From: CURTIS Andrea

Sent: Wed Jul 03 17:10:36 2013

To: ROOT Jenny

Subject: RE: Division 12 rulemaking - notification to permit holders and interested parties

Importance: Normal

 

Jenny,

The official notice can begin before the 1st of the month. In AQ, we’ll begin the notice July 15th, publish in the SOS bulletin August 1st, and hold the hearing August 15th.

How do we begin the notice? You got it. It’s the date we send an announcement to interested parties and stakeholders, publish the ad, and post the announcement on our rules website.

Thanks for letting me know about the new timeframe.

Andrea

From: ROOT Jenny

Sent: Wednesday, July 03, 2013 4:55 PM

To: CURTIS Andrea

Subject: RE: Division 12 rulemaking - notification to permit holders and interested parties

Andrea,

I’m sorry I didn’t respond to your email earlier. Thank you for the information below and all of your help with this rulemaking effort. As an FYI, we’ve moved our target EQC adoption date to December and I’ve changed the SIP revision date in the redlined Division 200 you provided to reflect December adoption.

I do have a question, though. What constitutes official “Notice”. I assumed it was the date notice is published in the SOS Bulletin, but by your email below (with our previously –planned date of August 1 for SOS Bulletin publication) it sounds like you can start notice before that. How is that? Is is by sending notice to the agency lists, posting on DEQ webpage and newspaper publication when we send notice off to SOS (15th of the month)? In other words, can I begin the notice timeframe by taking these action or am I misunderstanding your communication below and it really can’t start until the 1st of the month (in this case, September 1) when published? I’m sorry it this seems like a silly question--my goal here is to determine the earliest date we can re-set the public hearing to, keeping in mind the 30-day notice requirement for SIP.

Jenny

From: CURTIS Andrea

Sent: Tuesday, June 25, 2013 4:07 PM

To: ROOT Jenny

Subject: FW: Division 12 rulemaking - notification to permit holders and interested parties

Jenny,

Uri wants all AQ permit holders and interested parties to be notified about the Division 12 rulemaking public comment period. Since I’ve done this before for AQ rulemakings, I can explain how this works and can help a bit. Would you let me know if this sounds like a good approach? Also, what date we would issue the notice? July 20? This would ensure notice is issued at least 30 days before the hearing, which is a requirement.

AQ permit holders

· There are about 6,000 AQ permit holders. We have an email address for most of them; however, we’ll need to mail a letter or postcard to the rest.

· I’m creating a mailing list and email list of permit holders for another rulemaking now. We can use the lists I create. We’d insert the addresses into the letter/postcard by Mail Merge in Word.

· You’ll need to draft the letter/postcard and email message explaining how the rulemaking affects permit holders. Attached are example letters we drafted for other rulemakings. Please include language such as: The amendments, if adopted, will be submitted to the US Environmental Protection Agency for approval and as a revision to the State Implementation Plan, which is a requirement of the Clean Air Act. Upload the letter/postcard/email to the SharePoint site for the Division 12 rulemaking.

· The AQ Regional Management Team will likely want to review and approve the messages before they’re sent.

· I can send the email message through GovDelivery to permit holders.

· You’d need to print and mail the letter/postcard or get someone in the mailroom to help. The mailroom has cardstock and a cutting machine to make postcards.

Interested parties

We need to announce the rulemaking through GovDelivery to the group “Air Quality Permits”. The group includes anyone who subscribed to receive updates about the Air Quality Permit program. You’ll need someone in OCO to send a GovDelivery announcement to the group “Rulemaking”. That person could also send the announcement to the group “Air Quality Permits” and any appropriate WQ or LQ groups related to permitting. Please include language such as: The amendments, if adopted, will be submitted to the US Environmental Protection Agency for approval and as a revision to the State Implementation Plan, which is a requirement of the Clean Air Act.

We need to maintain a record for all of this outreach, including a Certificate of Notice, copies of the letters and emails, and the names/addresses they were sent to.

Thanks,

Andrea

From: PAPISH Uri

Sent: Tuesday, June 25, 2013 11:54 AM

To: CURTIS Andrea

Subject: RE: Division 12 rulemaking

Yes, I think both.

From: CURTIS Andrea

Sent: Tuesday, June 25, 2013 10:31 AM

To: PAPISH Uri

Subject: Division 12 rulemaking

Uri,

I’m helping Jenny with outreach for the division 12 rulemaking. Since it changes civil penalties, it’s a SIP update. When we open the comment period, would you like us to notify AQ permit holders and/or email the public who subscribe for updates in the permit program?

Andrea Curtis

Oregon Department of Environmental Quality

Air Quality Division

503-229-5946

curtis.andrea@deq.state.or.us