From: MCALLISTER Larry
Sent: Thu Jun 25 23:26:54 2009
To: VERNON Pat; BELYEA David; KNUDSEN Larry
Bcc: MCALLISTER Larry
Subject: draft SRF rule review
Importance: Normal
Attachments: rulemakingannouncement.docx; NoticeWithHearing.doc; LandUseEvalStmt.doc; Relationship to Federal Requirements.doc; StmtNeedFiscal.doc; 6-26 draft Permanent rules.docx; Pat, Dave and Larry K. Thank you for taking the time to review the attached public notice documents for the CWSRF permanent rulemaking. As you know, the EQC adopted temporary rule revisions in April which made DEQ eligible to accept an allocation by EPA of $44 million in American Recovery and Reinvestment Act funds. The temporary rules expire in late October (180 days). The attached documents make up the public notice package for the permanent CWSRF rules intended to replace the temporary rules. This request for your review is the preliminary review. I will incorporate your combined edits and send the package out again for a second, concurrence review. Attached are the following 6 documents: - Rulemaking Announcement -Please review for clarity and completeness. - Notice with Hearing - Larry K. please review citations for accuracy. Dave and Pat please review document for understanding. Note: the locations for 2 of the hearings are still being arranged, as is the email mailbox for receiving comments from the public. Also, this document indicates we are amending 3 rules and adopting 6 new rules. I have intentionally not attached the 3 rules being amended (one word is being changed in each of these rules!) - Land Use Evaluation Statement - This document is straight-forward. Please review for understanding and clarity. - Relationship to Federal Requirements - The proposed rules do not differ from Federal requirements. We made a point of indicating that both the CWA and ARRA allow states flexibility in implementing the federal requirements. Although Oregon's CWSRF program is clearly aligned with the federal requirements, aspects within the program differ from what other states might implement. Review for clarity. - Fiscal Statement - Please review for understanding and completeness. - Draft rules - Please review for understanding and program implementation. Larry K. please review changes in relationship to existing temporary rules. I would appreciate your comments by email before we start the Fourth of July weekend. The concurrence review is scheduled for the second week in July. Thanks and call me at 503 229-6412 with any questions, Larry M.