Oregon Records Management Solution

  
From:	KNUDSEN Larry
Sent:	Tuesday, March 17, 2009 1:38 PM
To:	MCALLISTER Larry; JOHNDOHL Judy
Subject:	RE: SRF Draft EQC packet

I just got a chance to give these a quick read. The documents looked pretty good to me. I'll try to back 
over this tomorrow, but here is what I have now:
 
Staff Report:  The Department Recommendation should include having the EQC adopt the findings in the 
justification.  That means the statement of need and justification will need to be added as Attachment B. 
 
Statement of Need and Justification:  Under statutes implemented, I don't think we need to include ORS 
197.180.  I think we added that to a previous statement because we were essentially modifying the 
Division 18 rules without opening Division 18. That wouldn't apply here.
 
Rules:  I think I would say that the statutory authority for the rules is ORS 468.020 and 468.440 and the 
statutes implement are ORS 468.423 to 468.440.  But I realize there is not a lot of guidance or 
consistency on how to sort these out.  
 
0098(2).  I'm not sure I understand the last clause "is granted upon execution of the loan agreement."  Is 
that part of the definition or a limitation on how you plan to operate?
 
-----Original Message----- 
From: MCALLISTER Larry  
Sent: Monday, March 16, 2009 4:33 PM 
To: JOHNDOHL Judy 
Cc: Knudsen Larry 
Subject: SRF Draft EQC packet
Judy, Larry K,
I have attached the following documents for your final review.  I am also sending the 
same documents on to the Director�s Office.
-Staff Report
-Statement of Need and Justification
-Proposed rules to Div 54 (I have only included the last few pages of Div 54 since that is 
the location of the proposed new rules)
Larry I would really appreciate you taking a good look at the proposed rules to see if 
there is any hole we stepped over.  Comments would be appreciated as soon as 
possible.
Thanks,
Larry M.
X6412
<<EQCStaffReport 3-16-09.docx>>      <<EQC StmtNeedJustification3-16-09.docx>>      
<<proposed new rules 0098-00108.docx>> 
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