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Section 3: Improvements Identified in Lean Air Permitting Events

Merely implementing specific solutions listed in this guide is unlikely to yield the compelling results that environmental agencies have achieved with Lean methods. Lean methods are specific approaches whose results cannot be replicated by simply brainstorming improvement ideas. A significant portion of all air permitting Lean events is spent identifying “wastes” in the current air permitting process and discussing potential improvements to address those “wastes.” This section describes examples of improvements to address common air permitting process “wastes” that were identified by state agencies during air permitting Lean events.

The breadth of program activities considered during an air permitting Lean event can be extensive. To help organize the air permit program improvements listed below, this guide categorizes the improvements under three general process steps: (1) improvements related to the development and submission of the permit application; (2) improvements relevant to the development and internal agency reviews of the draft air permit; and (3) improvements to the processes for external reviews of the draft permit and development of the final air permit.

Generalization of an Air Permit Development Process

Generalization of an Air Permit Development Process

Below are lists of example air permit program improvements that were brainstormed during past state agency air permitting Lean events. The list is provided to help you start thinking about areas for improvement within your air permitting process and to help your Lean event team understand the types of ideas that can result from an air permitting Lean event. You may also find this list beneficial for setting the scope and boundary conditions for your event.

Permit Application Development and Submission

Permit Application Development and Submission

“Permit application development and submission” encompasses all activities that lead up to the emission source sending an air permit application to the permitting agency. During past air permitting Lean events, state agencies recognized that key “wastes” in their air permitting processes include the receipt of incomplete applications, the receipt of applications that contain errors, and a lack of templates and standards for permit applicants to follow. State agencies implemented a number of improvements to address these issues, which fall into three main categories: (1) improvements to the information, tools, and resources available to permit applicants; (2) improvements to the application process; and (3) improvements to the air permit application forms. Specifically, state agencies considered or implemented the air permitting process improvement ideas listed below.

Improvements to the Information, Tools, and Resources Available to Permit Applicants

  • Update websites: Update the air permitting sections of agency websites to include improved information on how to apply for an air permit, and include targeted information for specific industry sectors.
  • Develop a checklist: Develop an air permitting application checklist which documents all forms and information that must be submitted with a permit application and post this checklist online.
  • Develop templates for calculations: Develop template spreadsheets for emissions calculations and make the templates available online.
  • Identify points of contact: Designate an agency staff member as the primary contact for air permitting questions and post this representative’s contact information online, or establish an air permit question hotline.
  • Provide information on “stopping the permitting clock”: Clearly define the types of issues that can cause the permit engineer to “stop the clock” during permit development and communicate these with sources.
  • Provide information on permit denials: Provide a clear description of common reasons for the agency to deny air permits, and the process followed when permits are denied.
  • Perform outreach on air permitting processes: Actively perform outreach to the regulated community on the air permitting process through targeted newsletters or electronic bulletins.
  • Perform outreach on rule changes: Perform targeted outreach to the regulated community for any air quality rule changes.
  • Work with the state business development office: Establish a working relationship with the state business development office to enhance joint air permitting communication opportunities.
  • Work with compliance assistance staff: Ask compliance assistance staff to discuss the air permitting program procedures with sources.
  • Get feedback from permit applicants: Actively request feedback from permit applicants on the air permitting process and tools available to applicants.

Improvements to the Permit Application Process

  • Set up pre-application meetings: Set up a formal pre-application meeting process, where sources are required to (or can elect to) meet with agency air permitting engineers and/or managers to discuss a set list of topics about their application, such as:
    • Appropriate air quality permits for the proposed construction or modification project;
    • Appropriate emissions control measures (e.g., BACT and LAER requirements);
    • Ideas for permit conditions, including existing permit conditions from previous permits held by the source or by similar sources;
    • Any questions the permit engineer may have on the source’s emissions calculations (provided that the source sent a draft to the permit engineer prior to the pre-application meeting); and
    • Anticipated timeline for permit development and source review of the draft permit.
  • Require electronic submission of calculations: Require the submission of electronic versions of emissions calculations spreadsheets at the same time the permit application is submitted to facilitate permit engineer review.
  • Tour the source: Allow permit engineers to tour the source in conjunction with the pre-application meeting if they are not familiar with the source.

Improvements to the Permit Application Form

  • Improve usability of forms: Revise and clarify air permit applications forms to improve usability.
  • Use electronic forms: Develop electronic application forms (e.g., editable PDF forms or spreadsheets).
  • Identify required fields: Clearly identify required fields on the air permit application forms.
  • Require applicants to highlight changes: Require applicants to highlight proposed changes in permit amendment applications.

Development and Internal Review of Permit

Development and Internal Review of Permit

“Development and internal review of the permit” includes all the activities and processes that take place within the state agency to develop the draft of the air permit that is provided to parties outside of the permitting authority for review and comment. During past air permitting Lean events, state agencies identified key “wastes” in their permit development processes include permit backlogs, review bottlenecks, inefficient use of staff time, unnecessary data entry and rework, unbalanced allocation of work, lack of templates and standard language, and poor communication during the development process. State agencies considered a number of improvements to address these air permit development issues, which fall into four main categories: (1) improvements to communication with the source and the public during permit development; (2) improvements to permit engineer processes and tools; (3) improvements for managing the permit development process and training staff; and (4) improvements to review and signature processes for draft permits. Specifically, state agencies considered or implemented the air permitting process improvement ideas listed below.

Improvements to Communication with the Source and the Public during Permit Development

  • Post permit development status online: Develop an online database or tracking system that lists the status of pending permit applications.
  • Ask the source to provide a single point of contact: Request that the source identify a single point of contact and, in cases where the sources work with a consultant, coordinate with its consultant when contacting the state agency.
  • Develop a plain English guide to air permitting: Develop a plain English guide to the air permitting process and post this guide online, with the goal of minimizing the number of queries received from members of the public.
  • Minimize lobbying: Engage industry to develop agreements to help minimize lobbyist congressional calls.

Improvements to Permit Engineer Processes and Tools

  • Clarify the process for sending “no permit required” letters: Clarify the process for “no permit required” letters and designate non-engineer staff to manage distribution of these letters.
  • Return permit applications that do not pass the administrative completeness check: Return permit application to source (deny the permit) immediately if it does not pass the administrative completeness test instead of “stopping the clock” on the permit development (in other words, take the permit out of the engineer’s queue so that he/she can concentrate on other administratively correct permit applications).
  • Give the source a “welcome call”: Formalize a procedure for the permit engineer to give the source a “welcome call” at the onset of permit development to expedite further communications during the permit development process.
  • Formalize kick-off check-ins with the source: Formalize a process for permit engineers and sources to meet at the onset of permit development to discuss permit conditions, emission calculations, and other permit requirements.
  • Formalize kick-off check-ins with managers: Formalize a process for permit engineers and managers to check-in at the onset of permit development to discuss permit structure and conditions.
  • Give the modeler a copy of the application immediately: If modeling is required for the permit, ensure that a copy of the permit application is given to an agency modeler as soon as the application is received and that the modeler and permit engineer are working under similar timelines.
  • Bring in compliance and legal experts early: Ensure that compliance and legal expertise are utilized early in the permit development process.
  • Create a technical review checklist: Create a checklist for technical reviews of permit applications.
  • Block time for communicating with the source: At the onset of permit development, schedule time blocks for permit engineers and permit applicants to discuss progress on the permit development and any questions the engineer may have on the application.
  • Block “no-interruption” time: Maximize time available for permit engineers to focus on permit development by shortening internal meetings, arranging blocks of “no-interruption” time for engineers, posting “quiet time” signs, and designating time blocks for engineers to respond to phone inquiries.
  • Update air permit templates: Update the air permit templates (e.g., use a table structure for permit conditions).
  • Develop a clearinghouse of standard permit language: Develop a clearinghouse of standard permit conditions, rules, and emission factors for permit engineers to reference during permit development.
  • Incorporate rules by reference: Develop a process for permit engineers to incorporate rules by reference in air permits.
  • Modifications or upgrades to existing information systems or tools: Lean event teams may opt to modify existing information system tools and or implement new electronic tools to aid in permit tracking. 

Improvements for Managing the Permit Development Process and Training Staff

  • Use project management software: Track permit development and staff workload using a tracking board or project management software.
  • Communicate permit development timelines and deadlines: Clarify deadlines and timelines for phases of air permit development (e.g., administrative and technical reviews, development of permit conditions, and managerial reviews of draft permits) and communicate these with engineers, modelers, and permit program managers.
  • Clarify prioritization and staffing policies: Clarify policies on prioritization of permits (e.g., implement a first-in, first-out policy), how to manage backlogs, and when and how to use consultants to supplement agency permit engineers.
  • Implement a rewards system: Implement a rewards system or other bonus to decrease employee turnover.
  • Develop updated training materials: Develop updated training materials for new permit engineers which incorporate state agency procedures and utilize existing training resources provided by other parties (e.g., NACAA, CenSARA, CARB, or consultants).
  • Cross-train staff: Cross-train staff and ensure that there are designated back-ups for critical duties.
  • Encourage permit engineers to mentor each other: Have more junior permit engineers shadow more senior permit engineers for the development of a complicated permit as part of ongoing training.
  • Encourage permit engineers and managers to discuss FAQs: Hold internal meetings between permit engineers and managers to discuss air permitting questions and processes.
  • Reconfigure the office layout: Reconfigure the office layout to facilitate better workflow.

Improvements for Review and Signature Processes for Draft Permits

  • Streamline internal review processes: Streamline and formalize permit review processes for state agency managers (decrease the number of hand-offs by minimizing the number of parties reviewing the permit drafts and/or the number of times the draft permits are reviewed).
  • Switch to electronic reviews: Complete reviews of draft permits electronically and send comments using “track changes”.
  • Improve systems for tracking comments: Develop processes or systems for tracking managers’ comments on draft permits.
  • Use permit tracking numbers: Use a unique permit number to more effectively track draft permits internally.
  • Increase number of managers that can approve permits and notices: Authorize more than one manager to sign off on public notices and approve draft permits for source review.

External Reviews of the Draft Permit and Development of the Final Air Permit

External Reviews of the Draft Permit and Development of the Final Air Permit

“External reviews of the draft permit and development of the final air permit” encompasses all external reviews of the draft air permit and development of the final air permit that incorporates changes based on these external reviews. It is important to note that for some air permitting programs, these external reviews occur multiple times during permit development or are incorporated earlier in the permit development process. In addition, not all air permitting processes require EPA reviews or public comment periods, so some of the improvements listed below may not apply to your air permit process. During past air permitting Lean events, state agencies recognized that a key “waste” in their external permit review processes is unnecessary rework caused by improper timing and planning for external reviews. State agencies implemented or considered a number of improvements to address this issue, which fall into two main categories: (1) improvements to the processes for sources and EPA to review draft permits and (2) improvements to the public comment process. Specifically, state agencies considered or implemented the air permitting process improvement ideas listed below.

Source Review Process

  • Allow the source to review the draft permit earlier or more often: Move the source review of the draft permit to as early in the permit development process as is possible, or allow multiple reviews of the draft permit at various points in permit development.
  • Ensure source buy-in to draft permit before public comment period: Ensure that the source has bought into the permit before it is sent for public review.

EPA Review Process

  • Standardize processes for EPA reviews: Standardize review timeframes and response processes for EPA air permit reviews.

Public Comment Process

  • Develop templates and standard language for responding to comments: Develop standardized templates and language for permit engineers to use when responding to public comments.
  • Alert senior management of significant public comments: Institute a procedure for permit engineers to alert management early if there are comments that will be difficult to address or respond to.
  • Provide guidance to the public on submitting comments: Develop a guidance document aimed at helping the public understand best practices for expressing and submitting comments on air permits.
  • Decrease public review timeframes: Decrease the length of public comment and public notice periods.
  • Coordinate public hearing and public comment period timeframes: Institute parallel schedules for public hearings and public notices.

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