December 18, 2013

Solomon Harris

Cutting Edge Illusions dba Visual Performance, Inc.

1210 Interior St Ste. 2

Eugene OR 97402

Subject: Proposal to incorporate Lane Regional Air Protection Agency rules into the State Implementation Plan

DEQ is proposing rules to incorporate LRAPA rules into the Oregon State Implementation Plan. This includes rules for open burning, permit streamlining, and permitting requirements including new source review and prevention of significant deterioration requirements for fine particulate pollution and greenhouse gases, and national emission standards for hazardous air pollutants. The LRAPA rules were adopted by the LRAPA Board of Directors several years ago and have been in effect in Lane County since their adoption.

Typically, DEQ submits LRAPA rules to the Environmental Quality Commission for incorporation into the State Implementation Plan immediately upon adoption by the LRAPA Board. However, in this case, DEQ determined that the public notice process held jointly by DEQ and LRAPA several years ago did not meet requirements for State Implementation Plan rules, which are above and beyond requirements for normal rulemaking. Adopting new rules is resource intensive and DEQ was unable to perform the additional public notice requirements until now.

DEQ is holding a public comment period beginning in December 2013 to incorporate relevant portions of the LRAPA rules as a modification to the Oregon State Implementation Plan. DEQ has authorized LRAPA to act as hearings officer on behalf of the EQC and accept for public comment. DEQ plans to bring the proposed rules to the EQC for consideration in March 2014.

There are three rule packages. The announcement and documents will be posted online as follows:

•  Open burning: http://www.oregon.gov/deq/RulesandRegulations/Pages/2013/LRAPAOB.aspx

•  Permit streamlining: http://www.oregon.gov/deq/RulesandRegulations/Pages/2013/LRAPAPS.aspx

•  Permitting requirements for NSR, PSD and national emission standards for hazardous air pollutants: http://www.oregon.gov/deq/RulesandRegulations/Pages/2013/LRAPAFED.aspx

DEQ will hold a public hearing on the proposed rule changes on January 22, 2014 at 5:30 pm at 1010 Main Street, Springfield, Oregon 97477. Oral and written comments will be accepted at the hearing. Written comments may be submitted anytime to the above address, or submitted through the online comment forms accessible through the website, but comments must be received no later than 5:00 pm on January 27, 2014. If you have questions, please contact me at Gartenbaum.andrea@deq.state.or.us or 503-229-5946.

Sincerely,

Andrea Gartenbaum

Rules Coordinator, Air Quality Division

CC:  Uri Papish, Administrator, Air Quality Division, DEQ

Max Hueftle, Lane Regional Air Protection Agency