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	AH	AI	AJ	AK
1
2			DEQ Rulemaking								Monday, October 6, 2025
3										Workbook Summary
4			Greenhouse Gas Permitting - Temporary
5			Operations Division - Air Program Operations Section - air quality
6			Brief description of rule proposal					Worksheets				Do nothing severity rating
7			Suspend permitting and NSR/PSD requirements for greenhouse gases.					1	Warm up
8								2	Basics				Risk rating low → high
9								3	Stakeholders				1	2	3	4	5	6	7	8	9	10					6
10								4	Program			1	1	2	3	4	5	6	7	8	9	10					1
11								5	Environmental			1	1	2	3	4	5	6	7	8	9	10					0
12								6	Timing				1	2	3	4	5	6	7	8	9	10					3
13								7	Financial			1	1	2	3	4	5	6	7	8	9	10					0
14								8	Legal			1	1	2	3	4	5	6	7	8	9	10					1
15								9	Technical				1	2	3	4	5	6	7	8	9	10					1
16								10	Policy				1	2	3	4	5	6	7	8	9	10					1
17								11	Political				1	2	3	4	5	6	7	8	9	10					1
18								12	Implementation				1	2	3	4	5	6	7	8	9	10					1
19
20		Schedule						legislative session
21
22			2014				2015				2016
23			Q1	Q2	Q3	Q4	Q1	Q2	Q3	Q4	Q1	Q2	Q3				Q4
24					<Start	Effective>
25
26
27						EQC
28		1	Environmental					The proposed rules involve
29			The proposed rules:					Compliance			0	not involved
30			● have no direct correlation to the environment.					Penalties			0	not involved
31								Permits, certifications			4	reduced
32								Fees			0	not involved
33								State Implementation Plan			7	involved
34								Land use rules			7	involved
35
36
37			Ideal				Reality				Consequences
38			What we want to happen.				What we are trying to change.				What will happen if we don't change.
39			A temporary rule that enables DEQ to put the "pause" on permitting requirements which may not exist when permanent rules are adopted by the EQC in early 2015.				DEQ rules that currently require Title V permitting and PSD for sources that only emit GHG at the trigger levels when our rules may change in a few months to align with the recent Supreme Court ruling.				Businesses may need to spend money to comply with rules that may be repealed.
40			Alternatives considered				Research/data needed				Models
41			Not do a temporary rulemaking and address the issue in an existing permanent rulemaking.				None.				None.
42		6	Public involvement					Affected parties
43			3					Business		3	affects under 100 currently regulated
44								Manufacturing		3	affects under 100 currently regulated
45								City/county/state		0	not affected
46								Individuals		0	not affected
47								Custom entry		0	not affected
48								Custom entry		0	not affected
49									Monday, October 6, 2025
50

	A	B	C	D	E	F	G	H	I
1	⧀ Summary
2			1	Warmed up
3
4
5				Action drop down	Object drop down selection	Driver drop down selection
6				eliminate	existing regulatory program	court order
7				prevent	an external process	court order
8
9
10
11
12
13
14
15				Optional discussion
16
17				Process improvement
18	Go to top
19					Monday, October 6, 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		Greenhouse Gas Permitting - Temporary
3
4	HOW TO: Insert bullets and break text to new line within a cell			Brief description of rule proposal
5				Suspend permitting and NSR/PSD requirements for greenhouse gases.
6
7					Rulemaking type	temporary		Chapter 340 divisions			200, 216, 218, 224
8				Strengths/weaknesses going into rulemaking				Risk option drop down selection
9					The proposed rule…						Riskometer
10					Has public interest			definitely true			1	2	3	4	5	6	7	8	9	10
11					Is backed by science			does not apply			1	2	3	4	5	6	7	8	9	10
12					Is backed by data			does not apply			1	2	3	4	5	6	7	8	9	10
13					Supports sustainability			does not apply			1	2	3	4	5	6	7	8	9	10
14					Supports strategic directions			does not apply			1	2	3	4	5	6	7	8	9	10
15					Furthers DEQ priorities			does not apply			1	2	3	4	5	6	7	8	9	10
16					Would make DEQ's work easier			somewhat true			1	2	3	4	5	6	7	8	9	10
17					Would reduce DEQ costs			somewhat true			1	2	3	4	5	6	7	8	9	10
18
19
20							Risk average				1	2	3	4	5	6	7	8	9	10
21				Ideal - What do we envision?
22				Short	A temporary rule that enables DEQ to put the "pause" on permitting requirements which may not exist when permanent rules are adopted by the EQC in early 2015.
23				Optional long	blank
24				Reality - What are we trying to change?
25				Short	DEQ rules that currently require Title V permitting and PSD for sources that only emit GHG at the trigger levels when our rules may change in a few months to align with the recent Supreme Court ruling.
26				Optional long	blank
27				Consequences - What will happen if we do nothing?
28				Short	Businesses may need to spend money to comply with rules that may be repealed.
29				Optional long	blank
30				Alternatives to rulemaking already considered or to explore
31				Short	Not do a temporary rulemaking and address the issue in an existing permanent rulemaking.
32				Optional long	blank
33				Research or data needed to develop proposal
34				Short	None.
35				Optional long	blank
36				Models that could be leveraged for this proposal
37				Short	None.
38				Optional long	blank
39							Land Use/SIP
40							Land use rules			Y
41
42							State Implementation Plan			Y
43				Out of the scope for this proposal
44				Topic				Reasoning
45
46
47
48
49				Compliance, penalties, permits, certifications, registrations and licensing
50						Extent that proposal addresses listed items

51
52				Compliance
53				Penalties
54				Select program from drop down list to change listing
55				Air quality
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
70				Process improvement
71	Go to top
72								Monday, October 6, 2025

	A	B	C	D	E	F	G	H	I	J	K	L	M	N	O	P	Q	R	S	T	U	V	X	Y	Z	AA	AB
1	⧀ Summary
2			3	Stakeholders and public involvement			Greenhouse Gas Permitting - Temporary
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					Number affected drop down to select X																10s	100s	1,000s
6							Previously																		2	0	0
7					Not involved	Involved	unregulated		10s			100s			1,000s								involves under one hundred current regulated parties		under one hundred
8				Business					X														2	1	under 100	affects under 100 currently regulated	3
9				Manufacturing					X														2	1	under 100	affects under 100 currently regulated	3
10				City/county/state																			1	0		not affected	0
11				Individuals																			1	0		not affected	0
12				Custom entry																			1	0		not affected	0
13				Custom entry																			1	0		not affected	0
14				Stakeholder complexity
15
16																							3	Cell to left must be unlocked		medium, manageable opposition
17				External stakeholder interest
18				Selecting an interest level indicates the group to the left is a stakeholder.
19				Group		Interest drop down selection		Riskometer
20				Regulated community		high interest - for rule		1	2	3	4	5	6	7	8	9	10						5	high interest - for rule
21				Business and industry		high interest - for rule		1	2	3	4	5	6	7	8	9	10						5	high interest - for rule
22				Environmental groups		medium interest - against rule		1	2	3	4	5	6	7	8	9	10						8	medium interest - against rule
23				Public		does not apply		1	2	3	4	5	6	7	8	9	10						0	does not apply
24				State legislators		does not apply		1	2	3	4	5	6	7	8	9	10						0	does not apply
25				Federal environmental regulators		medium interest - for rule		1	2	3	4	5	6	7	8	9	10						4	medium interest - for rule
26				Other state and federal agencies		does not apply		1	2	3	4	5	6	7	8	9	10						0	does not apply
27				Local governments		does not apply		1	2	3	4	5	6	7	8	9	10						0	does not apply
28				Tribal nations		does not apply		1	2	3	4	5	6	7	8	9	10						0	does not apply
29				Custom entry		does not apply		1	2	3	4	5	6	7	8	9	10						0	does not apply
30				Custom entry		does not apply		1	2	3	4	5	6	7	8	9	10						0	does not apply
31
32
33						Interest average		1	2	3	4	5	6	7	8	9	10						6	medium	Interest in this proposal is medium.
34				Optional stakeholder information
35																							Summary
36				Advisory committee appointment		Type of committee (check all that apply)																	Interest in this proposal is medium. DEQ does not plan to appoint an advisory committee. We plan to ask the committee to provide advice.	FALSE	DEQ does not plan to appoint an advisory committee.
37				No advisory committee			Fiscal			Scientific													1	FALSE	FALSE
38				Use a standing committee			Policy			Rule language													none	FALSE	FALSE
39				Reconvene a committee			Technical			Legally required														FALSE	FALSE
40				Convene a new committee			Implementation			Custom entry														FALSE	FALSE
41				No. of meetings																			DEQ does not plan to appoint an advisory committee.		We plan to ask the committee to provide advice.
42					0																		0	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																		1

51				Portland area			No public notice																FALSE	none	No public notice
52				Regional			Public notice, no hearing																FALSE		FALSE
53					No. of meetings		Public notice with hearing
54					0		Re-notice
55				Optional hearing information
56
57				Reminders
58
59				Process improvement
60	Go to Top
61						October 6, 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			Clean Fuels - Phase II
3
4				Program name	Operations Division - Air Program Operations Section
5					drop down selection
6				Media	air				drop down selection
7				Program consequences of doing nothing					low
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 consequence here - Unnecesary financial burden on sources
16				Enter custom consequences here
17				Subject program considerations
18
19				Other DEQ program considerations
20
21				Dependencies
22
23
24				Optional dependency information
25
26				Include program considerations in:						drop down selection
27										definitely not complex
28							Complexity			1	2	3	4	5	6	7	8	9	10
29				Committee charter
30				Communication plan
31				Messsage map
32				Reminders
33
34				Process Improvement
35	Go to top
36							Monday, October 6, 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	Y	AA
1	⧀ Summary
2			5	Environmental			Greenhouse Gas Permitting - Temporary
3						drop down selection
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									drop down selection
7				Environmental consequences of doing nothing					low
8							Severity		1	2	3	4	5	6	7	8	9	10
9				Science does not apply to Oregon
10				Delay in public health protection
11				Adverse effect on vulnerable populations
12	DEQ - EJ			Adverse effect on environmental justice communities
13				Enter custom environmental consequence here
14				Enter custom environmental consequence here
15				Describe environmental considerations
16
17				Environmental reach
18				Select the most expansive environmental reach of this proposed rule.
19
20
21				Links
22				2011-2015 EPA Strategic Plan
23				The proposed rules align with actions in the EPA Strategic Plan:
24				Taking Action on Climate Change/Improving AQ
25				Protecting America's Waters
26				Ensuring Safety of Chemicals/Preventing Pollution
27				Enforcing Environmental Laws
28				Cleaning Up Communities/Advancing Sustainable Development
29
30				the Natural Step
31				The proposed rules support the elimination of Oregon's contribution to:
32				The progressive buildup of substances extracted from the Earth's crust (for example, heavy metals and fossil fuels)
33				The progressive buildup of chemicals and compounds produced by society (for example, dioxins, PCBs, and DDT)
34				The progressive physical degradation and destruction of nature and natural processes (for example, over harvesting forests and paving over critical wildlife habitat)
35				Conditions that undermine people’s capacity to meet their basic human needs (for example, unsafe working conditions and not enough pay to live on)
36				Environmental data
37
38
39										drop down selection
40				Include environmental consideration in:						does not apply
41				Committee charter				Complexity		1	2	3	4	5	6	7	8	9	10
42				Communication plan
43				Messsage map
44				Reminders
45
46				Process Improvement
47	Go to top
48							Monday, October 6, 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			Greenhouse Gas Permitting - Temporary
3
4				Rationale for developing proposal now - drivers
5				Some businesses may have to spend money to comply with rules that may go away soon.
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		2014	3
12				Advisory committee						not involved
13				Rulemaking notice						not involved
14				EQC Action		2014	4			Start date is out of sequence.
15				Effective		2014	4			Start date is out of sequence.
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											drop down selection
20				Include timing rational above in:							potential for minor complexity
21				Committee charter				Complexity			1	2	3	4	5	6	7	8	9	10
22				Communication plan
23				Messsage map
24				Reminders
25
26				Process Improvement
27	Go to Top
28								Monday, October 6, 2025