A	B	C	D	E	F	G
1	First Name	Last Name	Email Address	Organization	State	Comment	Additional Document
2	a	b	ab@ab.com	ab	or	ab
3	Mark	Sytsma	sytsmam@pdx.edu	Portland State University	OR	Thank you for the opportunity to comment on DEQ rulemaking on ballast water management. I worked with DEQ in development of the ballast water management program and assisted in its implementation in the early years of the program, prior to DEQ acquiring adequate staffing. I served on the advisory committee for development of the current language, and I have chaired the STAIS since its inception. I support the proposed exchange plus treatment recommendation, however, I believe that the 18 ppt threshold for this treatment is arbitrary and fails to adequately protect Oregon’s water resources from invasive species. I recommend the more protective approach used by EPA for the Great Lakes other states, arguably with less biologically and culturally important freshwater resources, that requires exchange plus treatment for ALL ballast water prior to discharge. Such a requirement would be more protective for Oregon than the current rule. In addition, the 18 ppt threshold complicates shipboard ballast water management by requiring the ship operator to measure salinity prior to making a decision on how to manage ballast; requiring exchange plus treatment for ALL ballast water is a much simpler and more protective approach.
4	Doug	Heiken	dh@oregonwild.org	Oregon Wild	OREGON	Please accept the following comments on behalf of 15,000 members and supporters of Oregon Wild's mission to protect and restore Oregon's wildlands, wildlife, and waters. The stated purpose of the rules is "to prevent the discharge of ballast water that represents a high-risk for the transport and release of aquatic invasive species." We feel this purpose is too narrow. Oregon's aquatic ecosystems are too valuable and too vulnerable for these rules to address just "high risk" situations. We urge DEQ to be more risk averse and strive to control all substantial risks. It makes sense to require exchange plus treatment for ALL ballast water. It is a much simpler and more protective approach. This approach has worked in other jurisdictions.
5	Nicole	Dobroski	nicole.dobroski@slc.ca.gov	California State Lands Commission	California		OregonComments_25May2016.pdf
6	Kate	Mickelson	kate@crsoa.net	American Waterways Operators	Oregon	For the last several years, the American Waterways Operators, the Columbia River Steamship Operators’ Association, the Oregon Public Ports Association, the Port of Portland, Sause Bros., and the Western States Petroleum Association have worked together with DEQ and other stakeholders to provide technical understanding and perspective to the development and refinement of Oregon’s ballast water rules.  We appreciate DEQ’s willingness to work with us throughout this process and we look forward to continuing this collaborative effort moving forward.   The maritime community recognizes the value and importance of the work being done by DEQ’s Ballast Water Management program to protect Oregon waterways from the introduction of non-indigenous aquatic invasive species.   We continue to support DEQ in these efforts and would like to provide the attached comments to the proposed revisions to the Oregon ballast water management regulations (OAR 340-143) your consideration.