B	C	D	E	F	G	H	I	J	K	L	M	N	O	P	Q	R	S	T	U	V	W	X	Y	Z	AA
1
2			DEQ Rulemaking								Friday, October 3, 2025
3										Workbook Summary
4			2008 LRAPA Industrial Streamlining
5			Permitting programs - specifics known later - air quality
6			Brief description of rule proposal					Worksheets				Do nothing severity rating
7			Reviewing LRAPA's permitting titles for streamlining and stringency.					1	Warm up
8								2	Basics				Risk rating low → high
9								3	Stakeholders				1	2	3	4	5	6	7	8	9	10
10								4	Program			1	1	2	3	4	5	6	7	8	9	10
11								5	Environmental			0	1	2	3	4	5	6	7	8	9	10
12								6	Timing				1	2	3	4	5	6	7	8	9	10
13								7	Financial			0	1	2	3	4	5	6	7	8	9	10
14								8	Legal			0	1	2	3	4	5	6	7	8	9	10
15								9	Technical				1	2	3	4	5	6	7	8	9	10
16								10	Policy				1	2	3	4	5	6	7	8	9	10
17								11	Political				1	2	3	4	5	6	7	8	9	10
18								12	Implementation				1	2	3	4	5	6	7	8	9	10
19
20		Schedule						legislative session
21
22			2012				2013				2014
23			Q1	Q2	Q3	Q4	Q1	Q2	Q3	Q4	Q1	Q2	Q3				Q4
24						<Start	---	Effective>
25							<AdvCom>
26							<Notice	End>
27								EQC
28		0	Environmental					The proposed rules involve
29			The proposed rules have no direct correlation to the environment.					Compliance			0	not involved
30								Penalties			0	not involved
31								Permits, certifications			0	not involved
32								Fees			0	not involved
33								State Implementation Plan			7	involved
34								Land use rules			0	not involved
35			Ideal				Reality				Consequences
36			What we want to happen.				What we are trying to change.				What will happen if we don't change.
37			Carrying out PPA commitment to bring LRAPA's SIP submissions current with EPA and determining stringency is at least equivalent to OARs.				Bringing LRAPA current with their SIP submissions.				LRAPA will remain past due that could potentially lead to federally unenforceable rules
38			Alternatives considered				Research/data needed				Models
39			LRAPA can remain past due for another year or so.				Review of rulemaking package submitted by LRAPA to DEQ - for stringency.				Previous joint LRAPA / DEQ rulemaking: Eugene/Springfield PM10 LMP, Oakridge PM10 and joint rulemaking contract between LRAPA and DEQ.
40		0	Public involvement					Affected parties
41			There is no expressed interest in this proposal at this time. DEQ does not plan to appoint an advisory committee. We plan to ask the committee to provide advice.					Business		0	not affected
42								Manufacturing		0	not affected
43								City/county/state		0	not affected
44								Individuals		0	not affected
45								Custom entry		0	not affected
46								Custom entry		0	not affected
47									Friday, October 3, 2025
48

	A	B	C	D	E	F	G	H	I
1	⧀ Summary
2			1	Warmed up
3
4
5				Action	Object	Driver
6				carry out	a commitment in PPA	EPA direction			ï drop down Action/Object/Driver lists
7									ï drop down Action/Object/Driver lists
8									ï drop down Action/Object/Driver lists
9									ï drop down Action/Object/Driver lists
10									ï drop down Action/Object/Driver lists
11									ï drop down Action/Object/Driver lists
12									ï drop down Action/Object/Driver lists
13									ï drop down Action/Object/Driver lists
14									ï drop down Action/Object/Driver lists
15				Optional discussion
16
17				Process improvement
18	Go to top
19					Friday, October 3, 2025

	A	B	C	D	E	F	G	H	I	J	K	L	M	N	O	P	Q	R	S	T	U	V	W	X
1	⧀ Summary
2			2	Basics		2008 LRAPA Industrial Streamlining
3
4				Brief description of rule proposal
5				Reviewing LRAPA's permitting titles for streamlining and stringency.
6
7					Rulemaking type	permanent		Chapter 340 divisions			200												ï drop down Rulemaking type
8				Strengths/weaknesses going into rulemaking
9					The proposed rule…			Risk option			Riskometer
10					Had prior public input			definitely true			1	2	3	4	5	6	7	8	9	10			ï drop down to select options
11					Is backed by science			does not apply			1	2	3	4	5	6	7	8	9	10			ï drop down to select options
12					Is backed by data			does not apply			1	2	3	4	5	6	7	8	9	10			ï drop down to select options
13					Supports sustainability			does not apply			1	2	3	4	5	6	7	8	9	10			ï drop down to select options
14					Supports strategic directions			definitely true			1	2	3	4	5	6	7	8	9	10			ï drop down to select options
15					Furthers DEQ priorities			definitely true			1	2	3	4	5	6	7	8	9	10			ï drop down to select options
16					Would make DEQ's work easier			does not apply			1	2	3	4	5	6	7	8	9	10			ï drop down to select options
17					Would reduce DEQ costs			does not apply			1	2	3	4	5	6	7	8	9	10			ï drop down to select options
18
19
20							Risk average				1	2	3	4	5	6	7	8	9	10
21				Ideal - What do we envision?
22				Short	Carrying out PPA commitment to bring LRAPA's SIP submissions current with EPA and determining stringency is at least equivalent to OARs.
23				Long	blank
24				Reality - What are we trying to change?
25				Short	Bringing LRAPA current with their SIP submissions.
26				Long	blank
27				Consequences - What will happen if we do nothing?
28				Short	LRAPA will remain past due that could potentially lead to federally unenforceable rules
29				Long	If LRAPA remains past due, that may lead to additional work for DEQ staff in the event a lawsuit occurs, strains the partnership between LRAPA, DEQ and EPA.
30				Alternatives to rulemaking already considered or to explore
31				Short	LRAPA can remain past due for another year or so.
32				Long	blank
33				Research or data needed to develop proposal
34				Short	Review of rulemaking package submitted by LRAPA to DEQ - for stringency.
35				Long	blank
36				Models that could be leveraged for this proposal
37				Short	Previous joint LRAPA / DEQ rulemaking: Eugene/Springfield PM10 LMP, Oakridge PM10 and joint rulemaking contract between LRAPA and DEQ.
38				Long	blank
39							Land Use/SIP
40							Land use rules																ï drop down to select Land Use/ SIP boxes
41
42							State Implementation Plan			Y													ï drop down to select Land Use/ SIP boxes
43				Out of the scope for this proposal
44				Topic				Reasoning
45				Amending OARs to be as stringent as LRAPA's titles				not necessary/not applicable
46
47
48
49				Compliance, penalties, permits, certifications, registrations and licensing
50						Extent that proposal addresses listed items

51
52				Compliance
53				Penalties
54
55				Air quality																			ï drop down to select program
56
57				Asbestos License
58				Air Contaminant Discharge Permit
59				Air Quality Registrations
60				Open Burning Letter Permit
61				Tanker Certification
62				Title V permit
63				Vehicle Emissions Certification
64				Enter custom item here
65				Enter custom item here
66				Enter custom item here
67
68				Reminders
69				Will know more about overall impact to OARs once rulemaking package is reviewed (after EMT approval).
70				Process improvement
71	Go to top
72								Friday, October 3, 2025

	A	B	C	D	E	F	G	H	I	J	K	L	M	N	O	P	Q	R	S	T	U	V
1	⧀ Summary
2			3	Stakeholders and public involvement			2008 LRAPA Industrial Streamlining
3
4				"The Legislative Assembly finds and declares that it is the policy of this state that whenever possible the public be involved in the development of public policy by agencies and in the drafting of rules. The Legislative Assembly encourages agencies to seek public input to the maximum extent possible before giving notice of intent to adopt a rule. The agency may appoint an advisory committee that will represent the interests of persons likely to be affected by the rule, or use any other means of obtaining public views that will assist the agency in drafting the rule." ORS 183.333
5				Affected parties
6							Previously		Number affected
7					Not involved	Involved	unregulated		10s			100s			1,000s
8				Business																	ï drop down to X boxes
9				Manufacturing																	ï drop down to X boxes
10				City/county/state																	ï drop down to X boxes
11				Individuals																	ï drop down to X boxes
12				Custom entry																	ï drop down to X boxes
13				Custom entry																	ï drop down to X boxes
14				Stakeholder complexity
15
16
17				External stakeholder interest
18				Selecting an interest level indicates the group to the left is a stakeholder.
19				Group		Interest		Riskometer
20				Regulated community		does not apply		1	2	3	4	5	6	7	8	9	10				ï drop down interest options
21				Business and industry		does not apply		1	2	3	4	5	6	7	8	9	10				ï drop down interest options
22				Environmental groups		does not apply		1	2	3	4	5	6	7	8	9	10				ï drop down interest options
23				Public		does not apply		1	2	3	4	5	6	7	8	9	10				ï drop down interest options
24				State legislators		does not apply		1	2	3	4	5	6	7	8	9	10				ï drop down interest options
25				Federal environmental regulators		does not apply		1	2	3	4	5	6	7	8	9	10				ï drop down interest options
26				Other state and federal agencies		does not apply		1	2	3	4	5	6	7	8	9	10				ï drop down interest options
27				Local governments		does not apply		1	2	3	4	5	6	7	8	9	10				ï drop down interest options
28				Tribal nations		does not apply		1	2	3	4	5	6	7	8	9	10				ï drop down interest options
29				Custom entry		does not apply		1	2	3	4	5	6	7	8	9	10				ï drop down interest options
30				Custom entry		does not apply		1	2	3	4	5	6	7	8	9	10				ï drop down interest options
31
32
33						Interest average		1	2	3	4	5	6	7	8	9	10
34				Optional stakeholder information
35				LRAPA is responsible for engaging stakeholders, therefore these do not apply to DEQ.
36				Advisory committee appointment		Type of committee (check all that apply)
37				No advisory committee			Fiscal			Scientific
38				Use a standing committee			Policy			Rule language
39				Reconvene a committee			Technical			Legally required
40				Convene a new committee			Implementation			Custom entry
41				No. of meetings
42					0
43				Describe appointment strategy
44
45				Describe how DEQ will use their input
46
47
48	Advisory Committee Guide
49	ORS 183.333			Information meetings/hearings during public notice
50				Information meetings/hearings			Public notice

51				Portland area			No public notice
52				Regional			Public notice, no hearing
53					No. of meetings		Public notice with hearing
54					0		Re-notice
55				Optional hearing information
56				LRAPA will need to re-notice the rulemaking package. Hearing and newspaper ad will be up to LRAPA and decided later - at minimum, SOS notice, govdelivery.
57				Reminders
58
59				Process improvement
60	Go to Top
61						October 3, 2025

	A	B	C	D	E	F	G	H	I	J	K	L	M	N	O	P	Q	R	S	T	U	V	W
1	⧀ Summary
2			4	Program			2008 LRAPA Industrial Streamlining
3
4				Program name	Permitting programs - specifics known later
5
6				Media	air																	ï drop down Media list
7				Program consequences of doing nothing					low													ï drop down Media list
8							Severity		1	2	3	4	5	6	7	8	9	10
9				Loss of delegation
10				Failure to keep commitment
11				Failure to respond to legislature
12				Increased difficulty doing business
13				Unclear administrative rules
14				Loss of reputation
15				Enter custom consequences here
16				Enter custom consequences here
17				Subject program considerations
18				Reviewing for stringency.
19				Other DEQ program considerations
20
21				Dependencies
22
23
24				Optional dependency information
25
26
27				Include program considerations in:						potential for minor complexity												ï drop down Complexity list
28							Complexity			1	2	3	4	5	6	7	8	9	10
29				Committee charter																		ï drop down charter/map/proposal
30				Message map
31				Proposal
32				Reminders
33
34				Process Improvement
35	Go to top
36							Friday, October 3, 2025

	A	B	C	D	E	F	G	H	I	J	K	L	M	N	O	P	Q	R	S	T	U	V	W	AA
1	⧀ Summary
2			5	Environmental			2008 LRAPA Industrial Streamlining
3
4			The proposed rules		have no direct correlation to the environment.																	ï drop down environmental correlation
5				The team does not need to complete this worksheet.
6				Environmental consequences of doing nothing					does not apply
7							Severity		1	2	3	4	5	6	7	8	9	10				ï drop down Severity list
8				Science does not apply to Oregon
9				Delay in public health protection
10				Adverse effect on vulnerable populations
11	DEQ - EJ			Adverse effect on environmental justice communities
12				Enter custom environmental consequence here
13				Enter custom environmental consequence here
14				Describe environmental considerations
15
16				Environmental reach
17				Select the most expansive environmental reach of this proposed rule.
18
19
20				Links
21				2011-2015 EPA Strategic Plan
22				The proposed rules align with actions in the EPA Strategic Plan:
23				Taking Action on Climate Change/Improving AQ
24				Protecting America's Waters
25				Ensuring Safety of Chemicals/Preventing Pollution
26				Enforcing Environmental Laws
27				Cleaning Up Communities/Advancing Sustainable Development
28
29				the Natural Step
30				The proposed rules support the elimination of Oregon's contribution to:
31				The progressive buildup of substances extracted from the Earth's crust (for example, heavy metals and fossil fuels)
32				The progressive buildup of chemicals and compounds produced by society (for example, dioxins, PCBs, and DDT)
33				The progressive physical degradation and destruction of nature and natural processes (for example, over harvesting forests and paving over critical wildlife habitat)
34				Conditions that undermine people’s capacity to meet their basic human needs (for example, unsafe working conditions and not enough pay to live on)
35				Environmental data
36
37
38
39				Include environmental consideration in:						does not apply												ï drop down Complexity list
40				Committee charter				Complexity		1	2	3	4	5	6	7	8	9	10			ï drop down charter/map/proposal
41				Message map
42				Proposal
43				Reminders
44				This is a streamlining rulemaking; need to review package if anything more; LRAPA has already implemented their amendments into their daily operations so the environment is not really affected.
45				Process Improvement
46	Go to top
47							Friday, October 3, 2025

	A	B	C	D	E	F	G	H	I	J	K	L	M	N	O	P	Q	R	S	T	U	V	W	X
1	⧀ Summary
2			6	Timing			2008 LRAPA Industrial Streamlining
3
4				Rationale for developing proposal now - drivers
5
6
7						Consider any challenges to the rulemaking for each activity below that may occurs during a legislative session (Q1 of even years, Q1 and Q2 of odd years.)
8
9						START		END
10						Year	Qtr	Year	Qtr
11				Start		2012	4																ï drop down Year and Qtr
12				Advisory committee		2013	1	2013	1	not involved													ï drop down Year and Qtr
13				Rulemaking notice		2013	1	2013	2	not involved													ï drop down Year and Qtr
14				EQC Action		2013	2																ï drop down Year and Qtr
15				Effective		2013	2																ï drop down Year and Qtr
16				Timing challenges
17				No challenge in meeting rule adoption		Compressed or extended timeframe for rule adoption					Difficult schedule, no contingencies allowed, uncontrolled changes to deadline likely
18
19
20				Include timing rationale above in:							does not apply												ï drop down Complexity list
21				Committee charter				Complexity			1	2	3	4	5	6	7	8	9	10			ï drop down charter/map/proposal
22				Message map
23				Proposal
24				Reminders
25
26				Process Improvement
27	Go to Top
28								Friday, October 3, 2025

	A	B	C	D	E	F	G	H	I	J	K	L	M	N	O	P	Q	R	S	T	U	V	W
1	⧀ Summary
2			7	Financial			2008 LRAPA Industrial Streamlining
3
4				Funding source
5				Rulemaking
6				Implementation
7				Financial consequences of doing nothing						does not apply												ï drop down Severity list
8								Severity		1	2	3	4	5	6	7	8	9	10
9								Optional notes
10				Loss of program funding
11				Failure to address costs
12				Loss of federal funding
13				Insufficient funding
14				Failure to address undue burden
15				Enter custom financial consequence here
16				Enter custom financial consequence here
17				Fees
18	ORS 291.055 (2)(d)			Action				DAS Fee Approval
19				Establish new fees				Does not apply
20				Increase existing fees				Exempt under ORS 291.55(2)(d)
21				Decrease existing fees				Exempt under ORS 291.55(2)(m)
22
23				Authority to adopt, amend or repeal fees:			ORS
24				Fiscal impact on:			Impact			Riskometer
25				Regulated community			minor cost decrease			1	2	3	4	5	6	7	8	9	10			ï drop down Impact list
26				Small business (50 emp or less)			minor cost decrease			1	2	3	4	5	6	7	8	9	10			ï drop down Impact list
27				Business and industry			minor cost decrease			1	2	3	4	5	6	7	8	9	10			ï drop down Impact list
28				Local governments			minor cost decrease			1	2	3	4	5	6	7	8	9	10			ï drop down Impact list
29				Other state or federal agencies			minor cost increase			1	2	3	4	5	6	7	8	9	10			ï drop down Impact list
30				Public			no fiscal impacts			1	2	3	4	5	6	7	8	9	10			ï drop down Impact list
31				DEQ			no fiscal impacts			1	2	3	4	5	6	7	8	9	10			ï drop down Impact list
32				Program -Air Quality			minor cost increase			1	2	3	4	5	6	7	8	9	10			ï drop down Impact list
33				Custom entry			no fiscal impacts			1	2	3	4	5	6	7	8	9	10			ï drop down Impact list
34				Custom entry			no fiscal impacts			1	2	3	4	5	6	7	8	9	10			ï drop down Impact list
35
36
37							Fiscal impact average			1	2	3	4	5	6	7	8	9	10
38				Optional fiscal discussion
39
40				Invoicing system
41				Develop new			CHRIS			TRAACS
42				Access database			HazWaste Invoicing			UST Invoice.new
43				Access template			SWIFT			WQSIS
44				Custom entry			Custom entry			Custom entry
45
46				Description
47
48				Include description above in:
49				Committee charter						definitely not complex												ï drop down Complexity list
50				Message map				Complexity		1	2	3	4	5	6	7	8	9	10

51				Proposal
52				Reminders
53
54				Process improvement
55	Go to Top
56							Friday, October 3, 2025
57