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Willamette Mercury Variance Comments
Willamette Mercury Variance Comments
With regard to the amendments to the variance authorization rule, it is unclear why the Department of Environmental Quality (DEQ) is choosing to establish its own variance rules since mostly all it has done is cut and past parts of the federal rule into its own, yet it has also omitted necessary parts of the federal rule. It has certainly rolled back any additional protections that Oregon’s rule already provided on the basis that those protections are not required by the federal rule. In other words, DEQ does not adopt a policy of providing any protection that could be justified as a matter of policy but only chooses to do the minimum
required by the U.S. Environmental Protection Agency (EPA). The problem with the proposed rule for the Mercury Variance starts with the fact that the
