From: WILES Wendy

Sent: Thu Jan 03 13:21:18 2013

To: FULLER Brian

Subject: RE: Draft reply to Mary Sue Gilliland comments on CT rules

Importance: Normal

Thanks.

From: FULLER Brian

Sent: Thursday, January 03, 2013 12:58 PM

To: WILES Wendy

Subject: RE: Draft reply to Mary Sue Gilliland comments on CT rules

I think they addressed her concerns, some of our responses she was OK with and some she still had concerns about.

I think her main concern remains over who determines what is recyclable. She also mentioned concern about the 2050 vision, specifically P3c:

c. Evaluate legislation, other authority, or other program

approaches to direct materials to their highest and best use

(e.g. limit feedstock sent to energy recovery and conversion technology facilities to non-recyclable material, as appropriate; send used petroleum products to their highest and best use; improve collection and processing to maintain the high value of

the material collected).

From: WILES Wendy

Sent: Thursday, January 03, 2013 11:35 AM

To: FULLER Brian

Subject: RE: Draft reply to Mary Sue Gilliland comments on CT rules

Do you know if our responses to Mary Sue’s comments addressed her concerns?

From: FULLER Brian

Sent: Wednesday, December 05, 2012 10:42 AM

To: WILES Wendy

Subject: FW: Draft reply to Mary Sue Gilliland comments on CT rules

From: LUMPER Bruce

Sent: Tuesday, December 04, 2012 2:27 PM

To: SPENDELOW Peter H

Cc: LUMPER Bruce; PICKERELL Loretta; RAWSON Stephanie; BARROWS Bob; FULLER Brian

Subject: Draft reply to Mary Sue Gilliland comments on CT rules

Hi Peter,

Nice work on the draft reply to Mary Sue’s comments.

I have a couple of very minor suggested edits.

In addition, I think we should add some language to the final document offering to discuss our response with Mary Sue – on the phone or in person.

Sincerely,

Bruce

From: SPENDELOW Peter H

Sent: Monday, December 03, 2012 9:59 PM

To: BARROWS Bob; FULLER Brian

Cc: LUMPER Bruce; PICKERELL Loretta; RAWSON Stephanie

Subject: Draft reply to Mary Sue Gilliland comments on CT rules

Hi Brian, Bob, and all,

I’ve drafted a proposed response to the comments by Mary Sue. I think we should make at least one change in the rules based on her comments. One of her requests was actually dealt with in a different subsection of the same rule, dealing with material separated by a dirty MRF for recycling. Most of her other comments were just (pointed) questions on why we changed certain requirements, but did not give any particular argument as to why we shouldn’t make the changes. On the exemption section where facilities send off as residue less than 10% of the weight of their incoming feedstock could potentially be exempt, Mary Sue suggested raising the percent to 20% “to deal more effectively with MRF plastic.” I’m uncomfortable allowing that much garbage to go into a pyrolysis facility without requiring some sort of permit so we can better examine the issues at the facility.

A copy of the draft response is attached, and is also included in Section 5 Public Comments on the SharePoint site.

Peter Spendelow

Oregon Department of Environmental Quality

503-229-5253