From: CURTIS Andrea
Sent: Wed May 15 08:35:25 2013
To: OLIPHANT Margaret
Subject: FW: Civil Penalty Increase - SIP change?b Importance: Normal
FYI – Jenny Root’s fee increase rulemaking (Civil Penalties) is considered a SIP change. Let’s spend a few minutes of Thursday’s meeting with Justin on this.
Andrea
From: Spenillo, Justin [mailto:Spenillo.Justin@epa.gov]
Sent: Tuesday, May 14, 2013 6:05 PM
To: CURTIS Andrea
Subject: RE: Civil Penalty Increase - SIP change?
Andrea,
Yes, this will be considered a change to the SIP which would ideally be reviewed before being submitted for approval into the Oregon SIP. I have identified an EPA reviewer and attorney but need to confirm that they are the appropriate contacts.
On a related note, for the submission of this revision, it may be more efficient (for both ODEQ and EPA) to submit with another revision package. Doing rules one at a time can become overwhelming. We can chat more about it on Thursday or otherwise.
Hope this helps,
Justin
From: CURTIS Andrea [mailto:CURTIS.Andrea@deq.state.or.us]
Sent: Tuesday, May 14, 2013 10:43 AM
To: Spenillo, Justin
Subject: Civil Penalty Increase - SIP change?
Justin,
We’re performing an additional rulemaking that might be part of the SIP under part 1.L. on the attachment. The rulemaking would increase the dollar amount of civil penalties. It affects chapter 340 division 12. It’s being performed by DEQ’s Enforcement program, not the Air Quality program.
Is an increase in penalty amounts considered a change to the SIP? If yes, how can we get an EPA project manager assigned to work with the rulewriter and me? DEQ’s Enforcement program wants to begin DEQ’s public notice for the rulemaking in mid June this year.
Thanks,
Andrea Curtis
Oregon Department of Environmental Quality
Air Quality Division
503-229-5946