Communication and Outreach Plan
Amendments to Oregon Administrative Rules affecting small-scale solid fuel boilers.
Timeline: March to December 2012
Outreach Team: Carrie Ann Capp (project lead), Rebecca Hillwig (small business assistance coordinator) Jerry Ebersole (air toxics specialist)
Objectives:
1. Identify those potentially affected and inform them of the rule requirements.
2. Provide guidance to DEQ staff and stakeholders on how to meet the rule requirements.
3. Clarify applicability of DEQ’s existing authority to require registration of small-scale solid fuel-fired boilers.
Background: In February of 2012, the EQC adopted rule amendments to exempt small-scale industrial, commercial, and institutional sold fuel-fired boilers from the Heat Smart rules if they obtain construction approval from DEQ and are subject to National Emission Standards for Hazardous Air Pollutants. These amendments allow for the sale and operation of such boilers in Oregon. The adopted rule amendments also clarify DEQ’s authority to require solid fuel boilers located at unpermitted facilities to register with DEQ upon written request, in order to verify compliance with applicable National Emissions Standards for Hazardous Air Pollutants and state visibility standards.
Audience: DEQ is still in the process of identifying businesses that may be affected by the NESHAP standards. Because the boilers affected by the rule amendments are not under air quality permits, the affected sources are not entered into our TRAACS database. DEQ HQ-AQ staff will work with DEQ regional staff, Regional Solutions Team members, the Oregon Department of Energy, the Boiler Codes Division and others to identify additional businesses and institutions not currently identified. DEQ will create a list of affected sources to contact and provide information and technical assistance to owners and operators in meeting the Notice to Construct and registration requirements.
Stakeholders and interested parties include:
• Industry: Businesses with small-scale solid fuel-fired boilers (those with maximum heat output capacities below 1 MMBtu/hr)
• Owners and operators of small-scale solid fuel-fired boilers located at institutional facilities
• Project developers interested in biomass development
• Organizations that assist entities pursuing biomass utilization
• The Governor’s Office
• Regional Solutions Team members
• Local government: Lane Regional Air Protection Agency
• Elected Officials
• Solid fuel-fired boiler manufacturers
Outreach:
Media: In March 2012, DEQ will post an update to the rulemaking webpage. The update will direct users to a new webpage that describes the rule changes affecting small-scale solid fuel-fired boilers and informs owners and operators of their obligations under the new rules.
Mailings:
To all stakeholders and interested parties: In March 2012, DEQ will send notice of the adopted rule amendments to all stakeholders and interested parties and direct them to DEQ’s website for more information.
To industry and institutions: In March 2012, DEQ will send information packages to potentially affected businesses. The package will include an overview of the rule changes; applicability summary with information to help sources determine whether they are affected by the rule amendments; and an explanation of how to obtain technical assistance from DEQ. The package will also direct users to a webpage dedicated to implementation of adopted rule amendments. The webpage will contain answers to frequently asked questions, factsheets, resource lists and links to the Notice to Construct and registration forms. The webpage will also describe how to obtain Construction Approval and how to register the boiler(s) with DEQ, if required. DEQ anticipates that there will be no negative fiscal and economic impacts as a result of the adopted rule amendments because there are no fees associated with either the Notice to Construct or registration processes. Because the electronic database will not be functional at the onset of implementation, DEQ will ask affected parties to fill out electronic NC and registration forms and submit them as PDF’s via email or fax.
Meetings and public hearings: DEQ will hold information sessions to inform stakeholders of the rule changes and requirements. DEQ will hold these in Klamath Falls, Bend, Medford and Portland in June 2012.
Follow up: In June 2012, DEQ will send a follow-up letter to the businesses and institutions that did not respond to the first mailing. As the department receives construction notification and registration forms from affected businesses and institutions, DEQ will create a list of affected facilities and enter the information into the database upon its completion. The attached table describes the timeline and staff persons responsible for each aspect of the communication and outreach plan.
Next steps: The following is a summary of implementation tasks (for more information, see the Implementation):
Outreach materials: The following informational materials will be developed for the program:
• Fact sheets
• Q & A
• Talking points (for internal and external audiences)
• Webpage content
Mailings to affected boiler owners and operators: Outreach materials developed for this rulemaking will be disseminated to all potentially affected parties identified through the scoping process. Information included will cover:
• New rule amendments
• Who’s affected
• Obligations of affected parties
• Action Items and Due Dates
IMD for Regional Permitting Staff: At the annual Inspector’s Forum in May 2012, DEQ will present an IMD on how to evaluate Notice to Construct applications and approve construction of small-scale solid fuel-fired boilers. The IMD will cover the following topics:
• Criteria to consider when determining whether to approve an NC for unpermitted commercial, industrial and institutional solid fuel boilers
◦ Proximity to schools, stack height, fuel type and quantity, etc.
• How to determine which regulations are applicable
• How to determine if source testing is needed
◦ Test Methods
• How to determine if registration should be a stipulation of NC approval
• How to document decisions
• Information to disseminate regarding how to conduct NESHAP tune-ups
Online tool:
• Work with BSD to design and develop database for NC and registration (or use TRAACS?)
• Budget for database design and development
• Fillable forms (for interim use before database development)
Webpage:
• Content Development
• Background
• Links
◦ Fact sheets
◦ Area Source NESHAP Page crosslink
◦ Electronic forms
▪ NC
▪ Registration
• Rulemaking documents
• Notice to Construct /Registration Tool
• Electronic Forms (fillable)
◦ NC
◦ Registration
Resource Lists
• Tune-up specialists
• Source Testers
• Boiler inspectors
• Boiler maintenance and repair workers/companies
Timelines: Education and outreach materials will be developed in the following order:
• Information:
◦ Forms
◦ Factsheets
◦ Flowchart
◦ Resource Lists
• Webpage
• Mailings to affected boiler owners and operators
• Guidance for Regional Permitting Staff
• NC and Registration
◦ Forms
◦ Online tool/web interface
Roll-out of outreach efforts will occur in the order described below:
• Informational website online
• Guidance for Regional Permitting Staff presented at Inspector’s Forum
• Mailings to affected boilers
• Presentations to affected and interested parties (statewide?)
Note: The order of the task lists above does not reflect priority. Some tasks may overlap or need to be accomplished simultaneously.
ccapp, 2012-03-13T17:42:00Z
End date?
ccapp, 2012-03-13T17:42:00Z
It this true?
ccapp, 2012-03-13T17:42:00Z
AND TO OTHERS?
ccapp, 2012-03-13T17:42:00Z
Pros and cons of mailings vs emails
ccapp, 2012-03-13T17:42:00Z
Budget?
ccapp, 2012-03-13T17:42:00Z
EMMA: Do we want to make this option availale? Will this interfere with forms being fillable and easy data entry/reduced enty error on our end? Would we want to make fax an option only while paper forms are used, and not offer it when online tool is available? Risk in changing midstream?
ccapp, 2012-03-13T17:42:00Z
OTHERS? DATE?
ccapp, 2012-03-13T17:42:00Z
More logical to hold after inspector’s forum?
ccapp, 2012-03-13T17:42:00Z
DATE?
ccapp, 2012-03-13T17:42:00Z
Rebecca – per TR
ccapp, 2012-03-13T17:42:00Z
OCO and Regional Review
ccapp, 2012-03-13T17:42:00Z
Rebecca – per TR
ccapp, 2012-03-13T17:42:00Z
Use Georges suggested rule language
ccapp, 2012-03-13T17:42:00Z
Do we mean approval to operate or to construct, or both?
ccapp, 2012-03-13T17:42:00Z
• With disclaimers – may not catch all –to be included contact DEQ- this list does not represent endorsement or assurance of quality…
ccapp, 2012-03-13T17:42:00Z
create with disclaimer, OR - do boiler assoc or boiler codes division have lists we could refer to?