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Lean in Air Permitting Guide

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Section 2: Applying the Starter Kit to an Air Permitting Lean Event

This section provides details on applying the Starter Kit to air permitting Lean events. The boxes associated with each of the subsections below link to the related sections of the Starter Kit. It is recommended that you read chapters 2 and 3 in the Starter Kit prior to reading this section.

Selecting the Target Air Permitting Program

Many agencies new to using Lean methods choose a relatively simple air permitting process—such as minor source construction permitting—as the target for their first air permitting Lean event. However, simplicity is just one factor in deciding where to focus your Lean event; Chapter 2 of the Starter Kit provides further tips on selecting a target program for your event. Additionally, the table below provides examples of air permitting programs that were targeted during past Lean events.

Air Permitting Programs Targeted During Past Air Permitting Lean Events
State Agency Air Permitting Programs
Delaware Department of Natural Resources and Environmental Control
  • Minor source air construction permitting
  • Synthetic minor air construction permitting
Idaho Department of Environmental Quality
  • Air quality permit issuing process (permit to construct)
Illinois Environmental Protection Agency
  • Minor source air construction permitting
Indiana Department of Environmental Management
  • Title V permit modification process
Iowa Department of Natural Resources
  • Air quality complex permitting;
  • Air quality new source construction permits
Michigan Department of Environmental Quality
  • Air construction permitting  (permit to install application review process)
Minnesota Pollution Control Agency
  • Air construction permitting
Nebraska Department of Environmental Quality
  • Air construction permitting
Virginia Department of Environmental Quality
  • State minor new source construction permits;
  • Major New Source Review permits;
  • Title V permits

Setting Event Goals and Objectives

When considering goals and objectives for your air permitting Lean event, consider some of those identified for previous air permitting events, including:

  • Improve the permitting process while maintaining the rigor of state air quality regulations
  • Optimize program resources to allow for increased attention to other agency functions
  • Reduce the air permit development timeframe
  • Better understand the permitting experience from the source’s perspective
  • Provide the public and sources with further transparency into the permit development process
  • Identify permitting program improvements that could reduce the costs of compliance for the agency and the regulated community

Setting Event Boundary Conditions

The boundary conditions selected for your event will depend on your needs. However, you should consider excluding discussion of changes that cannot be adopted immediately following an event. For example, the following two topics have commonly been excluded in past air permitting Lean events:

  • Changes to agency policies or state regulations
  • Processes outside of the agency’s control, such as EPA reviews of draft title V permits

Agencies need to think through the extent to which the Lean team should be open to considering interpretations or changes to agency rules when determining the scope of the event. In addition, consider the example boundary conditions shown in the following box.

Example Boundary Conditions for a Lean Air Permitting Event[3]
In Scope Out of Scope
  • Interpretation of agency policies and guidance documents
  • Internal organizational structure
  • Internal permit process and timing
  • Applicant permit process and timing
  • Electronic submittals
  • Application content and format
  • Permit and technical memo format
  • Permit condition content
  • Communication (internal/external)
  • EPA regulations
  • Interpretation of EPA rules, policies, and guidance documents
  • Modifying existing agency rules
  • Additional resources
  • Permit appeal process
  • Permits involving enforcement action
  • Mandated public participation requirements
  • Public hearing process

Identifying Performance Metrics

You will also need to identify and document a short list of performance metrics for measuring the success of your air permitting event. The performance metrics you select should address the goals and objectives selected for your event. It is important to collect data prior to the event, especially information on key aspects of the current permitting process and, if possible, information on the perspectives and experiences of permittees and other stakeholders (e.g., customer research data). To help guide your agency in brainstorming potential performance metrics, the following list provides example metrics used for past air permitting Lean events:

  • Total number of days to develop a permit (total number of days from the receipt of the permit application to permit issuance)
  • Number of days the permit clock is stopped
  • Number of steps within the air permit development process that are completed on time
  • Percentage of permit applications received that are incomplete or inaccurate
  • Number of air permit related questions received from the public and/or sources each month
  • Number of air permit applications denied
  • Number of “no permit required” letters sent each month
  • Number of iterations of draft permits developed (amount of re-work)

If your agency sets goals or objectives related to improving customer service, you may also choose to set customer perception metrics that relate to how the public, regulated community, and/or EPA view your agency’s permitting process. If you choose to use this type of metric, surveys or interviews of appropriate parties can enable you to develop a baseline of customer perceptions and track changes over time.

Selecting Event Participants and Determining Roles

Using the “thirds rule” for selecting event participants can ensure an effective and successful Lean event team. For an air permitting Lean event, consider selecting a team that is comprised of representatives from the following categories:

  • A representative mix of permit engineers (e.g., more senior and more junior engineers, and/or engineers that work on different types of air permits)
  • Air permit program managers from all levels (e.g., direct supervisors of the permit engineers and more senior managers)
  • Administrative staff involved in the air permitting process (e.g., mail room staff or administrative staff that assist with mailing “no permit required” notices)
  • Administrative managers that oversee staff involved in the air permitting process
  • Compliance program staff that are involved in inspecting permitted sources
  • Compliance program managers
  • A representative from the agency’s legal department (depending on preference, this representative can supplement one of the compliance program staff)
  • A mix of source representatives (e.g., representatives from sources that differ in size, in number of permits held, and/or in quality of past permit applications)
  • A representative from the regional EPA office, if the Lean event is for an air permitting process that requires EPA reviews
  • A representative from an environmental non-governmental organization

As an example, a hypothetical air permitting Lean event team could be comprised of:

  • 3 air permit engineers
  • 3 air permit program managers (from different levels within the agency)
  • 1 administrative staff member
  • 1 administrative manager
  • 2 compliance program staff members
  • 1 compliance program manager
  • 4 source representatives (from different sources)
  • 1 EPA representative

Preparing for the Lean Event

Prior to your air permitting Lean event, remember to collect background materials and inputs that team members can reference during the event. For example, consider bringing some or all of the following materials to your event:

  • Examples of past air permits and/or permit applications to assist in reviewing the permit process[4]
  • Air permit program statistics that provide a baseline for performance metrics selected for the event
  • Templates or other resources used for air permit development
  • A copy of the state air quality regulations and policies
  • A copy of the performance metrics you selected to measure event success
  • A “voice of the customer” survey conducted with permit applicants and others can help identify more subjective metrics

You may also want to ask the team members to bring a copy of any individually- developed tools or resources. For example, a permit engineer may have created a permit development checklist or standard permit condition language that he or she uses when developing air permits.


[3] Example “In Scope, Out of Scope” list based on a presentation of the Delaware DNREC.

[4] Example “In Scope, Out of Scope” list based on a presentation of the Delaware DNREC.

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