From: OLIPHANT Margaret
Sent: Fri May 03 15:52:36 2013
To: CURTIS Andrea
Subject: FW: LRAPA Stmt of Fiscal/Economic Impact for rulemakings
Importance: High
Attachments: Title 47 - Open Burning - needfiscal.doc; Industrial Streamlining Rulemaking 2008 - needfiscal impact.doc; Industrial Streamlining Corrections 2010 - needfiscal statement.doc; PM2.5-GHG-NSR 2011 - needfiscal.doc; FW: Q-time #s for charging and LRAPA / DEQ joint rulemaking contract; From: VANDEHEY Maggie Sent: Wednesday, February 06, 2013 8:20 AM To: OLIPHANT Margaret Subject: FW: LRAPA Stmt of Fiscal/Economic Impact for rulemakings Importance: High Hi, There are no requirement for Financial Services to sign off on the fiscal but there are requirements that I sign off when submitting to SOS. I rely on Financial Services’ approval. Having an inadequate fiscal risks is the major reason for challenging our rules. I would ask Jim what LRAPA needs to submit but let’s review what he has to say before we ask LRAPA to provide additional information. The fiscals have language that raise flags; I think we can reword some of this. I took a few minutes to edit part of the PM2.5 fiscal. We need a short introduction about our relationship between LRAPA and DEQ. This is in the wrong format for our public notice and the organization will make it hard to submit using the online form. DOCUMENTS REQUIRED FOR NOTICE We need to complete the following documents for Notice: Announcement About the Proposal Proposed Rules I will load the blank documents to folder 4-Public Notice on rulemaking SharePoint site after we decide if we are going to combine them into one public notice. If we do that, we’ll need an appropriate name. There are three rulemakings on our Proposed Rules that have examples of these documents. SCHEDULE If we are publishing in the March 1 Oregon Bulletin, here is the very tight and close to undoable schedule: February 14 Complete and submit About the Proposal to SOS. I have a furlough day on Friday and Nicole was my backup for online submittal. and filing. February 28 Final day to post all three documents to the website and required notices (GovDelivery, other lists, key legislators.) This means they need to go through internal review. About the Proposal becomes part of the staff report; therefore, we have a stringent review before notice. March 15 First date for public hearing is any. I have plenty of things to do but I would donate a few hours on Friday if you are determined to make the February 14 deadline. I would work on moving the information to NOTICE.About the Proposal-4.00 and doing some organization. Maggie From: OLIPHANT Margaret Sent: Tuesday, February 05, 2013 3:51 PM To: VANDEHEY Maggie Subject: FW: LRAPA Stmt of Fiscal/Economic Impact for rulemakings Importance: High Maggie, Since we spoke a few minutes ago, I ran into my first roadblock. Roys doesn’t want to sign off on LRAPA fiscals (see his e-mail below) although Nicole noted in another e-mail that he had done so in the recent past! Do you know if DEQ sign off on the fiscal is necessary? Thanks, Margaret From: WILLIAMS Robin G Sent: Tuesday, February 05, 2013 3:45 PM To: OLIPHANT Margaret Subject: FW: LRAPA Stmt of Fiscal/Economic Impact for rulemakings Importance: High Email with attachments. Robin Williams Air Quality Budget Analyst Oregon Department of Environmental Quality (503) 229-5316 From: ROYS Jim Sent: Tuesday, January 15, 2013 1:34 PM To: VICK Nicole R. Cc: OLIPHANT Margaret; GINSBURG Andy; WILLIAMS Robin G; NELSON Kerri Subject: FW: LRAPA Stmt of Fiscal/Economic Impact for rulemakings Importance: High Nicole, Although Robin and I looked through the attached fiscal statements, I am uncomfortable with “signing off” or “approving” fiscal impact assessment produced by an organization outside of DEQ, even if those assessments are produced on DEQ document templates. Reviewing our own internal fiscals is challenging enough, and I don’t know how I would go about confirming the LRAPA assertions that the impacts of the rule changes are net revenue neutral. I looked through the LRAPA/DEQ joint rulemaking contract, which does not address a DEQ approval of a LRAPA FIS. If AQ feels that review of LRAPA FIS is something to be addressed, we can have a conversation about what information LRAPA would need to send. That review would need to get billed to the LRAPA Q-Time centers. Obviously, with 24 hours notice, that won’t be happening this time around. Jim Roys Financial Services Manager Oregon DEQ From: WILLIAMS Robin G Sent: Tuesday, January 15, 2013 8:20 AM To: ROYS Jim Subject: FW: LRAPA Stmt of Fiscal/Economic Impact for rulemakings Importance: High Jim, The program needs to get this submitted today if possible. I’ve checked it over, and things look to be in order. Robin Williams Air Quality Budget Analyst Dept. of Environmental Quality (503) 229-5316 From: VICK Nicole R. Sent: Monday, January 14, 2013 3:25 PM To: WILLIAMS Robin G Cc: INAHARA Jill; DOWNING Kevin; Robbye Lanier Subject: LRAPA Stmt of Fiscal/Economic Impact for rulemakings Hi, Robin- Thanks for looking these over. Here's a quick overview:
Some of the forms have different formats. However, we do perform online filings now, so Maggie takes sections and inserts into the SOS online system and I made sure each FIS has those categories. Robbye from LRAPA took the forms from SOS website and since DEQ is changing the rulemaking process, Maggie is familiar with the oddities.
Thanks, again, Robin! Let me know if you have any questions.
Thanks!
Nicole