Andy Ginsburg
Air Quality Administrator
Oregon Department of Environmental Quality
ginsburg.andy@deq.state.or.us
503/229-5397

-----Original Message-----
From: MCALLISTER Larry
Sent: Tuesday, February 26, 2008 5:21 PM
To: GINSBURG Andy
Subject: RE: EQC adopts change in rulemaking procedure

Thanks Andy for spotlighting my effort.  It is appreciated and everyone likes to be acknowledged.  It has been a little challenging moving two different rulemakings through the process at once.  Thank you.

 

The truth is this rulemaking would not have happened without your guidance.  You likely developed that portion of SB107 language, I know you promoted this rulemaking before the EMT, wrote the first draft of the proposed rule amendments, produced a response to Donna's comment during the rule's public comment period and then really answered some good questions at the EQC.  So thank you for the effort you made to get these changes adopted.

And thank you also (it is my experience) that you frequently highlight the work of others here at DEQ and seldom acknowledge yourself in public.

So thank you Andy.

 

Larry

 

-----Original Message-----
From: GINSBURG Andy
Sent: Friday, February 22, 2008 12:56 PM
To: (All DEQ) staff Statewide
Subject: EQC adopts change in rulemaking procedure

Thanks to great work by Larry McAllister, EQC has adopted changes to Division 11 that should make all DEQ rule writers smile. 

 

The changes implement SB 107, which required us to disclose any alternatives considered when we adopt a requirement that is "in addition" to a federal requirement.  Larry, with the assistance of the Program rule coordinators, took the opportunity to streamline the existing rulemaking form for disclosing the relationship between a proposed rule and applicable federal requirements, boiling the form down from 11 questions to three.  The new form applies to all DEQ rulemaking.  In addition, the rule change provides an opportunity for a hearing before the EQC under certain circumstances when we propose rules that impact air quality Title V permittees.

 

Rule writers who have rules that are about to go out for public notice should check with your program rule coordinator or Larry to determine if you need to use the new form.

 

Thanks.

 

Andy

Andy Ginsburg
Air Quality Administrator
Oregon Department of Environmental Quality
ginsburg.andy@deq.state.or.us
503/229-5397