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			Amend fees for WPCF 600 permits - both small and large operations.
5			Surface Water Mgmt. Section - water quality
6			Brief description of rule proposal					Worksheets				Do nothing severity rating
7			Create new permit fees for WPCF 600 small and large operations. The permit regulates non-chemical offstream small scale mining of metals (primarily gold). Currently, small operations pay no application or annual fee. Large operations pay only a $202 application fee and no annual fee. Almost all of the permittees are small operations. There were approximately 200 permits in 2004; currently there are 1,200 permits. The WPCF 600 fees are proposed in an effort to recover costs associated with administering the permit. Proposed fees have not yet been developed.					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			5	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
21		Schedule						legislative session
22
23			2013				2014				2015
24			Q1	Q2	Q3	Q4	Q1	Q2	Q3	Q4	Q1	Q2	Q3				Q4
25			<Start	---	---	---	Effective>
26				<AdvCom	End>
27					<Notice	End>
28						EQC
29		0	Environmental					The proposed rules involve
30			Alignment					Compliance			0	not involved
31			Natural Step conditions				0	Penalties			0	not involved
32			EPA Strategic Plan actions				0	Permits, certifications			6	involved, not new or expanded
33			Reach	Local				Fees			5	establish new fees and increase existing fees, require DAS approval
34			Correlation					State Implementation Plan			0	not involved
35			Not directly					Land use rules			7	involved
36
37			Ideal				Reality				Consequences
38			What we want to happen.				What we are trying to change.				What will happen if we don't change.
39			EQC approves fees with minimal stakeholder opposition.				Current fees for WPCF 600 are not covering the cost to implement the permit.				Current fees will continue to not cover the cost to implement the permit.
40			Alternatives considered				Research/data needed				Models
41			None at this time.				History of permit issuance for both small and large operations. Permit fees from other states.				Determine if fee model from 2011 rulemaking for 1200-C individual lots can be utilized.
42		4	Public involvement					Affected parties
43			Interest in this proposal is low/medium. DEQ plans to use our standing committee and estimates we will meet 2 times. We plan to ask the committee to provide advice.					Business		3	affects under 100 currently regulated
44								Manufacturing		3	affects under 100 currently regulated
45								City/county/state		3	affects under 100 currently regulated
46								Individuals		4	affects thousands currently regulated
47								Custom entry		0	not affected
48								Custom entry		0	not affected
49									Tuesday, September 30, 2025
50

	A	B	C	D	E	F	G	H	I
1	⧀ Summary
2			1	Warm up
3
4
5				Action	Object	Driver
6					Oregon law	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				Amend		increased permitting activity			ï drop down Action/Object/Driver lists
14									ï drop down Action/Object/Driver lists
15				Optional discussion
16
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		Amend fees for WPCF 600 permits - both small and large operations.
3
4				Brief description of rule proposal
5				Create new permit fees for WPCF 600 small and large operations. The permit regulates non-chemical offstream small scale mining of metals (primarily gold). Currently, small operations pay no application or annual fee. Large operations pay only a $202 application fee and no annual fee. Almost all of the permittees are small operations. There were approximately 200 permits in 2004; currently there are 1,200 permits. The WPCF 600 fees are proposed in an effort to recover costs associated with administering the permit. Proposed fees have not yet been developed.
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			unknown at this time			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 approves fees with minimal stakeholder opposition.
23				Long
24				Reality - What are we trying to change?
25				Short	Current fees for WPCF 600 are not covering the cost to implement the permit.
26				Long	Fees are insufficent to cover the costs of administering the program. Offstream placer mining has grown markedly as gold proces have risen. DEQ, Oregon State Police and federal land management agencies spend substantial time and effort to ensure compliance with permit requirements. Much of this activity occurs in watersheds with threatened salmon stocks.
27				Consequences - What will happen if we do nothing?
28				Short	Current fees will continue to not cover the cost to implement the permit.
29				Long	Oregon State Police and federal land management agencies rely of DEQ to provide guidance or technical asistance to their staff. Failure to increase fees will result in greater subsidies of the program from public funds and other permitted activities that have fees (and probably less environmental impact), or the need to discountinue supporting outreach and compliance efforts conducted by OSP, BLM and USFS.
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	History of permit issuance for both small and large operations. Permit fees from other states.
35				Long	Research demand for permits by small and large operations over time, fees for comparable WPCF activities in Oregon or other states, estimated costs for current permit issuance, technical assistance and compliance activities.
36				Models that could be leveraged for this proposal
37				Short	Determine if fee model from 2011 rulemaking for 1200-C individual lots can be utilized.
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
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				Near stream placer mining activities can affect water quality in a number of ways including subsurface discharge of turbid water, dewatering of riparian areas and eventual loss of riparian vegetation and subsequent loss of fish habitat, channel stability and shade.
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			Amend fees for WPCF 600 permits - both small and large operations.
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		maximum interest		1	2	3	4	5	6	7	8	9	10				ï drop down interest options
21				Business and industry		considerable 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		moderate 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		minor interest		1	2	3	4	5	6	7	8	9	10				ï drop down interest options
27				Local governments		minor 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				Miners are generally outspoken and in opposition to all regulation of instream or offstream mining. OSP and federal land managers rely on DEQ participation. Cow Creek Tribes are interested in adequate regualtion and protection of streams in their area. Some local governments are not supportive of DEQ efforts to protect water quality and beneficial uses.
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					2
43				Describe appointment strategy
44				Utilize Blue Ribbon Committee.
45				Describe how DEQ will use their input
46				Adjust fees as appropriate based on 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 hearings to be determined.
57				Reminders
58
59				Process improvement
60	Go to Top			Riskometer doesn't reflect support for action
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			Amend fees for WPCF 600 permits - both small and large operations.
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
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			Amend fees for WPCF 600 permits - both small and large operations.
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			Amend fees for WPCF 600 permits - both small and large operations.
3
4				Rationale for developing proposal now - drivers
5				Rulemaking is anticipated to be bundled with the permit fee increase rulemaking. The schedule will coincide with the permit fee increase rulemaking schedule.
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		2013	1																ï drop down Year and Qtr
12				Advisory committee		2013	2	2013	3														ï drop down Year and Qtr
13				Rulemaking notice		2013	3	2013	4														ï drop down Year and Qtr
14				EQC Action		2013	4																ï drop down Year and Qtr
15				Effective		2014	1																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
23				Proposal	Y
24				Reminders
25
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
1	⧀ Summary
2			7	Financial			Amend fees for WPCF 600 permits - both small and large operations.
3
4				Funding source
5				Rulemaking	GF/fee
6				Implementation	GF/fee
7				Financial consequences of doing nothing						medium												ï drop down Severity list
8								Severity		1	2	3	4	5	6	7	8	9	10
9								Optional notes
10				Loss of program funding
11				Failure to address costs
12				Loss of federal funding
13				Insufficient funding
14				Failure to address undue burden
15				Enter custom financial consequence here
16				Enter custom financial consequence here
17				Fees
18	ORS 291.055 (2)(d)			Action				DAS Fee Approval
19				Establish new fees				Required
20				Increase existing fees				Exempt under ORS 291.55(2)(d)
21				Decrease existing fees				Exempt under ORS 291.55(2)(m)
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
26				Small business (50 emp or less)			moderate cost increase			1	2	3	4	5	6	7	8	9	10			ï drop down Impact list
27				Business and industry			moderate cost increase			1	2	3	4	5	6	7	8	9	10			ï drop down Impact list
28				Local governments			no fiscal impacts			1	2	3	4	5	6	7	8	9	10			ï drop down Impact list
29				Other state or federal agencies			no fiscal impacts			1	2	3	4	5	6	7	8	9	10			ï drop down Impact list
30				Public			no fiscal impacts			1	2	3	4	5	6	7	8	9	10			ï drop down Impact list
31				DEQ			moderate cost decrease			1	2	3	4	5	6	7	8	9	10			ï drop down Impact list
32				Program -Air Quality			no fiscal impacts			1	2	3	4	5	6	7	8	9	10			ï drop down Impact list
33				Custom entry			no fiscal impacts			1	2	3	4	5	6	7	8	9	10			ï drop down Impact list
34				Custom entry			no fiscal impacts			1	2	3	4	5	6	7	8	9	10			ï drop down Impact list
35
36
37							Fiscal impact average			1	2	3	4	5	6	7	8	9	10
38				Optional fiscal discussion
39
40				Invoicing system
41				Develop new			CHRIS			TRAACS
42				Access database			HazWaste Invoicing			UST Invoice.new
43				Access template			SWIFT			WQSIS
44				Custom entry			Custom entry			Custom entry
45				Since an invoicing system is involved with this rulemaking, please consult with resource system owner early in the rulemaking process.
46				Description
47				Database will need to be updated with new fees.
48				Include description above in:
49				Committee charter						potential for minor complexity												ï drop down Complexity list
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			difficult to quantify what a moderate cost increase is to a small business or individual. Is $202 too much to charge for a permit that allows one to excavate 1500 cubic yards of placer deposit per year on public lands and gold at $1700 an ounce? Any fee increase is a dramatic leap from $0
56							Tuesday, September 30, 2025
57