June 26, 2022 - Thank you for the opportunity to comment on the petition to amend OAR 250-010-0120 with regard to noise from boats. Many of my constituents have contacted me with serious concerns around the proposed rule changes as outlined in the petition. After listening to their feedback and carefully reviewing the proposed changes, I am writing to oppose the petition – specifically the new Narrative Standards - and urge the Oregon State Marine Board to permanently adopt a 75 decibel shoreline limit instead.
Limiting noise exposure on our waterways is important to preserving a healthy and peaceful environment where all Oregonians can recreate safely and responsibly. Reducing our shoreline decibel limit from 84 to 75 decibels is a positive change that will ensure all Oregonians can enjoy our waterways and shorelines. This level is also widely recognized by leading boating associations and is the standard that most western states have chosen to adopt.
This new 75 decibel limit is sufficient to regulate noise on Oregon’s waterways. The petition, however, proposes the adoption of “Narrative Standards” which bring a whole new level of subjectivity to enforcement. This approach is simply not appropriate. Such narrative standards will take what would otherwise be a clear, objective standard of 75 decibels and leave boaters open to unnecessary stops and unfair citations based solely on the discretion of individual officers.
These narrative standards threaten to undermine the 75 decibel limit and will force law enforcement officers to spend valuable time and resources responding to complaints based solely on the opinions of individual waterfront homeowners. Our law enforcement officers are already stretched thin and should be focused on their critical mission of safety and life preservation. Oregon’s waterway policies should favor the public, not those who choose to live on busy waterways. The rules proposed by this petition will unfairly target boaters and personal watercraft users – the vast majority of whom are using our waterways safely and responsibly.
In conclusion, I urge the Oregon State Marine Board to reject the petition in favor of adopting a permanent 75 decibel shoreline limit instead. Thank you for your consideration.
State Representative - Oregon House District 40