From:	JOHNDOHL Judy
Sent:	Tuesday, July 16, 2013 9:12 AM
To:	HAMMOND Joni
Cc:	ALDRICH Greg; FOREMAN Katie; JOHNDOHL Judy
Subject:	RE: We are a go for the Jan EQC meeting--thanks for your help

Joni -

Thank you for the discussion and understanding of our concerns. I believe the January schedule is a great compromise for this rulemaking. 

I just spoke with Larry Knudsen regarding the issue of needing EPA approval to implement longer-term financing while we are trying to propose rules to EQC for adoption. There are two options:
•	Develop draft rules, go through the public notice process, then wait for EPA approval until proposing rules to EQC for adoption. We would need to consider and be aware of the “late comment” provision if EPA were to provide further comments for their approval.
•	Develop draft rules and include language in the rule that these would be effective upon EPA approval. Depending on how prescriptive the rules are, EPA approval may not warrant the need to revise the rules and go back the EQC.

Katie and I will continue to work closely with EPA to ensure our approach and the rules we develop for longer-term financing are sufficient to obtain their approval. 

-----Original Message-----
From: HAMMOND Joni 
Sent: Tuesday, July 16, 2013 8:00 AM
To: ALDRICH Greg; JOHNDOHL Judy; FOREMAN Katie
Subject: We are a go for the Jan EQC meeting--thanks for your help