B	C	D	E	F	G	H	I	J	K	L	M	N	O	P	Q	R	S	T	U	V	W	X	Y	Z	AA
1
2			DEQ Rulemaking								Tuesday, September 30, 2025
3										Workbook Summary
4			Create major modification fees for municipal stormwater phase 1 and underground injection control permits.
5			Surface Water Mgmt. Section - water quality
6			Brief description of rule proposal					Worksheets				Do nothing severity rating
7			Create major modification fees for municipal stormwater phase 1 and underground injection control permits. Currently, major modification fees do not exist for MS4 phase 1 and UIC permits. The major modification fees are proposed in an effort to recover costs associated with future major modification requests. DEQ is proposing major modification fees of $8,746 for MS4 phase 1 permits and $4,971 for UIC permits.					1	Warm up
8								2	Basics				Risk rating low → high
9								3	Stakeholders				1	2	3	4	5	6	7	8	9	10
10								4	Program			1	1	2	3	4	5	6	7	8	9	10
11								5	Environmental			0	1	2	3	4	5	6	7	8	9	10
12								6	Timing				1	2	3	4	5	6	7	8	9	10
13								7	Financial			1	1	2	3	4	5	6	7	8	9	10
14								8	Legal			0	1	2	3	4	5	6	7	8	9	10
15								9	Technical				1	2	3	4	5	6	7	8	9	10
16								10	Policy				1	2	3	4	5	6	7	8	9	10
17								11	Political				1	2	3	4	5	6	7	8	9	10
18								12	Implementation				1	2	3	4	5	6	7	8	9	10
19
20		Schedule						legislative session
21
22			2012				2013				2014
23			Q1	Q2	Q3	Q4	Q1	Q2	Q3	Q4	Q1	Q2	Q3				Q4
24						<Start	---	---	Effective>
25							<AdvCom>
26							<Notice>
27								EQC
28		0	Environmental					The proposed rules involve
29			Alignment					Compliance			0	not involved
30			Natural Step conditions				0	Penalties			0	not involved
31			EPA Strategic Plan actions				0	Permits, certifications			6	involved, not new or expanded
32			Reach	Statewide				Fees			5	establish new fees, require DAS approval
33			Correlation					State Implementation Plan			0	not involved
34			Not directly					Land use rules			7	involved
35
36			Ideal				Reality				Consequences
37			What we want to happen.				What we are trying to change.				What will happen if we don't change.
38			EQC adopts fees with little to no stakeholder opposition.				Major modification fees do not exist for municipal stormwater phase 1 and UIC permits				DEQ will charge minor modification fees or no fee. Doing nothing will result in lost revenue opportunity and perpetuate inequity in fee tables.
39			Alternatives considered				Research/data needed				Models
40			None at this time.				Proposed fees have already been calculated.				Model was already developed when developing fees.
41		2	Public involvement					Affected parties
42			Interest in this proposal is low/medium. DEQ plans to use our standing committee and estimates we will meet 1 times. We plan to ask the committee to provide advice.					Business		3	affects under 100 currently regulated
43								Manufacturing		3	affects under 100 currently regulated
44								City/county/state		3	affects under 100 currently regulated
45								Individuals		3	affects under 100 currently regulated
46								Custom entry		0	not affected
47								Custom entry		0	not affected
48									Tuesday, September 30, 2025
49

	A	B	C	D	E	F	G	H	I
1	⧀ Summary
2			1	Warm up
3
4
5				Action	Object	Driver
6				reduce	insufficient funding	stable funding source			ï drop down Action/Object/Driver lists
7									ï drop down Action/Object/Driver lists
8									ï drop down Action/Object/Driver lists
9									ï drop down Action/Object/Driver lists
10									ï drop down Action/Object/Driver lists
11									ï drop down Action/Object/Driver lists
12									ï drop down Action/Object/Driver lists
13									ï drop down Action/Object/Driver lists
14									ï drop down Action/Object/Driver lists
15				Optional discussion
16				Take action to reduce but not eliminate insufficient funding for the service provided and address gaps in program fee tables.
17				Process improvement
18	Go to top
19					Tuesday, September 30, 2025

	A	B	C	D	E	F	G	H	I	J	K	L	M	N	O	P	Q	R	S	T	U	V	W	X
1	⧀ Summary
2			2	Basics		Create major modification fees for municipal stormwater phase 1 and underground injection control permits.
3
4				Brief description of rule proposal
5				Create major modification fees for municipal stormwater phase 1 and underground injection control permits. Currently, major modification fees do not exist for MS4 phase 1 and UIC permits. The major modification fees are proposed in an effort to recover costs associated with future major modification requests. DEQ is proposing major modification fees of $8,746 for MS4 phase 1 permits and $4,971 for UIC permits.
6
7					Rulemaking type	permanent		Chapter 340 divisions			45												ï drop down Rulemaking type
8				Strengths/weaknesses going into rulemaking
9					The proposed rule…			Risk option			Riskometer
10					Had prior public input			somewhat true			1	2	3	4	5	6	7	8	9	10			ï drop down to select options
11					Is backed by science			does not apply			1	2	3	4	5	6	7	8	9	10			ï drop down to select options
12					Is backed by data			definitely true			1	2	3	4	5	6	7	8	9	10			ï drop down to select options
13					Supports sustainability			does not apply			1	2	3	4	5	6	7	8	9	10			ï drop down to select options
14					Supports strategic directions			unknown at this time			1	2	3	4	5	6	7	8	9	10			ï drop down to select options
15					Furthers DEQ priorities			unknown at this time			1	2	3	4	5	6	7	8	9	10			ï drop down to select options
16					Would make DEQ's work easier			does not apply			1	2	3	4	5	6	7	8	9	10			ï drop down to select options
17					Would reduce DEQ costs			does not apply			1	2	3	4	5	6	7	8	9	10			ï drop down to select options
18
19
20							Risk average				1	2	3	4	5	6	7	8	9	10
21				Ideal - What do we envision?
22				Short	EQC adopts fees with little to no stakeholder opposition.
23				Long
24				Reality - What are we trying to change?
25				Short	Major modification fees do not exist for municipal stormwater phase 1 and UIC permits
26				Long
27				Consequences - What will happen if we do nothing?
28				Short	DEQ will charge minor modification fees or no fee. Doing nothing will result in lost revenue opportunity and perpetuate inequity in fee tables.
29				Long
30				Alternatives to rulemaking already considered or to explore
31				Short	None at this time.
32				Long
33				Research or data needed to develop proposal
34				Short	Proposed fees have already been calculated.
35				Long	The fees were originally proposed for the 2012 WQ permit fees rulemaking, but were removed from that rulemaking due to fee approval issues with DAS and internal policy discussions.
36				Models that could be leveraged for this proposal
37				Short	Model was already developed when developing fees.
38				Long
39							Land Use/SIP
40							Land use rules			Y													ï drop down to select Land Use/ SIP boxes
41
42							State Implementation Plan																ï drop down to select Land Use/ SIP boxes
43				Out of the scope for this proposal
44				Topic				Reasoning
45				Major modification fee for MS4 phase 2				Process used to develop major modification fees for MS4 phase 1 and UIC is not applicable for MS4 phase 2 permits.
46
47
48
49				Compliance, penalties, permits, certifications, registrations and licensing
50						Extent that proposal addresses listed items

51
52				Compliance
53				Penalties
54
55				Water quality																			ï drop down to select program
56
57				NPDES permit
58				Sewage Disposal Service Business Licensing
59				Stormwater Discharge permit
60				UIC Registration/Permits
61				WastewaterSystem Operator Certification
62				Water Pollution Control Facilities Permit
63				Water Quality Permit Program
64				Enter custom item here
65				Enter custom item here
66				Enter custom item here
67
68				Optional discussion
69
70				Reminders
71
72				Process improvement
73	Go to top
74								Tuesday, September 30, 2025

	A	B	C	D	E	F	G	H	I	J	K	L	M	N	O	P	Q	R	S	T	U	V
1	⧀ Summary
2			3	Stakeholders and public involvement			Create major modification fees for municipal stormwater phase 1 and underground injection control permits.
3
4				"The Legislative Assembly finds and declares that it is the policy of this state that whenever possible the public be involved in the development of public policy by agencies and in the drafting of rules. The Legislative Assembly encourages agencies to seek public input to the maximum extent possible before giving notice of intent to adopt a rule. The agency may appoint an advisory committee that will represent the interests of persons likely to be affected by the rule, or use any other means of obtaining public views that will assist the agency in drafting the rule." ORS 183.333
5				Affected parties
6							Previously		Number affected
7					Not affected	Affected	unregulated		10s			100s			1,000s
8				Business					X												ï drop down to X boxes
9				Manufacturing					X												ï drop down to X boxes
10				City/county/state					X												ï drop down to X boxes
11				Individuals					X												ï drop down to X boxes
12				Custom entry																	ï drop down to X boxes
13				Custom entry																	ï drop down to X boxes
14				Stakeholder complexity
15
16
17				External stakeholder interest
18				Selecting an interest level indicates the group to the left is a stakeholder.
19				Group		Interest		Riskometer
20				Regulated community		moderate interest		1	2	3	4	5	6	7	8	9	10				ï drop down interest options
21				Business and industry		moderate interest		1	2	3	4	5	6	7	8	9	10				ï drop down interest options
22				Environmental groups		minor interest		1	2	3	4	5	6	7	8	9	10				ï drop down interest options
23				Public		no interest		1	2	3	4	5	6	7	8	9	10				ï drop down interest options
24				State legislators		minor interest		1	2	3	4	5	6	7	8	9	10				ï drop down interest options
25				Federal environmental regulators		minor interest		1	2	3	4	5	6	7	8	9	10				ï drop down interest options
26				Other state and federal agencies		no interest		1	2	3	4	5	6	7	8	9	10				ï drop down interest options
27				Local governments		moderate interest		1	2	3	4	5	6	7	8	9	10				ï drop down interest options
28				Tribal nations		minor interest		1	2	3	4	5	6	7	8	9	10				ï drop down interest options
29				Custom entry		does not apply		1	2	3	4	5	6	7	8	9	10				ï drop down interest options
30				Custom entry		does not apply		1	2	3	4	5	6	7	8	9	10				ï drop down interest options
31
32
33						Interest average		1	2	3	4	5	6	7	8	9	10
34				Optional stakeholder information
35
36				Advisory committee appointment		Type of committee (check all that apply)
37				No advisory committee			Fiscal			Scientific
38				Use a standing committee			Policy			Rule language
39				Reconvene a committee			Technical			Legally required
40				Convene a new committee			Implementation			Custom entry
41				No. of meetings
42					1
43				Describe appointment strategy
44				Utilize the Blue Ribbon Committee.
45				Describe how DEQ will use their input
46				DEQ may adjust fees based upon input.
47
48	Advisory Committee Guide
49	ORS 183.333			Information meetings/hearings during public notice
50				Information meetings/hearings			Public notice

51				Portland area			No public notice
52				Regional			Public notice, no hearing
53					No. of meetings		Public notice with hearing
54					1, 2 or 3		Re-notice
55				Optional hearing information
56				Number of meetings to be determined. Attendance at hearings has been almost nonexistant at previous hearings for permit fees.
57				Reminders
58
59				Process improvement
60	Go to Top
61						September 30, 2025

	A	B	C	D	E	F	G	H	I	J	K	L	M	N	O	P	Q	R	S	T	U	V	W
1	⧀ Summary
2			4	Program			Create major modification fees for municipal stormwater phase 1 and underground injection control permits.
3
4				Program name	Surface Water Mgmt. Section
5
6				Media	water																	ï drop down Media list
7				Program consequences of doing nothing					low													ï drop down Severity list
8							Severity		1	2	3	4	5	6	7	8	9	10
9				Loss of delegation
10				Failure to keep commitment
11				Failure to respond to legislature
12				Increased difficulty doing business
13				Unclear administrative rules
14				Loss of reputation
15				Enter custom consequences here
16				Enter custom consequences here
17				Subject program considerations
18				Annual fee increases of up to 3% may also be proposed for water permits based on inflation and other cost drivers.
19				Other DEQ program considerations
20
21				Dependencies
22
23
24				Optional dependency information
25
26
27				Include program considerations in:						potential for minor complexity												ï drop down Complexity list
28							Complexity			1	2	3	4	5	6	7	8	9	10
29				Committee charter																		ï drop down charter/map/proposal
30				Message map	Y
31				Proposal
32				Reminders
33
34				Process Improvement
35	Go to top
36							Tuesday, September 30, 2025

	A	B	C	D	E	F	G	H	I	J	K	L	M	N	O	P	Q	R	S	T	U	V	W	AA
1	⧀ Summary
2			5	Environmental			Create major modification fees for municipal stormwater phase 1 and underground injection control permits.
3
4			The proposed rules		have no direct correlation to the environment.																	ï drop down environmental correlation
5				The team does not need to complete this worksheet.
6				Environmental consequences of doing nothing					does not apply
7							Severity		1	2	3	4	5	6	7	8	9	10				ï drop down Severity list
8				Science does not apply to Oregon
9				Delay in public health protection
10				Adverse effect on vulnerable populations
11	DEQ - EJ			Adverse effect on environmental justice communities
12				Enter custom environmental consequence here
13				Enter custom environmental consequence here
14				Describe environmental considerations
15
16				Environmental reach
17				Select the most expansive environmental reach of this proposed rule.
18
19
20				Links
21				2011-2015 EPA Strategic Plan
22				The proposed rules align with actions in the EPA Strategic Plan:
23				Taking Action on Climate Change/Improving AQ
24				Protecting America's Waters
25				Ensuring Safety of Chemicals/Preventing Pollution
26				Enforcing Environmental Laws
27				Cleaning Up Communities/Advancing Sustainable Development
28
29				the Natural Step
30				The proposed rules support the elimination of Oregon's contribution to:
31				The progressive buildup of substances extracted from the Earth's crust (for example, heavy metals and fossil fuels)
32				The progressive buildup of chemicals and compounds produced by society (for example, dioxins, PCBs, and DDT)
33				The progressive physical degradation and destruction of nature and natural processes (for example, over harvesting forests and paving over critical wildlife habitat)
34				Conditions that undermine people’s capacity to meet their basic human needs (for example, unsafe working conditions and not enough pay to live on)
35				Environmental data
36
37
38
39				Include environmental consideration in:						does not apply												ï drop down Complexity list
40				Committee charter				Complexity		1	2	3	4	5	6	7	8	9	10			ï drop down charter/map/proposal
41				Message map
42				Proposal
43				Reminders
44
45				Process Improvement
46	Go to top
47							Tuesday, September 30, 2025

	A	B	C	D	E	F	G	H	I	J	K	L	M	N	O	P	Q	R	S	T	U	V	W	X
1	⧀ Summary
2			6	Timing			Create major modification fees for municipal stormwater phase 1 and underground injection control permits.
3
4				Rationale for developing proposal now - drivers
5				Major modification fees are proposed in an effort to recover costs associated with future major modification requests.
6
7						Consider any challenges to the rulemaking for each activity below that may occurs during a legislative session (Q1 of even years, Q1 and Q2 of odd years.)
8
9						START		END
10						Year	Qtr	Year	Qtr
11				Start		2012	4																ï drop down Year and Qtr
12				Advisory committee		2013	1	2013	1														ï drop down Year and Qtr
13				Rulemaking notice		2013	1	2013	1														ï drop down Year and Qtr
14				EQC Action		2013	2																ï drop down Year and Qtr
15				Effective		2013	3																ï drop down Year and Qtr
16				Timing challenges
17				No challenge in meeting rule adoption		Compressed or extended timeframe for rule adoption					Difficult schedule, no contingencies allowed, uncontrolled changes to deadline likely
18
19
20				Include timing rationale above in:							potential for minor complexity												ï drop down Complexity list
21				Committee charter				Complexity			1	2	3	4	5	6	7	8	9	10			ï drop down charter/map/proposal
22				Message map	Y
23				Proposal
24				Reminders
25				No major modifications for MS4 or UIC are anticipated in 2013 at this time.
26				Process Improvement
27	Go to Top
28								Tuesday, September 30, 2025

	A	B	C	D	E	F	G	H	I	J	K	L	M	N	O	P	Q	R	S	T	U	V	W	X	Y	Z	AA	AB
1	⧀ Summary																							FORMULAS
2			7	Financial			Create major modification fees for municipal stormwater phase 1 and underground injection control permits.																	Pass to Proposal
3
4				Funding source
5				Rulemaking	Fee and other funds (60/40)
6				Implementation	Fee and other funds (60/40)
7				Financial consequences of doing nothing						low												ï drop down Severity list		1	low
8								Severity		1	2	3	4	5	6	7	8	9	10
9								Optional notes
10				Loss of program funding																				FALSE			0
11				Failure to address costs																				TRUE	failure to address costs and		7
12				Loss of federal funding																				FALSE			0
13				Insufficient funding				Permit program is chronically under-funded																TRUE	insufficient funding		7
14				Failure to address undue burden																				FALSE			0
15				Enter custom financial consequence here																				FALSE			0
16				Enter custom financial consequence here																				FALSE			0
17				Fees																				failure to address costs and insufficient funding.
18	ORS 291.055 (2)(d)			Action				DAS Fee Approval																Required				required
19				Establish new fees				Required																TRUE	establish new fees		5	1
20				Increase existing fees				Exempt under ORS 291.55(2)(d)																FALSE				establish new fees, require DAS approval
21				Decrease existing fees				Exempt under ORS 291.55(2)(m)																FALSE				, require DAS approval
22
23				Authority to adopt, amend or repeal fees:			ORS
24				Fiscal impact on:			Impact			Riskometer
25				Regulated community			moderate cost increase			1	2	3	4	5	6	7	8	9	10			ï drop down Impact list		8	moderate cost increase
26				Small business (50 emp or less)			significant cost increase			1	2	3	4	5	6	7	8	9	10			ï drop down Impact list		#N/A	significant cost increase
27				Business and industry			moderate cost increase			1	2	3	4	5	6	7	8	9	10			ï drop down Impact list		8	moderate cost increase
28				Local governments			moderate cost increase			1	2	3	4	5	6	7	8	9	10			ï drop down Impact list		8	moderate cost increase
29				Other state or federal agencies			no fiscal impacts			1	2	3	4	5	6	7	8	9	10			ï drop down Impact list		0	no fiscal impacts
30				Public			no fiscal impacts			1	2	3	4	5	6	7	8	9	10			ï drop down Impact list		0	no fiscal impacts
31				DEQ			unknown at this time			1	2	3	4	5	6	7	8	9	10			ï drop down Impact list		6	unknown at this time
32				Program -Air Quality			no fiscal impacts			1	2	3	4	5	6	7	8	9	10			ï drop down Impact list		0	no fiscal impacts
33				Custom entry			no fiscal impacts			1	2	3	4	5	6	7	8	9	10			ï drop down Impact list		0	no fiscal impacts
34				Custom entry			no fiscal impacts			1	2	3	4	5	6	7	8	9	10			ï drop down Impact list		0	no fiscal impacts
35
36
37							Fiscal impact average			1	2	3	4	5	6	7	8	9	10					#N/A
38				Optional fiscal discussion																					TRUE
39				Anticipated that no to very few municipalities or businesses will seek major modifications in near future so risks are likely overstated.
40				Invoicing system
41				Develop new			CHRIS			TRAACS														FALSE	FALSE	FALSE	involved
42				Access database			HazWaste Invoicing			UST Invoice.new														FALSE	FALSE	FALSE
43				Access template			SWIFT			WQSIS														FALSE	FALSE	TRUE
44				Custom entry			Custom entry			Custom entry														FALSE	FALSE	FALSE
45				Since an invoicing system is involved with this rulemaking, please consult with resource system owner early in the rulemaking process.																				Since an invoicing system is involved with this rulemaking, please consult with resource system owner early in the rulemaking process.
46				Description
47				Update database with new fees.
48				Include description above in:
49				Committee charter						potential for minor complexity												ï drop down Complexity list		3	potential for minor complexity
50				Message map	Y			Complexity		1	2	3	4	5	6	7	8	9	10

51				Proposal
52				Reminders
53
54				Process improvement
55	Go to Top
56							Tuesday, September 30, 2025
57