respond promptly to new factual information.
And DEQ? DEQ is pushing a temporary rule that asks CAGM’s to melt Cr in oxidizing conditions, guaranteeing Cr conversion. This testing is not based on glass making practices, proves nothing and is, in fact, contradictory to scientific study related to Bullseye’s furnaces. What is needed is specific testing to determine Bullseye’s actual monitored emissions with a baghouse in place. Once those emissions are determined, all parties will clearly understand how to logically and safely proceed.
Fear is rooted in ignorance, promotes careless action, engenders substandard results and puts genuinely excellent business practices at risk. A temporary ruling would be based on fear, not facts. I urge DEQ to move forward in an intelligent and responsible manner by thoroughly investigating the realities of this situation, via extensive scientific inquiry prior to making a ruling that will stand the test of time.
484 484 Nancy Coscione nintu9@yahoo.com   Oregon I stand with EPAC.    
485 485 Robert Price pricetesc@earthlink.net Present Time Dream Factory Oregon I stand with EPAC.    
486 486 Carla Fpx carla.fox@icloud.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.
Don't punish the good guys and their customers!
487 487 marianne parr parrglass@hotmail.com Ms. GA I have been a glass artist for over 35 years. Please do everything you can to get these companies up and running or alot of us will be out of a job. Large companies like oil, coal, mining and refineries seem to destroy and defile shamelessly, while escaping scrutiny until vast environmental damage is done. Won't you please find a way to keep these glass companies open while appropriate changes are being made.
488 488 Melissa Ehn melissalehn@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!
489 489 Becky Ratliff rbc@ratbonel.net RatBone Creations, LLC Montana I have attempted to submit and not sure it went through so this is to make sure. I am concerned by the idea of imposing temporary rules without full and proper information. Information released earlier that caused so much anxiety has already proven to be lacking in substance. That alone should cause the realization that facts should be correct and scientifically based and not knee jerk action. Everyone involved wants to get it right so DO IT RIGHT! This attempt to possibly CYA on your part impacts lives and jobs...not only the people that own and work at these companies but those of us around the country (and world) that depend on their product for our livelihood.
490 490           Shouldn't the role (and first priority?) of the DEQ be to protect the health of the public and the environment, not polluters? Please impose regulations that proactively protect public health, not polluters.

Also, many of these comments quote Dr. LaCourse as a reference that CrIII does not convert to CrVI. Dr. LaCourse himself has stated "Unfortunately I know a quite a bit about glass, but not much about environmental testing. In general the method would be determined by the objective.....e.g. Long term vs short term and "all sources" vs specific sources." Given his admitted lack of knowledge on environmental testing, I believe its erroneous to quote him as a source.

The socially responsible course is to follow the precautionary principle and regulate known toxics cautiously. Requiring that a certain percentage of the population acquire cancer before taking action seems not only perverse, but an ethically slippery slope.

I stand with EPAC.

Thank you.
491 491 Edward Voss edebvoss@sbcglobal.net SGAA California Please take the time to consider the implications resulting from "temporary rules." If science and fairness are both chosen in resolving the perceived problem, some changes to the current manufacturing process will need to be adopted. Best results are achieved, in my opinion, by engaging science and common sense. Besides the immediate loss of local revenue from employment, temporary changes spell an end to the stained glass industry in the U.S. Let's be sure before we mandate.
492 492 Alex Stanyon alex@stanyon.com   WA Please consider the impact of hasty decisions. Environmental and health concerns are important to everyone, but need to be addressed in a thoughtful and meaningful way rather than with hasty action that has would create unnecessary hardship to a vibrant local business and their employee families. Bullseye is an ethical company that will do the right thing when given the opportunity to work through this issue. Putting them out of business is not optimal for anyone...please consider the long run when taking action.
493 493 Sandra Auestad sauestad@yahoo.com Independent Artist New York Bullseye and Uroborus glass have a long history of responsible operation in Portland. I stand with them in their efforts to continue operations as a responsible citizens of the social and business community of Portland, Oregon.

Work with these companies and give them time to address your concerns without implementing poorly written temporary rules that will "likely" put them out of business. These companies are acting responsibly to your concerns, you should do the same. The impact to these businesses will be felt worldwide.
494 494 Marie Karan marieakaran@gmail.com none TX Please rely only on fact before putting rules into place that will affect the operation of Bullseye Glass and their workers. There is no proof that their glass produces toxic chemicals, therefore no measures should be taken.
495 495 Marie Karan marieakaran@gmail.com none TX Please rely only on fact before putting rules into place that will affect the operation of Bullseye Glass and their workers. There is no proof that their glass produces toxic chemicals, therefore no measures should be taken.
496 496 Kate Braid kate@hungrydogprinting.com Marshal Designs California Bullseye Glass is an industry leader in the glass industry.

I implore you to please come to solutions (temporary and permanent) that allow Bullseye to continue to operate.

A huge number of people/artists are employed in this industry. Professionals, hobbyists, wholesalers, art galleries, boutiques etc etc etc.

Uroboros Glass is a smaller but very high end glass supplier that supplies the upper crust of glass artist.

Bulleye is prepared to install whatever emission system required - once the state establishes requirements.

In California we have emission controls on many different types of manufacturing plants.

The only case I'm aware of that couldn't be resolved in a safety and aesthetic nature by emission control equipment, was the hot sauce manufacturer in Irwindale.

Please reach out to find a solution that will benefit this wonderful manufacturer and all the people employed in the thriving glass arts community.
497 497       Cecilia Y. Youngs, Attorney at Law Washington Attached is my letter to EQC on proposed rules for AGM. Already submitted to you, but just making sure it is read. Remember, air contaminants do not recognize state lines. LTR - EQC - BULLSEYE GLASS -03282016.pdf https://data.oregon.gov/views/trwb-z8xe/files/5fab875a-df77-4a8b-b2f8-61f2c427ca85
498 498       Cecilia Y. Youngs, Attorney at Law Washington Attached is my letter to EQC on proposed rules for AGM. Already submitted to you, but just making sure it is read. Remember, air contaminants do not recognize state lines. LTR - EQC - BULLSEYE GLASS -03282016.pdf https://data.oregon.gov/views/trwb-z8xe/files/fa575db5-7506-417d-8509-48099b28a5f5
499 499 Paul Tarlow paul@heliosglass.com Helios Fused Glass Studio Texas My wife and I currently support our family by selling Bullseye products and teaching classes on their use. We have been in business for 9 years. Our financial survival is dependent on Bullseye's products.

Many of our customers are professional artists and craftspeople who have developed art using Bullseye's products. Like us, many of them have livelihoods dependent on using Bullseye glass.

I know literally thousands of people, who, like us, are dependent on availability of Bullseye products to keep our homes and feed our children.

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 Bullseye, Portland residents, and DEQ.

Respectfully,
Paul tarlow
500 500 Cecilia Youngs   Attorney at Law Washington Attached is my letter to EQC on proposed rules for AGM. Already submitted to you, but just making sure it is read. Remember, air contaminants do not recognize state lines. LTR - EQC - BULLSEYE GLASS -03282016.pdf https://data.oregon.gov/views/trwb-z8xe/files/cb2c65f9-9c5b-4963-a97a-d886b16c9f6c
501 501 Cecilia Youngs 04072012c@gmail.com Attorney at Law Washington Attached is my letter to EQC on proposed rules for AGM. Already submitted to you, but just making sure it is read. Remember, air contaminants do not recognize state lines. LTR - EQC - BULLSEYE GLASS -03282016.pdf https://data.oregon.gov/views/trwb-z8xe/files/ff7546b6-d7f8-4c62-a8a2-3a6c2e0dfea3
502 502 Cecilia Youngs 04072012c@gmail.com Attorney at Law Washington Attached is my letter to EQC on proposed rules for AGM. Already submitted to you, but just making sure it is read. Remember, air contaminants do not recognize state lines. LTR - EQC - BULLSEYE GLASS -03282016.pdf https://data.oregon.gov/views/trwb-z8xe/files/65fb9d84-aa8d-4411-a857-cf10266e2b24
503 503 betsy Hinze betsy.hinze@gmail.com   Oregon I would implore the DEQ to base their decisions on scientific fact and long-term, peer-reviewed studies instead of politics and sensationalist media. I stand with Bullseye Glass in its efforts to continue producing glass in a responsible manner in Portland, Oregon.

These temporary rules will be very damaging to the art glass industry and these two small companies in particular and there is no clear scientific evidence that they are protecting public safety. Please consider the economic repercussions of this decision and wait to make it until you have substantial scientific evidence instead of fear mongering and political agendas.
504 504 Cecilia Youngs 04072012c@gmail.com Attorney at Law Washington Attached is my letter to EQC on proposed rules for AGM. Already submitted to you, but just making sure it is read. Remember, air contaminants do not recognize state lines. LTR - EQC - BULLSEYE GLASS -03282016.pdf https://data.oregon.gov/views/trwb-z8xe/files/2c6710be-f329-4c86-a178-d69054bb6500
505 505 Rick Bewley bewley@artfusionstudio.com Art Fusion Studio Oklahoma I make a living making art with glass, Please be sure the restrictions you are proposing are necessary.  
506 506 Kent Rosner krosner@pacbell.net   CA California "More likely than not" is not fact based. It is not in line with US principles of "innocent unless proven guilty." Hard evidence should be in place before the State clamps down on a business.

Please do your homework before destroying jobs and industry that many others depend on.
507 507 Marta Edocs edocs@glass-design.hu Glass Design KFT Hungary I am a Glass Artist living in Hungary and have been using Bullseye glass for my own works for the last 25 years and I am still in love with this material. More than 20 years ago I have been visiting Portland’s glass manufacturers and glass artists with a solarship. What I have seen there , has influenced my work and my life. Bullseye factory is a leader in this field and is a very responsible company. Beside this they have generously supported contemporary glass art from the beginning all over the world -, also our Hungarian Glass Art Assosiation got their support several times. Through them I became to be part of a wonderfull community. Beside my studio I am operating two businesses, both relaying strongly on Bullseye and colored glass and both having a number of employees. We are selling glass materials to glass artists, all of them are relaying on this products and we are also manufacturing items that Bullseye needs from us. We are just one little part of the art glass community. Not only ours, but many-many more people’s life around the whole world would be affected by any limitation of the production of colored glass, not to speak about the employees of Bullseye. As far as I could follow, there is no scientific proove that the factories are producing toxic air. I am sure Bullseye as a responsible company will solve any problems that are sientific facts. I stand with them, they should not stop their operation.
508 508 Erik Nolke enolke@gmail.com Portland Resident Oregon * 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.
* 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.

* 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.

* This temporary rule only covers art glass manufactures and not other major polluters in the Portland Metro area.

* It needs to more adequately address Nickel pollution.

* 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.

Thank you.
509 509 Peggy Jo Hilburn Peggyjo@hilburnsartglass.com Hilburn's Art Glass Texas I'm a glass artist in Texas.
The only glass that I sculpt with is Bullseye Glass.
Bullseye Glass has an incredibly large color pallette to work with, the suspending of certain colors has been necessary, my hope is that the DEQ will find a resolution for this company as will allow the production of all colors.
Thank you for your time in advance, my lively hood as well of thousands of others rest in your gands.
Peggy Jo Hilburn
510 510 Greg Gorman greggorman@Hotmail.com The Studio NH Really, there needs to be a comprimise here - Bullseye seems to be willing to work with the Commission, but a knee-jerk reaction will do much more harm to the community than the theoretical damage supposed by the critics. My small business will be greatly harmed, if not ruined, if this goes forward. Greg Gorman, Lyme Center, NH
511 511 Tia Zilberstein siduriana@gmail.com Homemaker OR I live 10 blocks from Bullseye Glass and I'm not impressed with their history. My neighbor s mom moved here to work for them decades ago before she left to seek other work. It was well known then they were against testing. There is technology available to completely eliminate their emissions. The technology would cost a fraction of their yearly profits. If they are so neighborly and such good citizens then why haven't they implemented it? There is a day car hundreds of feet from them. If they can't be bothered to care for the toddlers, at least consider the 200 employees! I support local business and having a robust local economy, but not at the expense of our health when this was so preventable. My 8 year old child and all of the other kids in the neighborhood deserve better. Bullseye committed a gross neglect in its responsibility to all the people affected by not spending money to do the right thing BEFORE this issue became public. We have to have stricter standards to keep the health of our community strong, which benefits industry. It's not an either/or situation.
512 512 Nicholas Macdonald nick@nickmacdonald.net   Oregon * The wording in the temporary rule seems vague using terms like “will probably installâ€� 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. Please be reminded of that commitment.
513 513 Isaac Lamb isaaclamb@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!
514 514 John Kurman giant4hire@yahoo.com   IL Bullseye Glass is one of the most environmentally responsible organizations I know. To impose a temporary without garnering all evidence due to a suspicion that they may or may not be violating some type of standard is irresponsible and arbitrary, I would appreciate it if you put in more time and effort to resolve this issue.
515 515 Jane   seejanefall03@gmail.com   Oregon My daughter attends the daycare just down the road from Bullseye Glass. We did the testing and she has detectable cadmium in her urine. I want Bullseye to be able to make all the beautiful colors of glass they're known for... WITH bag houses on their stacks.
516 516 Robert Meder rdmeder@cmcast.net Portland citizen Oregon I stand wth EPAC.
Portland in particular and Oregon in general deserve s much more form the DEQ! Elected leaders must take stand for the people of Oregon. Fund the DEQ as needed. Protect the people who elected you.
517 517 Amy Ferber Amyferber@bullseyeglass.com Bullseye Glass Co. OR Thank you for the opportunity to comment. Please note that a previous comment was made in my name, unofficially by someone else without my permission. This is my official statement:

I’m Amy Ferber, a Bullseye employee and resident of the SE neighborhood surrounding the Bullseye Glass factory. I have been an employee at Bullseye Glass since 2001 and I have always felt completely safe and confident in our company’s efforts to operate in an environmentally conscious way. There are safety protocols in all areas of our operation and we have always had an excellent safety record.
The owners, Dan Schwoerer and Lani McGregor have built this company from very humble beginnings, in its current location. They created Bullseye with a high level of integrity, have always focused on making a quality product and offering the best service to our customers, while also creating a safe, health conscious and excellent work place for their employees.
Dan is 73 years old and has been working at the factory every day for the last 42 years. He is not only one of the healthiest people I know, he is also one of the most honest and a true man of his word. If he says he is going to do something, not only does he get it done, he does it in the best way possible.
I have always been very proud to be part of all that Bullseye Glass is and represents. Bullseye Glass is a small company. Because of Bullseye’s pioneering spirit, it created a new art medium and new market for art glass, and therefore has worldwide influence. This sometimes makes it appear much larger than it actually is. Bullseye is not a giant, industrial corporation. The owners and employees of Bullseye Glass are hard-working, everyday people with families, much like all of our neighbors in the community. The company culture is more like being part of a family rather than employees of a factory. Dan and Lani interact with us every day, they know us, they know our families and not only do they appreciate us, they care about our futures.
If you implement these temporary rules, even though the Oregon Health Authority has already stated that there is no immediate health risk, you are putting my job and my coworkers’ jobs in very real jeopardy.
We are Portlanders. We are a company of makers. If you shut us down, you are shutting down part of Portland’s history and eliminating a cottage industry that prides itself in being American made.
We can co-exist and lead the way in the future of air quality standards in Portland. I have complete trust that Dan and Lani will spend all of their energy and the necessary expense to put the best emission controls in place for the safety of Bullseye employees, our families and our neighbors.
Please give us the time to complete our state of the art emission controls and maintain our business.
518 518 Ruslan Kanonik kanonik@yahoo.com - Saint-Petersburg, RF I can't vote against the new rules if the threat to the health of local people is proven. But I want DEQ to use facts and not speculation on new rules. I order Uroboros glass across half of the globe and as a person who interested in stained glass I hope for your fair decision.
519 519 Rachael Torchia rtorchia@gmail.com   Oregon DEQ needs to rebuild the public trust by putting our health and well being first. As a lifetime resident of the Bullseye neighborhood, and a new mom, I am concerned that these rules do not adequately protect my family from the heavy metals in our air. Summer is coming up and a return to production without necessary filtration for Bullseye means another summer of exposure for my family. The loophole for businesses like Bullseye must be closed now NOT in September 2016.
520 520 Tracey Bewley traceybewley@gmail.com Art Fusion Studio Oklahoma This is an improper use of temporary rule making. The Oregon Environmental Quality Commission should only consider a temporary rule when credible evidence demonstrates a rule is needed to prevent “serious prejudice to the public interest.� This is not the case here.

Hastily adopting temporary rules make it appear that agencies are being proactive, but these rules do not protect the public, and makes Bullseye a scapegoat. There is no evidence that emissions from the facility pose any acute health risk nor that Bullseye is fully responsible for the emissions, nor 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.

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.�

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. Bullseye will support that effort. 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.

With minor changes to correct scientific errors and omissions in the currently proposed rule, Bullseye Glass is willing to sign an agreement that achieves all of DEQ’s goals and allows DEQ and Bullseye to respond promptly to new factual information.

The haste to adopt technically flawed temporary rules makes it appear that Oregon is repressive to manufacturing businesses and does not care about jobs.

Oregon agencies should strive for proper and fair treatment of all parties, based on law, rather than responding to public concern resulting from sensational blog posts and test results with partial data and no peer review.

The health and safety of the community can be achieved without forcing these businesses to close.

If Bullseye Glass is forced to stop producing 50% of its glass products for 6 months, without regard to ongoing test results or added emission controls, Bullseye’s survival is at risk. We support an agreement that is similar to the temporary rules, but unlike the temporary rules, also allows DEQ and Bullseye to respond promptly to new factual information.

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.
521 521 Jennifer Jones thejonesfour@mac.com Eastside Portland Air Coalition Oregon * 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. Please be reminded of that commitment.
522 522 Susan Crane susan.crane@gmail.com A Crane Creation CO My greatest concern is for Oregon community members whose health could be negatively impacted by unsafe levels of toxic chemicals in the environment. I hope the source of these chemicals will be found as soon as possible and further production stopped. At the same time, there appears to be vastly insufficient evidence that the glass manufacturing in the area is the source of these unacceptable levels of Cr(VI). To have Bullseye Glass temporarily stop production of all glass which utilizes CR(III), is a knee-jerk reaction not based in scientific findings. This measure could actually lull the community into a false sense of security, as the true source of Cr(VI) has not been determined. Bullseye has voluntarily started installing filtration systems for the furnaces, and has invited monitoring to ensure community safety. Please consider the livelihood of Bullseye glass employees and artists across the country [and internationally], before implementing unfair and ineffective interventions for this serious situation.
Thank you for your consideration.
Susan Crane [glass artists & sole proprietor of A Crane Creation]
523 523 Hayden Jones pacotaco2010@gmail.com   Oregon Please pass these temporary rules to begin protecting Portlanders from heavy metals. I stand with EPAC  
524 524 katherine Jones katherinealice365@gmail.com EPAC Oregon I stand with EPAC.    
525 525 Theo Bourquin theobq5@gmail.com EPAC Oregon I stand with EPAC and their commitment to a cleaner, greener Portland.  
526 526 Jeff Woods anomalight@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!
527 527 Charmian Creagle charmian.creagle@gmail.com Neighbor OR Why has health of our neighbors become secondary to profit? As a neighbor that lives less than a mile from one of the facilities, I am wondering why my 6 year old tested high for arsenic 6 weeks after they stopped pumping these pollutants into the air? The doctor suggested the levels must have been higher before and are still currently reducing, but what does that mean for her health? And others? We are not within the 1/2 mile zone of concern, we are farther out, so what is the true area affected? There are too many questions that still need to be answered. More testing, more listening. Let's put health first!
528 528 Leslie Kilbride lakilbride@att.net     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.
529 529 Susan Beal susan.beal@gmail.com Eastside Portland Air Coalition Oregon Unlike many of those from out of state who have left a comment here defending industry, I live here in Portland, which has well over a dozen dangerous pollutants in its airshed at all times. Among the most concerning are arsenic, cadmium, and hexavalent chromium, all of which can be and often are emitted in art glass manufacturing. Please take careful steps to regulate all toxic emissions from these smaller art glass operations, holding them to the same standards as Title 5 companies with bigger capacity. We need comprehensive air toxics regulation and reform, and this is a very important start. The Lane County local toxics authority is a great example of the careful, fact- and science-based approach we need so much here in Portland.

Too many of our PPS schools (Chapman, Abernethy, Sitton, James John and many others) are in the bottom 2% nationally for air quality due to unchecked industry and transportation pollution. Please put these vulnerable younger children's health first and limit emissions quickly across the board. Many of us live in the cadmium and arsenic clouds emanating out from factories and railyards. We need your protection to begin cleaning up our air and take quick concrete steps towards real air toxics reform like our neighboring states, Washington and California. Thank you so much for the chance to comment. This is a historic moment to move forward on real reforms that immediately benefit public health.
530 530 Susan Hobbs trcat12@aol.com   Oregon I would like to reiterate that I would like the DEQ to work with the glass community on the rules ... not to just put these rules out there willy-nilly ... BE is willing to work with the state to make everyone safer ... but I don't feel that the DEQ needs to cut the glass people off at the knees to show everyone how they are handling the situation ... we have a history of working together to fix problems here in Oregon and I would us to do that with this problem ... please work WITH the glass companies and not just shut them down ..

thank you
531 531 Teresa Garay teresa@hummel.com.ar Imagen Vitral Argentina 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.
532 532 Marita Ghobrial       I stand with Eastside Portland Air Coalition. I also want to advocate for better regulation of autobody paint shops. The industrial paint fumes blow into our yards and into our homes. Let me reiterate this point: our homes smell like autobody paint fumes. My child inhales these fumes. Fumes and no doubt particulate matter. The business at the end of our block is reportedly "in compliance". Please stand in our yards, in our homes, and consider what compliance should actually mean.
533 533 Lynn Short LMShort@comcast.net   Georgia I am writing in support of Bullseye and Uroboros Glass. Considering your concern with chromium: Many of the green glasses Bullseye makes include Chromium compounds that contain trivalent chromium (Cr+3), a naturally occurring element. Cr+3 can oxidize to dangerous hexavalent chromium (Cr+6) under certain conditions. However, if that happens, the glass doesn't come out green as intended, so their manufacturing process includes steps to ensure the chromium remains in its safe trivalent state. (Note: chromium is used in making all green glass, including wine bottles.) Chromium (Cr+3) in glass making does not oxidize to the +6 state unless the glass engineer wants it to. He/she has a lot control over what happens. If it did convert, the glass would not have the right color and would be useless. Both Bullseye and Uroboros glassmakers are very careful and responsible, and make fantastic glass enjoyed by many, many people, including myself, who use this glass in their career or hobby. I understand these glassmakers are making modifications to their equipment which will render it even safer than it had been. Please work with these companies to ensure they can continue making a much needed and much appreciated material which is safely produced. As an employer in your area, and a valuable resource nation-wide, the good people of Bullseye and Uroboros Glass deserve your assistance in ensuring they may continue producing their wonderful glass. If they are forced to close their business, we glass-workers will be forced to purchase our glass from other makers in the US or abroad. I, personally, prefer to support American companies whenever possible, especially those producing a valuable product in a safe manner, as I know these companies are.
534 534 Richard Mortensen r.morten@sbcglobal.net MORICA Glassworks California Although we all favor minimizing/eliminating toxic substances from our air, this proposed temporary rulemaking seems to be overkill for a local industry (Bullseye Glass) that is voluntarily taking steps to greatly reduce their already low levels of toxic emissions. Small glass businesses such as mine would suffer not only increased costs and loss of certain types of glass, but the more serious consequence of not being able to stay in business. I believe this holds true for glass manufacturers such as Bullseye as well. This appears to be a hastily drafted proposal that ignores the lack of evidence that emissions from Bullseye pose any public health issue (see OHA website). Please reconsider this proposal.
535 535 Ethan Ogle ethanogle@gmail.com EPAC Oregon Thank you for extending the time for public comment on the proposed temporary rules. I believe DEQ should adopt temporary rules that prohibit the uncontrolled emissions of hazardous air pollutants (“HAPs�) from industrial facilities. The proposed temporary rules could be significantly improved and strengthened:

1) The wording in the temporary rules often seems vague, using terms like “will probably install� and “DEQ and OHA believe to be safe for the public." Coming from regulatory agencies centered on public health, I would like to see these phrases become much more black and white.
2) There appears to be no enforceable penalty provision. There needs to be specific, quantifiable penalties for breaking the rules, with enough gravity to compel compliance. This would better reflect a public health based approach to regulation, instead of the apparent protection of industry to the detriment of the public.
3) The proposed rules should apply to the entire State of Oregon, not just the City of Portland. On that same note, the proposed rules should apply to the many other industrial polluters, and not only focus on CAGM's.
4) "If DEQ does not deny or approve the Notice of Intent to Construct within 10 days after receiving the Notice, the Notice will be deemed to be approved." This needs to be completely reversed, the Notice should be denied. No response means NO. Additionally, the public should have a full and fair opportunity to review that information and to provide comments on the draft permit. Only then should DEQ issue the permit, thereby authorizing emissions of heavy metals.

Again, thank you for allowing ample time for public comment, and also thank you for your thoughtful consideration of this matter. With all parties involved having opportunity to voice their opinions, I am certain we can reach an outcome that benefits everyone: citizens, employees, and businesses alike.
536 536 Mark Valadez markvaladez@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!
537 537 Taylor Wirtheim taylor.wirtheim@gmail.com   Oregon I stand with Eastside Portland Air Coalition.    
538 538 judy Jones judyj7774@yahoo.com Fused glass group Nevada I sincerely hope you will get more information on actual glass manufacturing before you close down two thriving businesses. It seems to me they would have sick employees if in fact they were creating the toxins you "think" they are. You should also consult with PhD William LaCourse at New York State College who has taught GLASS SCIENCE for 40 years and has a mountain of knowledge on this exact subject. Please don't make this decision without further information. What is the EXACT time for this "temporary" rule? There should certainly be something specified as to how many days or weeks you are talking about. Living in Nevada we recently found out that asbestos exists in the ground not far from Las Vegas. It is blown around by the winds. Our earth provides many elements, both good and bad, so PLEASE be certain before shutting down a thriving business and robbing glass artists of the products they need.
Thank you
539 539 Pamela Domick pdomick@aol.com   Oregon I fully support Bullseye's past compliance with current rules and their commitments to their employees. It would seem fair to allow the glass manufactures to continue with qualified production while these latest levels of acceptance are put in place. It would be a hardship to many to force these manufactures to close. We need to ensure companies that are TRYING to comply to NOT be vilified, we need to work with the companies that are trying to KEEP employment in the USA!
540 540 judy brown judy@cdnw.com   OR I find it hard to believe that DEQ would totally ignore the heath of Portlanders and the future one's too. This is the most irresponsible act this city could make. I am ashamed and want to see changes immediately.
541 541 Greta Gillmore gretagillmore@gmail.com Ms. California Before you shut down this plant, and effecting the employment of MANY (including artists) please instead look at ways to clean the air at the facility.
542 542 Pamela Domick pdomick@aol.com   Oregon I fully support Bullseye's past compliance with current rules and their commitments to their employees. It would seem fair to allow the glass manufactures to continue with qualified production while these latest levels of acceptance are put in place. It would be a hardship to many to force these manufactures to close. We need to ensure companies that are TRYING to comply to NOT be vilified, we need to work with the companies that are trying to KEEP employment in the USA!
543 543 sharon Griffin drsagriffin@yahoo.com   Oregon I stand with EPAC!!!    
544 544 Shawn Fleek shawn@opalpdx.org OPAL Environmental Justice Oregon Oregon DEQ needs to be held accountable to the low-income people and people of color who have been complaining about air quality in our neighborhoods for DECADES. This rule does nothing to address our longstanding concerns. Broaden your focus to the real dangers of diesel, auto emissions, industry, airports. You have a job. Do your job. Stop saying "it's within the rules" and make some new rules. Make a lot of new rules. Don't let industry continue to block action. Our lives are at risk.
545 545 Jennifer Roberts jroberts0307@hotmail.com   OR I stand with EPAC.    
546 546 Charity Heroux Sourgirlglass@yahoo.com SOURGIRL glass art California I think that it is criminal how you are hanging the responsibility for these findings on the glass industry. Without any extensive testing to speak of, you've caved to (sensationalized) public outcry and hung the blame on the first, and easiest scapegoats you can find. What about the trainyards? All the construction? All the factories and processing plants? What tests are you doing to ensure those companies have not added to the toxicity? Your own tests have come back to show that the contamination is nowhere near as bad as you first suggested, and yet you are still helping to persecute a forty-year member of the community. We are supposed to believe that "suddenly" the Bullseye factory is causing all this contamination? After forty years? It is your job to educate the public, not feed their hysteria. Shame on you! Be RESPONSIBLE!
547 547 Bill Johns info@bluewaterconsulting.com Bluewater Consulting Tennessee The DEQ needs to listen to the experts on this topic. They should contact Bill LaCourse, Professor of Glass Science at the New York State College at Alfred University. In short, the environment is very important but too often we see knee jerk reactions with poor data and logic
disturbing the both mother nature and business environments.
548 548 Daniel Enberg danielenberg@hotmail.com   OR As a Portlander living in Ladd's Addition for the past 10 years, I feel tremendously let down by the DEQ. It is not a surprise that businesses in the are would knowingly do nothing to curb their toxic emissions. I expected more from the DEQ, however. I hope that the DEQ and city of Portland work to regain the trust of the community for which they serve. This is the quality of air that we breath and the quality of soil in which we grow food. Please take the trust the neighborhood has placed in you seriously. Bullseye glass should either be shut down or forced to place extensive filters on their business. The DEQ should regularly test this business and transparently report their findings to the community. Thank you, Daniel Enberg.
549 549 Jody McComas Jody.mccomas@gmail.com   Oregon It is way past due for DEQ to start doing what's right and protect the health and well being of children and families near businesses like Bullseye. We stand we EPAC!
550 550 JAKE FALLDORF Jsnake91@gmail.com   OR I stand with the Eastside Portland air coalition.    
551 551 Maximilian Schlosshauer mschlosshauer@gmail.com   Oregon I strongly support requiring emission controls on all furnaces using toxic metals such as cadmium, chromium, lead, and arsenic. I live very close to Bullseye and I'm the father of two young children, and my family has been very worried about the recent discovery of toxic emissions from Bullseye. In addition to temporary rules, I also hope that long-term rules for mandatory furnaces can be agreed on, so that any emissions would be limited to a low and safe level. Thank you for helping address this significant concern of our community.
552 552 Carolyn okeefe c.okeefe@sasktel.net   sk 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.
553 553 Kali Kiger Kalikiger@gmail.com   OR I stand with SE Clean Air Coalition.    
554 554 Helene Cempa Hcempa@verizon.net   Pennsylvania Please be sure that these restraints are based on hard evidence & not emotional speculation. The result of these restrictions has a larger effect on a huge community of individuals whose livelihood depends on the products from these companies.
Yes, health is number one but only when based on fact with implementations made with all parties in mind.
555 555 Glenn Ostergaard glenn@glennostergaard.com   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.

To put Bullseye Glass in jeopardy for political reasons is repressive, unfair, and an insult to the people of Oregon who deserve truth and honesty from their government. Adopting flawed rules not based on scientific data is a mistake. Bullseye Glass has a world wide reputation, has always been proud of its Portland roots and supported its community. Your temporary actions will cause unnecessary harm to both Bullseye Glass and artists around the world who depend on their glass. I urge you to act responsibly and with scientific intelligence.

Glenn Ostergaard
Artist and Collector
556 556 Claudia Serafin Claudia.serafin@gmail.com   Oregon Portland Oregon has long been know for the production of hand made glass by local artists. I moved to Oregon in April of 2015 because of this glass history and access to Bullseye. When I first visited their factory I was impressed by their clean store and production facilities. In addition, the service and knowledge sharing was outstanding.

Many people complain that industry is moving overseas and taking jobs with them. Here in Portland we have a company that produces magnificent glass made by US Citizens. Bullseye offers classes by renown artists that brings people from around the country to our city.

I find it amazing that regulations would be set based on non scientific facts. If Bullseye is made to close then Portland will lose jobs and tourism and it will rip the heart out of the glass art community.

Please do not needlessly make this company close. I for one do not want to buy my glass from overseas producers.
557 557 Leanya Guilyn Maros guilyn_maros@yahoo.com   OR I stand with Eastside Portland Air Coalition    
558 558 Dave Jordan prairie_isleglassworks@yahoo.com Prairie-Isle Glassworks Ltd. Alberta, Canada DEQ does a great dis-service to the science of health management and industrial safety by adopting these temporary rules based on poor science. DEQ becomes a "Merchant of Doubt" similar to the pro-tobacco lobby and the climate change deniers who spread misinformation and doubt that thrives in a climate of poor 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. I urge DEQ to rely on science and fact, and not to rush to impose these poorly written and misdirected rules.

Please have respect for sound science, and ensure your regulations are based on fact.

Thank You.
559 559 Kyle Day daykyle@gmail.com   OR I do not supporr the EPA regulatory loophole that Bullseye created for glass companies. I support the temporary DEQ regulations.

EPA lists glass factories as one of the top 5 industries of concern between coal and petroleum stating:

"There are approximately 125 large glass plants operating in the United States. These plants emit approximately 200,000 tons per year of NOx, SO2 and particulate matter (PM). Investigation of this sector has shown that there have been a significant number of plant expansions but few applications for the installation of pollution controls required under NSR/PSD."

https://www.epa.gov/enforcement/air-enforcement

This is a known issue by the EPA and this issue has been known and buried for decades by the DEQ.

As you know, the DEQ detected arsenic at 159 times the government safety level benchmark and cadmium at 49 times the safety benchmark.

The IMT, along with the DEQ, OHA, Multnomah County, and other organizations are attempting to quell public concerns by modifying benchmarks where they see fit. This type of behavior is of great concern to me.

Furthermore, while soil testing has looked encouraging for the most part, some residents gardens are showing elevated levels of metals in plant tissues. The DEQ/OHA are claiming the soil is safe for gardening, but as far as I know, they haven't done plant tissue analysis.

Nevertheless, rules on air emissions should not be based on soil readings. They should be based on air testing – which was "unprecedented" and "magnitudes higher" than the DEQ had ever seen in the past. Let us not forget what the initial data conveyed. The initial data, along with the recent air data suggest that Bullseye Glass and Uroboros need pollution controls. Precision Cast Parts must not be forgotten either.
560 560 Darius Pierce dariuspierce@hotmail.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!
561 561 Lynette Hasegawa Lynette.hins@gmail.com Private citizen OR I stand with EPAC.    
562 562 Valerie Adams Valerie@ValerieAdamsGlass.com   California As a full-time glass artist and instructor who depends upon Bullseye Glass for my supplies, education, and livelihood, I strongly oppose the proposed temporary ruling which affects Bullseye Glass and those of us who rely on them.

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. 
 

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.
563 563 Michael Marshall mmarshallpdx@gmail.com   Oregon As I live one block from Bullseye Glass, I stand with Eastside Portland Air Coalition!  
564 564       Glass artist Oregon Shouldn't the role (and first priority?) of the DEQ be to protect the health of the public and the environment, not polluters? Please impose regulations that proactively protect public health, not polluters. Also, many of these comments quote Dr. LaCourse as a reference that CrIII does not convert to CrVI. Dr. LaCourse himself has stated "Unfortunately I know a quite a bit about glass, but not much about environmental testing. In general the method would be determined by the objective.....e.g. Long term vs short term and "all sources" vs specific sources." Given his admitted lack of knowledge on environmental testing, I believe its erroneous to quote him as a source. The socially responsible course is to follow the precautionary principle and regulate known toxics cautiously. Requiring that a certain percentage of the population acquire cancer before taking action seems not only perverse, but an ethically slippery slope. I stand with EPAC. Thank you.
565 565 Luke Griffin lukeg003@gmail.com Concordia Neighborhood Association Oregon I stand with Eastside Portland Air Coalition    
566 566 Adam Saari Arsaa123@gmail.com   Oregon I stand with Eastside Portland Air Coalition.    
567 567 Julie Vincent Jvcorte@frontier.com Retired, glass artist Oregon As a mother, grandmother and glass artist I appreciate the concerns raised over the emissions of local glass factories. I do however encourage that any temporary and/or permanent restrictions be based on sound scientific data and not only in response to sensationalist journalism.
My perception is that these glass companies try to be responsible citizens in our community - demonstrated by voluntary reduction in production when issues were raised about emission issues.
Overly harsh restrictions have impact directly on these small businesses and secondary impact on those of us who use their products.
568 568 anne Smyth annes157@comcast.net Concerned citizen Oregon I stand with Eastside Portland Air Coalition    
569 569 Justin Kertson jkertson@yahoo.com 15 Now PDX Oregon I stand with the Eastside Portland air coalition.    
570 570 Erica Sakurai Aeryca110@gmail.com   Oregon I stand with Eastside Portland Air Coalition!    
571 571 Virginia Spalter virginiaspalter@gmail.com   Florida I have been working with and using Bullseye glass for over a decade. It's my understanding that the scientific evidence shows the use of CR(III) to not be harmful and the soil samples around the factory to be not at heightened levels of toxicity. As an artist who uses this glass as my mode of income the reduction of 50% of supplies would devastate my business. Please get more evidence and scientific studies before making hasty judgements requiring shutting off production. I would not want to do anything to hurt our environment. It does however seem to me, far larger companies are dumping in our environment with a get out of jail free cards and you have singled out 2 business to make political scape goats. This hasty judgement seems to smell of some political aspiration and not care for the public or the environment. Thank you
572 572 Cory Cairn     OR As a resident of the neighborhood impacted by Bullseye’s decades of uncontrolled heavy ‎metal emissions, I reviewed the proposed temporary rules and have the following comments:‎

‎1) The temporary rules allow the use of nickel in uncontrolled furnaces prior to the permit ‎application deadline of September 1st. Nickel needs to be added to the immediate operating ‎restrictions prior to the emission control installation/approval deadline.‎

‎2) Chromium III to chromium VI conversion must be tested in worst case conditions. ‎Unless the glassmaking industry can demonstrate to you that oxidizing combustion conditions ‎cannot possibly occur with their practices, you must keep the current chromium conversion ‎testing requirements. Emission control requirements must be based off of potentiality for harm ‎through accident or equipment malfunction and not just standard daily practices.‎

‎3) Permitting the use of chromium III in uncontrolled furnaces (following the ‎establishment of maximum allowable usage rate) does not account for potential atmospheric and ‎soil conversion. Neighborhoods already heavily impacted by unregulated emissions from these ‎industries should not be the testing grounds for “good enough� emission control requirements ‎regarding less-understood pollutant conversion conditions. Chromium III should only be ‎allowed to be melted in controlled furnaces.‎

‎4) The rules only require source testing on one controlled furnace per facility to ‎demonstrate compliance. Bullseye has acknowledged that smaller baghouses like the one they ‎are currently installing are “relatively new territory for the professionals [they] are working with.� ‎It is too risky to allow hazardous air pollutants to be used in a furnace with an untested emission ‎control device. Every controlled furnace used to melt cadmium, arsenic, chromium, or nickel ‎needs to be source tested to demonstrate compliance.‎

‎5) Stiff enforceable penalties need to be added for violators of the temporary rules, as ‎these issues are well known and understood by the affected businesses. It is impossible to ‎imagine that any violation would not be willful.‎

‎6) These proposed regulations need to be extended to small and medium facility polluters ‎in other industries besides colored art glass manufacturing. Emitters of hazardous air pollutants ‎need to enact appropriate emission controls for public safety as the expected cost of doing ‎business. Ignoring other industries after the glass-making hotspots have been addressed would ‎be unacceptable and have a deleterious effect on public health.‎

Thank you for allowing the opportunity to review and comment on the proposed ‎temporary rule.‎
573 573 Elizabeth LeDoux 26ledoux@gmail.com Cully Neighborhood resident Oregon The Cully neighborhood has been long ignored and marginalized due to our high population of low income and minorities.

I am concerned that this temporary rule only covers art glass manufactures and not other major polluters in the Portland Metro area.

Regulate Precision Cast Parts, Porter-Yett, and other industries that are endangering Portlander's health and the livability of our neighborhoods -- not just glass manufacturers.

I demand substantive enforceable regulations, that are clearly defined. I demand immediate air monitoring in Cully.

DEQ, STOP ALLOWING INDUSTRY POLLUTERS TO WRITE YOUR POLICIES.

STOP ALLOWING INDUSTRY POLLUTERS TO POISON MY CHILD AND MY COMMUNITY!

-Elizabeth LeDoux
574 574 Meg Van Buren Megvb1046@gmail.com South Portland Air Quality OR I stand with EPAC!    
575 575 Cindy Young rocknrollschool@msn.com Neighbor & EPAC OR I'm hoping that the comments from out of state glass makers will not affect the health based decisions that you should be making. Poisoning our neighbor hood so they can make glass is not a good trade off. People from other states and towns will lose their trade? So now DEQ has to worry about their jobs and put the people in the neighborhood in the toxics zone? Please think of people physically effected by your decisions first. Maybe Bullseye could not make this glass anywhere else. Laws are in place to protect communities from these toxics. Please make sure that Oregon's laws are as strict as other state's laws on these issues.
576 576 Fran Bartlett Accbyfran@aol.com Accents by Fran South Carolina This questionable temporary ruling will
Have devistating effects on small art glass
Businesses throughout the country. We
Get much of our glass from the Oregon
Area. The reasoning behind this decision
Defies common sense. Thanks for
Allowing me to speak on this matter.
577 577 Percy Echols Percyecholsii@hotmail.com   Illinois 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.
578 578 Nanette Bowring markcannell.az@netzero.com Personal user of Bullseye glass New Mexico This would affect more people than just the Oregon residents. It would hurt the those artists that are in other states as well.

I really believe that 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.

Please reconsider.
579 579 andrew Dickson andrewcarydickson@gmail.com none Oregon Please, please, please do everything in your power to prevent companies like Bullseye to continue to pollute our neighborhood. Yes to these proposed rules. Yes to any and all increases you deem appropriate. My 5 year old has tested for elevated levels of heavy metals. Naturally we live very close to Bullseye. We have been following the case closely since day one and are convinced their failure to install a 35k filter years ago while not illegal, should be. Their negligence (which looks premeditated based on reporting from various news sources) is shameful. I am an artist. They are hiding behind a false argument that artists are being persecuted. They are willfully polluting to save costs. They are capitalists who make a product for artists. And I find it sickening that they are enlisting costumers from all over the country to use this very same forum to defend them. How dare they. Thank you for doing everything in your power to curtail their behavior. Thank you, Andrew Dickson
580 580 Todd Van Voris toddvanvoris@yahoo.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!
EPAC Comments for DEQ.pdf https://data.oregon.gov/views/trwb-z8xe/files/828ccac6-4ab0-4404-9d52-859ed609d4ec
581 581 Kate blackmore slowgrrl@yahoo.com self Oregon I could care less about Bullseye Glass having the ability to create green glass. What I do care about is the fact that all the residents around the building are then affected with cancer-causing chemicals, and have been for a very long time, with no regard for the effects this is having on human lives.

I care about Portland’s air quality. Please act responsibly and adopt rules that protect children and neighbors from toxics immediately. No exceptions. Bullseye and other glass companies knowingly putting these toxins into the air should NEVER be allowed to do it again, even if only temporarily. Cry me a river, "small colored art glass manufacturers."
582 582 Paula Wilson lilwilson@aol.com   Florida If scientific proof has been given that this actually occurs, then I can see this ruling. But so far my research has shown this is all speculation without any scientific proof. How can you close a factory, put factories workers out of a job, cause artists to change products for production need all based on erroneous information.
583 583 Jennifer Lin jnnfrlin@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!
584 584 Jennifer Lin jnnfrlin@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!
585 585 Jennifer Lin jnnfrlin@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!
586 586 Cindy Young rocknrollschool@msn.com EPAC OR Please remember your own testing results. There is a problem. The neighbors of these glass company's are not crazy or hysterical. They are concerned for their family's health, gardens and property values. Please consider the most effected by this. When the glass factory quite using the monitored toxics levels went down. We know they're the source and it is not our imagination it is scientific fact.
587 587 Cindy Young rocknrollschool@msn.com EPAC OR Regulations on polluters is important to maintain accountability and safety. There have been safety issues concerning these glass company's since 2007. Please stop the continued protection of businesses before health. It is not in our best interest. Thank you-
588 588 Sattie Clark sattie@eleekinc.com Eleek, Inc. CA I had to move my family and my business from Oregon to California because my child's arsenic levels were chronically elevated. DEQ needs to remember it works for the people not the polluters. Oregon families deserve clean air and full disclosure about risks. DEQ and EQC have a responsibility to fight for the toughest standards for filtering from this point forward. No more hiding the facts and no more collusion with the polluters!
589 589 Jesse Eells-Adams cobblerguitar@gmail.com   Oregon I stand with the Eastside Portland air coalition.    
590 590   glass artist     Oregon I would like DEQ to look at what WA and CA do about glass manufacturing rules and monitoring, be reasonable and don't make it ridiculous for these companies to stay in Oregon. The DEQ monitoring rules were too lax, the companies didn't step up and monitor themselves. Now things have changed and its hammer time. Put on the filters for the metal emitting stacks. Just do it. If the Chromium science is too complex, let that part get ironed out later. OSU has a College of Engineering that is right down the freeway, hire somebody. Get your focus on Precision Cast Parts, please.
591 591 Jennifer S.     Oregon Please do not allow harmful chemicals to go back into the air.    
592 592 Sugene Yang-Kelly fluxions3@yahoo.com   OR I stand with the Eastside Portland Air Coalition!    
593 593 Katie Bretsch Kbretsch@gmail.com EPAC Oregon Bullseye and its like should be required to implement best internationally available technology to prevent exposure of the public to toxics of any kind. The acceptable amount of subsidy to industry from degraded public health is ZERO. It is most important that the regulations under which they operate be risk based, and respecting the precautionary principle. It is not acceptable that the only risk indexed is life cancer risk. All risks of toxics exposure must be assessed and prevented. Especially inexcusable is the absence of neurotoxicicity assessment and protection.

I live in the impact area, am a retired environmental manager and Oregon qualified hazardous materials manager, formerly responsible for managing an industrial waste process for the protection of the public health and environment. It is my belief that the air quality regulation of Bullseye and its like has been criminally lax. Care for the public and environmental health, which has been the responsibility of the DEQ and OHA, has been completely and knowingly ignored. Oregon should have the most protective air quality regulation in the US, and preferably, the world.
594 594 Emily Eisele emilyaeisele@gmail.com     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!
595 595 Kathy Bayha Kathybayha@yahoo.com none Oregon Please hold off on implementing temporary rules that would cripple the stained glass industry in Portland Oregon. It is unscientific and unfair to target just one kind of business. Please wait and implement researched, factual laws with emmision controls that would apply to all industries alike. We support Bullseye and Urbanos efforts to comply and make expensive safety changes to their production processes. Please dont put these amazing companies and employers out of business. We rely on them and so do artists around the globe. They are not lawbreakers. They will conform to scientific and fair regulation! Thank you for listening, Kathy Bayha
596 596 Francesca Monga fmonga@gmail.com EPAC OR I stand with EPAC. Why do the proposed rules allow nickel in uncontrolled furnaces prior to the permit application deadline? Why do they allow chromium III in uncontrolled furnaces? And above all, why do these rules only require source testing on ONE controlled furnace per facility? Please make these rules more stringent to protect those of us who have been exposed by Bullseye to these harmful chemicals for years.
597 597 Chris Canote chris@chriscanote.com   Oregon I stand with EPAC.    
598 598 TERRY Petta chung5357@comcast.net Mr. OR I stand with Eastside Portland Air Coalition.    
599 599 Cindy Young rocknrollschool@msn.com EPAC OR Please note that many of the comments concerning glass manufacturing are from states where it would be against the law for Bullseye to make any colored glass. Interesting that those folks don't think anything about the neighborhoods and people effected here. People's health first please.
600 600 Emery Way situationalistint@gmail.com   OR I am happy to stand with the Eastside Portland Air Coalition.

It is good to see the DEQ making some effort to address the mammoth environmental issues which have been raised by the recent EPA moss testing and certainly support the passing of these temporary rules as it is the DEQs elected duty to protect the health and well being of the people of oregon. However, I encourage the DEQ to not view these rules as the end of a process but as the first step in the right direction, these recent news has brought to light a much more systemic problem of lack of general oversight by the DEQ especially when it comes to minority and low-income neighborhood environmental quality. It is time for the DEQ to rectify the effects of its negligence and lack of responsibility. The health of the people of our state is more important then the maintenance of licensing loopholes that protect the profit margins of faceless companies.
601 601 Kristi Lund Kalund@gmail.com   Oregon      
602 602 Paulette Marchand yellowgardenhouse@yahoo.com   Oregon I stand with EPAC's recommendations on regulations.    
603 603 Brian Routh Jr Brrouth@yahoo.com   Oregon Please enact rules to prevent the release of heavy metals in excess of safe levels in the mixed light industrial/residential areas around glass manufacturers. I have friends who have lived 1 block away from Bullseye for years and I am very concerned for their well-being. No manufacturer should be able to expose nearby residents to harmful levels of heavy metals, regardless of how small the business.
604 604 Carrie Bonnett bonntonic@gmail.com EPAC OR As a concerned homeowner and parent in Portland, I stand with Eastside Portland Air Coalition.  
605 605 Theodora Devereux tdevereux@nc.rr.com retired environmental health scientist and glass artist North Carolina 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. I have visited the Bullseye Glass plant on several occasions. Safety of the workers, students and visitors seemed to me to be paramount at all times.

Regulatory decisions must be based on science, and it seems like DEQ is acting hastily. 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 misdirected rules.
606 606 Mary White mwhiteglass@mac.com Former head of San Jose State University Glass Program California As a glass educator, I have known the owners of Bullseye glass for over thirty years. They are respected leaders in our arts community. I want to testify to their honesty, careful respect for environmental rules and regulations and general environmental consciousness.

I urge DEQ to work with Bullseye to carefully research in more detail the sources of the metal emissions and mitigations before making hasty temporary rules.

Thank you.

Mary White
607 607 Jessica loughlin jessloughlin@internode.on.net   Australia I am most concerned and dismayed at the unfolding events happening around air quality control in Portland. I am totally against the Air QualityTemporary Ruling 2016 that appears to be based on politics and sensational headlines rather than scientific testing and any credible evidence. I am one of the many artists around the world that uses colored fusible sheet glass in my art practice. This ruling appears to make companies like Bullseye Glass the scapegoat for the DEQ - but it is not just bullseye, this ruling will put at risk the survival of the colored art glass production and jeopardize an entire global industry of kilnformed glass makers world wide. The health of every person should be put first before art, industry or anything else. As a mother of a young child I completely sympathize with the neighbours of the glass factories and I too would be very fearful with all continuous misleading information. However, please, proper due process is required adequately address and solve the issues with Portlands air quality. I don’t believe the statement made by the DEQ that “likelyâ€�* is good enough evidence to shut down 50% production. I urge you to reconsider what would appear to be a hasty decision and allow Bullseye to work with the relevant organizations to ensure a viable lasting solution that will be in everyones best interest.

*http://www.oregon.gov/deq/RulesandRegulations/Pages/2016/Rtoxics2016temp.aspx
608 608 Heather Lovell heather.r.lovell@gmail.com Citizen Oregon I care about Portland’s air quality. Please act responsibly and adopt rules that protect children and neighbors from toxins immediately.
609 609 Leah Mocsy lmocsy@yahoo.com EPAC OR I stand with EPAC    
610 610 Jessica Applegate applegatebrown@msn.com Concerned parent OR This is a test. Some members of our group are getting error messages when they try to submit their comments.  
611 611 Julie Re Joejuliere@yahoo.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.
612 612 Kathleen Bromley Rothman katglass@aol.com G.K. Enterprizes of Clearwater, INC Florida I stand with Bullseye Glass and The Art Glass Industry! Please do whatever needs to be done to make sure that a truly American artform is not oblitereated! Our Industry has already had to survive an economic downturn due to poor choices in US governmental regulations and oversights, let us not add extraordinary measures that would change the face of this industry forever.
Thank you, Kathleen Bromley Rothman
613 613 Sophia Howell Foshie@msn.com   Washington I stand with the Eastside Portland air coalition.    
614 614 Leslie Byster Lbyster@igc.org Epic and right to clean air Oregon I support epic and the community to adopt health-protective standards. First do no harm. Adopt the precautionary principle when formulating rules.
615 615 J Jones       .    
616 616 Jodi Grimmett-Ozen jodi@glassalchemy.com Glass Alchemy OR - Oregon Please see attached comment from Glass Alchemy Glass Alchemy - Comment on The Air Toxics Temporary Rulemaking.doc https://data.oregon.gov/views/trwb-z8xe/files/999c1050-4784-4233-93a3-6ad43e8bb331
617 617 Annalise Woods albriga@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!
618 618 Carla Hervert chervert@peacehealth.org   OR The following rules need to be strengthened:
1) Statewide rule making- the temporary rules must apply to all glass manufacturers, not just in Portland
2) Must regulate all heavy metals
3) Public review is a must!
Thank you!
619 619 Rose Mccaffrey mcfigpsl@att.net   FL Dr William LaCourse states that Bullseye Glass furnaces don't produce toxic chromium. Bullseye is installing baghouses on furnaces that melt glass with chromium. I can see that other businesses who don't cooperate by installing devices to control emissions should be compelled to comply. Please base your decision on science and evaluation of air and soil around the facility by Mr Johnson.
Bullseye is a responsible company that provides jobs to hundreds of people in the community and through out the country by providing the media to create beautiful art. Please don't put Bullseye Glass out of business. Thank you
620 620 Glass Artist       .    
621 621 Cindy Young rocknrollschool@msn.com   OR I stand with EPAC!    
622 622 Meg Ruby megruby@gmail.com EPAC and NCA OR Hello, My Name is Meg Ruby. Please pass temporary rules to stop glass factories from using arsenic, cadmium, chromium (all forms) and nickel. Know this is only a temporary step. The goal must be to provide adequate protections to prevent exposure to air toxics for the health of all in Portland, and indeed in Oregon.

DEQ must immediately identify/inventory all additional glassmakers in the Portland Metro area and in the state. DEQ should begin with the Moss Monitoring data and use other resources to find all glass producers. DEQ temporary rules should not be adopted until they are calibrated to be relevant to all glassmakers’ practices in the Portland Metro area and beyond, e.g., product lines, use of metals, firing practices, known emissions, and correlated moss monitor results.

DEQ’s temporary rules for glassmakers must include appropriate provision for all types of glassmakers and their practices and they must include timely and precise monitoring of emissions to document glassmakers are not releasing dangerous toxic emission into our air. DEQ must focus on the goal of keeping every Oregonian safe.

DEQ's temporary rules for glassmakers should explicitly require the adoption of ‘Best Practices’ in the industry for filter use, calibration, installation, operation, cleaning and maintenance.

DEQ itself must also adopt best practices for regulating this industry, for example in the assessment, testing, monitoring, and abating of emissions from glassmakers.

Please adopt best practices in management of all industrial sources contributing to the Portland area toxic air crisis including proposing state of the art regulation of diesel emissions.

Please keep your focus on solving Oregon’s toxic air debacle. DEQ must be overhauled, recalibrated and given adequate funding to do the job at hand. Currently, DEQ has proven to be dysfunctional and captive to the interests of the Associated Oregon Industries (AOI) and their fancy lawyers. Please leave such practices behind. Fly right.

Ask the Governor/State legislature for the budget needed and permission to bring in the proven leadership. Reboot DEQ into becoming an agency about which we can be proud! This Oregon! DEQ can become the agency we need to protect all Oregonians.
623 623 Mary Rose Zambonirose@gmail.com   OR I stand with EPAC    
624 624 Richard Mackin richmackin@gmail.com   OR Please adapt the strongest possible protections to ensure the health and safety of everyone.  
625 625 Gayanne Robimson gayanne.robinson@gmail.com Santa afe Community College New Mexico As a student at the above named colkege, our class and teacher would be hurt by these UNNECESSARY TEMPORARY rules.
We purchase glass from Bullseye, and while we are concerned about our own safety, and that of the Oregon community, no research indicates a crisis situation, or a need for a sudden change.
626 626 AAA_TEST AAA_TEST not@real.com     This is a test comment; please ignore    
627 627 AAA_TEST AAA_TEST not@real.com     This is a test comment; please ignore    
628 628 AAA_TEST AAA_TEST not@real.com none OR Test comment... please ignore.    
629 629 AAA_TEST AAA_TEST not@real.com none OR Test comment... please ignore.    
630 630 Cheri Riznyk littlepi3@hotmail.com   Oregon I stand with EPAC    
631 631 Shana Canote info@twinkleandwhimsy.com South Portland Air Quality OR The rules need to apply to other polluters as well (such as Precision Castparts and McClure Industry, and others). There needs to be consequences and fines for polluters that break the rules or polluters will do whatever they want. It is perfectly reasonable for the public to want clear rules for all polluters and penalties for rules broken. It is important that we have clean air for all residents of Oregon. There is nothing wrong about demanding clean air.
632 632 Carolyn Hintz sackettandjetta@hotmail.com Neighbor OR I live and work in the SE neighborhood. I am outraged that enough is not being done to stop this out-of-control air pollution! Please do everything necessary and enact strong measures to make sure we are all breathing clean air. Our children deserve our protection! We need to have strict adherence to the benchmarks to ensure our health and we need protections in place so that DEQ is not enabled to make all of the decisions. There should be oversight and lots of checks and balances. It's finally time to do the right thing!!
633 633 Cristi Miles cristimiles@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!
634 634 Michele Davis numbah1bluegirl@hotmail.com Ms. 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!
635 635 Ata Saedi atasaedi@hotmail.com   OR I encourage DEQ to adopt stronger temporary rules that protect public health and ensure public participation.  
636 636 Alma Velazquez advelazquez@comcast.net Cully Stink Team Oregon I live in the NE Cully neighborhood of Portland and I don't believe the temporary rules would make a difference for enough of the air quality problems we currently face. We need a plan that includes ALL emitters of TOXINS, no matter the size. Let the impact (the emissions level) be the guide, regardless of the size of the emitter or the type of company it is. Also, ensure that the benchmark for emissions be guided by the Precautionary Principle, whereby emission standards are at a level that is POTENTIALLY harmful, even if note yet verified. I stand with the Eastside Portland Air Coalition.
637 637 Jules Elias verdilovers@comcast.net retired Oregon Why do we insist on ignoring the data from the National Science Foundation that envirornmental toxins are major contributors to cancer causation and other seriour diseases.
638 638 Julie Parker japarker55@gmail.com   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.
639 639 Samantha Pennington-Vrsek Pennings1@sou.edu Southern Oregon University Oregon I stand with the Eastside Portland Air Coalition. We have a right to clean air.  
640 640 Ben Stabley quillaja@hotmail.com   OR I've been an employee for Bullseye for about 2.5 years. I also have a B.S. in Environmental Science from the Rochester Institute of Technology, for what that's worth as an illustration that I have some idea about environmental issues.

First, I do think this proposed "temporary" rule has no concrete evidence behind it, and is motivated largely by political pressure and public fear stirred up by a sensational news media. In fact, your own investigations have shown the health risk to be minimal, despite the temporary rule stating that there are "serious health effects".

Second, Bullseye Glass has been in compliance with existing regulations. Although regulations can change, Bullseye needs some time in order to install proper pollution control measures. I always thought it was odd that the factory did not have some sort of filtration system installed, but assumed (correctly) that the company was operating legally. I think it is wonderful that Bullseye is now installing pollution control systems. However, this "temporary" rule is hasty, sudden, and irrational. It targets a small number of specific businesses--that were complying with the law--and ignores other potential sources of pollution.

Furthermore, from my perspective as an employee, Bullseye has bent over backwards to work with the DEQ in response to the issue. Bullseye voluntarily suspended use of cadmium, lead, arsenic, and chrome, and is also voluntarily begun the process of installing pollution controls. I suppose it would have been possibly for the company to simply say "we're in compliance" and continue using these materials.

As it stands, Bullseye is currently producing less than 50% of its product line, taking significant revenue loss while simultaneously spending untold sums on pollution controls AND continuing to employ all of its 140 employees. I believe Dan Schwoerer, the owner of Bullseye, is doing more than most in his position would do to operate a responsible business and protect us employees.

My fear is that this "temporary" rule will strangle an otherwise excellent small business before it has a chance to comply with any new regulations, unfairly targets specific businesses, and ignores other sources of pollutants and the larger overall issue of air quality in Portland and Oregon as a whole.

Ben Stabley, melter 1, graveyard shift
641 641 Becky Binion beckybinion@gmail.com   GA I stand with EPAC    
642 642 Emily Von W. Gilbert Bigemily@gmail.com   Oregon Please take into serious consideration the recommendations made by neighbors for clean air, EPAC and other neighborhood groups. A temporary rule send like a perfect time to expand the reach of DEQ to finally take serious control over pollution.
643 643 Kirk Miller Kirkmillerglass@gmail.com   FL My glass business relies completely on bullseye glass. I use almost exclusively green, turquoise and blue. Without Bullseye glass my business would fail.
644 644 Lisa Mentz Mentzor@gmail.com   Oregon      
645 645 Meryl Raiffe theglassunderground@gmail.com The Glass Underground NJ 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.

Bullseye Glass manufactures a wholly unique product. If Bullseye Glass is forced into compliance, we and thousands of others like us, will be forced out of business.

Chromium III is essential to the production of green glass. Scientific evidence shows the use of this compound by Bullseye Glass is not harmful. Nevertheless, the DEQ wants to restrict Bullseye from using Cr(III) for an extended period of time. They are essentially basing these rules off an assumption of guilt without any supporting evidence.

Neither DEQ or EPA have required any other US producer, of green glass, to entirely and arbitrarily stop their production without notice and perform the kind of extensive testing and modeling that DEQ is asking for. A typical green bottle manufacturer uses 1,000 times more Cr(III) per year than Bullseye Glass. A bottle producer, with emission controls, would melt more Cr(III) each day than Bullseye uses in a year.

These newly proposed regulations are based on politics and fear, not science. A leading scientist, Dr. LaCourse, has said Bullseye's furnaces do not produce toxic chromium. These regulations could be forced upon Bullseye Glass in the next 24 hours via a temporary rule making procedure by DEQ.

If Bullseye Glass not allowed to use Cr (III), they can no longer make green glass. On top of their voluntary suspension of cadmium glass production until their baghouse is in place, this new limitation would eliminate 50% of their product line. It would result in employee layoffs, huge economic impacts to Bullseye and could even drive them out of business.

It also impacts us, medium to small businesses and artisans and hobbyists all over the world. We are a new start-up glass business with 5 employees, one of whom has metastasized breast cancer and has not been able to find employment elsewhere, a fifteen year old kid who's dad just passed away and is trying to help his mom, a young woman with chronic lime's disease, a young mom with 50% hearing loss and a woman with scleroderma. All these people need their jobs!
Please help!
646 646 Eugene Johnson chrisngene.os@gmail.com   Oregon So your beating up on these guys but letting Intel do what ever it wants? Looks like money talks  
647 647 Timothy Bowersox harold1917@icloud.com   NY That are needed and not polluters.    
648 648 Greg Gabel Rhinochaser67@yahoo.com   Oregon I have been an employee at Bullseye Glass for 24 years where I have spent my days working on the production floor. I have lived on Hickory St. in Ladds Addition for 20 of those years. During which time I ate food from my yard, eggs from chickens and walked and biked to work. All of the medical monitoring tests which I have received during this time to date have shown normal results for metals. We are not in the midst of an environmental nor public health emergency.
.
I love our community, I love Portland, and I love Oregon. My decisions on the shop floor as a manager have always been to protect the safety of employees and to environmentally do the right thing. I am an avid fisherman and birder and would never knowingly participate in an activity that degredates our environment.

We are a small business who offers a world class handmade product. I am proud to work at Bullseye. We create some of the most sought after handmade glass in the world. We treat our employees with dignity. Making glass is no easy task. This is not a business of the elite, but a business of the working class. We add to Portland’s reputation, not detract from it. I encourage all those interested to take a tour of our facility to see what we create first hand. We are American made! Shouldn’t we support local businesses instead of relying on China for all our goods?

At this point we can only make a small portion of our pallet which puts us in economic danger.
The temporary rule will strangle our ability to move forward as we install filtration. I ask DEQ to take this unprecedented opportunity to provide strong leadership that is based on science instead of emotion, protect the safety of the public, not demonize a small business, and move toward a conclusion where all prevail. Please do not enact the temporary rule.
649 649 Sandra Joos joosgalefamily@comcast.net   OR I am writing to express my opinion that the rule proposal is not adequate to address the true emergency and risk to public health posed by metal emissions from small colored glass manufacturers. Particular problems with the proposed rule include: 1) it will allow emission of chromium 6 at levels 20 times less protective than Oregon's established ambient benchmark; 2) it will allow DEQ to make decisions that affect human health, including for production to recommence, without adequate public involvement; and 3) by too narrowly limiting which facilities will be subject to this rule, it will not sufficiently safeguard against ongoing racial injustice and environmental justice disparities caused by toxic air pollution.
I urge DEQ to adopt stronger temporary rules that protect public health and ensure public participation.
Thank you for your attention.
650 650 Maud Whalen maud@prettyarmadillo.com home owner OR I live in SE Portland and am very concerned about the air pollution and very dismayed at the government's seeming lack of concern. I live very close to Precision Castparts which has been named as a top air polluter in the nation! I stand with EPAC in requesting that our air pollution regulations be tightened!
651 651 Ronnie Werner werneron@yahoo.com citizen of SE Portland OR I stand with EPAC    
652 652 James Tadsen laughingdogacres@msn.com Private individual Illinois Ladies and Gentlemen:
I am responding to the Oregon DEQ’s offer to accept public commentary regarding proposed implementation of temporary regulations affecting operations of both Bullseye Glass and Uroboros Glass companies in Portland, Oregon.
In contrast to many of the comments you will review, I am neither a resident of Portland nor Oregon. Nor, am I a dedicated user of either company’s products.
I am, however, an avid glass artisan and a user of art glass primarily from domestic and European sources. In “Artworld�, both Bullseye and Uroboros provide artisans around the world unique opportunities to create fused glass art – with products NOT available elsewhere - period. Both companies occupy a unique niche not otherwise met. Further, putting the viability of either company at risk is putting the art glass community at risk, not only in Oregon and the United States, but with negative worldwide ramifications.
Based upon everything I have read, it appears that the DEQ is attempting to overcompensate for its having possibly been asleep at the wheel, in terms of overseeing effluents from both manufacturers. It also appears that both companies have followed the letter of existing law in terms of compliance. Extensive and expansive environmental and human sampling has broadly refuted any notion that past decades of operation have resulted in any actionable pollution or risks to health.
As you must know in your heart of hearts, bad science can easily lead to bad politics. Bad politics can easily lead to bad public policy. Bad public policy can easily damage businesses and the public good.
Both companies have signed on to agreements wherein they will bear the costs of installing appropriate air quality devices. I do not know the case for Uroboros, but I do know that Bullseye has been sued by the Keller Rohrback firm out of Seattle, associated with local counsel. Both companies have faced public scrutiny and demonstrations, which may well have distracted them from the business of providing quality products for their worldwide customer base. Both companies have plenty of irons in their fires, without thoughts of facing even more restrictions from the State of Oregon and other governmental agencies.
From the viewpoints based both in reason and science, I ask that any further restrictions or impediments to the business of making glass by either company be set aside. Plainly and obviously, were either company to have, in reality, polluted to the extent of actually compromising public health over decades, the scientific proof would support such contention. Collaterally, allowing both companies to reinstate their normal production over the relatively short period required to design, install, activate, and test the proposed 99% effective baghouses will NOT contribute significantly to the already minimal risks to public health. Rather, allowing both companies to catch up with state of the art pollution control devices with allow both companies a better chance of staying in business, meeting customer needs, and continue contributing quality employment opportunities to the greater Portland area.
653 653 JB Rinaldi jb.rinaldi9@gmail.com   OR I am writing because it is time to make air quality a priority in Portland, but that means we need local solutions for local problems. 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
654 654 James Tadsen laughingdogacres@msn.com Private individual Illinois Ladies and Gentlemen:
I am responding to the Oregon DEQ’s offer to accept public commentary regarding proposed implementation of temporary regulations affecting operations of both Bullseye Glass and Uroboros Glass companies in Portland, Oregon.
In contrast to many of the comments you will review, I am neither a resident of Portland nor Oregon. Nor, am I a dedicated user of either company’s products.
I am, however, an avid glass artisan and a user of art glass primarily from domestic and European sources. In “Artworld�, both Bullseye and Uroboros provide artisans around the world unique opportunities to create fused glass art – with products NOT available elsewhere - period. Both companies occupy a unique niche not otherwise met. Further, putting the viability of either company at risk is putting the art glass community at risk, not only in Oregon and the United States, but with negative worldwide ramifications.
Based upon everything I have read, it appears that the DEQ is attempting to overcompensate for its having possibly been asleep at the wheel, in terms of overseeing effluents from both manufacturers. It also appears that both companies have followed the letter of existing law in terms of compliance. Extensive and expansive environmental and human sampling has broadly refuted any notion that past decades of operation have resulted in any actionable pollution or risks to health.
As you must know in your heart of hearts, bad science can easily lead to bad politics. Bad politics can easily lead to bad public policy. Bad public policy can easily damage businesses and the public good.
Both companies have signed on to agreements wherein they will bear the costs of installing appropriate air quality devices. I do not know the case for Uroboros, but I do know that Bullseye has been sued by the Keller Rohrback firm out of Seattle, associated with local counsel. Both companies have faced public scrutiny and demonstrations, which may well have distracted them from the business of providing quality products for their worldwide customer base. Both companies have plenty of irons in their fires, without thoughts of facing even more restrictions from the State of Oregon and other governmental agencies.
From the viewpoints based both in reason and science, I ask that any further restrictions or impediments to the business of making glass by either company be set aside. Plainly and obviously, were either company to have, in reality, polluted to the extent of actually compromising public health over decades, the scientific proof would support such contention. Collaterally, allowing both companies to reinstate their normal production over the relatively short period required to design, install, activate, and test the proposed 99% effective baghouses will NOT contribute significantly to the already minimal risks to public health. Rather, allowing both companies to catch up with state of the art pollution control devices with allow both companies a better chance of staying in business, meeting customer needs, and continue contributing quality employment opportunities to the greater Portland area.
655 655 Meg Ruby megruby@gmail.com EPAC, NCA Oregon I am submitting an additional comment to that submitted earlier today. And that is that these temporary rules are in adequate for the following reasons:
The temporary ruled 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.
656 656 Gaye Chapman Gchap333@yahoo.con   Oregon I stand with Eastside Portland Air Coalition    
657 657 Genevieve Moore Sportlandacupuncture@gmail.com   OR I stand with EPAC    
658 658 Susan Hayes Suzanmhayes@yahoo.com none   All I ask is that you get the facts before you make any decision that jeopardizes jobs.

I feel as though there are plenty of facts to illustrate that this over reaction is both unjustified and unfounded.

Work on permanent solutions built from facts not temporary restraints based upon speculation.
659 659 hibiki miyazaki hibikimiyazaki@gmail.com hibiki miyazaki OR we need DEQ to work harder at preventing the ongoing pollution created by companies in the city that is negatively effecting the health of Portlanders.
660 660 Cynthia Morgan cynthia@morganica.com Individual Oregon DEQ's "temporary" rules are a hasty and ill-conceived attempt to paper over a significant issue with air quality management in the greater Portland metro area (and, indeed, throughout Oregon): The lack of consistent, science-based regulation and fair application of those regulations to all businesses. These rules are an attempt at damage control without consideration of the real problems.

Accordingly, DEQ should take the following steps:

1) Develop strong guidelines, based on the latest scientific guidelines, conducting any operation of any size which employs identified HAPs per EPA guidelines. Where legislation does not exist to require emissions/pollution control levels for those businesses, draft such legislation and work with Oregon state legislature to pass it. If needed apply to community action groups for assistance and use the current laws of nearby states (Washington and California) as examples.

At minimum, such legislation should require businesses to submit to regular independent testing to ensure no/minimal levels of emissions (and, obviously, those levels should be defined). Where levels are exceeded, compliance and remediation should be enforced.

2) Provide expedited review, testing/analysis, and approval of the current glass factory situation to ensure that (a) residents are reassured about the safety of their neighborhood air and soil and (b) glass factories are able to resume safe production as quickly as possible. DEQ can take as long as 18 months to review and approve such permits and plans; I as a citizen would like to make it clear that such delays are abominable here, when so many of DEQ's constituents are relying on the outcome.

3) Make public all test and sampling records, as well as all test and construction plans, related to the "hotspot" announcements of arsenic, cadmium, chromium, etc., contamination due to USFS moss research.

4) Provide clarifying information and continuing test results on other potential sources of contamination in the neighborhood, including but not limited to the local cement transfer station(s) in SE, metal plating factory, Precision Castparts, the Brooklyn railyard construction project, etc. Early DEQ information pointed to the railyard as a potential secondary contamination source but there has been little or no additional news regarding whether there has been followup testing to determine if this is actually the case.

DEQ and its partner OHA have frankly done an atrocious job to date of managing this crisis, with the result that many of my friends, neighbors, co-workers, and vendors have been thrown into financial and emotional crisis. I would love to see DEQ do more than simply hire a $50,000 PR consultant to manage its own image in this regard. It's time to step up and actually manage the air quality in this town correctly.
661 661 Kimberly Brooks Filkins Kbfilkins@aol.com Consumer/Artist & Mother PA These points should be considered carefully before imposing this plan

There is no evidence that emissions from the facility pose any acute health risk nor that Bullseye is fully responsible for the emissions, nor that Bullseye’s 42 years of operation have resulted in areas of health concerns in the vicinity of the facility.
Point #9
An economical disaster!!!

Please be careful and mindful
Kindly,
Kimberly

Please consider
662 662 Kimberly Brooks Filkins Kbfilkins@aol.com Consumer/Artist & Mother PA These points should be considered carefully before imposing this plan

There is no evidence that emissions from the facility pose any acute health risk nor that Bullseye is fully responsible for the emissions, nor that Bullseye’s 42 years of operation have resulted in areas of health concerns in the vicinity of the facility.
Point #9
An economical disaster!!!

Please be careful and mindful
Kindly,
Kimberly

Please consider
663 663 kathleen Barta calbart@comcast.net   OR , I am communicating because it is time to make air quality a priority in Portland, but that means we need local solutions for local problems. My daughter and grandchildren live 8 blocks from Bullseye Glass company. 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.
664 664 Esmé Nadeau MiniRecollections@gmail.com   OR I stand with EPAC!    
665 665 James Kingwell icefire@theoregonshore.com Icefire glassworks Oregon I was born and raised in Portland. In1970 I moved away from the city because of air quality issues. I speak from 45 years experience as a glass maker. Comments to DEQ.docx https://data.oregon.gov/views/trwb-z8xe/files/484a1502-a251-4750-a9d8-e8fc04f0702c
666 666 Bev Larson Larsonfrank2@gmail.com Glass artist New Mexico and Virginia With no evidence of harm and Bulleseye has followed al government regulations I feel that stopping glass manufacturing wold be very harmful to glass business,artists and the fastest growing hobby everywhere. Please do not stop Bulleseye from making wonderful product for ALL
667 667 Paige Montgomery paig2@pdx.com Geography Department of Portland State Oregon I stand with EPAC.    
668 668 Roisin Crawford pinn.s.crawford@gmail.com   Oregon Clean Air now! (we agree with EPAC)    
669 669 Charlie Crawford pinn.s.crawford@gmail.com     Can't talk yet, he's only 1 - still likes clean air and a future without runaway unregulated industry  
670 670 Gregory Sotir gsotir@gmail.com   OR It is not just about glass plants. Other source pollution sites need to be addressed by DEQ as well. While community members have made numerous complaints to the Oregon DEQ regarding foul and chemical odors in Cully, we have seen little real progress in addressing the mediation of such odors. Neither have we seen an accounting of the origin or monitoring of such odors. We, as residents of the Cully neighborhood of Portland, Oregon, are concerned that unregulated chemical releases may affect our long term health in a negative way as well as our short-term comfort. This is of special concern given our high population of children and elderly.

Perhaps the DEQ is unaware of the amount and nature of the chemicals being used. If so, please access the following document at http://www.ncair.org/toxics/asphalt/. Granted, this document only addresses toxic air pollutants related to the Porter Yett facility (5949 NE Cully Blvd.) but we hope it may spur on the DEQ to take a more responsive and transparent approach to protect the health of Cully residents. Other industries may be using similar TAPs, toluene and other PAHs yet there seems to be little information about how these TAPs are being addressed.

Cully, as a community within Oregon, is home to a very diverse and economically vulnerable population, and so we know we have been ignored in the past and many of our residents may have become resigned to the fact that the air around us may be laced with known carcinogens. However, given the recent interest in making DEQ more proactive and efficient in protecting the health of Oregonians, we now demand that the Oregon DEQ restrict Porter Yet and other TAP industries from polluting our air and endangering our health. We would further request increased monitoring and a listing of all known TAPs being used in industrial processes within 1000 feet of the Cully neighborhood boundaries.
671 671 Jina K     OR Portland is quickly losing it's claim to being a green city. 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 DEQ to do it's job of 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."
672 672 Dawn Smallman velvethammer00@hotmail.com   OR I'm writing to encourage DEQ to adopt stronger temporary rules that go much further in protecting public health than the ones currently proposed. We need a more conservative chromium level than the level being proposed. We need a process that ensures public involvement and comment periods. Members of our community need to have a place as stakeholders at the table - to be included as decision-makers on all critical, key decisions in crafting both temporary and long-term rules concerning toxic emission standards. Any and all temporary and long term emission rules need to be applied to all facilities - no loopholes, nor selective picking of which facilities they will apply to. Rules and standards need to apply to all emissions being generated by all facilities - no loopholes or "opt-outs" should be allowed. Meeting healthy air standards should not be optional for any facilities. Its clear that the DEQ has not been adequately protecting public health as it relates to the levels of toxic air emissions - its time that changes. And the changes need to come in the form of the strictest standards possible.
673 673 Sarah Page Ognie@yahoo.com   OR All plans for moving forward should absolutely take public health not only into account, but it should place health at the forefront. We should have a team of doctors working with a new local air quality authority to improve environmental rules for manufacture of all glass and other products in the entire state. Monitors should be proven, state of the art, measures of air quality, soil quality, and water quality within 1, 2, 3, 5, 10 miles of facilities. Where there is elevated health concern (anything above a range the doctors choose as "normal", which may be a new, lower level), burden of cost of care falls on the manufacturer.
674 674 Joe Walsh lonevet2008@comcast.net individuals for justice Oregon We must have clean and clear air in our city, you have an obligation to make sure our children are not poisoned .  
675 675 Jody Bleyle bleyle@gmail.com Eastside Portland Air Coalition OR Thank you very much for allowing a public comment period.

I stand with the Eastside Portland Air Coalition in asking that the EQC and the DEQ use the Precautionary Principle when regulating all manufacturers. The burden of proof must be on the polluter to prove that their emissions are safe. We ask for state-of-the-art emissions controls. We ask for continuous monitoring of all hazardous materials at all emissions sources. We ask for open and transparent communication between the DEQ and the public.

Thank you for your consideration.
Jody Bleyle
676 676 judy Tuwaletstiwa tuwalets@gmail.com self New Mexico i have submitted an additional document questioning the need for these temporary rules. bullseye.docx https://data.oregon.gov/views/trwb-z8xe/files/1174d742-0afb-4b86-939c-71ed54318706
677 677 Nina Landey landey@gmail.com Eastside Portland Air Coalition Oregon I stand with the Eastside Portland Air Coalition.

Thank you,
Nina Landey
 
678 678 Peter Wickman peter@glassrestoration.biz Stained glass studio owner California I support the responsibility to the community to ensure the quality of the air is safe for all. But there also needs to be a process by which small manufacturers working with government agencies can remain in business and provide a multitude of benefits to the community.
679 679 Edward Kent kodiakbear80@gmail.com   OR I have been following the news and debate about air pollution in Portland since this story broke in early February. I am an advocate for pollution control and holding businesses (as well as individuals and officials) responsible for actions that affect public health and well-being. However, I do not think these proposed temporary rules serve the purpose of protecting the public.

The businesses in question have voluntarily stopped using the toxic metals (cadmium and arsenic) until they can install additional filtration. They also use trivalent chromium which is non-toxic, not hexavalent chromium.

I have read the proposed rule. It is self-contradictory. "The consequences of the EQC not taking immediate action to adopt the proposed rules would be that
emissions from colored art glass manufacturers could continue to cause elevated and possibly unsafe
levels of metals in the Portland area."

"Could" and "possibly" do not indicate the kind of imminent harm this kind of rule is intended to address. The two glass factories have been operating for forty years, and cadmium stays in the body for 28 years. If harm was being caused, we would already be seeing evidence. We are not, and the Oregon Health Authority (OHA) and the Multnomah County Health Department have stated that there is no immediate health risk to the community.

This proposed rule is not intended to prevent harm. It's intended to absorb political heat. That's not a good reason to ruin our local businesses. Businesses that contribute to the art scene that makes Portland unique. Please do not implement this proposed rule.
680 680 Adriana Baer adriana.baer@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!
EPAC Comments for DEQ.pdf https://data.oregon.gov/views/trwb-z8xe/files/051cdf01-7d2d-4dae-b2e3-a099fe0e7d4f
681 681 Erin Crosby Erin@crosbyglass.com Crosby Glass Washington As a small business owner of a stained glass studio (with a family to support) i ask that you consider the depth of importance our industry brings to bear. Culturally and economically.

The local glass manufacturers could use your help in compliance, but not over regulation.
682 682 Barbara Comnes barbara.comnes@gmail.com   OR Addressing art glass manufacturing facilities' emissions of heavy metals is only a beginning when it comes to cleaning up Oregon's air. DEQ's performance relating to Oregon's air quality has been shameful:
http://www.oregonlive.com/environment/index.ssf/2016/03/how_portland_learned_its_air_w.html What will be done about diesel emissions, for example?
683 683 Julia Reed Juliasreed@gmail.com   Oregon I stand with EPAC    
684 684 Heidi Byrne Heiditbyrne@gmail.com     I stand with EPAC    
685 685 Karen Ferrantelli karenferrantelli@yahoo.com   Colorado I am a glass artist. I use bullseye glass in my artwork. I depend on bullseye glass.

I have visited bullsee several times and have taken classes there. They are a responsible company and have already taken steps to mitigate the risks of their production of glass.

I hope that the DEQ doesn't just take the easy way out and actually bases the rules on the facts not just assumptions.

Bullseye glass is a honorable company performing amazing work. I encourage you to visit the factory and watch the magic of creating glass and understand the beauty they bring into the world. We all need that beauty, please take everything into consideration not just react without facts.

Sincerely,

Karren Ferrantelli
686 686 Melisa Mitchell Melisagmitchell@gmail.com   OR I stand with EPAC    
687 687 Elliot Nail Jreed@frego.com   Oregon Our air quality regulations need to be stronger. Please require Bullseye to filter their emissions. I stand with EPAC.  
688 688 Tara Miner trae.miner@gmail.com   Oregon Thank you for this opportunity to comment. I am urging you to strengthen the proposed temporary rules. The current proposal will: allow 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. For the sake of our children, who suffer the impacts of toxic air at a much greater level than adults, please work to strengthen these rules and protect all of Portland's citizens.

Sincerely,
Tara Miner
689 689 Cathy Camper cfastwolf@hotmail.com Citizen Oregon I stand with EPAC and their insistence that we need better regulations in Portland to address all pollution, more transparency from regulators, and regulations that put citizens' health before industrial profits. See attached please. letter DEQ.docx https://data.oregon.gov/views/trwb-z8xe/files/78fb3ee3-c535-49cd-a264-95a8051d6582
690 690 Lisa Avena avena.lisa@gmail.com Inner SE Portland resident OR I stand with EPAC. We need better regulations in place to protect the health of the community.  
691 691 Caitlin Carleton Barnes Evelyncait@gmail.com n/a Oregon      
692 692 Barney Johnson     OR 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.
693 693 Gregory Sotir gsotir@gmail.com   OR I stand with EPAC. Chromium 6 and other toxic heavy metals should not be dispersed in residential neighborhoods,and should be 100% contained in all other locations.
694 694 Martha Perez marthaoperez@yahoo.com NA OR      
695 695 Caitlin Quinn cquinn@pps.net Portland Public Schools Oregon Hello! I just want to say thank you for taking all of our comments seriously. I know you are doing you best to look out for our students and future generations, making sure that we all have clean air to breathe. I very much appreciate you taking this seriously.
696 696 Domonique Myers-Elatawy Onefinefeline@live.com Civilian Oregon I live 1 block from Bullseye Glass for the last 15 Years. I have had kidneys infections for the last two years. I have been sick for the last 3 months. I eat healthy I don't drink or smoke there's no reason I should be this sick except for toxic air. Please help them put a stop to this.
697 697 Domonique Myers-Elatawy Onefinefeline@live.com Civilian Oregon I live 1 block from Bullseye Glass for the last 15 Years. I have had kidneys infections for the last two years. I have been sick for the last 3 months. I eat healthy I don't drink or smoke there's no reason I should be this sick except for toxic air. Please help them put a stop to this.
698 698 Tiffany Prado Potionista@gmail.com   OR Regulations that prohibit pollution are important for the health of our community: the people, the land, the air, and the water. The necessary filters and remediation equipment are an investment, and one that must be mandatory in order for these businesses to comply. There is no excuse for polluting our land and people.
699 699 Tim Roberts Teroberts70@hotmail.com Grants Pass Clinic OR I stand with EPAC!    
700 700 katherine Coffland kathycoffland@gmail.com Artist Washington I am a Health, Safety and Environmental Manager. In addition, I am also a stained glass and fused glass artist. As such, I embrace human health, environmental stewardship, and corporate safety and responsibility.

That is why Bullseye Glass has my support.

Bullseye Glass has responded to the public’s response to the DEQ by voluntarily installing filtration systems.

Bullseye Glass has a long history of being a responsible partner and citizen in Portland.


Regulatory decisions must be based on science, not political issues. I urge teamwork, and effective problem solving, rather than the divisiveness that has been perpetrated by the media, and DEQ.

I urge you to rely on science and fact, and not to rush to impose poorly written and misdirected rules as a reactionary a knee-jerk response.

I appreciate your attention to this matter.
701 701 Deb Lowenthal DebL2602@aol.com   OR I stand with EPAC. As a neighbor living less than a half-mile from Bullseye Glass, I am not hysterical but I am angry and upset that my life, my family, my pets, my garden have been affected by poison spewing unfiltered from a factory in the middle of a residential area. I hope the personal attacks and name-calling insults against the victims of this situation do not affect the rules we need put in place to protect current and future residents of Portland.
702 702 Julie Yeggy Jyeggyshop@gmail.com   OR Please institute regulations that protect neighborhoods in Portland from toxic emissions from all sources. As it has become clear that glassmaking is a huge source of heavy metals, rules should be put in place to limit these emissions to what is considered below the threshold to cause health problems.
703 703 Dana Reid Dana.d.lmt@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!
704 704 Kaia Wilson Kaiawilson@gmail.com   Oregon I stand with EPAC    
705 705 Laura Rost laura.rost@gmail.com   OR I want stricter air quality standards and enforcement that will adequately address the elevated air pollutants in Portland. This are is densely populated, so there is an opportunity to improve the health of a lot of people at once.

Thank you for your time and for your sincere efforts to address this situation.
706 706 Heidi Wojcik hwojcik@att.net   Ohio Regulatory decisions must be based on science, not political or media 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 sound scientific investigation and a thoughtful process to address Portland’s air quality issues. These rules should give clear directions to all businesses and support the safety of the community. Testing and any subsequent new regulations should cover all businesses, not just target minor specific industries. This is not about only one company; it's about all of Portland, Oregon and beyond. Step up and show those of us in other states how these issues are professionally and responsibly handled. Other states will be watching...and hoping to follow your lead.
707 707 Daniel Hong hongd@reed.edu Reed College Oregon I stand with EPAC.    
708 708 Kerry   kerrykp@swbell.net Artist Texas I am a glass artist. I also have a great interest in our earth and the condition of it's environment.. It is unfounded scientifically that these small glass businesses are responsible for any significant emissions. The use of your language "likely emitted" certainly does not justify the drastic measures you are planning in effecting these small glass businesses. It is a far reaching effect that the measures will have on glass artists nationwide. These findings need more independent study. I am very opposed to the proposed temporary rules.
709 709 Kerri Nelson kerrinelson541@gmail.com Self - Test Oregon Testing the site.    
710 710 Test Test Test@test.com Test OR Test    
711 711 Mark Nadeau Markhnadeau@gmail.com   Oregon I encourage you to enact regulations that are extremely risk-averse. And the "risk" that I'm referring to is human health risk. I realize there are financial and political considerations that are competing for your concern, but those should be dismissed out of hand. Your decision framework should solely be focused on mitigating toxicity in our air so that there's zero risk to human health. To me, that means establishing limits for both known and untested chemicals that result in no significant deaths or disease. I don't think there's an acceptable limit except zero. And I don't really care if that means that manufacturing facilities can't operate within the city. I don't care if it means that our economy will suffer, or that the DEQ will have to fight lawsuits from industry. The only duty DEQ has is to ensure we breath clean air. It's a very important job. Please do it right.
712 712 kathleen Elliot kathleenelliot@comcast.net Kathleen Elliot, Inc. CA Bullseye has been a leading innovator in the field of glass for the arts. They have been a responsible manufacturer, fully willing and capable of complying with safety regulations, with the health and safety of their customers and communities at the forefront. 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.
713 713 Jenine Bressner pickupmyglasseye@yahoo.com   Rhode Island Because your focus is on local government, you may be unaware of the fact that Bullseye Glass is the greatest glass manufacturer in the world. NO ONE ELSE IN THE WORLD DOES WHAT THEY DO. No one makes as many forms of glass, nor in as many colors, nor with such care, nor do any of those companies educate, support, and foster the innovation and creative growth that Bullseye does! Bullseye Glass's rigorous and careful standards are unparalleled. I have a 4 year degree in glass, and nearly 20 years of professional experience with glass. Bullseye is immeasurably important to the livelihoods of so many people, myself included. PLEASE, if any rules are to be imposed it is of the utmost importance that they are based on scientific truth. Dr. William LaCourse of Alfred University has confirmed that Bullseye’s furnaces do not produce toxic chromium. Please do not jeopardize the livelihoods for 150 families of Bullseye employees, nor the livelihoods of tens of thousands of artists around the world! The cessation, even temporarily, of half of their product line could be a blow from which they might not recover. Please do not make that grave mistake. So many people rely on them, and noone else does what they are so wonderful at. Bullseye really is the best!!!
714 714 Rosalind Cooper rsc12789@gmail.com independent glass artist Oregon Now that Bullseye has set up the bagging system for filtration, it would be prudent to wait and see if that solves the issue. Bullseye has cooperated and taken the initiative. I do not feel that drastic measures need to be taken at this time.
715 715 Rosalind Cooper rsc12789@gmail.com independent glass artist Oregon Now that Bullseye has set up the bagging system for filtration, it would be prudent to wait and see if that solves the issue. Bullseye has cooperated and taken the initiative. I do not feel that drastic measures need to be taken at this time.
716 716 Faye Liston fayeliston@yahoo.com   North Carolina I have been a glass artist for 35 years and began using Bullseye glass when I lived in Portland. I took my first fused glass class from one of the former owners. Bullseye Glass Company is a world-class leader in warm glass production and education. I urge you to make your decisions based on science rather than emotion. This is your opportunity to allow a local company to solve a problem with innovative leadership and sience-based facts. Thank you for your consideration.
717 717 Jenine Bressner pickupmyglasseye@yahoo.com   Rhode Island Because your focus is on local government, you may be unaware of the fact that Bullseye Glass is the greatest glass manufacturer in the world. NO ONE ELSE IN THE WORLD DOES WHAT THEY DO. No one makes as many forms of glass, nor in as many colors, nor with such care, nor do any of those companies educate, support, and foster the innovation and creative growth that Bullseye does! Bullseye Glass's rigorous and careful standards are unparalleled. I have a 4 year degree in glass, and nearly 20 years of professional experience with glass. Bullseye is immeasurably important to the livelihoods of so many people, myself included. PLEASE, if any rules are to be imposed it is of the utmost importance that they are based on scientific truth. Dr. William LaCourse of Alfred University has confirmed that Bullseye’s furnaces do not produce toxic chromium. Please do not jeopardize the livelihoods for 150 families of Bullseye employees, nor the livelihoods of tens of thousands of artists around the world! The cessation-- even temporarily-- of half of their product line could be a blow from which they might not recover. Please do not make that grave mistake. So many people rely on them, and noone else does what they are so wonderful at. Bullseye really is the best!!!
718 718 Rick Holmes rholmes55@comcast.net Resident of Portland Oregon Please see attached document. I received an error when responding in this box. Bullseye DEQ commment March 29 2016.doc https://data.oregon.gov/views/trwb-z8xe/files/32132a7e-bba5-43eb-9f89-eb7acabc5be0
719 719 Emily Chenoweth emilychenoweth@yahoo.com Ms. Oregon Too many of our Portland schools are in the bottom 2% nationally for air quality due to unchecked industry and transportation pollution. I stand with Eastside Portland Air Coalition in its efforts to bring about reforms that immediately benefit the health of our children and our communities.
720 720 Rick Holmes rholmes55@comcast.net Resident of Portland Oregon Sorry if this is a duplicate message. I get a status error message each time I submit it. so I am trying again. Bullseye DEQ commment March 29 2016.doc https://data.oregon.gov/views/trwb-z8xe/files/c6caeed2-9ca0-4205-b49f-7e9cd66ee947
721 721 Jennifer Flynt flynt.jennifer@deq.state.or.us DEQ OR Test    
722 722 Sabrina Youngs     Oregon I stand with EPAC    
723 723 Kate Foster kateafoster@gmail.com   OR I stand with Eastside Portland Air Coalition.    
724 724 Paulette Marchand yellowgardenhouse@yahoo.com   Oregon I stand with EPAC . I find it strange and upsetting to see comments that are not from Oregon residents.DEQ you are here to protect us ,the residents of Oregon. Protect the people who live,work ,and go to school in these afflicted areas.Please listen to the residents of the eastside portland air coalition.
725 725 Cassandra Straubing Cassandra.straubing@sjsu.edu Straubing studios CA I support Bullseye and their efforts to improve their operations. They have always been pro active with the health and safety of their employees and beyond. By limiting their production with this temporary ruling does not fix the problem in the long run. It only puts employees out of business, as well as thousands of artists around the globe who depend on their product to make a living.
As Bullseye moves forward with their efforts to improve the safety of their operations, please don't make it more difficult for the rest of us with this temporary hearing. If operations are limited or shut down, I will not be able to work and support my family.
726 726 Ann Young atymp@yahoo.com   OR Please keep the air & water clean for our children & grandchildren .  
727 727 James Adair jmadair@gmail.com   OR I stand with EPAC    
728 728 Colleen Mitchell colleenmitchell@hotmail.com   Oregon As a resident of SE Portland and a mother of two young daughters who live, play and go to school within one mile of Bullseye Glass Co., I support the immediate regulation of all glass manufacturers including Bullseye. However, the temporary rules as they are currently proposed do not go far enough to adequately protect public health. In order for DEQ to adequately fulfill its mission to be a leader in restoring, maintaining and enhancing the quality of Oregon's air, land and water, please consider the following:

Under Operating Restrictions: (1) CAGMs may not use arsenic, cadmium or chromium VI in raw materials in any glass-making furnace that is not controlled by an emission control device DEQ approved. Please add beryllium, cobalt, lead, manganese, nickel, and selenium.

Under (4) Option 2: Please reduce the Chromium VI maximum emission level to one that is protective of human health. Per EPA, the Reference Concentration (RfC) for chromium VI is 0.000008 mg/m3 based on respiratory effects in humans. (U.S. Environmental Protection Agency. Integrated Risk Information System (IRIS) on Chromium VI. National Center for Environmental Assessment, Office of Research and Development, Washington, DC. 1999)
729 729 Francine Lofrano ftblote@sbcglobal.net Independent Artist CA 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. Please do not adopt this ruling! Rely on the science!!!
730 730 DON Graham Donnie3iii@gmail.com   OR I support Bullseye Glass and think you need to look at all of the facts.

I see a lot of inconsistencies in the data being reported and think that decisions like this need to be science and fact based. Please don't let mob mentality rule.
731 731 Colleen Mitchell colleenmitchell@hotmail.com   Oregon As a resident of SE Portland and a mother of two young daughters who live, play, and go to school within one mile of Bullseye Glass Co., I support the immediate regulation of all glass manufacturers including Bullseye. However, the temporary rules as they are currently proposed do not go far enough to adequately protect public health. In order for DEQ to adequately fulfill its mission to be a leader in restoring, maintaining and enhancing the quality of Oregon's air, land and water, please consider the following:

Under Operating Restrictions: (1) CAGMs may not use arsenic, cadmium or chromium VI in raw materials in any glass-making furnace that is not controlled by an emission control device DEQ approved. Add beryllium, cobalt, lead, manganese, nickel, and selenium.

Under (4) Option 2: Please reduce the concentration of Chromium VI to one that is protective of human health. Per EPA, the Reference Concentration (RfC) for chromium (VI) is 0.000008 mg/m3 based on respiratory effects in humans. (U.S. Environmental Protection Agency. Integrated Risk Information System (IRIS) on Chromium VI. National Center for Environmental Assessment, Office of Research and Development, Washington, DC. 1999).
732 732 Michael De Vito devitoemail@gmail.com   Oregon I am a long time resident of SE Portland, six blocks from Bullseye glass. I have been breathing the dirty air from this glass factory for over twenty years. I stand with the Eastside Portland air coalition. People who do not live in this area should not have a deciding voice on this issue. Bullseye glass needs to step up and do the right thing. They can fix this issue with 100% filtration and protect the safety of the citizens of this neighborhood. The DEQ needs to regulate these uncontrolled glass furnaces. Factories emitting toxic pollution (no matter what size the factory is) needs to be regulated.
733 733 Lauren Ward-Selinger Laurenjward@gmail.com   OR I stand with EPAC.    
734 734 Melissa Rehder misslissr@yahoo.com   Oregon I stand with EPAC!

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.
735 735 Ada Bording beadshield@hotmail.com   British Columbia There have to be solutions to the problem that are less invasive and destructive to the companies involved. They are important to the art community as well as the economic health of that community. Our air would be better served if we shut down the fuel burning auto industry
736 736 Eduardo Vides Edartvides@gmail.com   OR As a neighbor of Bullseye Glass and as a physician, I expect that the state and DEQ will impose the most stringent rules on the controls of toxic emissions and place the onus on the polluters whomever they may be, to prove their industries as safe. The approach of looser regulations is the opposite of other developed nations. Public health and safety should never be a question of politics. The state of Oregon has an imperative to protect the public.
737 737 Julia       Oregon No one should ever have to be exposed to these chemicals. I'm surprised that it has been allowed to continue for so long in a developed country like the US. Protect the people and the environment and continue with this excellent proposal. The world can wait a bit longer to get green glass and everyone will be so much happier if that can be produced in a safe way.
738 738 David Ricardo deq@davidricardo.net   Oregon Hi, I'm a Brooklyn neighborhood resident with a family, living perhaps 2,000 feet from the Bullseye stacks. I'm pleased that there are some stopgap measures being taken to protect us, and look forward to more carefully considered and broader permanent rules for emissions.

Even these temporary rules should address similar pollution from any source, not just glass manufacturing, and consequences for non-compliance should include substantial fines. Also, a non-response to an application should be counted as a denial, not a tacit acceptance for which no one need claim responsibility.

The DEQ's job is "to protect the quality of Oregon's environment." Citizens' health and environmental impacts are the top priorities, not profits — or even jobs! It's fine to root for local business — I certainly do — but these local businesses must not threaten the community's health or environment. If the rules are made with environmental and human safety as the sole considerations, they will be good rules. Businesses will adapt, or else fail, but their survival should not be the DEQ's concern. Determine the rules that keep us safe, and let the market determine the rest.

With regard to anything I haven't mentioned above, I stand with EPAC, and you should read their position as my own.

Thanks,
David Ricardo
739 739 Ella DeVito elladevitopdx@gmail.com Portland Public Schools Oregon I stand with EPAC as a student of Cleveland High School I want to DEQ doing everything in there power to protect us. 100% filtration.Heavy fines for anything less than best possible practices .DEQ protect the people.
740 740 Laura Randall Aforeffort@gmail.com   OR I stand with Eastside Portland Air Coalition! Hold these glass makers accountable to a healthy standard!  
741 741 Elizabeth Clune lizardclune@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!
742 742 Peter Mackie ramstone1@shaw.ca Ramstone Mill British Columbia, Canada As some one worked forty years in govt service, BC Parks and Ministry of Environment I can't understand how you can impose restictions based on quesswork and conjecture. Without positive proof that the furnaces actually produce those metao concentrations you are simply imposing limits to cover your backsides.
743 743 Barbara Richmond Brichmon@me.com   Oregon These proposed temporary rules are not supported scientifically and are discriminatory. Please work with the companies to find a better solution than this.
744 744 Vincent DeVito   Portland Public Schools Oregon I live and go to school within half a mile of Bullseye. DEQ put rules in to place to give 100% assurance that I am safe.DEQ protect our air.
745 745   Makuch kbmglass@earthlink.net Glass artist Ct Dear Sir:
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.

I firmly stand behind Bullseye Glass Co and their commitment to the community and the environment. I have been a customer of theirs for nearly 20 yrs and know that they stand to their word . Allow them to make changes necessary, while keeping their door open.

Thank you!
Kelly Makuch
746 746 stacey schroeder stacey.schroeder.moultrie@gmail.com North Portland Air Quality/Neighbors for Clean Air OR I stand with EPAC.    
747 747 Amy O'Connor acolumbo@comcast.net South Portland Air Quality Oregon Why is DEQ not ooking into temporary rule making around Precision Castparts? I understood from a community meeting at Lane Middle School that Precision is being allowed to operate under a old permit while DEQ works on more health based standards associated with permit applications. I anticipate that will take months or more than a year to result in any change. If DEQ can swoop in with temporary rules for glass manufacturers, you should do the same for the industrial air polluter in our neighborhood too.
748 748 Bill C.M. Welch bcmwelch@earthlink.net Northwest District Asociation Board Member Oregon I encourage the DEQ to adopt rules that limit metal emissions from glass manufactures and all the other factories in the city of Portland and the rest of the state. There are also suspicions that ESCO in Northwest Portland also emits a variety of metals into the air of my neigborborhood Northwest Portland. Please make these rule city wide or even state wide.
749 749 Heidi West h_a_west@comcast.net   OR Health must be prioritized above business. I stand with EPAC.    
750 750 Ted Whitney tr_whitney@yahoo.com   Oregon I am a resident of Portland and a glass artist who has been a customer of Bullseye Glass for the last 10 years. I am concerned with the poor state of Portland's air quality and I agree with the DEQ that immediate action must be taken to minimize the health impacts of emissions from art glass factories. I stand with the Eastside Portland Air Coalition and I agree with their criticisms of the proposed DEQ temporary rules. Having read the DEQ temporary rules document, I have the following comments and criticisms:
1) The DEQ rules are too narrow, in that they only address emissions from art glass factories in Portland. Rules should be applied to all factories that emit toxic heavy metals throughout the entire state of Oregon. At the very least, all glass factories in the state of Oregon should be subject to these rules. These rules also narrowly address emissions of three toxic metals (cadmium, arsenic, chromium(VI)), while failing to provide protection from another metal that was detected in high levels: nickel. The use of nickel should not be allowed in uncontrolled furnaces.
2) There are no penalties for businesses that violate the rules. The temporary rules should include strict penalties for non-compliance, including "cease and desist" shutdown orders for factories that violate the rules and standards multiple times.
3) There should be clear and understandable standards that define unsafe levels of toxic metals and other hazardous air pollutants (HAPs). These standards should be conservatively determined by the best available studies and knowledge of the potential for emissions to harm human health. To determine standards, DEQ should rely on information from a wide range of sources, including the US EPA, CDC, OSHA, and OHA, as well as the latest environmental research studies. "Conservative" to me means practicing the Precautionary Principal: If an action has a suspected risk of causing harm to the public or the environment, in the absence of scientific consensus, the burden of proof falls on those taking the action. In other words, public health should come first and, if there is any doubt about the harmfulness of a given HAP, it should not be allowed into the air where it can cause harm.
4) I would like to specifically address the use of chromium(III) and its potential to be converted into the dangerous chromium(VI). There have been arguments made by representatives of Bullseye Glass that their use of chromium(III) should not be restricted to controlled (filtered or bagged) furnaces. These arguments are based on the findings of Professor William C. LaCourse of Alfred University. His argument is that chromium(III), when used effectively and properly in glass furnaces, is melted in reductive conditions, thus minimizing the probability that chromium(III) will convert to chromium(VI). Conversion of chromium(III) to (VI) requires an oxidizing environment, which (he argues) does not happen if the furnace is operated properly. My argument is that this ignores what might be happening in the exhaust flue. The glass furnace is not a closed system, so some chromium(III) will be released into the exhaust flue. Inside this flue, especially near the top, chromium(III) can combine with oxygen under conditions which are still relatively hot and the result is that chromium(VI) will be released into the atmosphere outside the glass factory. There is at least one study documenting the conversion of chromium(III) to chromium(VI) at temperatures as low as 200C to 300C, temperatures that are very possible inside the exhaust flue of a furnace operating at 1300C (http://www.ncbi.nlm.nih.gov/pubmed/16297546). Professor LaCourse's own words are a reason for caution: "Note, that is does not mean that NO Cr+6 could be emitted from a stack...I cannot rule out the possibility that some of the Cr+3 entering the stack could be oxidized to Cr+6. " I urge the DEQ to require the use of controlled furnaces whenever chromium is combined with glass. Chromium(III) and chromium(VI) should NEVER be used in an uncontrolled furnace.
Thank you for considering my comments.
Respectfully yours,
Ted Whitney
751 751 Eric Long Eric@mves.us none Oregon If the business was in existence prior to the community that is allegedly affected, updating or relocating should be the responsibility of the allegedly affected residents.
752 752 andrew Lightcap lightcapa@yahoo.com an Oregon Citizen Oregon This is way more than an art glass company that has slipped through DEQ's poor and archaic air quality standards. For years I filed complaints about the toxic air my family and I endured while living in North Portland on the bluff by the University of Portland. The irony is not lost that when an issue came in in inner SE Portland that DEQ actaully tries to do something about it. When it rained in north Portland, the people/companies released their toxic air pollutants. When it was night time and/or the weekend, and they knew the DEQ employees were home and not doing any of the rare site visits, the polluters released their toxins into our air. These people know how to game the system and have been for decades to make DEQ look foolish.

As defenders of the public health, I implore DEQ to really and truly get a handle on air quality in Portland, which has some of the worst air quality in the USA in many measures. Step up and do something meaningful about this problem. The people are speaking to you. Its like we have the old 1960's era toxic Willamette river floating through our air and lungs. My two cats died of the same cancer within a year of each other and well before their time. They spent many days outside breathing this air. My neighbors got cancer. My solution was to move before my children got sick. It shouldn't have come to that.
753 753 Katharine Salzmann katharinesalzmann@gmail.com Ms. Inner SE Portland, OR I love living in a manufacturing town. I do not want to banish industry, nor do I think that would solve our pollution problems. However, 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 work in the health-care field and in order to maintain my state (OR) licensure I am required to stay current with advances and best practices in my field and am ethically obliged to "do no harm" because vulnerable human bodies are entrusted to my care. I believe that industries handling toxic materials that are potentially harmful to human health are similarly obliged to an equally rigorous level of care, caution, best practice and oversight. I would like to see that ethical obligation reflected and supported by the law. If smaller industries need financial help with compliance under stronger regulations, our legislators might consider offering tax credits or state/federally-managed low-interest loans. I am confident there are many creative, appropriate solutions to any financial burden stricter regulations might bring about. I am a 35-yr resident of SE Portland living .38 miles from Bullseye Glass Co.

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.
754 754 Kathryn Kendall kendallishere@gmail.com   OR I stand by the recommendations of Eastside Portland Air Coalition, co-authored with Mark Riskedahl and Chris Winter, and look forward to seeing these new, revised rules put into action.
755 755 Blake Dore blakedore@gmail.com   Oregon I stand with Eastside Portland Air Coalition.    
756 756 Blake Dore blakedore@gmail.com   Oregon I stand with Eastside Portland Air Coalition.    
757 757 Blake Dore blakedore@gmail.com   Oregon I stand with Eastside Portland Air Coalition.    
758 758 Blake Dore blakedore@gmail.com   Oregon I stand with Eastside Portland Air Coalition    
759 759 Tabitha Boschetti hitiddleyiti@gmail.com   Oregon I appreciate the drive to take provisional action on this very specific issue. However, I believe that this temporary rulemaking should be paired with an explicit, funded, commitment to a more comprehensive evaluation of the cumulative effect of air toxins and general air pollution in our urban areas. This commitment should include greater involvement of our most marginalized communities, striving toward environmental justice. It is not enough only to manage our environment and our health crisis by crisis.
760 760 Katie smith Smithkc1@klsoaps.com Resident Portland, Oregon Please see attached file. I stand with EPAC. Comment to DEQ.pdf https://data.oregon.gov/views/trwb-z8xe/files/30cbdd3b-01f6-4478-a752-442cf7465824
761 761 Sarah Milliron     Oregon I work for Bullseye. I am concerned for my health and also my friends and coworkers who live within the bubble and I've fought from the get go for stricter regulation and state of the art filtration systems. Emotions are running high creating a very polarizing situation but all can agree, we want cleaner air. The lack of accountability both from DEQ/OHA and glass manufacturers has been dismaying. With that being said, I truly believe glass manufacturers want to make a change. That being said, I believe the rules as written now will hinder rather than help. They are a stop gap instead of a long term plan. On one hand, they prohibit the use of chromium in either controlled or uncontrolled furnaces (what?) without proper testing (double what?), but they also don't define penalties for lack of use. They require filters and emission testing on cadmium but not nickel. These rules are also only applicable to glass makers. This is a hastily written rule, very much targeting the low hung fruit in an effort to quell public outrage that for all intents and purposes is fighting a bigger fight. Please utilize YOUR precautionary principle and do your due diligence before enacting these rules. As the queen Taylor Swift says, "band aids don't fix bullet holes."
762 762 Andy Kennedy playpurpose@yahoo.com   Oregon Tighten standards until we're SURE of health concerns raised by EPAC. Thank you.  
763 763 Katie powers katie.powers2@pcc.edu none Oregon i stand with eapc.    
764 764 Rebecca f moccasinshuffle@gmail.com   OR The human rights of our children have been mercilessly violated. Our neighbors and families have been permanently damaged by oversights that were purposefully fabricated. There is no profit nor material item that is worth trading our health and wellbeing for. If we wish to lead others by example, then new technologies should be applied that allow these manufacturers to create these items without the toxic pollution.
765 765 Sheryl Maloney sheryl.maloney@gmail.com Resident OR Dear EQC Commissioners,

Thank you for allowing public comment both at the last ECQ meetings 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 that the manufacturers and the global glass artists have about losing jobs and potentially an art form, I am unable to put their needs above the health of my family and neighbors.

The Oregon DEQ is supposed to be 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 and it is time for real change.

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 other 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 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 is regulated. 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 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 this 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. Don't let this opportunity pass.

In that spirit, I also urge you to consider other industries in all of Oregon that may be using heavy metals and toxics in during both your short and long-term rule-making process. There are so many sources that contribute to our dirty air and simply putting a cap on Bullseye’s operation is not a long-term or comprehensive solution that our community will stand by.

Our children are the best resource to be “Made in Oregon� and many, including my own, attend schools that are ranked in the bottom two percent in the nation for air quality. The time is now 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
766 766 Elizabeth Breitenstein lisabreitenstein@yahoo.com   Oregon The DEQ's emergency rules should cover not just glass factories but other polluters like ESCO and Precision Castparts. It's nice that some companies are voluntarily installing better pollution controls, but this should never have been voluntary. It should have been a rule long ago and it must become a rule effective immediately. No company should be allowed to profit at the expense of the health of the community.
These rules must have solid follow through to check air quality consistently as well as consequences for violation - serious consequences that are enough to motivate polluters to properly install and maintain pollution controls.

I support strong regulations for air quality.

Air emission enforcement should be based on air testing, which should occur often and in all neighborhoods.

Elizabeth Breitenstein, Portland Resident
767 767 Katharine Salzmann katharinesalzmann@gmail.com EPAC Portland, OR The Precautionary Principle. Please see attached document. Precautionary_Principle_031416.pdf https://data.oregon.gov/views/trwb-z8xe/files/321dc364-8803-4f73-ac05-c1d918c07ab3
768 768 Lisa   Brei7588@gmail.com   Oregon I support stronger regulations. I value human health and safety over pretty glass.  
769 769 Robert Bino bcbino@yahoo.com retiered Oregon I get mixed messages, One report is Bullseye is within specs. on there permits, and the local soil is OK to do gardening? Now DEQ said it is polluting. What is real hear? Can you E-Mail and tell me and or other people in the area, what the permit standards are and where Bullseye falls out of the standards? Your above comment, states; uncontrolled furnaces show metal concentrations at levels "that can" increase cancer and other health problems. And Bullseye "likely" may emit said heavy metals. So why not work with Bullseye and other art glass manufacturers to install scrubbers and such on there exhaust system. We don't need to run jobs to other states, or loos them all together. And Bullseye Glass is a provider of art glass the world over, and puts Portland and Seattle on a public stage in the world. Bob Bino
770 770 silvia levenson silvialevenson@gmail.com Artist Italy I am an artist based in Italy. I use Bullseye glass in my art work. At the moment I have a show in Murano Glass Museum and I just received a prize as international artist from the Insituto Veneto, Venice. I cannot make my work with other glass than Bullseye. I also teach in several workshops by using their glass.

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.

Respectfully,

silvia levenson
www.silvialevenson.com
771 771 ccc ccc       abc

123
   
772 772 Jeremy smith jsmith@mailismagic.com   OR Please amend the proposed temporary rules to require that all furnaces using any hazardous materials be fully filtered by a state of the art filtration system.

The current rules contain numerous loopholes, and seem tilted towards industry in may respects. Please tighten the language and reduce the terrible air pollution in Portland.

Thank you.
773 773 ccc ccc       This isa test    
774 774 Junji Miwa m-junji@jujo.net Jujo Co., Inc JAPAN We have worked with Bullseye glass company for more than 30 years and they are very reliable company. We buy their glass because their glass has such a great quality and we sell their glass well. We pay approximately $275,000 to $300,000 annually for their glass and earn about $521,000. If the regulation would be forced them to stop their production, we would loss that amount money and cause severe damage on our sales. If the regulation would be implemented based on the scientific data, that would be understandable; however, the scientific evidence shows no result of the sign that impacts on people's health. Then we wonder why the government needs the regulation for the products which does not have the impact against the health issue.

Please let them make their products that helps us to remiain the art glass business Japan. The suspension of their products impacts on even our business.
775 775 hisao nabete   Glass artist JAPAN I'm producing glass to a kiln work in Japan.
I use glass of Bulls eye company for glass production for 25 years.
I see glass of Bulls eye company worldwide and provide a stable supply relatively.
It's also high-quality.
Coloring of glass also is good and is my material very important to glass production.
The glass work with vivid color is being produced, so it's a problem this time.
The glass material will be the very important material.
At the top where enough study and environmental research were performed and discharge of a toxic substance was abolished, the one of the glass
I wish for production operation.
There are many glass authors with glass of Bulls eye company all over the world.
I'd like to ask you also not to stop a product line of Bulls eye company by all means for the author.
776 776 Eric Yore ericyore@hotmail.com   Oregon Please don't enforce rules based on public outcry. Let sense and science show the way.
Bullseye are a responsible Company and are pushing to do the right thing.
777 777 Laura Dunn Lauracdunn@gmail.com   Oregon I stand with EPAC. Close the loopholes and tighten clean air laws to protects oregon citizens.  
778 778 debbie Gilliam rapunzels34@yahoo.com   Oregon I live close to Bullseye glass. I am concerned about the heavy metals, I believe in basing my opinion on the facts.
I believe more research is needed before we blame and impact one particular business for all the pollutants. They are located in an industrial area with many business who also pollute.
The glass companies have been cooperative and are installing the needed filtration immediately. They were in compliance with current standards and have worked with the community to upgrade and address these issues. I don't believe it is fair to act in haste with out adequate study.
I believe the DEQ and other agencies should continue to monitor ALL the polluter in the area including the small glass companies and correct any issues that create an unhealthy environment.
To sum it up, more facts, less emotion.
779 779 Rachel Murfitt Remmurf@comcast.net   Oregon Let's raise our standards to those of Washington, at least. Now that hat we know what is being emitted, how could we even consider doing nothing?
780 780 Rachel Murfitt Remmurf@comcast.net   Oregon Let's raise our standards to those of Washington, at least. Now that hat we know what is being emitted, how could we even consider doing nothing?
781 781 Rachel Murfitt Remmurf@comcast.net   Oregon Let's raise our standards to those of Washington, at least. Now that hat we know what is being emitted, how could we even consider doing nothing?
782 782 John Zeigler Zigzeigler@copper.net Zeigler Stained Glass KENTUCKY please base any new regulations on established facts and not just on speculation.without these wonderful glasses I will be out of business.
783 783 Tom Musselwhite tom_m@q.com Trainsong Neighbors, Eugene Oregon The new millennium is witnessing increasing urbanization, more acceptance of anthropogenic impacts on climate and the environment, and continued economic stratification. At the same time our water, our air, and the land we live on are increasingly threatened , if not endangered, by our own waste. Oregonians everywhere depend upon the EQC and the DEQ to protect us; our land, our water, and our air. Please don't drop the ball on the urgent need to control metals emissions from small colored art glass manufacturing facilities.
784 784 Pam Isner isner001@hotmail.com Carolina Stained Glass NC 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.
785 785 Sebastian McGaw   Local Resident Oregon Having read through many of the comments below, I have a grave concern that the proposed rules are not ready for enactment. Key among my points of concern: I am given to understand that the rules are based upon the tons of glass produced, rather than the quantities of materials used. If our concern is about exposure to dangerous elements, such as arsenic and chromium, then the rules should focus on the amount of materials used that actually produce the toxic waste. The rules should directly regulate the quantities of elements used by the manufacturer, e.g., how many pounds or tons of arsenic (or whatever compound is used that contains the arsenic). Further, it appears that the rules would only affect the Portland area, and not the whole state. This seems to me to be of great concern. Air is not restricted by regional boundaries. The rules should be statewide. Finally, it seems that the rules do not apply to all sizes of manufacturer equally. This also seems to be an area that needs attention in the rules.. Please do not rush into regulation; it is clear to me that more time is needed, both for development of the rule set, as well as time for the public to digest and consider the outcome of the rules development. In the interim, all use of elements of concern should simply stop, until we know what the dangers truly are, and until we have put a set of rules in place that will effectively regulate the production of these hazards. Thank you very much for your thoughtful consideration of my input.
786 786 Dale brown dale.brown@normandale.edu MN Community College Minnesota We use Bullseye glass in a teaching environment & feel that they are a wonderful company on the leading edge of research & technology related to fused glass. We utilize Bullseye glass because of their technical expertise & overall concern for their employees & the environment.

These proposed temporary rules would adversely affect us, Bullseye employees etc., without improving the air quality in the area.

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.
787 787 Louise Cartledge l.cartledge@icloud.com   Western Australia Having followed the developments with great interest and concern, I believe that with the signing of the agreements with Uroboros Glass and Bullseye Glass Co and the adjustments that they are making towards limiting metal emissions, that the proposal to adopt temporary rules is shortsighted.

Further investigation should be sought and experts in the field of Art Glass Manufacture be contacted for their opinions eg: Dr. William LaCourse of Alfred University and other glass manufacturers in other countries eg UK.

This does not need to be a long drawn out process (over a period of months not years) and if the manufacturers are prepared to work with the DEQ, there should be some leeway given.
788 788 Brenna Sheridan lastbroadcastdesign@gmail.com   OR I'm writing because it is time to make air quality a priority in Portland, but that means we need local solutions for local problems. 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.
789 789 Nathan Sandberg nathansandberg@gmail.com Nathans LLC OR I beg you to not implement any rules, temporary or not, that cause these two small factories that support hundreds of local families and thousands of their customers families internationally to modify their current production schedule. Unless you have solid science to back up your claims you will be doing nothing but feeding the unfounded fear that has thus far driven this public campaign against the two (or more) factories. If DEQ didn't pay attention for 30 years, and levels aren't proven to be a problem how can another 6 months really matter? During which time you can gather actual scientific information and present it to the manufacturers and the public in a clear and understandable manner that makes us believe you know what you are talking about. Also please do something about the (lack of) zoning laws that allow residential neighborhoods, including daycare centers, to build next to a smokestack.
790 790 David Rael davidrael@hotmail.com   Oregon I have read both sides of this argument and feel that this temporary "solution" is nothing more than a political move by DEQ with inadequate evidence. Please allow Bullseye the opportunity to continue to remedy their process without this temporary ban. They are a vital part of my industry and I fully support their efforts going foreword.
791 791 Gina Murray casamurina@gmail.com Casamurina Studio NEW JERSEY
Bullseye glass has a long history of responsible operation. As a professional glass artist for over 15 years, 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.
792 792 Michael Freedman mr.mikefreedman@gmail.com Fused In Glass Florida We operate a small glass studio in South Florida. Our business relies on Bullseye and Uroboros glass for 100% of our sheet glass. The availability of this glass is critical to our business and if it were made unavailable we would not be able to operate. Yellows, greens and reds are 3 of the most popular colors our artists choose for their artwork. We ask that you please consider all the scientific evidence before shutting down the selected glass production. Such a move would be devastating to small business like ourselves.
Thank you,
Michael Freedman
Fused In Glass
Boynton Beach, FL
793 793 Cassie Weiss cweissphotography@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
794 794 Robert OShea thecolorsoftime@att.net SGAA Connecticut This is America, the country I love ,trust ,and defend. Uroboros and Bullseye have done the same for hundreds of years. We as Americans have the responsibility to pull together and help resolve these issues including the local and federal governments. We all need clean air and we have the resources to make it so. So let's help them not condemn them.
795 795 Tom Birch portlandho@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!
796 796 Judith Lieberman Judelieberman@gmail.com   Oregon Please put measures in place to reduce the harmful emissions to our air quality!  
797 797 Nanette Phillips nan@nan-art.com Nan Phillips Art Glass & Sculpture Texas The DEQ should NOT force a temporary shutdown of Bullseye Glass based on “possibly unsafe" levels of metals and unsubstantiated and unscientific findings such as “…are more likely than not...� These are unfair rulings and are not based in science or fact. Bullseye understands the public health concern and has already agreed to address the issues of protection WITHOUT being shut down, and is already in the process of installing baghouses on their furnaces. A temporary shutdown could easily lead to a permanent shutdown, not only for Bullseye, but for all of us who depend on Bullseye’s glass and glass products.
I am a glass artist, sculptor and glass teacher in Richardson (Dallas) Texas and depend almost exclusively on Bullseye’s glass and glass products (and some Uroboros glass) both to create my artwork and to sell to my fused glass students for their work. Glass is already an expensive product, and red colors are already unavailable. The costs of these environmental protection devices will of necessity be passed on to Bullseye’s consumers. DEQ’s forced shutdown would lead to even higher costs and unavailability of products, if their business is even able to survive the shutdown. If Bullseye shuts down, I also will be out of business, as I will not be able to create work to sell. Nor will I have glass for my students, and my teaching studio will close. The DEQ’s hand is far-reaching and potentially devastating.
I would not like to live near a manufacturer which produces toxic wastes, and I do have concerns for Portland’s residents. However, Bullseye has been in existence for 42 years and has already demonstrated its willingness install the protective equipment WITHOUT being shut down. Please DO NOT unfairly impose these measures on Bullseye and Uroboros glass manufacturers.


Nan Phillips
Art Glass & Sculpture
www.nan-art.com
nan@nan-art.com
972-238-5842
Past President, Texas Sculpture Association
Treasurer, Texas Jewish Arts Association
Advisory Board Member, Arts Incubator of Richardson
798 798 Rachel Hanes hanesian@gmail.com   OR - Oregon I live in Portland, which has a reputation as a green state but I have come to find has well over a dozen dangerous pollutants in its airshed. Arsenic, cadmium, and hexavalent chromium can be and often are emitted in art glass manufacturing is of particular concern to me as I live in the SE hotspot and have for over 20 years. Please take careful steps to regulate all toxic emissions from these smaller art glass operations, holding them to the same standards as Title 5 companies with bigger capacity. We need comprehensive air toxics regulation and reform, and this is a very important start. The Lane County local toxics authority is a great example of the careful, fact- and science-based approach we need so much here in Portland. I am also a Portland Public Schools teacher and too many of our PPS schools (Chapman, Abernethy, Sitton, James John and many others) are in the bottom 2% nationally for air quality due to unchecked industry and transportation pollution. Please put these vulnerable younger children's health first and limit emissions quickly across the board. Toxic air also impacts the health of staff at these schools. Many of us live in the cadmium and arsenic clouds emanating out from factories and railyards. Neighbors living near Precision Cast Parts have been fighting for clean air for years. We need your protection to begin cleaning up our air and take concrete steps towards real air toxics reform like our neighboring states, Washington and California. Thank you so much for the chance to comment. This is a historic moment to move forward on real reforms that immediately benefit public health.
Rachel Hanes
799 799 Robert OShea thecolorsoftime@att.net SGAA Connecticut This is America the country I love,trust and defend. Uroboros and Bullseye have done the same for hundreds of years. We as Americans have the responsibility to come together and help these companies resolve these problems,this includes the local and federal governments. We all need clean air and it is possible if we act like true Americans.
800 800 Sofia Jamison sofia@jamison.org   Oregon I stand with EPAC! I am so saddended to learn that Portland and Oregon has some of the most toxic air in the US! It was always my impression that we were a clean and thoughtful state, caring about the environment and sustainability, planting many trees each year (which I did my first two years living here in 2002-03), etc. This is UNACCEPTABLE! No more toxic air, for all of us but especially for our children and our elders. Please, do the right thing and make the right rules for Oregon businesses who put toxins into our environment.
801 801 John Nettleton jpn5710@yahoo.com   OR After review, we find the rule proposal 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.
802 802 Suzanne Sigafoos suzannesigafoos@gmail.com Eastside Portland Coalition, Neighbors for Clean Air Oregon I am a Southeastside Portlander who is proud to live in a place where manufacturing occurs, and in the case of Bullseye, a place where materials of great beauty are made. For the moment, I have great concerns for the health of the environment and for citizens of all ages who live and breathe here. I am convinced that there are workable and effective solutions for the problems Portland is facing with industrial polluntants showing up in our air and soil. Surely, in this lovely place that is known for "liveability" we can find a way to regulate industry so we can continue to thrive.

If smaller industries need financial help with compliance under stronger regulations, our legislators might consider offering tax credits or state/federally-managed low-interest loans. I feel confident there are many creative, appropriate solutions to any financial burden stricter regulations might bring about.

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.
803 803 Keith Lyon krlyon2@sbcglobal.net   WI As a glass artist and a chemist with 25+ years of R&D experince I stand behind Bullseye and the others that show Cr+6 is not an accidental byprodut of them producing their glass. I think Bullseye is doing the prudent thing in adding the bag houses even when the data does not show that is source of contamination.I think a long term solution should be developed but the science needs to be strong so the proper solution is implemented. The knee jerk reaction and temporay solutions does no one any good and will cause harm to the companies and employess involved.
Keith Lyon, PhD
804 804 Paige Schlupp Pschlupp@hotmail.com Brooklyn Action Corp (BAC) Oregon Increased air quality and health benefits for all or industry and profit? It's a no brainer. Clean air is something we all have a right to and should not be asked to sacrifice for the benefit of a few or fear of lost jobs. The negative health impacts are proven. An industry dying because we all weren't willing to compromise is not. They have been pursuing their interests at our expense and their profit for long enough. The glass industry and many other industries survive and thrive operating cleanly in other communities. Change is hard, but the time for this change is long overdue. Please use this opportunity to help us all live the healthiest and strongest lives possible and maximize the standards.
805 805 Alan Glickenhaus aglicken8401@msn.com   Oregon Dear DEQ,
As a resident of SE Portland, I am concerned about air quality in our neighborhoods. I urge more science to be heeded before any temporary measures are taken against Bullseye Glass. Up to this point, Bullseye has been in compliance with all existing environmental laws and they seem to be willing to make adjustments if the science and environmental impacts dictate it.
The company employs many people and it would be foolish to victimize them unfairly before a thorough scientific study has been completed... I also see many future lawsuits if they are 'villianized' without supporting evidence, further delaying clean air in our neighborhoods and slowing the entire process.
Please do not imposes any brash measures that single out Bullseye until scientific facts are available. It may pacify some to feel like they have identified the 'polluter', but it may not be the right perpetrator. We need hard data.
Thank you, Alan Glickenhaus
806 806 Maureen Aderman aderman5@aol.com The Glass Shack New York PLEASE READ!!! If you put these restrictions in place, you will not only destroy the two glass manufacturing businesses in Portland, you will put thousands of us artists around the country out of business. Our livelihoods depend on the glass that these companies produce. Please consider this seriously before you rush into a decision that will effectively destroy the businesses and jobs of thousands. Don't do it.
807 807 Derek Aderman glassshack@aol.com The Glass Shack New York
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.
808 808 Meg Thompson Megthompson@me.com   Oregon Please use your wisdom and power to protect the air quality for all the citizens of Oregon by expanding the glass air quality rules beyond Portland.

My 5-year-old granddaughter lives near Uroboros and has struggled with a deadly brain cancer for the past year. She is being tested by the OHSU oncologists for cadmium. While no direct cause can be made for any cancer diagnosis, the responsibility is yours: Oregon should not put our citizens health at risk.

The EQC and DEQ have failed to take a leadership role in our citizen concerns about air and drinking water pollution on the coast inflicted by the timber industry. Please use your positions of influence to make public health Oregon's number one priority, not industry profits.
Thank you;
Meg Eastman Thompson
809 809 Christina Larson dairymaiden123@yahoo.com   OR I stand with Eastside Portland Clean Air Coalition.    
810 810 Claudia Michel claude1252@yahoo.com   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.
811 811 debbie Maurina flatlatex@yahoo.com   Oregon This temporary rule will do nothing to fix the actual problems, will not prevent dangerous levels of material to be exhausted into the atmosphere, but will do severe harm to two small Portland businesses that provide for working families. Work with the glass manufacturers to develop real, long-term solutions to this issues. Don't succumb to knee-jerk, legislative responses that destroy the kind of local businesses that make Portland vibrant.
812 812 Patrice Schelkun info@americanglassguild.org American Glass Guild PA "The American Glass Guild, a non-profit association of glass artisans, conservators, historians and educators in the stained glass industry, fully supports Bullseye Glass and Uroboros Glass in their efforts to continue operations as responsible citizens of the social and business community of Portland, Oregon. Both companies share a long history of responsible operation.

We believe that regulatory decisions, while seemingly serving the welfare of citizens, must be based on science, not political issues or fear-mongering. 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. Failure of the DEQ to act responsibly in this matter could have a devastating effect on both the art glass industry as a whole and the local community in Portland."
813 813 Adriana Escobedo-Land landified@hotmail.com   Oregon I stand with EPAC.    
814 814 Sheryl Maloney sheryl.maloney@gmail.com Hot Spot Resident OR Please take a few minutes to comment on the Temporary rule that the DEQ is considering to limit heavy metal emissions from Glass manufacturers! Here is my comment below:

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 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 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
815 815 Terah Dolleman Terahjean@gmail.com EPAC Oregon EPAC! I stand with Eastside Portland Air Coalition    
816 816 Minna Shirley minnaming@gmail.com Bullseye Glass Company Oregon I have been an employee of Bullseye Glass for almost ten years. Many of my colleagues have worked in the neighborhood for at least as long, if not for decades more. The issue of air toxics in Portland is not a new one, but recent news has turned this newest reminder of our not-so-green city into a false dichotomy of Us vs. Them. We are all breathing the same air, we are all working to understand the information being meted out by authorities that we thought were looking out for us.

At first the information was alarming and grim - like being told not to eat from our home gardens - and as we split into our "us" and "them" sides to mobilize and try to deal with the repercussions of that new knowledge, we lost the opportunity to work together. Worse than that - subsequent information (follow up soil and air testing) got lost in the noise, pushed to the side and/or filtered through our new "us" vs. "them" lenses.

Ultimately, the DEQ, in conjunction with the OHA, has made a confusing decision to on the one hand announce no acute nor discernible long term health effects from the emissions perceived in our neighborhood; but on the other hand are pushing through a hastily assembled temporary rule that all but guarantees to hamstring one specific type of industry - ignoring all other contributing factors to our airshed.

I urge the EQC to consider the facts. I know that Bullseye is committed to installing filtration and honoring its suspension of cadmium use until said filtration is in place and has been proven to be effective.

The proposed temporary rule is mostly a shadow of what is already being done, with the added chromium III restriction. This restriction will do very little to improve my neighborhood's air, but it will severely impact Bullseye's ability to move forward with its plans for filtration.

Let's work toward permanent regulations that consider not only the science of what is in our air, but also the scale of all the contributing factors. From small CAGMs to the constant stream of diesel trucks, from looming concrete silos, to the massive factories that have faded into the background as the spotlight keeps shifting between "us" and "them".
817 817 Terrie Burdette pdxterrie@gmail.com   OR The temporary rules as I understand them are not rigorous enough to properly protect citizens. Why are the emissions of chromium 6 set at levels 20 times less protective than Oregon's established ambient benchmark? Why should we allow DEQ to unilaterally make decisions that affect human health, including for production to recommence, without adequate public involvement? Your track record does not build trust with the community and the temporary rules as stated will not sufficiently safeguard against ongoing racial injustice and environmental justice disparities caused by toxic air pollution, due to the narrow limiting of which facilities will be subject to this rule.
818 818 Mary Zodnik azurestainedglass@gmail.com AZURE Stained Glass Studio LLC OH We at Azure Studio stand by Bullseye Glass Company in asking for slow, careful and scientific determinations on health and safety issues. Reactionary drastic measures do not benefit anyone in the long term, and in the short term these actions only serve to puff the feathers of those posing as environmental protectionists.
819 819 Jay Moorman beauverre@fuse.net BeauVerre Riordan Studios Ohio 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.
820 820 Sherina McIntyre sherinamcintyre@gmail.com Kennedys Stained Glass MT As as stained glass worker, I certainly support needed changes IF and WHEN there is proof of the implied dangers. Of course we need to be cautious, but I believe we need alot more study on this situation before any drastic steps are taken.
821 821 Tali Grinshpan Taligd@gmail.com self CA I support Bullseye Glass Company and stand behind their claim to be allowed to continue manufacture ALL their glass.
I am a glass artist and depend on their supply to create my work and livelihood.
I know Bullseye Glass Company to be an honest and environmentally conscience company who cares deeply about the environment, its employees and customers.
I ask that you base your decision on scientific facts and not politics.
Thank you.
822 822 ruth Gundle ruth.gundle@icloud.com The Eighth Mountain Press OR It is time to shift the balance that has favored industry in the city limits and implement a truly health-based permitting and regulatory system. I have lived in inner SE Portland since 1975. 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.
823 823 Jill Inahara inahara.jill@deq.state.or.us DEQ OR This is a test to see if the online comment page is working.    
824 824 Juanita Remien jmremien@gmail.com   Oregon DEQ should adopt temporary rules that prohibit uncontrolled heavy metal emissions and not only fine, but suspend operations of such facilities who do not comply. I support the 99% filtration standard, but would like this to apply to Chromium III as well as Chromium VI. Permits for these facilities should be focused on protection of public health with measurable monitoring. Enforcement of rules is key.
825 825 Anna Noble marcheam@yahoo.com BeauVerre Riordan Studios Ohio 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.
Thank you.
826 826 Debora Coombs Dcoombs@myfairppint.net Coombs Criddle Associates Vermont Please do not impose temporary manufacturing restrictions on colored glass manufacture by Uroborus or Bullseye without further scientific evidence. I support all real environmental concerns in Oregon, nationwide and across the world and believe that solutions may swiftly be found if the companies in question are given the opportunity to do so. Please do not hamstring their efforts to do do. Please do not risk putting these companies out of business, making local people unemployed, and threatening the continuation of the stained glass industry.
I would be most grateful if my comments were to be read, digested and considered as part of today's deliberations. Your sincerely, Debora Coombs (802)423-5640
827 827 Tod Beall beallglass@verizon.net Beall Glass Studio Massachusetts 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.
Thank you,
Tod Beall
828 828 Michelle Smit     OR Please pass immediate rules and regulations to require all polluters, not just art glass manufacturers, to install filtration systems that will stop toxic metals and chemicals from being emitted into our air. You should require them to install state of the art filtration systems within a short time period, like 30 to 60 days, or halt production until these companies comply by install state of the art filtration systems or face a massive fine, how about $1,000,000. a day? The health of the people and environment should be your priority, over profits of these companies. I also implore you to monitor the air continually in our city. Please set up long term monitoring near industry knows to emit toxic metals and chemicals and take immediate action (within days) if monitors detect harmful emissions. The state and federal government should give these companies tax credits for updating their systems to protect the environment and the people. Don't settle for for minimum regulations. Set a historical precedent by making Portland's environment the best it can be by passing the most stringent environmental legislation and rulings possible.
829 829 sue teso sueteso@gmail.com   OR Clear air is our right. Your organization is the one appointed to make sure we have it. Your organization has failed. It is very simple, do your job. Protect us and our children.
830 830 Lia Boyarshinova boyarshinova.lia@deq.state.or.us DEQ Oregon this is test. d    
831 831 Robert Clapp profigliano1@yahoo.com Citizen OR I stand with EPAC. I believe manufacturing and residential life can co-exist in relative harmony--and more importantly, harmlessly. There are good people at the DEQ who want to be able to do their jobs. I believe we should let them. In this instance there seems to be a clear path forward--require emissions controls and monitor their effectiveness. IF they are ineffective, THEN seek by whatever means necessary to ensure that local residents do not have to worry about (for instance) neurotoxic pollutants in their air, on the food they grow, or in their children. And please, please ensure that whatever comes out of this is not guided by individuals with clear conflicts of interest . . . or deep political ambition.
832 832 James Lodwick nitchwick@comcast.net   Oregon I am writing regarding small glass manufacturing and air pollution. I am a former employee of Bullseye Glass Co. and current customer of theirs.

DEQ has an opportunity to create a positive public relations story for itself now. By supporting Bullseye’s emissions controls upgrade, the environment will improve and DEQ is shown as leading the way. However, the temporary rule being considered by DEQ could cripple Bullseye causing layoffs, or worse. If Bullseye goes out of business DEQ will be seen as improving the environment by killing a local, homegrown business that directly employs 150 people and indirectly many more---including my job.

Bullseye has a good track record regarding health and safety regulations. During my 26 year relationship with Bullseye, they have improved their safety practices as environmental regulations evolved.

Most importantly, I believe Bullseye Glass Co. has a company culture of doing what is right. Any implication that they have knowingly poisoned the environment is inconsistent with my knowledge of the owners and their employees.

In recent weeks Bullseye has demonstrated a strong willingness to upgrade their manufacturing processes with newer pollution control technology to improve their air quality discharges and meet DEQ’s requirements. They should be allowed to do this. Any DEQ actions that could result in layoffs at Bullseye due to loss of business are misguided.

Please support Bullseye as it becomes a model of best practices regarding emissions of heavy metals. Do not enact regulations that will cripple Bullseye’s ability to remain in business.

Make it a win/win/win for DEQ, Bullseye Glass, and the environment. That is a story that will enhance DEQ’s image.

Thank you.

Jim Lodwick
SE Portland
833 833 Meyer Goldstein goldstein.meyer@deq.state.or.us     Meyer's test    
834 834 Mary Kay Nitchie nitchwick@gmail.com   Oregon I believe Bullseye is doing the right thing for neighbors, and EQC, DEQ and the Office of the Governor should support Bullseye’s efforts by moving forward with an agreement, not with temporary rules. There is no imminent health and safety danger, and therefore, the conditions for temporary rules have not been met.

Since early February 2016, the reputation of Bullseye Glass Co. was severely damaged by the careless and unsubstantiated communications from DEQ, OHA and MCHD. The DEQ leaked air monitoring data with no associated testing protocol and insufficient context, and said that Bullseye was the source, without adequate explanation. The OHA stated that health benchmarks were exceeded, without explaining to all of us what health benchmarks mean. The MCHD warned people not to eat from their gardens, raising fears that later, after soil testing, turned out to be completely without foundation, and at the same time, implicated Bullseye without acknowledgement of other industries that currently and historically have contributed to pollution. Near Bullseye, these include metal recycling, plating, cement, diesel trucks and buses, the rail yards, and Tri-Met’s Orange Line construction, and residential wood-burning fireplaces, among others.

In my personal view, Bullseye is not fighting the neighbors. Bullseye is fighting to improve and survive while being hobbled from making half its product line, while investing in expensive filtration equipment. Not many small businesses could survive under those conditions. The enforcement of temporary rules would hobble Bullseye even further, which is totally unfair, because the same scrutiny and demands have not been applied to any other Portland businesses. Bullseye has demonstrated great motivation and progress toward adding filtration systems in the last 60 days, and the adoption of temporary rules will slow that down, if it doesn’t cause the business to fail. If Bullseye fails, that will have a domino effect on many other businesses, statewide, nationwide, and worldwide.

My confidence will not be restored in the Office of the Governor, the EQC, or in DEQ until DEQ starts working in good faith with Bullseye and with our neighbors. An agreement that can be adapted in response to new testing data will be more effective than the adoption of flawed temporary rules.

I have worked at Bullseye Glass Co. for over 25 years, breathing the same air as our closest neighbors. My comments are my personal opinions, and Bullseye Glass may or may not agree with me.
835 835 John Rose john.rose3@comcast.net Rose Design Studios Oregon I have been a customer of Bullseye Glass for well over 30 years. They are a company that can be trusted to abide by the law and regulations, and they are a socially conscious company that attempts to do right by their customers and their community, both in Portland and nationally.
I have reviewed the scientific study by Dr. William LaCourse of Alfred University, famous for its glass and ceramics programs, and find that the proposed DEQ regulatory requirements miss the ultimate mark, being lacking in accurate science and fact.
Please consider further study for sake of accurate science and to create a better-composed set of regulations.
Thank you,
John Rose
836 836 Suzanne Zalokar     Oregon I have lived 5 of the last 17 years on the edge of the toxic hotspot emitted from Bullseye Glass in SE Portland. I know one person personally (and two others through her who live within blocks of each other and live inside the toxic Bullseye hotspot). All three of them have pre menopausal breast cancer. This is horrifying, immoral and tragic.

Though I have no documented chronic health issues, I know, and know of, many people in this neighborhood who do. We may not be able to prove that the unregulated emissions of Bullseye glass or Precision Cast Parts, et.al. were the cause of these illnesses, but suffice it to say that at the very least, these toxic emissions likely exacerbated the severity of them.

Shame on all of the regulators, legislators and business people who looked the other way to straight up create regulatory loopholes to allow the emission of Lead, Fluoride, Arsenic, Nickel, Cadmium and Chromium III and Chromium VI (and who knows what else).

Until the operations at these facilities can be regulated to protect public health and safety, be continually monitored and be completely transparent with the public, there should be NO operations.

Until the emissions of all these operations can be filtered through an appropriate bag house, no stack should be emitting anything.

If that cannot be done with our current means and technologies, then we should stop the industrial processes that produce toxic heavy metal emissions. I can live with out colored glass, but I cannot live without my lungs.

The proposed temporary rules are a continuation of this mindset of government agencies serving the interests of business and disregarding the lives of humans.

You know this. Please do the right thing and be leaders in the fight for a fair, just and healthy world. It’s the only one we’ve got.
Public Comment.DEQ.pdf https://data.oregon.gov/views/trwb-z8xe/files/56bc5649-3e7b-43a2-960b-a8a0f28f8e20
837 837 Kathy Liska-Jackson kathy.liska.jackson@gmail.com Blooming Lily Glass MN I am writing to express my opinions on the DEQ’s implementation of regulations on the art glass manufacturers of Oregon, in particular Bullseye Glass in Portland. I am a self-employed artist working with glass and depend completely on Bullseye Glass as a supplier for the glass I use in my studio. Your proposed regulations, if implemented, would greatly effect, even destroy my business as I cannot get the materials I need anywhere else.
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 and urge you to get all the scientific facts and understand the impact these regulations would have. 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.� In face, DEQ’s and OHA’s own statements provide that the rule is not needed to prevent “serious prejudice to the public interest.�

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 that could destroy an industry with a cascading effect across the country and around the globe.
Sincerely,

Kathy Jackson
kathy.liska.jackson@gmail.com
838 838 Marilyn Shultz Mshultz@westerlook.com Glass artist Oregon I am a beginning glass artist. Bullseye glass is the only reliable fusing glass I use. The people who work work at Bullseye have been so helpful in helping me become a glass artist. I have been coming to Bullseye glass since 1995 with my father who believed in their glass and encouraged me to use their great quality glass
I strongly feel the temporary rule making regarding their use of Cr lll is not fair.
I am glad Bullseye is installing filter/scrubbers on the furnaces that produce the glass colors which use Cr lll.
Your rules are hastily adopted and do NOT take in to consideration the science. This is not Cr V being produced.
In addition, the neighborhood that Bullseye has been in for more than 20 years has a long history of manufacturing....not residences.
I suspect these heavy metals could have come from other sources.
Please do NOT let Oregon, Portland and me loose this unique resource!
Thank you, Marilyn K. Shultz
Will this be another great job of sending jobs to China????
Way to go government.
839 839 Meyer Goldstein goldstein.meyer@deq.state.or.us     test 2 3.30.16    
840 840 Joanna Neal joannaneal@rocketmail.com   Oregon The proposed temporary rules are a continuation of this mindset of government agencies serving the interests of business and disregarding the lives of humans.

You know this. Please do the right thing and be leaders in the fight for a fair, just and healthy world. It’s the only one we’ve got.
841 841 Elizabeth Gatti kittyrock@comcast.net Ms. Oregon I live in SE Portland and have been impacted by lax DEQ rules. I stand with EPAC!  
842 842 Sarah MCKENZIE JENNYREB@SPIRITONE.COM Portland citizen Oregon PLEASE DO YOUR JOB: PROTECT YOUR CITIZENS...NOW, NOT LATER.  
843 843 Brandie Centi bcd42992@gmail.com   Illinois      
844 844 Julia Jeffree julia.jeffree@gmail.com retired scientist and hobby glass worker UK   portland.docx https://data.oregon.gov/views/trwb-z8xe/files/fbdbb727-6bfc-4825-9b6a-c9a326b09b00
845 845 Briana Nicholson-Klingerman bnnk2013@u.northwestern.edu Clean Energy Works/Enhabit Oregon Hello,

It is your duty to protect the citizens of Portland and the surrounding metro area from being poisoned. Get this fixed before someone gets sick. It's not just the people, it's the earth. Stop poisoning the earth please.
846 846 Rhoda Baer rhoda@rhodabaer.com Glass artist Maryland There are many issues to consider. Please let DEQ and the Environmental Quality Commission know whether you agree with the points below, and let them know how you would be affected by the temporary or permanent loss of Bullseye’s products.

This is an improper use of temporary rule making. The Oregon Environmental Quality Commission should only consider a temporary rule when credible evidence demonstrates a rule is needed to prevent “serious prejudice to the public interest.� This is not the case here.

Hastily adopting temporary rules make it appear that agencies are being proactive, but these rules do not protect the public, and makes Bullseye a scapegoat. There is no evidence that emissions from the facility pose any acute health risk nor that Bullseye is fully responsible for the emissions, nor 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.

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.�

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. Bullseye will support that effort. 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.

With minor changes to correct scientific errors and omissions in the currently proposed rule, Bullseye Glass is willing to sign an agreement that achieves all of DEQ’s goals and allows DEQ and Bullseye to respond promptly to new factual information.

The haste to adopt technically flawed temporary rules makes it appear that Oregon is repressive to manufacturing businesses and does not care about jobs.

Oregon agencies should strive for proper and fair treatment of all parties, based on law, rather than responding to public concern resulting from sensational blog posts and test results with partial data and no peer review.

The health and safety of the community can be achieved without forcing these businesses to close.

If Bullseye Glass is forced to stop producing 50% of its glass products for 6 months, without regard to ongoing test results or added emission controls, Bullseye’s survival is at risk. We support an agreement that is similar to the temporary rules, but unlike the temporary rules, also allows DEQ and Bullseye to respond promptly to new factual information.

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.
847 847 Scott fernandez sltucino@gmail.com Eastside Portland Air Coalition Oregon To: Oregon DEQ - comments regarding Portland’s air
From: Scott Fernandez M.Sc. Biology chemistry/microbiology

Oregon has the third largest population at risk of excess cancer due to air pollution behind only California & New York. (USEPA National Air Toxics Assessment). 117 Oregon schools fall into the worst 10% nationally for exposure to industrial pollution. (USEPA).
Diesel particulate matter (from trucks, construction equipment and rail yards) is responsible for approximately 460 premature deaths a year in Oregon. That’s more than those who die from homicide and drunk driving, (USEPA) (Neighbors for Clean Air).
Oregon Department of Environmental Quality (DEQ) and city officials have known about these toxic and carcinogenic chemicals for over a decade.
It was testified at the Tubman School Town Hall that little had been done by officials to address the issue. State environmental regulators have been criticized since public disclosure of results February 3, eight months after learning about the heavy metal discoveries such as arsenic, then chromium, lead, and nickel in addition to cadmium.
Public health and well-being have been placed at high risk while state and city officials have done little to address these issues.
The most important policies not aggressively pursued by the state were the advancement of stronger air quality regulations. This would have allowed reducing, and eventually eliminating toxic chemicals through permitting and tightening filtration engineering improvements.
The EPA has recognized the “one size fits all� approach is outdated. In 2012 a Federal Register notice to California EPA provided a waiver as part of their State Implementation Plan (SIP) allowing stronger air quality standards; providing cleaner air by moving away from the one size fits all.
Revision of the Oregon State Implementation Plan and help from elected officials can move us into a direction of obtaining a waiver allowing tighter air quality regulations.
For this to happen, elected officials must hear community voices speaking up for healthy air quality.
City of Portland (Comprehensive Plan Update August 2015) and State of Oregon use “ambient benchmark concentration� as their “one size fits all� standard.
All ages of community members comingled together does not adequately provide meaningful individual specific risk assessments. The EPA Safe Drinking Water Act clearly and distinctly acknowledges differences between children and adults.
The state and the city ought to dismiss this “one size fits all� approach. Children are not smaller versions of adults. Children have developing immune, nerve, and bone systems much different than adults. Chemicals such as cadmium, lead, etc. can cross the placenta negatively impacting fetal development milestone processes. Chemicals can also be found in breast milk.
The chemicals chromium, cadmium and lead have been identified as metalloestrogens. These toxic and carcinogenic chemicals interfere with estrogen pathways and can be associated with breast cancer, etc.
The City of Portland and state officials need to stop industrial exposures of the heavy metals, fluorine, Volatile Organic Compounds, petroleum emissions, and other harmful air contaminants.
Residents have had enough of toxic and carcinogenic heavy metal chemical exposures, inadequate air filtration, information withheld from community, along with the uncertainty and deep concern for children’s health in the City of Portland and the State of Oregon.
Thanks to the US Forest Service for their efforts in identifying these toxic and carcinogenic chemicals.
Please write and enforce stricter pollution regulations.
Thank you
848 848 Jeanee Reichert Jeaneephil@peak.org   Oregon The first priority is the health of people living in the community and the second priority is maintaining a vibrant business community. Therefore, decisions need to be based on science not fear. Science will set these priorities clearly and objectively.
849 849 Bethany Elmer bethanyelmer@gmail.com Walk Rabbit Studio CA 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 the Bullseye 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.

Please allow Bullseye to test their baghouses!

Bullseye understands the public interest and supports stronger environmental standards for our industry. To that effect, the company has already begun the process of installing 99% efficient baghouses on furnaces that melt glasses with chromium, cadmium, and arsenic. Bullseye Glass and DEQ will test these filtration devices to make certain they operate correctly. My livelihood and other artists from around the world will be negatively by harsh unrealistic standards that are not scientifically based, but rather a false attempt to placate the misinformed public hysteria.
850 850 Lynn Latimer latimerglass2@gmail.com Latimer Glass Studio MA As a glass artist of 40 years, I implore you to make your decisions based on facts and science. We all want a healthy environment and we also want to support the employment of many artists and Bullseye employees. These two outcomes are not mutually exclusive. Bullseye Glass is willing to make changes and some are in the works but please don’t put us out of work and possibly risk the entire industry. Bullseye Glass is my only glass supplier; they make a unique glass and I am dependent on their glass for my livelihood.

Based on the information below I urge you to gather more information before acting in haste.

Thank you, Lynn Latimer, Latimer Glass Studio, artist

The Oregon Health Authority (OHA) and the Multnomah County Health Department have stated that there is no immediate health risk to our community.

"Scientific evidence clearly indicates our furnaces won’t turn Cr(III) into Cr(VI). If they did, our 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

Bullseye understands the public interest and supports stronger environmental standards for our industry. To that effect, the company has already begun the process of installing 99% efficient baghouses on furnaces that melt glasses with chromium. Bullseye Glass and DEQ will test these filtration devices to make certain they operate correctly."

If we are not allowed to use Cr (III), we can no longer make green glass. On top of our voluntary suspension of cadmium glass production until our baghouse is in place, this new limitation would eliminate 50% of our product line. It would result in employee layoffs, huge economic impacts to Bullseye and our worldwide customers, and could even drive us out of business.
851 851 BRENDA McIntyre brenda@cheekymonkeyglass.ca CHEEKY MONKEY GLASSWORKS NANAIMO, BC, CANADA I am writing in support of Bullseye Glass and Uroboros Glass. I have been following the issue of cadmium and chromium off gassing closely as it will very much impact my life and business here in Canada if those companies are made to suspend production of glasses containing those metals. It seems that the scientific information is not collaborating the stand the DEQ is taking by imposing these temporary rules. I very much hope you will reconsider this decision and get more research done before targeting such a narrow manufacturing market. On Vancouver Island there is a thriving stained glass community that depends on me and three other businesses to supply them with the wonderful glass produced in Portland. Not only will my family and my employees family be affected, but these other businesses as well as the many artists trying to make a living by selling there finished glass art. Please consider all of us before ruling against Bullseye and Uroborus!! Thank you for taking the time to read my comment and trying to understand how far reaching the effect of your ruling will be.

Sincerely, Brenda McIntyre.
852 852 Jerry Fotinatos jf@sgw.net Stained Glass Artisans Corp. NY Uroboros and Bullseye are very important manufacturers to stained glass artists around the world. If debilitating restrictions are placed on these small manufacturers it could cause catastrophic results to the art glass community. The environmental concerns are well justified, but should be scientifically proven before action is taken against these companies. If the concerns are justified, then gradual regulations should be implemented so as not to cripple these important manufacturers. Without these manufacturers, the art glass community would be put out of business, and the public deprived of beautiful art work for years to come.
853 853 Amy Provost amyprovost@gmail.com   Oregon Please consider legislation that will help industries make their processes healthier. I am a Portland resident and mother of a small child. I love Portland and the diversity of its commerce and industry and I believe there is a way to maintain that why keeping the air clean and healthy for our residents. 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
854 854           Just a reminder that your job as the Oregon DEQ is to protect the environment and health of the people of OREGON.

It's obvious from these comments that Bullseye has sent out a press release to their customers worldwide asking them to lobby for their glass.

Please value the health of the public over the pockets of industry and enact regulations that proactively protect Oregonians from known toxics.

I believe the strictest temporary regulations possible should be put in place, rather than gambling with people's health during the research process.

These regulations can be modified if comprehensive testing proves they are too restrictive. When dealing with known toxics isn't it better to err on the side of caution?
855 855 Grace Phillips Gdphill66@gmail.com Illinois state university Illinois Please reconsider this rule as it is falsely being imposed upon bullseye glass company. From my understanding, the scientific evidence shows that the making of their green glass color IS NOT harmful to the environment. Please take a closer look at how their glass is made. I'm a beloved costumer and would hate to see a brilliant company go under due to lack of research and understanding of how their product is made. Please contact them again, as they can provide the scientific evidence necessary to show that their product isn't harmful to the environment. Thank you
856 856 Maureen Melville Melvilleglauber@msn.com Melville Studio 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.
857 857 Cindy Young rocknrollschool@msn.com EPAC OR I stand with EPAC    
858 858 AA. Joshua Baker thevelowrench@gmial.com East Portland Air Coalition Oregon Whereas air testing conducted by the Oregon Department of Air Quality, in October 2015 and March 2016, in the vicinity of Bullseye Glass in Southeast Portland, has confirmed that the glass company was the likely source of high levels of heavy metals pollution, I expect the temporary rules to require the cessation of all dangerous toxic emissions effective immediately. All furnaces employed in the manufacture of colored art glass should be outfitted with state of the art baghouse filtration systems before the art glass companies are permitted to continue to manufacture using dangerous materials recognized to be harmful to human health. This expectation that city residents be protected from exposure to these incredibly high levels of carcinogenic heavy metals should not be in dispute. Up to now the safety of the public has come second to the industries that have been allowed to put them at risk. This is a shameful disrespect to the well being of the people of Portland. Benchmark levels adopted to regulate toxic emissions should be the lowest standards of any State rather than an average or an arbitrary level. The Multnomah river valley is prone to atmospheric inversions that trap air pollution which is why the need for lower benchmark standards than in other communities. Clearly outlined and strictly imposed penalties need to be written into the temporary rules in order to enforce the benchmark standards.
859 859 Neile Cooper neilec@mail.com   NEW JERSEY 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.
860 860 Linda Prinsen Lindaprinsen8@gmail.com Eastside Portland Air Coalition Oregon DEQ needs to Act on behalf of it's citizenry. I am VERY concerned about the air quality and the general pollution in Portland, especially because For 35 years I have live d less than one-half mile from Bullseye. PLEASE take this as a vote for STRICTER conditions.
861 861 Cara Humphries c_humphries@sbcglobal.net Cara Humphries Studio Missouri My name is Cara Humphries and I am a small art glass studio owner in Kansas City. I employee 3 people including myself.
I am concerned that my industry and 1st amendment rights are about to take a huge and unnecessary blow due in large part to our election year fear mongering and hysteria.
So I'd like to remind us all of some big picture facts.
American manufacturing and industry have been decimated over the last few decades.
One area where we are still working is in the fine arts. Here, in Kansas City we have numerous examples of how the arts industry has revitalized blighted urban areas or have kept people employed as other industries have moved over seas.
Uroborus and Bullseye are both examples of the fine art industry providing employment opportunities. In fact they support industry all over the country. I rely heavily on their product in large part because it is made in America where I know there are environmental and employment standards in place. It is distressing to me to think I may have to purchase product from areas of the world where it has been documented that the powers that be do not care what they are doing to their citizens, much less the global community.
Arts entrepreneurs here in Kansas City have always been progressive and responsive community leaders. Uroborous has shown similar responsiveness in voluntarily shutting down manufacturing to improve their emissions standards. This should be applauded and supported. Don't forget there is no documented scientific evidence supporting emissions concerns emanating from current manufacturing practices by these two companies.
The only reason to shut down their manufacturing is to cave to election year irrationality.
There are other big issues at stake here, free expression and religion. The arts have always been afforded protection by the federal courts as they are recognized bastions of our first amendment right to free expression.
Stained glass has the long and well documented history of being the preeminent form of the expression of religious and social themes. The proof of this is in almost every religious building on this country.
In allowing fear to override fact you will be responsible for the erosion of free expression, free religion, and American industry. Is this the history you want written about Oregon?
I implore you to take a deep breath, look at the facts, and remember you are about to play a significant role in some big picture issues. Make it a positive one.
Thank you for your thoughtful consideration,
Cara Humphries
Cara Humphries Studio L.L.C.
862 862 Nancy Merryman nmerryman@merrymanbarnesarchitects.com Oregon I love living in a manufacturing town. I do not want to banish industry, nor do I think that would solve our pollution problems. However, 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 would like to see that ethical obligation reflected and supported by the law. If smaller industries need financial help with compliance under stronger regulations, our legislators might consider offering tax credits or state/federally-managed low-interest loans. I am confident there are many creative, appropriate solutions to any financial burden stricter regulations might bring about. I am a 25-year resident of SE Portland living very close to Bullseye Glass Co.

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.
863 863           Protect the public, not polluters.    
864 864 Viki Keating viki@keatingproductions.com   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.
865 865 Ellen Hanley ellenpoppy@aol.com none Oregon Please make any future changes in air quality regulations based on firm, peer reviewed science and not on hysteria.  
866 866 Selma Craft selmafc@gmail.com   Oregon Thank you for allowing the opportunity to review and comment on the proposed temporary rule.

I fully support the Eastside Portland Air Coalition and the comments and proposals made by its members.

Sincerely,
Selma Craft
867 867           Just a reminder that your job as the Oregon DEQ is to protect the environment and health of the people of OREGON. It's obvious from these comments that Bullseye has sent out a press release to their customers worldwide asking them to lobby for their glass. Please value the health of the public over the pockets of industry and enact regulations that proactively protect Oregonians from known toxics. I believe the strictest temporary regulations possible should be put in place, rather than gambling with people's health during the research process. These regulations can be modified if comprehensive testing proves they are too restrictive. When dealing with known toxics isn't it better to err on the side of caution?
868 868           Just a reminder that your job as the Oregon DEQ is to protect the environment and health of the people of OREGON. It's obvious from these comments that Bullseye has sent out a press release to their customers worldwide asking them to lobby for their glass. Please value the health of the public over the pockets of industry and enact regulations that proactively protect Oregonians from known toxics. I believe the strictest temporary regulations possible should be put in place, rather than gambling with people's health during the research process. These regulations can be modified if comprehensive testing proves they are too restrictive. When dealing with known toxics isn't it better to err on the side of caution?
869 869 Renee Brachfeld kesem@verizon.net   District of Columbia I implore you not implement the proposed temporary rules limiting metals emissions from small colored art glass manufacturers. I am deeply concerned with environmental quality, and a lover of the Portland, Oregon, area. But these proposed temporary rules are not in any way helpful.

I am also a glass artist who uses Bullseye glass almost exclusively in my work. I understand that Bullseye Glass is already working closely with the environmental agencies to be sure that they are being good environmental citizens.

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.

Implementation of these rules will force Bullseye to severely curtail production, and to reduce its workforce if not to close its factory altogether. There is no critical health reason to implement these rules, and the lives of Oregon citizens will not in any way be improved.

Thank you for your willingness to consider reason.
870 870 Ana Helena DeCastro anahelena.lmt@gmail.com   OR I stand with EPAC.    
871 871 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.
872 872 Millie Wilson milliewilson48@gmail.com self TX this is a solid company and it has many customers who depend on the glass.  
873 873 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
874 874 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.
875 875 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!  
876 876 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
877 877 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.
878 878 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.
879 879 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.
880 880 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.
881 881 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
882 882 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.  
883 883 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.
884 884 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.
885 885 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
886 886 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.
887 887 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 "rights" when DEQ learns air quality is compromised.
888 888 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
889 889 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.
890 890 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.
891 891 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
892 892 Lauren Oliver   Resident Oregon I stand with EPAC    
893 893 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
894 894 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.
895 895 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.
896 896 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.
897 897 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.
898 898 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
899 899 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.
900 900 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.
901 901 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.
902 902 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.
903 903 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
904 904 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.
905 905 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.
906 906 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.
907 907 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.
908 908 Daisy Lemvke Daisylembke@gmail.com     I stand with east side air coalition!    
909 909 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.
910 910 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.
911 911 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
912 912 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
913 913 Jeanne deParrie-Turner jeannedeparrie@gmail.com   Oregon I stand with Eastside Portland Air Coalition.    
914 914 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.
915 915 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
916 916 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.â€� 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 seeâ€� approach to public health. Again, thank you for taking steps to improve our air quality.
917 917 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..
918 918 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.
919 919 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
920 920 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
921 921 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.
922 922 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.
923 923 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.
924 924 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.
925 925 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
926 926 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
927 927 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.
928 928 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.
929 929 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
930 930 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
931 931 Kerby Strom Kerbystrom@hotmail.com No affiliation Oregon Clean up the air! What are our tax dollars doing?    
932 932 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
933 933 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.
934 934 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.
935 935 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
936 936 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.
937 937 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.
938 938 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.
939 939 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
940 940 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
941 941   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.
942 942 Caten Layland     Oregon I stand with the Eastside Portland air coalition.    
943 943 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
944 944 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
945 945 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.
946 946 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.
947 947 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.
948 948 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.
949 949 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.
950 950 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.
951 951 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.  
952 952 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
953 953 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.
954 954 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
955 955 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 .
956 956 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.
957 957 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
958 958 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.
959 959 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.
960 960 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.
961 961 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.
962 962 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!
963 963 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.
964 964 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.
965 965 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
966 966 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!
967 967 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.
968 968 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.
969 969 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
970 970 Sally Sawyer Salsawtim@hotmail.com   Minnesota Rule is premature, discriminatory and more about PR than protecting public health.  
971 971 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.
972 972 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
973 973 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.
974 974 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.
975 975 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.
976 976 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.
977 977 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!
978 978 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.
979 979 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.
980 980 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.
981 981 Trisha Diaz trishadiaz83@gmail.com   Oregon I stand with EPAC    
982 982 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
983 983 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
984 984 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.
985 985 Merrilee Harrigan merrileeharrigan@yahoo.com JoyofGlass DC   letter to DEQ.docx https://data.oregon.gov/views/trwb-z8xe/files/72ee63d8-8421-4ec6-9248-0553597ab17f
986 986 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.
987 987 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
988 988 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.
989 989 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,�.
990 990 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.
991 991 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.
992 992 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.
993 993 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.
994 994 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).
995 995 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.
996 996 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.
997 997 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."
998 998 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
999 999 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.
1000 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.
1001 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
1002 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.
1003 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.
1004 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.
1005 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...
1006 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
1007 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.
1008 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
1009 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.
1010 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
1011 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
1012 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.
1013 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.
1014 1014 Joseph Witt Josephwitt@hotmail.com   Oregon I stand with EPAC.    
1015 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
1016 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.
1017 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
1018 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.
1019 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.
1020 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.
1021 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
1022 1022 Sarah Brostrom Litna_one@hotmail.com Portland State University Oregon      
1023 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.
1024 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.
1025 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.
1026 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
1027 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.
1028 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.
1029 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.
1030 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
1031 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.
1032 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.
1033 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
1034 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
1035 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.
1036 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.
1037 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.
1038 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
1039 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
1040 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.
1041 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.
1042 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.
1043 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.
1044 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.
1045 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.  
1046 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.
1047 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.
1048 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)
1049 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.
1050 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.
1051 1051 hazel Love Gmoo503@yahoo.com n/a OR Clean air is essential for quality life. Oregon can be a leader for our country.  
1052 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!!!
1053 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.
1054 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.
 
1055 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.
 
1056 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
1057 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.
1058 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.
1059 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
1060 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
1061 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!
1062 1062 Mike Freese mikefreese@aoi.org Associated Oregon Industries Oregon Please find attached AOI's Comment Letter.

Thank you.
   
1063 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.
1064 1064 shane mccoy shanemccoypdx@gmail.com   OR Please do something to help regulate these emissions. clean air!  
1065 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
1066 1066 Cindy Young rocknrollschool@msn.com EPAC OR I stand with EPAC!    
1067 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 .
1068 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
1069 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.
1070 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.
1071 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
1072 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
1073 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.  
1074 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.
1075 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
1076 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
1077 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!
1078 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.
1079 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.
1080 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
1081 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
1082 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
1083 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
1084 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.
1085 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.
1086 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!
1087 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
1088 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.
1089 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
1090 1090 Jennifer wietecki jhwietecki@icloud.com NA OR - Oregon I am attaching a letter that provides my comments to the proposed emergency rule.  
1091 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.
1092 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!  
1093 1093 Patricia Osborne posborne33@gmail.com   Oregon I stand with EPAC.    
1094 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!
1095 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.
1096 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.
1097 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
1098 1098 Graham Fox Princelyfox@gmail.com   OH Please keep making beautiful American opalescent glass.    
1099 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
1100 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.
1101 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
1102 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!
1103 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
1104 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.
1105 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
1106 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
1107 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.
1108 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.
1109 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

}
1110 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
1111 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.
1112 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.
1113 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.
1114 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
1115 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
1116 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 “passâ€� 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.
1117 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!
1118 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!
1119 1119 Sheryl Eckrich Sheryl@SherylEckrich.com   Oregon I stand with EPAC and Neighbors for Clean Air.    
1120 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.
1121 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
1122 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.
1123 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.
1124 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
1125 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.
1126 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.
1127 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.
1128 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.
1129 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.
1130 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
1131 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.
1132 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.
1133 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.
1134 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"
1135 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 .
1136 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
1137 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?
1138 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
1139 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.
1140 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 DEQ – 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.
1141 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.
1142 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.
1143 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.
1144 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.
1145 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.
1146 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.  
1147 1147 Ryan Malia ryanmalia@gmail.com   OR - Oregon I stand with EPAC. Businesses need to conform to pollution control standards.  
1148 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.
1149 1149 Rich Richards richrich@mailismagic.com   OR Almost at the end of the list of stuff to review! Good job!    
1150 1150 Ariel Malia arielmalia@gmail.com   Oregon I stand with EPAC. Businesses need to conform to pollution control standards.  
1151 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.
1152 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!
1153 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
1154 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.
1155 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
1156 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!
1157 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
1158 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.
1159 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  
1160 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.

Sheet1