Completed

Task

Notes

Rule verification and edits              

x

1.  New rule numbers are available

Not applicable

x

2.  Redline/Strikethrough based on latest compilation

9/5/14 Discrepancies found. Asked technical lead to re-enter amendments to 340-200-0020 and 340-216-8010 in redline.

9/9/14 Corrected by technical lead

x

3.  Compared history in proposed rules to compilation

Complete

x

4.  Rule units comply with Procedural Rules – Administrative Rules Unit

Complete

x

5.  References to rule units meet DEQ guidelines

Complete. Note: Maggie V. made a suggestion on definition 61 concerning past/future tense.

x

6.  Citations and document references in rule text are accurate and current

Complete

x

7.  Tables and table references meet DEQ guidelines

Complete

x

8.  Statutory authorities citations in rule are accurate and align with staff report and SOS online filing

Complete.

x

9.  Statutes implemented citations in rule are accurate and align with staff report and SOS filing

Complete.

x

10.  Accuracy and sufficiency of SIP Notes

Not applicable

x

11.  Appropriate use and accuracy of rule NOTES and ED.NOTES

Complete

x

12.  Other edits

Changed font color from red to black.

Note: AQ Ops did not accept all of Maggie Vandehey’s recommended edits to the temporary rules because this is a temporary rulemaking and AQ Ops does not want the proposed temporary rules to differ from the draft proposed permanent rules that were on pubic notice.

Public document edits

x

Meets DEQ and Associated Press style guides, spelling, grammar, active voice

The staff report is primarily in active voice. In a couple places, change passive voice to active voice, such as “EPA’s rule was challenged.”

Do not use a comma before the last item in a simple series (which constitutes a list of one-word items).

Remove acronyms and parenthesese

(completed)

x

Balanced, professional tone, documents are clear and meet plain English requirements

Clarify or define meanings of: attainment area, ambient air quality standards, Prevention of Significant Deterioration, radically expand, render them un-administratable, biogenic, bioenergy, over the last three years. Where the document is a little heavy on technical words, I ask for clarifications or swapped in simpler words.

Consider word choice describing EPA’s authority: “may not” vs. “must not” vs. “is not authorized” treat greenhouse gases as a regulated pollutant.

Clarify whether Oregon rules are independent from EPA rules.

Clarify whether we are asking EQC to take the U.S. Supreme Court decision into consideration vs. address the decision.

Explain what will happen if the rules expire or EQC does not remove the requirements in the temporary rulemaking.

Use “remove” in place of “suspend” and “repeal” because our proposed action does not suspend and repeal rules.

Either remove the paragraph about biogenic CO2 from the Background action or demonstrate its relevance to the proposed rules.

Summarize EPA’s role in Background section.

It’s not always clear whether the permitting requirements and consequences apply to Title V permit holders only, Prevention of Significant Deterioration permit holders only, or both.

Explain the environmental consequences of adopting the proposed rules. The EQC and the public might fear that removing the permitting requirements will cause environmental harm.

Begin paragraphs with pointed, direct statements. In a few places, the point of the paragraph was buried.

Concerning consequences of not adopting the proposed rules:

•  Estimate the number of facilities that will pay the permitting and control costs.

•  Provide an approximate range of fees facilities will likely pay.

•  Update the fee amounts to reflect Gregg Dahmen’s Title V fee increase rule adoption in Aug. 2014.

In the documents relied upon section, did we use specific rules and statutes to prepare this rulemaking, other than the statutory authority and statutes implemented? If yes, list them. If not, delete the general references to rules and statutes.

(completed)

x

Consistent use of terms

Two areas need attention:

1.  amend vs. revise

2.  source vs stationary source vs. major source vs. major emitting facility vs. facility vs. business

(completed)

x

Format standard met, format supports information conveyed

Complete

x

Includes recent document enhancements

Added back authorizing statute.

Aligned EQC recommendation with staff report.

x

Rules listed in Staff Report match Proposed Rules

Complete

Other

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