December 31, 2012

Paul Koprowski, Air Program Coordinator

U.S. Environmental Protection Agency

Oregon Operations Office

805 S.W. Broadway; Suite 500

Portland, OR 97205

RE: MOE Exception Request

Dear Paul:

As discussed, the Lane Regional Air Protection Agency (LRAPA) requests an exception, due to 

economic circumstances, from the maintenance-of-effort (MOE) requirements of the continuing air 

grant program under section 105 of the federal Clean Air Act. 

LRAPA has had to grapple with difficult economic conditions and variable levels of financial support in 

recent years. Economic recessions generally impact Oregon deeper and last longer than the rest of the 

United States, and the current recession from 2008 to present is no exception. As a result, LRAPA has 

experienced funding reductions from our major non-federal revenue sources and must request an 

exception from the MOE requirements for FY2012 and FY2013. [LRAPA has consistently met the 40% 

minimum match criterion, the other statutory cost-sharing provision in section 105, and is projected to 

continue to do so in future years.]

For review, LRAPA is the only local air pollution control agency in Oregon. It was established under 

Oregon statutes adopted by the 1967 Legislative Assembly and an intergovernmental agreement 

between Lane County and the cities of Eugene, Springfield, Cottage Grove and Oakridge. LRAPA is a 

local single-purpose air quality agency authorized to implement most aspects of state air quality rules 

and the federal Clean Air Act. The chief executive is the LRAPA Executive Director and the fiscal 

decision-making body is the 9-member LRAPA Board of Directors. 

The detailed budget information and supporting documentation are attached, but the MOE worksheet 

calculations are illustrated in the first attached graph and summarized as follows:

 Actual MOE = $1,010,832 in FY 2008 (July 1, 2007 to June 30, 2008);

 Actual MOE = $1,064,539 in FY 2009 (July 1, 2008 to June 30, 2009);

 Actual MOE = $1,067,889 in FY 2010 (July 1, 2009 to June 30, 2010);

 Actual MOE = $1,068,396 in FY 2011 (July 1, 2010 to June 30, 2011);

 Actual MOE = $935,855 in FY 2012 (July 1, 2011 to June 30, 2012); and

 Projected MOE = $800,313 in FY 2013 (July 1, 2012 to June 30, 2013).

LRAPA has evaluated its expenditure reductions in FY2012 (and its projected expenditures in FY2013) 

in accordance with the September 30, 2011 EPA guidance on MOE exceptions. We believe the LRAPA 

situation clearly meets the EPA criteria. 

 The expenditure reductions were the result of adverse economic conditions;

 Air program expenditure reductions were the result of general reductions in the LRAPA budgets;

 Air program expenditures were not singled out for disproportionate reductions; and 

 Air program expenditures were not reduced in order to increase funding for programs or 

activities that clearly degrade air quality and jeopardize the public's health.

1010 Main Street

Springfield, OR 97477

Phone: (541) 736-1056

Fax (541) 726-1205

1-877-285-7272

www.lrapa.org

E-mail: lrapa@lrapa.org
Paul Koprowski, EPA Oregon Operations Office

December 31, 2012

Page 2

The recent reductions in LRAPA funding are illustrated in the second attached graph. The biggest 

reductions occurred in LRAPA funding from state and local general funds. These reductions are the 

direct result of the economic recession. 

As a single-purpose air quality agency, most of the LRAPA programs are closely related to section 105 

program implementation. The major exception is the Title V industrial permitting-compliance program 

which relies on dedicated permit fees, and which is excluded and separate from the MOE calculations. 

A few other LRAPA programs are pass-through air quality grant programs with dedicated federal grant 

funding, which are also separate from the MOE calculations.

In order to operate within its FY2012 and FY2013 budgets, LRAPA implemented a combination of 

unpaid furlough days, schedule reductions, and systematic across-the-board reductions wherever 

possible in materials and services (M&S) expenses. In addition, open positions resulting from 

retirements or resignations were left vacant, with the related responsibilities redistributed, reduced, 

postponed or eliminated. The net result was an overall reduction across all LRAPA programs.

Therefore, LRAPA specifically requests that EPA reset our MOE, for the purposes of meeting the 

statutory cost-sharing provisions in section 105 of the Clean Air Act, to the following:

 $935,855 in FY 2012 (July 1, 2011 to June 30, 2012); and

 $800,013 in FY 2013 (July 1, 2012 to June 30, 2013).

Detailed documentation is attached. I look forward to discussing this request with you in the near future.

Sincerely,

Merlyn L. Hough

LRAPA Executive Director

Enclosure: LRAPA Documentation of Maintenance of Effort (MOE)
Paul Koprowski, EPA Oregon Operations Office

December 31, 2012

Page 3
Paul Koprowski, EPA Oregon Operations Office

December 31, 2012

Page 4
LRAPA Documentation of Maintenance of Effort (MOE) Page 1

LRAPA Request to EPA Oregon Operations Office 

for MOE Exception for FY2012 and FY2013 

December 31, 2012

EXECUTIVE SUMMARY

The Lane Regional Air Protection Agency (LRAPA) requests an exception, due to 

economic circumstances, from the maintenance-of-effort (MOE) requirements of the 

continuing air grant program under section 105 of the federal Clean Air Act. 

LRAPA has had to grapple with difficult economic conditions and variable levels of 

financial support in recent years. Economic recessions generally impact Oregon deeper 

and last longer than the rest of the United States, and the current recession from 2008 

to present is no exception. As a result, LRAPA has experienced funding reductions from 

our major non-federal revenue sources and must request an exception from the MOE 

requirements for FY2012 and FY2013. [LRAPA has consistently met the 40% minimum 

match criterion, the other statutory cost-sharing provision in section 105, and is 

projected to continue to do so in future years.]

For review, LRAPA is the only local air pollution control agency in Oregon. It was 

established under Oregon statutes adopted by the 1967 Legislative Assembly and an 

intergovernmental agreement between Lane County and the cities of Eugene, 

Springfield, Cottage Grove and Oakridge. LRAPA is a local single-purpose air quality 

agency authorized to implement most aspects of state air quality rules and the federal 

Clean Air Act. The chief executive is the LRAPA Executive Director and the fiscal 

decision-making body is the 9-member LRAPA Board of Directors. 

The detailed budget information and supporting documentation are included in this 

report, and the MOE worksheet calculations are summarized as follows:

 Actual MOE = $1,010,832 in FY 2008 (July 1, 2007 to June 30, 2008);

 Actual MOE = $1,064,539 in FY 2009 (July 1, 2008 to June 30, 2009);

 Actual MOE = $1,067,889 in FY 2010 (July 1, 2009 to June 30, 2010);

 Actual MOE = $1,068,396 in FY 2011 (July 1, 2010 to June 30, 2011);

 Actual MOE = $935,855 in FY 2012 (July 1, 2011 to June 30, 2012); and

 Projected MOE = $800,313 in FY 2013 (July 1, 2012 to June 30, 2013).
LRAPA Documentation of Maintenance of Effort (MOE) Page 2

LRAPA has evaluated its expenditure reductions in FY2012 (and its projected 

expenditures in FY2013) in accordance with the September 30, 2011 EPA guidance on 

MOE exceptions. We believe the LRAPA situation clearly meets the EPA criteria. 

 The expenditure reductions were the result of adverse economic conditions;

 Air program expenditure reductions were the result of general reductions in the 

LRAPA budgets;

 Air program expenditures were not singled out for disproportionate reductions; 

 Air program expenditures were not reduced in order to increase funding for 

programs or activities that clearly degrade air quality and jeopardize the public's 

health.

As a single-purpose air quality agency, most of the LRAPA programs are closely related 

to section 105 program implementation. The major exception is the Title V industrial 

permitting-compliance program which relies on dedicated permit fees, and which is 

excluded and separate from the MOE calculations. A few other LRAPA programs are 

pass-through air quality grant programs with dedicated federal grant funding, which are 

also separate from the MOE calculations. 

In order to operate within its FY2012 and FY2013 budgets, LRAPA implemented a 

combination of unpaid furlough days, schedule reductions, and systematic across-theboard reductions wherever possible in materials and services (M&S) expenses. In 

addition, open positions resulting from retirements or resignations were left vacant, with 

the related responsibilities redistributed, reduced, postponed or eliminated. The net 

result was an overall reduction across all LRAPA programs.

Therefore, LRAPA specifically requests that EPA reset our MOE, for the purposes of 

meeting the statutory cost-sharing provisions in section 105 of the Clean Air Act, to the 

following:

 $935,855 in FY 2012 (July 1, 2011 to June 30, 2012); and

 $800,013 in FY 2013 (July 1, 2012 to June 30, 2013).

This documentation is provided to support the LRAPA request to EPA to adjust the 

MOE for FY2012 and FY2013.
LRAPA Documentation of Maintenance of Effort (MOE) Page 3

BACKGROUND

What is the Lane Regional Air Protection Agency?

Lane Regional Air Protection Agency (LRAPA) is a local air agency authorized by state 

law to implement most aspects of state air quality rules and the federal Clean Air Act. 

The geographic jurisdiction of a local air agency may consist of a single county or may 

include multiple counties. LRAPA has jurisdictional responsibilities for Lane County, 

Oregon, and the cities within Lane County. The decision to create a local air agency is 

made by the governing bodies of the county or counties included in the jurisdictional 

boundary of the Agency. The applicable Oregon statutes are primarily in ORS 468A.

The chief executive is the LRAPA Executive Director and the fiscal decision-making 

body is the 9-member LRAPA Board of Directors.

What are the duties and mandates of a Local Air Agency?

LRAPA generally has these basic functions: 

 permitting of stationary (not mobile) industrial and other emission sources;

 adopting and implementing local regulations to meet local needs;

 enforcement of federal, state or local regulations relating to air pollution control; 

 monitoring the ambient air quality; 

 coordination and development of local air pollution control strategies for any 

nonattainment areas as part of the Oregon Clean Air State Implementation Plan; and 

 public education and outreach regarding air quality. 

In order to enforce federal regulations, LRAPA must receive delegation of specific 

programs from the U.S. Environmental Protection Agency (EPA). In order to receive 

delegation, LRAPA must adopt the necessary regulations and have staff capable of 

implementing them. A contract with EPA is agreed upon and outlines federal, state and 

local commitments to operate delegated federal programs. In Oregon, the 

Environmental Quality Commission (EQC) and the Department of Environmental Quality 

(DEQ) are responsible for statewide environmental regulatory oversight, while LRAPA 

and its Board performs similar regulatory duties for air quality in Lane County.

What does LRAPA actually do?

LRAPA performs a variety of tasks. Foremost, it regulates statutorily identified 

categories of activity that contribute to air pollution. Additionally, it monitors the ambient 

air quality within its jurisdiction, responds to citizen concerns about potential air 

pollution, enforces federal and state air quality regulations, reviews applications for 

projects which require permits, and issues such permits. LRAPA administers air quality 

grants that provide funding directly to communities for emission reduction projects. 

LRAPA also provides public education and facilitate citizen involvement in local air 

quality issues. Further, LRAPA operates in a transparent manner so as to ensure the 

public has access to information about current air quality and access to information 

concerning major sources of air pollution within its jurisdiction. Examples of LRAPA's 

transparency include its annual report and website.
LRAPA Documentation of Maintenance of Effort (MOE) Page 4

How is LRAPA funded?

Generally, the operational funding of a Local Air Agency such as LRAPA is a 

combination of permit fees, federal and state grants, and contributions by local partner 

governments. LRAPA also receives Airmetrics enterprise revenues, unique among 

Local Air Agencies, from the local manufacture of portable air monitoring devices now 

sold throughout the world. Major industrial source programs under Title V of the federal 

Clean Air Act require the Agency to collect fees equal to the cost of operating the Title V 

air permit program. Other air quality protection programs required by state and federal 

law allow the Agency to establish fees that cover the cost of the programs. Similarly, for 

minor emission source permitting programs (the various air contaminant discharge 

permits), the Agency is authorized to establish fees to cover the cost of the programs. 

Oregon law prevents LRAPA from receiving enforcement fines and penalties as a 

funding source. All LRAPA fines, after legal fees are recovered, are directed to the 

Lane County General Fund or up to 80% of a fine may be directed to a Supplemental 

Environmental Project.

To whom is LRAPA accountable?

LRAPA is a regional air quality control authority authorized by state statute (ORS 

468A.105) and established by a local intergovernmental agreement between Lane 

County and the cities of Cottage Grove, Eugene, Oakridge and Springfield. LRAPA 

financial statements are audited annually by an independent auditor in accordance with 

the Government Auditing Standards issued by the U.S. Comptroller General. As an 

EPA-delegated program, the Agency receives performance audits by the EPA as part of 

its audits of the overall Oregon programs. Most importantly, LRAPA is accountable to 

the citizens within its jurisdiction to faithfully perform its duties and thereby contribute to 

community health and well-being. 

Where can I find more information on the duties and procedures of the LRAPA 

Board?

The LRAPA Citizens Advisory Committee and LRAPA Board of Directors completed a 

Handbook for Board Members in May 2012. It provides more details on the duties and 

mandates of LRAPA, as well as the responsibilities of board members, board protocols, 

characteristics of effective board members, notification of meetings, public disclosure, 

ethics, and conflicts of interest. The handbook also outlines the corresponding duties of 

the LRAPA Citizens Advisory Committee and the LRAPA Executive Director and 

includes references with more detailed information.
LRAPA Documentation of Maintenance of Effort (MOE) Page 5

AIR QUALITY PRIORITIES AND PROGRESS

What are the priorities of LRAPA?

LRAPA updated its strategic plan in 2007 and has updated its strategic future priorities 

(and reviewed recent successes) each July since then. A copy of the July 2012 report is 

linked here.

What are the vision and mission of LRAPA that guides these priorities?

 Vision: "Community partners working together to ensure clean air for 

everyone."

 Mission: "To protect public health and the environment as a leader and 

advocate for the continuous improvement of air quality in Lane County."

What are the strategic goals of LRAPA to implement this vision and mission?

1. Air Quality: To ensure healthful air quality for all Lane County citizens.

2. Involvement: To inform and involve citizens and businesses in improving air 

quality.

3. Service: To serve citizens and other stakeholders fairly, courteously, and in a 

timely manner.

4. Partnerships: To work with our partners to leverage resources to make a 

difference in local air quality.

How is LRAPA doing on achieving these strategic goals and priorities?

LRAPA and our partners are doing remarkably well, even in these difficult economic 

times, as summarized in the linked letters and reports. For example:

 Air Quality: We have been remarkably successful in achieving and maintaining 

compliance with air quality health standards for particulate matter, ozone and carbon 

monoxide in Eugene for over 20 years, despite the tightening of national standards 

in 1988, 1997, 2006, and 2008. See the progress and trends in State of the Air. 

Involvement: LRAPA provides local control and decision-making, and frequent 

meetings/inspections of permitted facilities and asbestos abatement projects. 

 Service: Annual surveys conducted by the LRAPA Advisory Committee consistently 

report exceptional staff service on permit modifications, permit renewals, new permit 

applications, and construction permit reviews. Industry representatives appreciate 

the focus at LRAPA to minimize air pollution by working with industrial sources to 

maximize compliance with the prescribed standards.

 Partnerships: Independent of business permitting programs (which pay their own 

way), LRAPA has been successful in leveraging other funds. For example, we 

provide $2.72 of services for every dollar of local dues, as well as $2.10 of passthrough funding assistance to businesses, schools and residents for clean air 

projects. 
LRAPA Documentation of Maintenance of Effort (MOE) Page 6

BUDGET ANALYSIS 

Economic Recession and Impacts on Oregon Budgets

Economic recessions generally impact Oregon deeper and last longer than the rest of 

the United States, and the current recession from 2008 to present is no exception. 

The Oregon economic forecasts have resulted in a series of budget reductions in state 

general funds during FY2009, FY2010, FY2011, FY2012, and FY2013. These state 

general fund budget reductions have impacted both Oregon DEQ and LRAPA. Counties 

and cities of Oregon have been similarly affected by the economic recession, and these

county and city budget reductions have correspondingly impacted the local funding 

received by LRAPA. 

Reduced State Funding for Lane Regional Air Protection Agency

Since mid-way through the 2007-2009 biennium, revenues to the General Fund of the 

State of Oregon have declined. In response, the state has reduced agency budgets 

through a variety of measures including across the board mandatory unpaid furlough 

leave for state employees, wage and spending freezes, eliminating normal budget 

increases for inflation and identifying specific work and associated spending cuts to 

agency budgets. Below is a link to the analysis of the Oregon 2011-2013 Legislatively 

Adopted Budget published by the Legislative Fiscal Office: 

http://www.leg.state.or.us/comm/lfo/2011-13%20LAB.pdf

For the 2011-2013 biennial budget, DEQ was required to provide the Legislature with 

General Fund cut options. The Legislature reduced agency General Fund by 

approximately 24 percent overall. No particular program was singled out for reductions. 

Air Quality’s General Fund was cut by 31 percent, Water Quality’s by 31 percent and 

Land Quality by 44 percent, while General Fund for debt service increased to meet debt 

repayment obligations. Attachment A provides a summary of the DEQ 2011-2013 

Legislatively Adopted Budget by program by fund type.

The DEQ Air Quality budget includes state General Fund support for LRAPA as a 

separate item, Special Payments, in its biennial budget. As Air Quality is required to 

offer General Fund reductions in the budget development process, a similar percentage 

of LRAPA General funding is also offered as a reduction. Attachment B is the General 

Fund reduction list that DEQ submitted to the legislature. Reduction #3 on the 

Attachment B list ($112,544 for the biennium), is a 31% reduction to LRAPA General 

Fund support. Attachment C is the official Air Quality program budget for 2011-2013. 

The amounts that affect LRAPA are highlighted in yellow.

DEQ’s budget also includes General Fund support for current and former communities 

that violate National Ambient Air Quality Standards for particulate. The funding helps the 

communities to implement woodstove curtailment efforts to attain and maintain 

compliance with national standards. LRAPA receives a small amount of state General 

Fund from this funding; however, it is embedded in the Air Quality Services and 
LRAPA Documentation of Maintenance of Effort (MOE) Page 7

Supplies budget and cannot be identified separately. Reduction #4 in Attachment B is a 

reduction of $76,105 to the $246,720 biennial funding for this work statewide.

Attachment D provides a summary of the amount of reduced state General Fund 

support for LRAPA in fiscal year 2012. In total, DEQ reduced General Fund support to 

LRAPA by $66,601, $58,981 from direct General Fund support and $7,620 from 

woodstove curtailment.

Reduced Local Funding for Lane Regional Air Protection Agency

The budget crises in Lane County from FY2008 to FY2013 have been similarly severe 

to those of the State of Oregon. The Lane County budget reductions in recent years are 

reviewed on its website. The most recent Lane County Budget in Brief is included as 

Attachment E. 

For example, the Lane County general fund budget was reduced by 17% in FY2013, in 

addition to the 11% reduction in FY2012, for a total reduction of about 26% over the 2-

year period (for comparison to the biennial reduction in State General Fund mentioned 

previously). The linked and attached documents have additional details, but here is the 

Lane County budget overview for recent years (in $ millions) including the County 

General Fund which is most closely related to local LRAPA funding:

Budget Category FY2010 FY2011 FY2012 FY2013

Total Budget All Funds $680.6 $644.6 $579.5 $479.1

County General Fund $111.0 $106.1 $94.2 $78.1

A few recent media articles on the budget crises in Lane County and the City of Eugene 

are included as Attachment F. 

Cost-Share Requirements of Federal Air Grant Programs Under the Clean Air Act 

Section 105 of the federal Clean Air Act provides grant assistance to state and local air 

agencies to support their continuing air pollution control programs. Section 105 contains 

two cost-sharing provisions intended to ensure adequate recipient support: a minimum 

of 40% recipient match, and a maintenance of effort (MOE) requirement. MOE requires 

a recipient to expend at least as much for recurrent program activities each grant year 

as it did the previous grant year. The latest MOE guidance was provided by EPA on 

September 30, 2011.

LRAPA has consistently met the 40% minimum match criterion, and is projected to 

continue to do so in future years. But as a result of the difficult economic conditions in 

recent years, LRAPA has experienced funding reductions from our major non-federal 

revenue sources and must request an exception from the MOE requirements for 

FY2012 and FY2013. 

The primary purpose of this report is to provide the necessary documentation for 

LRAPA to request a MOE exception from EPA consistent with the MOE guidance dated 
LRAPA Documentation of Maintenance of Effort (MOE) Page 8

September 30, 2011. The MOE guidance includes ten questions to assist LRAPA and 

EPA in the determination that MOE reductions are non-selective; responses to those 

specific questions are included in Attachment G. The MOE guidance also outlines 

several guideline to determine whether a non-selective reduction in MOE is appropriate; 

the LRAPA responses to the four criteria applicable to LRAPA are:

 The LRAPA expenditure reductions were the result of adverse economic 

conditions;

 Air program expenditure reductions were the result of general reductions in the 

LRAPA budgets;

 Air program expenditures were not singled out for disproportionate reductions; 

 Air program expenditures were not reduced in order to increase funding for 

programs or activities that clearly degrade air quality and jeopardize the public's 

health.

LRAPA is a local single-purpose air quality agency, and the LRAPA Board of Directors 

is the fiscal decision-making body and executive agency for MOE calculation purposes. 

But it is not surprising that overall MOE reductions at LRAPA mirror the overall 

reductions in state and local general funding. For example, the actual LRAPA MOE 

reduction between FY2011 and FY2012 is about 12% compared to an 11% reduction in 

Lane County General Fund for the same period; and similarly, the projected 2-year 

LRAPA MOE reduction between FY2011 and FY2013 is about 25% compared to a 26% 

reduction in Lane County General Fund and a 24% reduction in State General Fund for 

the same period.

Economic Recession and Impact on LRAPA Budget

LRAPA has had to grapple with the difficult economic conditions and variable levels of 

financial support in recent years. In order to operate within its FY2012 and FY2013 

budgets, LRAPA implemented a combination of unpaid furlough days, schedule 

reductions, and systematic across-the-board reductions wherever possible in materials 

& services expenses. In addition, open positions resulting from retirements or 

resignations were left vacant, with the related responsibilities redistributed, reduced, 

postponed or eliminated. The net result was an overall non-selective reduction across 

all LRAPA programs.

For example, in order to stay within budget, LRAPA had to implement most of the 

contingency measures in its 5-year budget plan and reduced staffing from 23.4 FTE in 

the FY2008 budget to 19.3 FTE in the FY2012 proposed budget and then 16.5 FTE in 

the final FY2012 budget. The contingency measures in FY2012 included the elimination 

of all air toxics monitoring in Lane County, a significant reduction in travel & training and 

materials & services, and a reduction of almost three FTE:

 0.2 FTE from 12 furlough days per year by the director and managers;

 0.2 FTE from four furlough days (total office closures) per year by all staff;

 0.3 FTE elimination of part-time and intern staffing;

 0.5 FTE reduction in Airmetrics staffing;

 0.5 FTE reduction in woodstove replacement program staffing;
LRAPA Documentation of Maintenance of Effort (MOE) Page 9

 0.5 FTE reduction in airshed planning staffing;

 0.2 FTE reduction in monitoring staffing;

 0.2 FTE reduction in permitting staffing; and

 0.2 FTE reduction in compliance staffing.

In FY2013, three positions from retirement or resignations were left vacant, with the 

related responsibilities redistributed, reduced, postponed or eliminated, and the furlough 

days and schedule reductions were discontinued. These FTE reductions affected all 

staff directly or indirectly. For example, the reduction in staffing of the woodstove 

replacement program required a team effort by other existing staff to fill this gap and 

complete the project; the reduction in airshed planning staffing required a team effort to 

fill that gap and complete the Oakridge PM2.5Attainment Plan.

These FTE reductions, as well as reductions in materials & services and travel & 

training, affected all of the LRAPA air programs. The reductions significantly reduced

the amount of non-mandated ambient air monitoring and the number of compliance 

inspections and complaint responses. LRAPA programs continue to be implemented on 

a priority basis.

LRAPA Budget Reductions and Effect on MOE

The following series of stacked-bar charts (Figures A, B and C) illustrate the LRAPA 

budget reductions and the effect on the MOE calculation. 
LRAPA Documentation of Maintenance of Effort (MOE) Page 10

Figure A illustrates that LRAPA met the MOE requirement (i.e., MOE requires a 

recipient to expend at least as much for recurrent program activities each grant year as 

it did the previous grant year) in FY2009, FY2010, and FY2011, but did not meet the 

MOE requirement in FY2012 and is not projected to meet the MOE requirement in 

FY2013. The MOE data is summarized as follows:

 Actual MOE = $1,010,832 in FY 2008 (July 1, 2007 to June 30, 2008);

 Actual MOE = $1,064,539 in FY 2009 (July 1, 2008 to June 30, 2009);

 Actual MOE = $1,067,889 in FY 2010 (July 1, 2009 to June 30, 2010);

 Actual MOE = $1,068,396 in FY 2011 (July 1, 2010 to June 30, 2011);

 Actual MOE = $935,855 in FY 2012 (July 1, 2011 to June 30, 2012); and

 Projected MOE = $800,313 in FY 2013 (July 1, 2012 to June 30, 2013).
LRAPA Documentation of Maintenance of Effort (MOE) Page 11

Figure B illustrates that the MOE-related expenditures were reduced in all categories in 

FY2012 as a result of the overall LRAPA budget reductions, and that MOE-related 

expenditures will be further reduced in FY2013.
LRAPA Documentation of Maintenance of Effort (MOE) Page 12

Figure C illustrates that the reductions in MOE in FY2012 and FY2013 are the result of 

funding reductions from all of the major LRAPA non-federal revenue sources.

Detailed LRAPA FY2012 Budget Analysis

The following series of pie charts (Figures 1-11) illustrate in more detail the LRAPA 

budget and resource allocation for FY2012. These figures are not directly comparable to 

the previous MOE graphs since they include all budgeted core revenues (including 

federal funds and Title V permit fees that are not part of the MOE calculation) but they 

are useful for illustrating the range of air quality programs within the LRAPA core 

budget.
LRAPA Documentation of Maintenance of Effort (MOE) Page 13

The first pie chart summarizes the budgeted LRAPA core revenue sources for the most 

recently completed budget year (July 1, 2011 through June 30, 2012). Various permit 

fees provided about 65% of the LRAPA core revenue, and the various general fund 

sources (local, state and federal) provided about 32%. [When LRAPA began in 1968, all 

of the funding was from general fund sources.]
LRAPA Documentation of Maintenance of Effort (MOE) Page 14

The various general fund revenue sources are broken down in the second graph. Local 

contributions are required to at least equal state general funds. Local and state funds in 

turn are used to provide match for the federal funds and to help meet the Maintenance 

of Effort (MOE) requirements for federal air grants. [Major industry permit fees (i.e., Title 

V), federal grants, and non-recurring expenses are not included in the MOE 

calculations.]
LRAPA Documentation of Maintenance of Effort (MOE) Page 15

The various permit fee revenue sources are broken down in the third graph. 
LRAPA Documentation of Maintenance of Effort (MOE) Page 16

The fourth graph summarizes the LRAPA staff time distribution for calendar year 2011. 

Overall, the permit fees at least cover the costs of the permitting programs, although 

there are some fluctuations from year to year due to the number of projects requiring 

permit fees (e.g., asbestos abatement work related to demolition or renovation projects) 

or startup costs of new programs (e.g., gasoline dispensing facilities, autobody shops). 
LRAPA Documentation of Maintenance of Effort (MOE) Page 17

The fifth graph summarizes the major LRAPA programs provided by general funds 

during 2011-2012. The costs of these programs slightly exceed the amount of general 

fund revenues during 2011-2012; the difference is provided by reserves or other funds. 
LRAPA Documentation of Maintenance of Effort (MOE) Page 18

The sixth graph summarizes the geographic areas of these same LRAPA programs 

provided by general funds during 2011-2012.
LRAPA Documentation of Maintenance of Effort (MOE) Page 19

The seventh graph summarizes the geographic areas of LRAPA monitoring and 

reporting during 2011-2012. Most of the monitoring is in Eugene (based on population 

and air quality maintenance reasons) and Oakridge (based on PM attainment and 

maintenance reasons). 
LRAPA Documentation of Maintenance of Effort (MOE) Page 20

The eighth graph summarizes the LRAPA monitoring and reporting during 2011-2012 

by pollutant. Most of the monitoring is for PM2.5 purposes.

The next two graphs (Figures 9 and 10) summarize the locations and sources of air 

pollution complaints during 2011-2012. 
LRAPA Documentation of Maintenance of Effort (MOE) Page 21
LRAPA Documentation of Maintenance of Effort (MOE) Page 22

The last graph summarizes the populations of LRAPA's intergovernmental partners, 

which is the calculation basis for requested dues from the partners.

CONCLUSIONS REGARDING MAINTENANCE OF EFFORT REQUIREMENTS

The Lane Regional Air Protection Agency (LRAPA) needs to request an exception, due 

to economic circumstances, from the maintenance-of-effort (MOE) requirements of the 

continuing air grant program under section 105 of the federal Clean Air Act. 

LRAPA is a local single-purpose air quality agency authorized to implement most 

aspects of state air quality rules and the federal Clean Air Act. The chief executive is the 

LRAPA Executive Director and the fiscal decision-making body is the 9-member LRAPA 

Board of Directors. 

LRAPA has had to grapple with difficult economic conditions and variable levels of 

financial support in recent years. Economic recessions generally impact Oregon deeper 

and last longer than the rest of the United States, and the current recession from 2008 
LRAPA Documentation of Maintenance of Effort (MOE) Page 23

to present is no exception. As a result, LRAPA has experienced funding reductions from 

its major non-federal revenue sources and must request an exception from the MOE 

requirements for FY2012 and FY2013. 

LRAPA has evaluated its expenditure reductions in FY2012 (and its projected 

expenditures in FY2013) in accordance with the September 30, 2011 EPA guidance on 

MOE exceptions. LRAPA believes its situation clearly meets the EPA criteria. 

 The expenditure reductions were the result of adverse economic conditions;

 Air program expenditure reductions were the result of general reductions in the 

LRAPA budgets;

 Air program expenditures were not singled out for disproportionate reductions; 

 Air program expenditures were not reduced in order to increase funding for 

programs or activities that clearly degrade air quality and jeopardize the public's 

health.

As a single-purpose air quality agency, most of the LRAPA programs are closely related 

to section 105 program implementation. The major exception is the Title V industrial 

permitting-compliance program which relies on dedicated permit fees, and which is 

excluded and separate from the MOE calculations. 

In order to operate within its FY2012 and FY2013 budgets, LRAPA implemented a 

combination of unpaid furlough days, schedule reductions, and systematic across-theboard reductions wherever possible in materials & services expenses. In addition, open 

positions resulting from retirements or resignations were left vacant, with the related 

responsibilities redistributed, reduced, postponed or eliminated. The net result was an 

overall reduction across all LRAPA programs.

Therefore, LRAPA specifically requests that EPA reset its MOE, for the purposes of 

meeting the statutory cost-sharing provisions in section 105 of the Clean Air Act, to the 

following:

 $935,855 in FY 2012 (July 1, 2011 to June 30, 2012); and

 $800,313 in FY 2013 (July 1, 2012 to June 30, 2013).

MLH:mlh (12/31/2012)
Attachment A
Environmental Quality, Dept of 

Agencywide Program Unit Summary Versio2011-13 Biennium

Summary Cross Reference Number

2011-13

Agency

Request

Budget

2009-11 Leg

Approved

Budget

2009-11 Leg

Adopted

Budget

2007-09

Actuals

Cross Reference Description

001-00-00-00000 Air Quality

General Fund 9,557,999 7,768,464 7,633,053 8,249,664 Other Funds 31,479,705 38,514,722 38,514,722 42,977,675 Federal Funds 4,897,199 7,447,395 7,447,395 8,781,418 

All Funds 45,934,903 53,730,581 53,595,170 60,008,757 

002-00-00-00000 Water Quality

General Fund 19,407,897 19,314,798 19,126,500 21,364,985 Lottery Funds 5,610,171 5,426,117 5,415,717 5,632,937 Other Funds 17,714,771 21,168,587 21,165,014 22,053,405 Federal Funds 10,606,019 12,049,066 12,049,066 12,538,370 

All Funds 53,338,858 57,958,568 57,756,297 61,589,697 

003-00-00-00000 Land Quality

General Fund 2,091,894 995,736 967,313 1,925,335 Other Funds 46,356,874 55,581,888 55,581,888 56,407,864 Federal Funds 10,473,867 15,408,604 15,408,604 11,337,457 

All Funds 58,922,635 71,986,228 71,957,805 69,670,656 

004-00-00-00000 Agency Management

Other Funds 20,666,415 21,249,534 21,249,534 23,338,013 

_____ Agency Request _____ Governor's Recommended 

2011-13 Biennium Page __________ Agen
Environmental Quality, Dept of 

Agencywide Program Unit Summary Versio2011-13 Biennium

Summary Cross Reference Number

2011-13

Agency

Request

Budget

2009-11 Leg

Approved

Budget

2009-11 Leg

Adopted

Budget

2007-09

Actuals

Cross Reference Description

005-00-00-00000 Cross-Media

General Fund 674,001 658,776 658,776 742,324 Other Funds 354,164 149,645 149,645 171,191 Federal Funds 475,422 1,030,249 1,030,249 1,127,660 

All Funds 1,503,587 1,838,670 1,838,670 2,041,175 

008-00-00-00000 Non-Limited

Other Funds 133,527,390 174,778,200 174,778,200 110,225,000 

009-00-00-00000 PCBF Debt Service

General Fund 4,712,840 4,592,353 4,592,353 5,573,180 Other Funds 4,643,292 15,492,548 15,492,548 16,388,801 

All Funds 9,356,132 20,084,901 20,084,901 21,961,981 

TOTAL AGENCY

General Fund 36,444,631 33,330,127 32,977,995 37,855,488 Lottery Funds 5,610,171 5,426,117 5,415,717 5,632,937 Other Funds 254,742,611 326,935,124 326,931,551 271,561,949 Federal Funds 26,452,507 35,935,314 35,935,314 33,784,905 

All Funds 323,249,920 401,626,682 401,260,577 348,835,279 

_____ Agency Request _____ Governor's Recommended 

2011-13 Biennium Page __________ Agen
Attachment B
 


Oregon Department of Environmental Quality

2011 - 2013 Biennium Agency Number: 34000

Detail of General Reductions Incorporated in 2011-13 Legislatively Adopted Budget

1 2 3 4 5 6 7 12 16

Dept. 

Initials

Prgm. or 

Activity 

Initials

Program Unit/Activity Description An Rec

Pkg 085

An Rec

Pkg 090

LFO Rec

Pkg 810

 TOTAL 

FUNDS POS FTE POS FTE POS FTE Impact of Reduction on Services and Outcomes

Dept Prgm/ 

Div

1 3 DEQ AQ Air Quality Monitoring Efficiencies $ 265,487 $ 265,487 2 1.50 

The Air Monitoring section has streamlined operations which reduces staffing needs. They reduced 

quality assurance, network review and audit frequencies. Using regional staff or contractors to collect 

samples at remote sites saves travel time and costs. New data management system also provides 

efficiencies. EPA is adding many new monitoring requirements and normally these resources would be 

shifted to cover some of the new work.

2 1 DEQ LQ Eliminate .50 Hazardous Waste manager 

position in Eastern Region $ 175,516 $ 175,516 0 0.50

Consolidate Solid Waste & Hazardous Waste sections in Eastern Region, resulting in a larger span of 

control and expanded areas of responsibility. Could result in less manager attention to some program 

issues.

3 2 DEQ AQ Reduce Support for Lane Regional Air 

Protection Agency $ 112,544 $ 112,544 0 -

This cut would result in an across the board reduction for LRAPA through furloughs or other reductions. 

It would reduce the amount of inspections, air monitoring, reporting, forecasting, complaint responses, 

permits issued, enforcement actions, grant applications, and open office hours.

4 1 DEQ AQ Reduce Local Government Air Quality 

Outreach $ 76,105 $ 76,105 0 -

Reduces funding for local government fine particulate reduction outreach. DEQ’s support for these 

former non-attainment areas is a federal requirement of the State Implementation Plan (SIP). Work 

supported includes: daily air quality advisories, voluntary woodstove curtailment programs and 

conducting wood smoke public education activities to reduce emissions. May result in higher fine 

particulate emissions or in some communities, violation of the federal standard.

5 4 DEQ AQ Reduce Air Toxics Outreach $ 132,957 $ 132,957 1 0.50 

Cuts outreach work to reduce benzene and PAH emissions, two of the most significant toxic air 

pollutants. Reduction efforts target dry cleaners, gas stations and development of community burn ban 

and woodstove ordinances.

6 2 DEQ LQ

Shift a portion of existing Ballast Water 

program to new fee funding authorized in 

SB 81

$ 23,615 $ 23,615 0 -

Shifts program funding to fee funding sooner than planned, leaving less 2013-15 beginning balance for 

industry-supported increase in technical assistance and compliance efforts.

7 11 DEQ AQ Reduce Clean Diesel work $ 254,762 $ 254,762 1 1.00 

Reduce overall clean diesel work. The immediate impact would be eliminating the Fleet Forward clean 

diesel recognition program. The program recognizes fleets that burn less fuel, cleaner fuel and reduce 

diesel exhaust. Long term the reduction to education and outreach will make it more difficult to reach 

the statutatory goal to reduce the excess cancer risk from diesel engine emissions by 2017.

8 1 DEQ WQ Reduce State Water Quality Permitting, 

WPCF $ 393,105 $ 393,105 2 2.00

Reduces inspections, technical assistance and permit renewals for permittees that land apply their 

effluent. Permit renewals will be delayed. This means that DEQ will be unable to assure the public 

that permitted discharges are in compliance and potential water pollution violations will go unchecked. 

9 9 DEQ AQ Eliminate Carbon Monoxide and PM 10 

Monitoring $ 211,336 $ 211,336 0 1.00 

Eliminates carbon monoxide sites in Medford and Portland and four PM10 sites (Klamath Falls, 

Medford, Grants Pass, and Pendleton). The loss of the CO sites would eliminate the last two CO 

monitoring sites in the state. CO is a good indicator of vehicle emissions, including benzene. The four 

PM10 sites are in former non-attainment areas, and are an important component of the current plans to 

maintain air quality in those areas. 

10 5 DEQ AQ Reduce State Air Permitting (ACDP) $ 374,984 $ 374,984 3 1.65 

Eliminate most of remaining GF from ACDP, leaving less than 2 FTE of non-fee funded FTE in the 

program. Will reduce facility inspections and compliance oversight, eliminate coordinated inspector 

training and delay or eliminate outreach materials for new sources.

11 3 DEQ LQ Reduce Hazardous Waste compliance $ 206,582 $ 206,582 1 0.95

Reduces Hazardous Waste compliance staff by about 10%. Reduces ability to inspect generator and 

TSD facilities and follow up on compliance issues, to respond to complaints and to maintain current 

TSD permits.

12 8 DEQ AQ Reduce Fine Particulate Planning $ 165,720 $ 165,720 1 1.00 

Eliminates an Air Quality Planner developing and coordinating fine particulate reduction strategies and 

carrying out mandatory CAA requirements for new federal standards. Delays work to develop an air 

quality plan for returning Klamath Falls and Lakeview air to healthy levels. Extended violation of the 

fine particulate standard negatively impacts public health and economic development in the area. 

Postpones pollution prevention outreach and strategy development in Oregon communities at risk of 

violating federal standards.

13 3 DEQ WQ Reduce Toxics Monitoring and Mixing 

Zone Studies $ 106,367 $ 749,309 $ 855,676 0 0.75 4 4.00

Reduces work in the Water Quality Toxics Monitoring program and eliminates mixing zone studies for 

small communities. This means:

• Fewer monitoring samples will be taken from rivers and streams and analyzed. DEQ will have less 

data and information regarding the toxic pollutants found in water and fish in Oregon’s rivers and 

streams. 

• DEQ will stop doing mixing zone studies for small communities. This means all municipalities will be 

required to conduct their own mixing zone studies as part of the water permit renewal process. There 

will be additional costs to the communities that DEQ has previously assisted with this permit 

requirement. 

• Development of maps and other visual tools that geographically depict where toxics monitoring was 

done and the monitoring results will not be readily available to the public. DEQ has had frequent 

requests from the public for this information to date. 

• Remaining staff in the toxics monitoring program will not have administrative support to do copying, 

filing, mailings, scheduling and database work. 

• Reduced ability to develop informational materials for the public or conduct public outreach regarding 

the results of the toxics monitoring results. 

14 6 DEQ WQ Reduce Water Quality Enforcement $ 204,270 $ 204,270 1 1.00

Reduces enforcement capabilities for water quality violations. This means there will be reduced 

compliance with legal requirements, fewer Supplemental Environmental Projects funded by violators, 

and less civil penalty money contributed to the General Fund.

An Rec 085 LFO Pkg 810

Priority 

(ranked with lowest priority 

first)

An Rec 090

\\server01\Users\MLH\My Documents\LRAPA Overview\Budget\Maintenance of Effort - MOE\Attachment B - DEQ 2011-13 GF Reductions including LRAPAAttachment B - DEQ 2011-13 GF Reductions including LRAPA11-13 LAB GF Red Option Status
 


Oregon Department of Environmental Quality

2011 - 2013 Biennium Agency Number: 34000

Detail of General Reductions Incorporated in 2011-13 Legislatively Adopted Budget

1 2 3 4 5 6 7 12 16

Dept. 

Initials

Prgm. or 

Activity 

Initials

Program Unit/Activity Description An Rec

Pkg 085

An Rec

Pkg 090

LFO Rec

Pkg 810

 TOTAL 

FUNDS POS FTE POS FTE POS FTE Impact of Reduction on Services and Outcomes

An Rec 085 LFO Pkg 810

Priority 

(ranked with lowest priority 

first)

An Rec 090

15 7 DEQ AQ Reduce Air Emission Inventory $ 198,121 $ 198,121 1 1.00 

Delays air toxics and fine particulate planning work. Emission inventory is the scientific underpinning 

of air quality planning, including identification of sources, determining baseline emission levels, 

evaluating the benefits of proposed emission reduction strategies, and meeting federal technical 

requirements. With fewer resources, DEQ will have to delay planning efforts to reduce air quality 

health impacts.

16 10 DEQ AQ Reduce Fine Particulate Monitoring $ 197,277 $ 197,277 2 1.30 

Reduce fine particulate Federal Reference Method samplers in McMinnville, Portland, Madras and the 

Klamath Falls background site. These sites have the lowest PM readings and normally when sufficient 

data has been collected, DEQ would shift the samplers to new areas where air quality is unknown.

17 2 DEQ WQ Reduce Wastewater PermittingStormwater $ 595,757 $ 595,757 4 3.50

DEQ would not be able to meet the commitments made for the Stormwater program. Specifically, 

DEQ would:

• Reduce inspections and compliance activities for industrial and construction sites. This means that 

DEQ will be unable to assure the public that permitted industrial and construction discharges are in 

compliance and potential water pollution violations will go unchecked.

• Reduce permit issuance. This means that all stormwater permit issuance and responses to proposed 

new construction projects will be delayed. 

• Commitments to reissue the 1200Z industrial stormwater permit by August 2011 that is included in the 

settlement agreement with Northwest Environmental Defense Center and Columbia Riverkeeper would 

not be met.

18 7 DEQ WQ Reduce Wastewater Permitting $ 248,139 $ 381,100 $ 629,239 1 1.00

PARTIALLY IMPLEMENTED

Reduces capacity in the wastewater permit program. This means that municipal permits will take 

longer to issue, the backlog goal of 10% will not be met, and the timelines for inputting data into EPA's 

compliance database will not be met. DEQ’s ability to ensure consistent and up-to-date implementation 

of permit program policies will be reduced significantly. DEQ’s ability to ensure water quality issues are 

addressed through permits will be significantly reduced. 

19 6 DEQ AQ Reduce Air Toxics Monitoring $ 265,430 $ 265,430 2 1.00 

This would cut the air toxics monitor in Klamath Falls or a monitor in Medford. This reduction, together 

with a monitor cut in 2009-2011 would significantly undermine DEQ's air toxics monitoring effort. The 

monitors were added in the 2007 budget in response to substantial public interest. When sufficient 

data is accumulated, the Klamath Falls monitor (previously Salem) will move to a new location, which 

will provide air toxics information in another part of the state. 

20 4 DEQ WQ Reduce Willamette TMDL Implementation $ 554,642 $ 505,754 $ 1,060,396 2 2.00 2 2.00

Significantly reduces implementation work associated with the Willamette TMDL. This work includes:

• Providing technical assistance to local communities, watershed councils, local governments, other 

state agencies, federal agencies, businesses, citizens, and other groups in the Willamette Basin for 

implementing watershed restoration and pollution control activities.

• Collecting and analyzing mercury data to ensure DEQ, communities and other stakeholders can 

better understand how mercury affects the environment and make cost-effective decisions about 

mercury reduction strategies.

• Conducting compliance reviews for all stormwater annual reports submitted by local governments 

associated with the Willamette TMDL. 

This reduction option package includes a manager position. 

21 10 DEQ WQ

Reduce Biosolids Management, 

Compliance Support and Complaints 

Response

$ 305,221 $ 305,221 1 1.70

PARTIALLY IMPLEMENTED

Reduces staff responding to the public about illegal discharges to the environment and complaints 

about non-permitted sources of pollution by 25%. Will greatly limit DEQ's ability to assist and respond 

to the public and impact permit timeliness and inspection frequency because permit staff will need to 

respond to significant complaint issues. 

Reduces DEQ’s timely response to grant site authorizations for the land application of municipal and 

industrial biosolids by 40%. Reduces capacity to issue Water Pollution Control Facilities permits that 

have a biosolids component. 

Eliminates a compliance position that works with EPA, permit writers and permittes on compliance 

activities. Reduced effort in coordinating with other state agencies on permitting issues related to 

mining and water quality. Fewer resources to address DEQ’s general permit backlog. This means 

there will be a delay in evaluating and inconcorporating new water quality requirementes into expired 

general permits. In addition, DEQ cannot register new facilities to expired permits which makes them 

vulnerable to third party lawsuits.

22 8 DEQ WQ Reduce Water Quality Information 

Services and Support $ 157,415 $ 285,057 $ 442,472 1 1.00 1 1.00

Eliminates a manager position in the water quality program focused on information technology and 

process efficiencies. Staff to manager ratio will increase. The Water Quality program will have less 

support in organizing rulemaking hearings, responding to public comments and conducting background 

research. This means that technical staff will have less time to focus on the technical work. 

\\server01\Users\MLH\My Documents\LRAPA Overview\Budget\Maintenance of Effort - MOE\Attachment B - DEQ 2011-13 GF Reductions including LRAPAAttachment B - DEQ 2011-13 GF Reductions including LRAPA11-13 LAB GF Red Option Status
 


Oregon Department of Environmental Quality

2011 - 2013 Biennium Agency Number: 34000

Detail of General Reductions Incorporated in 2011-13 Legislatively Adopted Budget

1 2 3 4 5 6 7 12 16

Dept. 

Initials

Prgm. or 

Activity 

Initials

Program Unit/Activity Description An Rec

Pkg 085

An Rec

Pkg 090

LFO Rec

Pkg 810

 TOTAL 

FUNDS POS FTE POS FTE POS FTE Impact of Reduction on Services and Outcomes

An Rec 085 LFO Pkg 810

Priority 

(ranked with lowest priority 

first)

An Rec 090

23 5 DEQ WQ Reduce Groundwater Protection Program $ -

NOT IMPLEMENTED

DEQ would no longer do work associated with any of the Groundwater Management Areas (GWMAs) 

that are located in the Lower Umatilla Basin, Northern Malheur County, and in the Southern Willamette 

Valley. The work associated with the GWMAs includes:

• Implementation and monitoring of Groundwater Management Areas where the water quality has been 

degraded, beneficial uses are seriously impaired, and public health may be at risk in part from nonpoint 

source groundwater pollution

• Technical assistance to communities and watershed councils engaged in groundwater pollution 

prevention efforts.

$ -

$ 2,694,549 $ 6,161,033 $ 855,708 $ 7,146,572 13 13.25 16 14.40 4 3.70

An Rec 085 - 2009-11 Across the Board GF Reductions Implemented as 2011-13 Reductions in the Analysts Recommended 

An Rec 090 - GF Reduction Options Implemented as 2011-13 Reductions in the Analysts Recommended 

GENERAL OTHER FEDERAL

18 7 DEQ WQ Reduce Wastewater Permitting $ 483,194 $ 236,066 $ 85,832 4 4.00

21 10 DEQ WQ

Reduce Biosolids Management, 

Compliance Support and Complaints 

Response

$ 316,806 $ - $ - 2 1.30

23 5 DEQ WQ Reduce Groundwater Protection Program $ 909,010 $ - $ - 4 4.00

$ 1,709,010 $ 236,066 $ 85,832 10 9.30

Highlighted Cell Are Reduction Options Not Implemented in the LAB

\\server01\Users\MLH\My Documents\LRAPA Overview\Budget\Maintenance of Effort - MOE\Attachment B - DEQ 2011-13 GF Reductions including LRAPAAttachment B - DEQ 2011-13 GF Reductions including LRAPA11-13 LAB GF Red Option Status
Attachment C
Environmental Quality, Dept of 

Program Unit Appropriated Fund Group and Category Summary Versio2011-13 Biennium Cross Reference Air Quality

Description

2011-13 Agency

Request

Budget

2009-11 Leg

Approved

Budget

2009-11 Leg

Adopted

Budget

2007-09

Actuals

LIMITED BUDGET (Excluding Packages) PERSONAL SERVICES General Fund 4,294,600 4,109,774 4,109,774 4,596,017  Other Funds 24,291,192 27,635,451 27,635,451 31,145,824  Federal Funds 3,448,628 4,166,306 4,166,306 4,571,158  All Funds 32,034,420 35,911,531 35,911,531 40,312,999  SERVICES & SUPPLIES General Fund 3,493,744 3,260,772 3,125,361 3,125,361  Other Funds 6,550,848 10,000,205 10,000,205 10,000,205  Federal Funds 1,152,986 1,056,225 1,056,225 1,056,225  All Funds 11,197,578 14,317,202 14,181,791 14,181,791  CAPITAL OUTLAY General Fund 349,250 32,989 32,989 32,989  Other Funds 637,665 687,692 687,692 687,692  Federal Funds - 158,500 158,500 158,500  All Funds 986,915 879,181 879,181 879,181  SPECIAL PAYMENTS General Fund 1,420,405 364,929 364,929 364,929  Other Funds - 191,374 191,374 191,374  Federal Funds 295,585 2,066,364 2,066,364 2,066,364  All Funds 1,715,990 2,622,667 2,622,667 2,622,667 

_____ Agency Request _____ Governor's Recommended 

2011-13 Biennium Page __________ Program Unit Appropriated 
Environmental Quality, Dept of 

Program Unit Appropriated Fund Group and Category Summary Versio2011-13 Biennium Cross Reference Air Quality

Description

2011-13 Agency

Request

Budget

2009-11 Leg

Approved

Budget

2009-11 Leg

Adopted

Budget

2007-09

Actuals

TOTAL LIMITED BUDGET (Excluding Packages) General Fund 9,557,999 7,768,464 7,633,053 8,119,296  Other Funds 31,479,705 38,514,722 38,514,722 42,025,095  Federal Funds 4,897,199 7,447,395 7,447,395 7,852,247  All Funds 45,934,903 53,730,581 53,595,170 57,996,638 AUTHORIZED POSITIONS 237 246 246 246 AUTHORIZED FTE 230.09 236.27 236.27 238.91 LIMITED BUDGET (Essential Packages) 010 NON-PICS PSNL SVC / VACANCY FACTOR PERSONAL SERVICES General Fund - - - (22,874)  Other Funds - - - 130,830  Federal Funds - - - 28,960  All Funds - - - 136,916  021 PHASE-IN SERVICES & SUPPLIES Other Funds - - - 80,494  022 PHASE-OUT PGM & ONE-TIME COSTS SERVICES & SUPPLIES Federal Funds - - - (14,651)  SPECIAL PAYMENTS

_____ Agency Request _____ Governor's Recommended 

2011-13 Biennium Page __________ Program Unit Appropriated 
Environmental Quality, Dept of 

Program Unit Appropriated Fund Group and Category Summary Versio2011-13 Biennium Cross Reference Air Quality

Description

2011-13 Agency

Request

Budget

2009-11 Leg

Approved

Budget

2009-11 Leg

Adopted

Budget

2007-09

Actuals

 Federal Funds - - - (449,457)  031 STANDARD INFLATION SERVICES & SUPPLIES General Fund - - - 87,179  Other Funds - - - 347,926  Federal Funds - - - 35,928  All Funds - - - 471,033  CAPITAL OUTLAY General Fund - - - 792  Other Funds - - - 16,505  Federal Funds - - - 3,805  All Funds - - - 21,102  SPECIAL PAYMENTS General Fund - - - 8,758  Other Funds - - - 4,593  Federal Funds - - - 38,806  All Funds - - - 52,157  033 EXCEPTIONAL INFLATION SERVICES & SUPPLIES General Fund - - - 56,513  SPECIAL PAYMENTS

_____ Agency Request _____ Governor's Recommended 

2011-13 Biennium Page __________ Program Unit Appropriated 
Environmental Quality, Dept of 

Program Unit Appropriated Fund Group and Category Summary Versio2011-13 Biennium Cross Reference Air Quality

Description

2011-13 Agency

Request

Budget

2009-11 Leg

Approved

Budget

2009-11 Leg

Adopted

Budget

2007-09

Actuals

 Other Funds - - - 1,252  Federal Funds - - - 7,340  All Funds - - - 8,592  050 FUNDSHIFTS PERSONAL SERVICES Other Funds - - - 156,428  Federal Funds - - - (155,811)  All Funds - - - 617  SERVICES & SUPPLIES Other Funds - - - 13,606  Federal Funds - - - (13,606)  All Funds - - - - TOTAL LIMITED BUDGET (Essential Packages) General Fund - - - 130,368  Other Funds - - - 751,634  Federal Funds - - - (518,686)  All Funds - - - 363,316 LIMITED BUDGET (Current Service Level) General Fund 9,557,999 7,768,464 7,633,053 8,249,664  Other Funds 31,479,705 38,514,722 38,514,722 42,776,729  Federal Funds 4,897,199 7,447,395 7,447,395 7,333,561 

_____ Agency Request _____ Governor's Recommended 

2011-13 Biennium Page __________ Program Unit Appropriated 
Environmental Quality, Dept of 

Program Unit Appropriated Fund Group and Category Summary Versio2011-13 Biennium Cross Reference Air Quality

Description

2011-13 Agency

Request

Budget

2009-11 Leg

Approved

Budget

2009-11 Leg

Adopted

Budget

2007-09

Actuals

 All Funds 45,934,903 53,730,581 53,595,170 58,359,954 AUTHORIZED POSITIONS 237 246 246 246 AUTHORIZED FTE 230.09 236.27 236.27 238.91 LIMITED BUDGET (Policy Packages) PRIORITY 0 085 2009-11 ALLOTMENT REDUCTION ROLL-UPS PERSONAL SERVICES General Fund - - - -  Federal Funds - - - -  All Funds - - - -  SERVICES & SUPPLIES General Fund - - - -  AUTHORIZED POSITIONS - - - -  AUTHORIZED FTE - - - -  086 ELIMINATE INFLATION PERSONAL SERVICES Other Funds - - - -  Federal Funds - - - -  All Funds - - - -  SERVICES & SUPPLIES General Fund - - - - 

_____ Agency Request _____ Governor's Recommended 

2011-13 Biennium Page __________ Program Unit Appropriated 
Environmental Quality, Dept of 

Program Unit Appropriated Fund Group and Category Summary Versio2011-13 Biennium Cross Reference Air Quality

Description

2011-13 Agency

Request

Budget

2009-11 Leg

Approved

Budget

2009-11 Leg

Adopted

Budget

2007-09

Actuals

 Other Funds - - - -  Federal Funds - - - -  All Funds - - - -  CAPITAL OUTLAY General Fund - - - -  Other Funds - - - -  Federal Funds - - - -  All Funds - - - -  SPECIAL PAYMENTS General Fund - - - -  Other Funds - - - -  Federal Funds - - - -  All Funds - - - -  087 PERSONAL SERVICE ADJUSTMENTS PERSONAL SERVICES General Fund - - - -  Other Funds - - - -  Federal Funds - - - -  All Funds - - - -  SERVICES & SUPPLIES General Fund - - - - 

_____ Agency Request _____ Governor's Recommended 

2011-13 Biennium Page __________ Program Unit Appropriated 
Environmental Quality, Dept of 

Program Unit Appropriated Fund Group and Category Summary Versio2011-13 Biennium Cross Reference Air Quality

Description

2011-13 Agency

Request

Budget

2009-11 Leg

Approved

Budget

2009-11 Leg

Adopted

Budget

2007-09

Actuals

 090 ANALYST ADJUSTMENTS PERSONAL SERVICES General Fund - - - -  Other Funds - - - -  Federal Funds - - - -  All Funds - - - -  SERVICES & SUPPLIES General Fund - - - -  Federal Funds - - - -  All Funds - - - -  SPECIAL PAYMENTS General Fund - - - -  AUTHORIZED POSITIONS - - - -  AUTHORIZED FTE - - - -  801 TARGETED STATEWIDE ADJUSTMENTS SERVICES & SUPPLIES General Fund - - - -  802 VACANT POSITION SAVINGS PERSONAL SERVICES Other Funds - - - -  AUTHORIZED POSITIONS - - - - 

_____ Agency Request _____ Governor's Recommended 

2011-13 Biennium Page __________ Program Unit Appropriated 
Environmental Quality, Dept of 

Program Unit Appropriated Fund Group and Category Summary Versio2011-13 Biennium Cross Reference Air Quality

Description

2011-13 Agency

Request

Budget

2009-11 Leg

Approved

Budget

2009-11 Leg

Adopted

Budget

2007-09

Actuals

 AUTHORIZED FTE - - - -  805 BUDGET RECONCILIATION ADJUSTMENTS (SB 5508) SERVICES & SUPPLIES General Fund - - - -  Other Funds - - - -  Federal Funds - - - -  All Funds - - - -  810 LFO ANALYST ADJUSTMENTS PERSONAL SERVICES General Fund - - - -  SERVICES & SUPPLIES General Fund - - - -  AUTHORIZED POSITIONS - - - -  AUTHORIZED FTE - - - -  819 SUPPLEMENTAL STATEWIDE ENDING BALANCE PERSONAL SERVICES General Fund - - - -  SERVICES & SUPPLIES General Fund - - - -  CAPITAL OUTLAY General Fund - - - - 

_____ Agency Request _____ Governor's Recommended 

2011-13 Biennium Page __________ Program Unit Appropriated 
Environmental Quality, Dept of 

Program Unit Appropriated Fund Group and Category Summary Versio2011-13 Biennium Cross Reference Air Quality

Description

2011-13 Agency

Request

Budget

2009-11 Leg

Approved

Budget

2009-11 Leg

Adopted

Budget

2007-09

Actuals

 SPECIAL PAYMENTS General Fund - - - -  PRIORITY 3 111 IMPLEMENT NEW FEDERAL AIR QUALITY STANDARDS PERSONAL SERVICES Federal Funds - - - 701,157  SERVICES & SUPPLIES Federal Funds - - - 103,825  CAPITAL OUTLAY Federal Funds - - - 256,000  AUTHORIZED POSITIONS - - - 6  AUTHORIZED FTE - - - 5.00  PRIORITY 6 110 IMPLEMENT NEW FEDERAL GREENHOUSE GAS PERMITS PERSONAL SERVICES Other Funds - - - 175,946  Federal Funds - - - 161,875  All Funds - - - 337,821  SERVICES & SUPPLIES Other Funds - - - 25,000  Federal Funds - - - 25,000 

_____ Agency Request _____ Governor's Recommended 

2011-13 Biennium Page __________ Program Unit Appropriated 
Environmental Quality, Dept of 

Program Unit Appropriated Fund Group and Category Summary Versio2011-13 Biennium Cross Reference Air Quality

Description

2011-13 Agency

Request

Budget

2009-11 Leg

Approved

Budget

2009-11 Leg

Adopted

Budget

2007-09

Actuals

 All Funds - - - 50,000  AUTHORIZED POSITIONS - - - 2  AUTHORIZED FTE - - - 2.00  PRIORITY 15 112 AIR QUALITY PASS THROUGH GRANTS SPECIAL PAYMENTS Federal Funds - - - 200,000 TOTAL LIMITED BUDGET (Policy Packages) General Fund - - - -  Other Funds - - - 200,946  Federal Funds - - - 1,447,857  All Funds - - - 1,648,803 AUTHORIZED POSITIONS - - - 8 AUTHORIZED FTE - - - 7.00 TOTAL LIMITED BUDGET (Including Packages) General Fund 9,557,999 7,768,464 7,633,053 8,249,664  Other Funds 31,479,705 38,514,722 38,514,722 42,977,675  Federal Funds 4,897,199 7,447,395 7,447,395 8,781,418  All Funds 45,934,903 53,730,581 53,595,170 60,008,757 AUTHORIZED POSITIONS 237 246 246 254 AUTHORIZED FTE 230.09 236.27 236.27 245.91 

_____ Agency Request _____ Governor's Recommended 

2011-13 Biennium Page __________ Program Unit Appropriated 
Environmental Quality, Dept of 

Program Unit Appropriated Fund Group and Category Summary Versio2011-13 Biennium Cross Reference Air Quality

Description

2011-13 Agency

Request

Budget

2009-11 Leg

Approved

Budget

2009-11 Leg

Adopted

Budget

2007-09

Actuals

OPERATING BUDGET General Fund 9,557,999 7,768,464 7,633,053 8,249,664  Other Funds 31,479,705 38,514,722 38,514,722 42,977,675  Federal Funds 4,897,199 7,447,395 7,447,395 8,781,418  All Funds 45,934,903 53,730,581 53,595,170 60,008,757 AUTHORIZED POSITIONS 237 246 246 254 AUTHORIZED FTE 230.09 236.27 236.27 245.91 TOTAL BUDGET General Fund 9,557,999 7,768,464 7,633,053 8,249,664  Other Funds 31,479,705 38,514,722 38,514,722 42,977,675  Federal Funds 4,897,199 7,447,395 7,447,395 8,781,418  All Funds 45,934,903 53,730,581 53,595,170 60,008,757 AUTHORIZED POSITIONS 237 246 246 254 AUTHORIZED FTE 230.09 236.27 236.27 245.91 

_____ Agency Request _____ Governor's Recommended 

2011-13 Biennium Page __________ Program Unit Appropriated 
Attachment D
DEQ General Fund funding to Lane Regional Air Protection Agency

2009-2011 Biennium

 Legislative 

Budget FY 10 FY 11 2009-2011 Biennium FY 10 FY 11 FY 12

 FY 13 -

expected 

Base Budget 426,672 Lakeview 15,000 18,000 10,000 10,000

Inflation 11,947 La Grande 8,000 7,500 - -

2009-2011 LAB 438,619 Jackson County 30,000 30,000 15,000 15,000

 Reduction due to reduced GF 

revenue forecast 

 (73,690) Josephine County 10,000 13,720 10,000 10,000

 364,929 182,464 182,464 LRAPA 21,000 25,000 17,380 17,380

Klamath Falls 30,000 35,000 28,000 28,000

2011-2013 Biennium

 Legislative 

Budget FY 12

 FY 13 -

expected Burns - 3,500 - -

Base Budget 364,929 Total 114,000 132,720 80,380 80,380

Inflation 8,758 Biennium totals 160,760

Eliminate inflation (8,758) LRAPA reduction FY 11 to FY 12 (7,620)

Reduction taken (112,544)

 Statewide Ending Balance hold 

back 

 (8,373)

LAB Budget to LRAPA 244,012

 DEQ was able to cover LRAPA's 

portion of this reduction and did 

not pass it on to LRAPA 252,385 123,483 128,902

Reduction from FY 11 to FY 12 (58,981)

 Legislative appropration - to LRAPA through the DEQ budget - Special 

Payments - 2011-2013 Reduction option # 3 $112,544 

 Current and former non-attainment areas - GF support for woodstove 

curtailment work - 2011-2013 Reduction option #4 local gov outreach - 

$76,105 

 246,720
Attachment E
Lane County

FY 12-13 Proposed Budget

 

Example of Services General Fund pays for:

Animal Services

Assessment & Taxation

Criminal Prosecution

Deeds & Records

Elections

Emergency Management/Disaster 

Response

Facilities Management

Family Law (Child support collection, etc)

Governance (Board of Comm, etc)

Human Services Commission

Lane County Jail

Law Enforcement

Medical Examiner

Public Health

Search & Rescue

Sheriff’s Patrol

Veterans

Youth Services

Example of Services Road Fund pays for:

Emergency Management/Disaster 

Response

Facilities Management

Fish Passage Preservations & 

Enhancement

Geographical Information Services

Heavy Haul Permitting

Materials Quality Assurance & Testing

Right of Way

Road & Bridge Construction

Road & Bridge Design

Road & Bridge Maintenance

Road & Bridge Preservation

Road Utility Coordination

Stormwater Management

Surveying

Traffic Engineering

Transportation Planning

Weighmaster 
PERSONNEL/FTE REDUCTIONS

Lane County is a service organization, rather than one that produces products, and therefore its largest 

expense is personnel (salaries & benefits). In 2012-2013, the County will have 1,246 FTE (full time 

equivalent). Countywide, the County is eliminating 224 FTE (full-time equivalent FTE), which is a 15.3% 

reduction from current year and is 

the lowest staff level since 1990 

when there were 1,243 FTE. One 

important distinction between 

1990 and today is that the County 

population was 282,912 v. 353,155 

in 2012. This means that in 1990, 

there were 4.4 FTE per thousand 

County residents. Beginning July 1, 

2012, there will be 3.5 FTE for 

every thousand County residents.

For comparison, the City of Eugene 

reports in their FY 12-13 Proposed 

Budget that they will have 9.2 FTE for every thousand City residents.

WHY DOES THE COUNTY HAVE A BUDGET 

SHORTFALL

The short answer is because there is not enough revenue to 

support the services that Lane County has historically 

provided. This is primarily due to a reduction in funding from 

timber harvest as well as a very low permanent property tax 

rate and Property Tax Measures 5 & 47/50 passed by voters 

in the 1990’s. 

Timber Harvest Revenue

National Forests

Timber Harvest Revenue to Counties goes back more than 120 years. In 1893, President Harrison 

created Forest Reserves which were expanded by President Cleveland in 1897. Then, in 1908, President 

Theodore Roosevelt created the National Forests. 

 Photo credit: http://www.des.ucdavis.edu/faculty/lubell/Teaching/ESP172/Lecture7Forests.pdf

Also in 1908, President Roosevelt signed an agreement that provided for Counties to receive revenue for 

the land that had been ‘claimed’ by the federal government as forestland. It provided that Counties 

would receive a percentage of the revenue from timber harvests occurring on the lands. This revenue 

was needed by the counties because the federal lands are not taxed. The revenue from the National 

Forest harvesting went to supporting county road funds and eventually also school funds.

Which services use General Fund 

Revenue – and how much? 
This arrangement worked well, from a revenue standpoint, for decades. However, between 1970 and 

1993, policies changed. In 1976, 

the National Forest Management 

Act of 1976 was passed. In the 

1980’s the Spotted Owl was put 

on the endangered species list, 

and it had the effect of sharply 

decreasing the ability to harvest 

timber from National Forests, 

thereby decreasing the revenue 

counties were receiving. From 

1993 to present, there has been 

continuing decreases in timber 

harvests and reforms to Forest 

Service Planning. 

O&C Lands - Bureau of Land Management 

In addition to the National Forest system, in 1916 the Federal Government reclaimed 2.8 million acres in 

Oregon that had originally been designated for a railroad. The lands, now known as ‘O&C’, are managed 

by the Bureau of Land Management. In 1926, the Stanfield Act provided that the counties also receive a 

share of the revenue from the timber harvests occurring on the O&C lands. This revenue has gone to 

support General Fund 

services such as Public 

Safety, Elections, Deeds & 

Records, Assessment & 

Taxation, and a multitude 

of human services 

including communicable 

disease, human services

commission and public 

health. Timber harvest has 

also dramatically decreased 

on the O&C lands, for the 

same reasons it has 

decreased in the National

Forests.

Property Tax Revenue

Property tax revenue has severe limitations due to ballot measures that have been passed by the voters 

in the past fifteen years. Current provisions include a cap on the amount available for general 

government purposes ($10 per $1,000 assessed) and a limit on the percentage that assessments can be 

increased annually to 3%, regardless of the change in real market value. Two ballot measures in 1996 & 

1997 (47/50) went so far as to reduce property taxes to the 94-95 or 95-96 levels minus 10%. 

The property tax revenue shortage is exacerbated in Lane County due to the very low permanent tax 

rate of $1.28 per $1,000 assessed value. This puts Lane County in the lowest 5 counties for the State of

Oregon. It also puts the County well below the rate of every incorporated City within the County. Below

is a chart of the permanent rates for Lane County and its incorporated cities. Following is a graph

showing the property tax revenue collections and population for County and its two largest cities 

(Eugene & Springfield):
*Springfield revenue includes two operating levys (above their permanent rate)

WHAT IS LANE COUNTY DOING TO TRY AND SOLVE THE PROBLEM?

Lane County has explored multiple options in recent years to improve our financial situation. These 

have included:

 Refinancing of all eligible debt to obtain lower interest rates

 Moved employees to health insurance plans that are lower in cost, while maintaining care

 Revenue Stabilization Task Force consisting of residents and community partners

 Explored Public Safety Special Taxing District (City of Eugene objected)

 Budget planning meetings with hours of public comment 

 Reorganize County departments to increase efficiencies while maintaining customer service

 Innovate Lane County – creating a flexible, efficient, customer-oriented entity.

 Strategic Planning

 Long Term Financial Planning 

FY 12-13 SERVICE REDUCTIONS

Despite all of the best planning, there is no way to avoid service reductions when revenue decreases. FY 

12-13 will see major service reductions to our residents including:

HOW DO I STAY INFORMED?

Visit www.lanecounty.org and click on County Budget. Attend Budget Committee meetings in May, 

2012 and/or contact your County Commissioner and state and federal representatives!

You can also follow Budget & Financial Planning on Twitter with the hashtag #lcbudget or follow the 

Budget Manager at CMoodyLC and on Facebook at: http://www.facebook.com/LaneCountyBudget

Perm Rate

Taxing District Per 1,000

City of West Fir 9.30

City of Cottage Grove 7.21

City of Oakridge 7.20

City of Eugene 7.01

City of Junction City 6.04

City of Veneta 5.64

City of Springfield 4.74

City of Coburg 3.75

City of Florence 2.86

City of Creswell 2.67

City of Lowell 2.16

Lane County 1.28

 Sheriff’s Office Patrol decrease – no longer 

able to provide 24 hour patrol

 Closure of 131 jail beds (leaving 120-130)

 Elimination of Parole & Probation supervision 

for misdemeanor crimes. 

 Decrease in prosecution of crime by the District 

Attorney’s Office

 Elimination of a Medical Examiner for Lane 

County

 Reduce by 1⁄2 detention beds for youth

 Increased case loads in Youth Services, DA’s 

office and Parole & Probation

 Decrease in Veterans Services

 Decrease in Human Services Commission 

 Decrease in Public Health, including 

communicable disease control

 Decreased public access hours across the 

organization including Assessment & Taxation 

and Elections. 

 Reduce Road maintenance, engineering, and 

right of way services

 Reductions in Land Management
Attachment F
Lane County Budget

County faces severe cuts

A proposal includes a reduction of more than 200 jobs, 

mostly targeting public safety 

By Greg Bolt

The Register-Guard

Appeared in print: Wednesday, April 25, 2012, page A1

The precipice that the Lane County budget has been rolling toward for the past year came into 

view Tuesday, when the county administrator unveiled a proposal that lowers revenue by $100 

million and lays off more than 200 workers.

All of the worst predictions about deep cuts to vital programs are found in the budget proposal 

released by county chief Liane Richardson, including the loss of 131 jail beds, a 75 percent cut in 

the number of patrol deputies, closing half the juvenile detention beds, and severe reductions in 

criminal prosecutions and offender supervision. Cuts to a variety of other county departments —

such as public works, assessment and taxation and health and human services — also are 

proposed.

“We knew the cliff was coming,” Richardson told reporters Tuesday. “We knew the cliff would 

be here this year.”

Richardson’s proposal will go to the county budget committee, which will hold its first meeting 

Tuesday . The budget committee, made up of the five county commissioners and five citizens, 

will take public testimony and can make some adjustments to the spending plan before sending it 

on to the Board of Commissioners for final adoption in June.

In what is most likely the bleakest revenue picture in more than a decade, the county faces the 

elimination of the federal Secure Rural Schools Act funds that had replaced money once 

generated by timber sales in the days before habitat issues and overcutting almost shut down 

logging on federal lands.

But cuts also are coming from other federal programs and from the state, leaving virtually no 

county service immune from some level of reduction.
Particularly hard hit are the two funds that pay for some of the county’s most expensive and 

important programs: the general fund and the road fund. Both are taking big hits from the loss of 

the so-called county timber payments.

The general fund is expected to shrink by $16.1 million, or 17 percent, while the road fund will 

lose $18 million, a 23 percent drop.

The budget plan would eliminate 224 full-time-equivalent jobs, leaving the county staff at its 

lowest level since 1990, when there were 70,000 fewer people living here.

Because more than 60 percent of the general fund goes to public safety programs, those will take 

the biggest hit. The sheriff’s office alone gets 40 percent of the general fund, leaving it with a 

proposed $7 million cut.

But Sheriff Tom Turner said other revenue sources, such as jail beds rented to federal law 

enforcement and state funds for parole and probation, also are shrinking. That leaves him with a 

budget hole of more than $10 million.

That will mean cutting patrol deputies down to six from the current 24, which will mean only the 

most dire calls for help will be answered and even then help may be greatly delayed.

Turner said that as far as he’s been able to determine, no other county in the nation has ever had 

to deal with such deep cuts to law enforcement.

“This is going to be a very, very severe time for Lane County,” he said.

When the county has faced serious cuts to law enforcement in the past, it’s been able to rely on 

Oregon State Police to help fill the gap. But Turner said state police are understaffed as well and 

won’t be able to help as they have in the past.

With the reduction of 131 jail beds, only 121 will be available for local offenders, the lowest 

number in modern county history.

That means some people accused of violent crimes, including some Measure 11 crimes that 

require minimum mandatory sentences, will have to be released, putting the county in violation 

of state rules and its residents at higher risk.

The district attorney’s office will have to cut 171⁄2 full-time-equivalent positions, which would 

force a reduction of about 30 percent in the cases tried. That would most likely mean that people 

accused of property crimes and some low-level violent crimes would not be prosecuted, while 

those who are prosecuted probably would be released early because of jail reductions.

Other public safety programs, such as the medical examiner, would be eliminated, and the 16 

remaining beds at the county juvenile detention center would be reduced to eight. Cuts to parole 

and probation programs would mean that people convicted of misdemeanors and released from 

jail early no longer would be supervised.
Turner said that’s particularly worrisome because that group includes people convicted of 

domestic violence.

“They’re some of the most violent and difficult people and the people who need the most 

supervision,” he said.

In other departments, health and human services will lose 251⁄2 positions; assessment and 

taxation will cut 12; and public works will lose almost 50. The 20 percent drop in the road fund, 

driven mostly by the end of the county timber payments, means that oil will not be sprayed on 

rural roads, and other road maintenance work will be put off.

Richardson said she decided to cut each department roughly in proportion to the amount of 

general fund money each receives, even though that means cutting into the meat and bone of 

county services. She said that’s because the county, which has been through a long string of lean 

years, already has made the easy cuts.

“We’ve already cut all the extras,” she said. “We’ve already cut all of the services we deem not 

essential. All we have left are essential services.”

But even though the county will have to cope with a huge drop in revenue, some workers will 

continue to receive raises. Richardson said of the seven unions that represent county employees, 

three have existing contracts that call for cost-of-living raises in the coming year as well as what 

are called “step” increases for those who aren’t at the top of the seniority range.

She said none of those unions has said it’s willing to talk about reopening negotiations.

Four other bargaining units are currently in negotiations for new contracts. Richardson said the 

county is proposing no cost-of-living increases in those pacts and has not budgeted any money 

for raises.

But Richardson noted that some county bargaining units last year accepted a new, lower-cost 

health plan that saved the county a substantial amount of money. She said some unions 

voluntarily reopened their contracts to make the insurance change.
The Register-Guard http://www.registerguard.com/

Eugene on edge of own fiscal cliff

The city grapples with how to cover a $6 million budget gap

BY EDWARD RUSSO

The Register-Guard

Published: Midnight, Dec 9, 2012

Eugene city government faces a $6 million budget gap, but City Manager Jon Ruiz doesn’t want 

to plug it all by laying off employees.

Instead, Ruiz on Monday is expected to propose that the City Council balance next year’s budget 

through a combination of cost cuts and tax or fee increases.

The problem: While city government spending increases have slowed compared to previous 

years, personnel costs are still rising faster than revenue, creating the gap.

Two years ago, a citizens committee formed by Ruiz to analyze ways to raise revenue 

recommended the city impose a 5 percent tax on restaurant sales. The group examined other 

things, such as a local option levy to help pay for the rising cost of municipal operations, a utility 

tax and a citywide monthly service fee.

Ruiz on Monday is expected to mention ways the city could add revenue through fee and tax 

increases, but he won’t provide details about them.

“We want to hear from the council about whether they are interested in moving forward on new 

revenue,” said Kristie Hammitt, the city’s central services director. “If they are, we would come 

back to them later with more defined options.”

The council’s discussion is being driven by the $6 million gap — the difference between what 

the city expects to receive in its mainly property-tax-fed general fund in the 12-month fiscal year 

that begins next July, and what it would expect to spend if city expenses continued at the current 

pace.

The general fund is being squeezed by two factors: Ever-increasing employee costs and slowerthan-projected growth in property tax revenues, the latter caused by the weak economy and 

lagging real estate prices.

Eugene’s financial situation is not as dire as Lane County’s, where reduced federal payments 

have led to deep staffing cuts at the county jail, the sheriff’s office and other departments. And 

other local governments are feeling the same kind of financial pinch as Eugene.
Springfield city government, for example, is looking at a $1.5 million general fund gap for the 

next fiscal year.

Tax revenues “since 2008 have remained stagnant, and we are not seeing them bounce back like 

we would have expected them to,” said Bob Duey, Springfield’s finance director. 

In Eugene, salary increases and rising health insurance and pension expenses have pushed the 

annual average total cost of a city employee to nearly $100,000.

In simple terms, to plug the budget gap Ruiz could propose laying off about 60 employees, 

which would equal a 4 percent reduction of the 1,445-employee city workforce.

But Ruiz won’t do that, Hammitt said.

City employees, including librarians, police officers, firefighters, street sweepers and recreation 

workers provide valuable services to residents, she said.

“There would be a huge community service impact” if the city eliminated the gap by cutting 60 

positions, Hammitt said.

Community discussion

City councilors say the upcoming budget deliberations will lead to a community discussion about 

how the city spends its money.

“That will be the hard part about this process,” said Councilor Mike Clark. “Our community has 

a really broad spectrum of priorities. What is a priority in one part of the city is different in 

another part of the city.”

Clark, a conservative who represents north-central Eugene, said he doesn’t favor new taxes as a 

way to balance next year’s budget.

“I fear that a majority of my colleagues see the best answer as increasing taxes,” he said. “I 

don’t.”

A local option levy, Clark said, wouldn’t be a permanent solution because it would have to be 

renewed by voters every five years.

“I also don’t believe it will pass” the first time it would be put before voters, he added.

A widening gap

In the six years before Ruiz became city manager, city general fund spending increased each year 

by an average of 6.2 percent.
Ruiz started as city manager in 2008, about the same time as the effects from the recession hit 

the economy, which also depressed tax revenue.

In response, city government undertook a series of cost-cutting measures largely unseen by the 

public. They included reducing city employees by about 100 positions, mainly through attrition.

As a result, increases in general fund spending in the last four years slowed to an average of 0.6 

percent annually.

That took place even though the general fund had to absorb a $3 million expense in 2011, when 

the library local option levy expired.

The budget gap has loomed since last spring.

In March, Ruiz provided the council with a list of two dozen potential spending actions to show 

what various city services cost. They ranged from minor — such as eliminating the sister-cities 

program contract and saving $20,000 — to major, such as closing a swimming pool, thereby 

saving $500,000 a year, or a fire station, which would save $1.4 million a year.

Earlier this year, faced with another unbalanced budget, the public was no longer spared from the 

cutbacks. The city slashed in half the hours at its two branch libraries.

The move, projected to save $578,703 a year, reduced hours for some branch employees and 

eliminated branch and main library positions, some of them vacant.

The city in the current fiscal year, ending next June 30, is expecting to receive about $81.8 

million in property taxes, up from $80.3 million the previous fiscal year. 

Total general fund spending in the current fiscal year is set at $121.7 million, down slightly from 

the year before. 

For the coming fiscal year, the city projects property tax receipts at $83.5 million, up about 2 

percent from the current fiscal year, according to city Finance Director Sue Cutsogeorge.

But that’s not enough to meet rising personnel expenses.

The PERS factor

Employee and retiree pension costs are rising at an ominous pace.

The city pays into the state Public Employee Retirement System for 3,586 current employees and 

retirees. In the present fiscal year, the city is paying $18 million for retirement benefits, but a rate 

increase mandated by PERS to keep the pension system solvent will boost that to about $21 

million in the next fiscal year. That accounts for much of the projected budget gap.
Since 2010, the total average annual cost of a city employee, including wages and benefits, rose 

to $99,318, up $10,221.

With wages and benefits averaging a total of $117,230 annually, Eugene firefighters are the 

highest cost city employees. They are followed by non-unionized managers, who receive wages 

and benefits averaging $115,489; police officers, $106,572; employees represented by the 

American Federation of State, County and Municipal Employees, $80,540; and workers 

represented by the International Alliance of Theatrical State Employees, $67,425.

No more fat to trim

City Councilor Alan Zelenka said the city has done a good job of curbing expense growth in the 

last four years.

“Is there more we can do?” he asked. “Probably, but it won’t be enough” to close the budget gap.

Zelenka is politically liberal and, unlike Clark, is more willing to explore a tax increase.

Without more revenue, the city will be forced to cut employees and services , he said. 

“We are at the point that we are no longer able to get efficiencies and fat and waste out of 

government,” he said. “We are at the point of eliminating complete programs.”

Cindy Clarke, president of the American Federation of State, County and Municipal Employees 

Local 1724, said some city departments have too many managers. “If staff reductions are the 

only option, the city needs to evaluate the need for the many, many layers of management,” she 

said.

Also, vacant but funded city executive positions should be eliminated, and Ruiz’s management 

team should be restructured to save money, she said.

“If further reductions are necessary, the city needs to look at making cuts at the top of the pay 

scale, not at the bottom,” she said. 

THE COST OF A CITY OF EUGENE WORKER

Average cost per full-time equivalent employee (total wages and benefits, but excluding 

overtime)

American Federation of State, County and Municipal Employees

08-09 fiscal year: $70,419

12-13 fiscal year: $80,540
Full-time equivalent employees: 609 

Eugene Police Employees’ Association

08-09 fiscal year: $91,568

12-13 fiscal year: $106,572

Full-time equivalent employees: 241 

International Association of Firefighters

08-09 fiscal year: $107,434

12-13 fiscal year: $117,230

Full-time equivalent employees: 172

Non-unionized employees/managers

08-09 fiscal year: $106,375

12-13 fiscal year: $115,489

Full-time equivalent employees: 418

WHAT’S NEXT

The Eugene City Council on Monday will hear City Manager Jon Ruiz’s plan to eliminate a $6 

million budget gap.

When: 5:30 p.m.

Where: Harris Hall, 125 E. Eighth Ave.

Watch: Metrovision TV, Comcast channel 21. Webcast, www.eugene-or.gov 

Copyright © 2012 — The Register-Guard, Eugene, Oregon, USA
Attachment G
LRAPA Responses to Ten EPA Questions on Budget Data and Funding Actions Regarding Non-Selective MOE Reductions.

Number Question Response

1

When does the fiscal year begin and end 

for Lane Regional Air Protection Agency 

(LRAPA)?

LRAPA's fiscal year is from July 1st of the year to June 30th of the following year.

2

What is the budget (funding) period 

specified in the section 105 assistance 

agreement for which LRAPA has not, or 

will not, meet its MOE requirement.

LRAPA has filed the Federal Financial Report (FFR) for its 2010-2012 project 

cycle (i.e., for the two-year period that ended on June 30, 2012). The report 

specified that LRAPA was short of meeting MOE by $132,540.87. Furthermore, 

the staff at LRAPA are projecting an additional shortfall of $135,582.26 for the 

period ending on June 30, 2013. 

3

How much in non-federal funds did 

LRAPA expend on section 105 

expenditures over the budget that 

preceded the budget shortfall period? 

What portion of these expenditures was 

non-recurrent? What portion was 

recurrent? LRAPA's recurrent program 

expenditures are supported by a number 

of sources.

In the documentation that LRAPA has filed it shows all recurrent expenditures and 

the sources and uses of these resources including: State of Oregon General Fund; 

funding from the local government jurisdictional partner agencies within Lane 

County (Lane County Government, City of Eugene, City of Springfield, City of 

Cottage Grove, City of Oakridge); permit fees; reserves; and other miscellaneous 

revenue sources. 

4

What was LRAPA's MOE proposed MOE 

level for the budget shortfall period?

LRAPA's MOE for its FY2012 budget year that ended on June 30, 2012 is 

$935,855; this was $132,540 less than the $1,068,396 that LRAPA expended from 

its FY2011 budget year that ended on June 30, 2011. LRAPA is projecting to 

expend $800,313 for its FY2013 budget year that ends on June 30, 2013 or a 

reduction of $135,582. 
5a

a. If the period with the shortfall expired, 

and LRAPA submitted a final financial 

status report for the grant, what was the 

actual recurrent expenditure level that 

budget period?

LRAPA's actual MOE for FY2012 (July 1, 2011 - June 30, 2012) was reported at 

$935,855.26 and the projected MOE level for FY2013 (July 1, 2012 - June 30, 

2013) is estimated at $800,313.00. 

5b

b. If that budget period has not expired, 

or LRAPA has not submitted a final 

financial status report for the grant, what 

is the expected recurrent expenditure 

level for that budget period?

LRAPA's budget period for FY2012 has expired and the FFR has been filed. 

However, LRAPA budget period FY2013 is underway and LRAPA projects to 

expend $800,313 for this budget period.

5c

c. What is the amount of the actual or 

anticipated shortfall in the level of 

recurrent expenditures below the 

required MOE level due to the executive 

branch agency budget reduction for the 

budget shortfall period?

LRAPA's reported actual shortfall for FY2012 and the projected shortfall for 

FY2013 are directly related to the budget shortfall caused by the adverse 

economic conditions impacting LRAPA's funding sources, including the State of 

Oregon General Fund, local government contributions, and the reduction in the 

permit fees it receives from industrial facilities. 

6

What MOE level is LRAPA planning to 

(or proposing) to use in its application for 

a section 105 grant in the year following 

the budget shortfall period? What will be 

the sources of funding for the nonfederal, recurrent section 105 

expenditures?

LRAPA proposes to use the MOE level of $935,855.26 for its FY2012 budget year, 

and proposes to use an MOE level of $800,313.00 for the following FY2013 

budget year and thereafter. 
7

What were the budgets or the 

expenditure levels for all the 

departments or programs within LRAPA 

environmental programs containing the 

air program for the affected MOE 

shortfall period? For the prior funding 

period?

The MOE worksheet calculations are summarized as follows:

• Actual MOE = $1,010,832 in FY 2008 (July 1, 2007 to June 30, 2008);

• Actual MOE = $1,064,539 in FY 2009 (July 1, 2008 to June 30, 2009);

• Actual MOE = $1,067,889 in FY 2010 (July 1, 2009 to June 30, 2010);

• Actual MOE = $1,068,396 in FY 2011 (July 1, 2010 to June 30, 2011);

• Actual MOE = $935,855 in FY 2012 (July 1, 2011 to June 30, 2012); and

• Projected MOE = $800,313 in FY 2013 (July 1, 2012 to June 30, 2013). The 

other non-MOE funding categories in the core air programs are federal funds and 

Title V permit fees which are included in the response to the next question.

8

What were the budgets or the 

expenditure levels for all the 

departments or programs within the 

LRAPA operation for the affected MOE 

shortfall period? For the prior funding 

period?

The total LRAPA core program budgets are summarized as follows:

• $1,953,987 in FY 2008;

• $2,076,177 in FY 2009;

• $2,007,552 in FY 2010;

• $2,025,895 in FY 2011;

• $1,909,395 in FY 2012; and

• $1,833,020 in FY 2013.

The total LRAPA core program budgets include federal 103/105 base grant funds, 

Title V permit fees, and non-recurring expenses which are not included in the MOE 

calculations. Pass-through federal grants are excluded from both the core program 

budgets and the MOE calculations. 
9

What are the comparative differences in 

budget totals for the two periods when 

comparing the affected air program to 

other programs within its environmental 

agency (if applicable) and when 

comparing the air program budget and 

its agency's budget to those of other 

executive branch agencies? (Please 

show aggregate totals, dollar 

differences, and percentage changes by 

agency and/or program.)

This is not directly applicable since LRAPA is a local single-purpose air quality 

agency, and the LRAPA Board of Directors is the fiscal decision-making body and 

executive agency for MOE calculation purposes. But it is not surprising that overall 

MOE reductions at LRAPA mirror the overall reductions in state and local general 

funding. For example, the LRAPA MOE reduction between FY2011 and FY2012 is 

about 12% compared to an 11% reduction in Lane County General Fund for the 

same period; and similarly, the projected 2-year LRAPA MOE reduction between 

FY2011 and FY2013 is about 25% compared to a 26% reduction in Lane County 

General Fund and a 24% reduction in State General Fund for the same period. 

See pages 6-12, and Attachments A-F, for more details.

10

If the budgets of all executive branch 

agencies were not reduced, or were 

reduced in different ways (e.g., dollars 

vs. positions), or were not reduced 

proportionally relative to section 105 air 

program, please provide a thorough 

explanation.

This is not directly applicable since LRAPA is a local single-purpose air quality 

agency. In order to operate within its FY2012 and FY2013 budgets, LRAPA 

implemented a combination of unpaid furlough days, schedule reductions, and 

systematic across-the-board reductions wherever possible in materials & services 

expenses. In addition, open positions resulting from retirements or resignations 

were left vacant, with the related responsibilities redistributed, reduced, postponed 

or eliminated. The net result was an overall reduction across all LRAPA programs. 

See pages 8-9 for more details.

NM/MLH (12/31/2012)