From: CURTIS Andrea

Sent: Thu Jun 13 12:29:07 2013

To: GINSBURG Andy; OLIPHANT Margaret

Subject: RE: EQC approval of LRAPA rules

Importance: Normal

Yes, Andy, I’ll compile the information for Paul. I’m looking at this same information to verify whether LRAPA’s public notice for the 4 rulemakings complied with our public notice law.

Andrea

From: GINSBURG Andy

Sent: Thursday, June 13, 2013 12:26 PM

To: OLIPHANT Margaret; CURTIS Andrea

Subject: FW: EQC approval of LRAPA rules

Can you get this info to Paul?

Thanks.

Andy Ginsburg

Air Quality Administrator

Oregon Department of Environmental Quality

(503) 229-5397 - Office

(503) 572-7195 - Mobile

From: Garrahan Paul [mailto:Paul.Garrahan@doj.state.or.us]

Sent: Thursday, June 13, 2013 9:59 AM

To: GINSBURG Andy

Subject: EQC approval of LRAPA rules

Andy: To ensure that I provide thorough advice, could you ask your staff to send me all of the relevant LRAPA rulemaking documents used to approve the four rules that the EQC must now approve and submit to EPA for incorporation into the SIP? It would be helpful to have the rulemaking and hearing notices, including the FIS and other related documents.

It would also be helpful, for my comparison, to get the same set of documents for last year’s approval of the Oakridge PM 2.5 plan approval, including both LRAPA’s rulemaking documents and those DEQ used to approve that plan.

I want to include an assessment of whether differences in the processes, if any, might present any legal risks. And also try to figure out how to align the process for the four rulemakings that the EQC needs to approve with the process that worked fairly well for the Oakridge approval.

Thanks.

Paul Garrahan

Assistant Attorney-in-Charge, Natural Resources Section

Oregon Department of Justice

971-673-1943 (Portland Office; T, Th & F)

503-947-4593 (Salem Office; M & W)

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