| 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. |
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| 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. |
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| 5 | Nicole | Dobroski | nicole.dobroski@slc.ca.gov | California State Lands Commission | California | OregonComments_25May2016.pdf | |
| 6 | Allen | Pleus | allen.pleus@dfw.wa.gov | WDFW | Washington | WDFW supports this rulemaking and recommends a few technical edits to ensure future regulatory consistency between our states. One of two files attached. | vanden Hooff 6.17.16 Comments on Ballast Water Rulemaking.pdf |
| 7 | Allen | Pleus | allen.pleus@dfw.wa.gov | WDFW | Washington | WDFW supports this rulemaking and recommends a few technical edits to ensure future regulatory consistency between our states. Two of two files attached. | OARS 340_143 WDFW tech comments 062016.pdf |
| 8 | Debrah | Marriott | DMarriott@estuarypartnership.org | Lower Columbia Estuary Partnership | Oregon | ||
| 9 | Amanda | Hanson | Comment attachment submitted on behalf of Amanda Hanson and Lower Columbia Estuary Partnership by Meyer Goldstein, DEQ | C:\Users\mgoldst\Desktop\Comments on Ballast Water Rulemaking 7 2016.pdf | |||
| 10 | Kate | Mickelson | kate@crsoa.net | CR Steamship Operators Assn | Oregon | Ballast Water Comment Letter_052416.pdf | |
| 11 | Kate | Mickelson | kate@crsoa.net | CR Steamship Operators Assn | Oregon | Ballast Water Comment Letter_070816.pdf | |
| 12 | Kim | Cox | kim.cox@portlandoregon.gov | Portland Bureau of Environmental Services | Oregon | Please see the attached letter. | BES Comment Letter to DEQ_Proposed Ballast Water Rule_7-7-16_Final.docx.pdf |