June 21, 2006

Jerry Ebersole

Oregon DEQ, Air Quality Division

811 SW 6^th Avenue

Portland, Oregon 97204

Re: Clean Air Mercury Rule

Dear Mr. Ebersole:

The Oregon Center for Environmental Health appreciates the opportunity to comment on the proposal to adopt the new federal standards for mercury emissions. The Center would like to go on record opposing the current proposal before the EQC to adopt new federal regulations under the Clean Air Mercury Rule (CAMR) and asks that these comments be entered into the permanent record for these proceedings.

Mercury is a hazardous air pollutant that has built up in the environment to the point that it is having profound and long-lasting effects on the viable reproduction of humans and wildlife. Many of our own state’s rivers and lakes are home to fish that are too contaminated with mercury to be safe for consumption by children and women of child bearing age. Fish consumption warnings at the federal level for tuna and other long-lived fish speak to the degradation of our oceans world-wide from mercury poisoning.

To address this issue, the Center has worked for the past five years through the national Health Care Without Harm Campaign to virtually eliminate mercury in the hospital sector. Our success has been rapid and comprehensive because the industry, under their mandate to “first do no harm”, has cooperated fully with the campaign’s goals to eliminate mercury emissions from hospitals by 2005.

Portland General Electric also has stated publicly that they want to be good corporate partners in protecting public health and the environment. In order to fulfill that pledge, the company must take steps that reach beyond the CAMR and they must do it immediately.

We are calling upon DEQ to respond to public concern and implement the Model Rule proposed by the State and Territorial Air Pollution Program Administrators (STAPPA) and Association of Local Air Pollution Control Officials (ALAPCO). We agree with the STAPPA and ALAPCO that the EPA approach is far less protective of public health than it should be and that controls and resulting mercury emission reductions are achievable now.

The Model Rule spells out for the agency how to achieve 90-95% reduction rates within the next five and half years. The environmental and public health crisis we are currently facing from this toxin demands action at this level. It is our sincere hope that the recommendations from our organization, the other members of the Columbia Clean Air Alliance, and the public at large are adopted during this public outreach process.

Thank you again for the opportunity to comment.

Sincerely,

Jane Harris

Executive Director