EC O S
United Slates
Environmental Protection
Lean in Air Permitting
Guide
A Supplement to the Lean in Government Starter Kit
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Acknowledgments
This guide was developed by the U.S. Environmental Protection Agency's National Center for
Environmental Innovation and Office of Air and Radiation (www.epa.gov/innovation) in
partnership with the Environmental Council of the States (ECOS) to inform and support State
and federal environmental agencies' use of Lean. Ross & Associates Environmental Consulting,
Ltd. (www.ross-assoc.com) prepared this Guide under subcontract to Industrial Economics, Inc.
(EPA Contract # EP-D-04-006).
EPA thanks representatives from the following state environmental agencies for sharing
information on their Lean efforts and for reviewing and commenting on a draft of this Guide:
Delaware Department of Natural Resources and Environmental Control
(http: //www. dnrec. del aware. gov)
Illinois Environmental Protection Agency (http://www.epa.state.il.us/)
Iowa Department of Management and Department of Natural Resources
(http://lean.iowa.gov/www.iowadnr.com/)
Michigan Department of Environmental Quality (www.michigan.gov/deq)
Minnesota Pollution Control Agency (www.pca.state.mn.us)
Nebraska Department of Environmental Quality (www.deq.state.ne.us)
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Lean in Air Permitting
Streamlining and improving air permitting processes is a high priority for many environmental
agencies. Permitting authorities have carefully sought to address business concerns over permit
timeframes and predictability, while providing equal or greater environmental protection and
ensuring permit quality. The Lean in Air Permitting Guide focuses on an exciting approach
which has been successful at improving key dimensions of the air permitting process. Since 2003
public environmental agencies have dramatically improved agency permitting and administrative
processes using Lean and Six Sigma process improvement methods. Within a few months of
implementation, agencies have achieved impressive results, including:
Significant decreases in air permit development timeframes
Decreases to or elimination of permit backlogs
Improved completeness and quality of air permit applications
Improved relationships with other regulators, the regulated community, and the public
Elimination of non-value added activities, allowing permit engineers to devote more
value-added time on permit development
Improved coordination and consistency in permitting approaches within a permitting
authority
This was accomplished while ensuring equal or greater environmental protection and increasing
value-added activities and time. Furthermore, agencies report improved staff morale and
increased permitting process transparency among stakeholders as a result of their Lean
initiatives. The success stories from environmental agencies that have used Lean speak for
themselves:
Iowa Department of Natural Resources reduced the average time to issue standard air
quality construction permits from 62 days to 6 days and eliminated 70 percent of the
permitting process steps, moving from 23 to 7 steps.
Nebraska Department of Environmental Quality decreased their air construction permit
backlog by 55 percent and experienced a 50 percent reduction in the permit review
timeframe.
Lean techniques identify and eliminate unnecessary and non-valued added process steps and
activities that have built up over time. Lean efforts are not just about fixing broken processes.
State agencies have found that these methods enable them to understand how their processes are
working on the ground and to make adjustments that optimize desired outcomes. By getting
process activities and procedures to function smoothly and consistently, agencies free staff time
to focus on higher value activities that are more directly linked to environmental protection.
Successful Lean implementation also equips permitting authorities to move toward a culture of
continuous improvement, enabling on-going program performance improvement. While
successfully implementing Lean requires hard work and commitment, the results can be
impressive.
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The Lean in Air Permitting Guide is an important resource for any environmental agency
interested in improving their air permitting processes. The guide provides numerous specific
examples of the types of changes that several state environmental agencies have made as part of
their efforts to streamline and improve air permitting using Lean. Please note that much of the
value of implementing Lean lies in the ability of Lean methodssuch as value stream mapping
and kaizento provide a clear map of the current and desired future permitting process and to
foster rapid implementation of changes in a coordinated manner. Merely implementing the
specific solutions listed in this guide is unlikely to yield the compelling results that
environmental agencies have achieved through making these changes in conjunction with the
Lean methods. Improvements identified in a Lean event must fit the particular circumstances
and processes specific to state air permit programs and the needs of their customers.
This Lean in Air Permitting Guide will help you better understand the potential value and results
that can be achieved by applying Lean improvement methods to air permitting processes. For
more information on the application of Lean to environmental agency processes, visit EPA's
Administrative Lean website at http://www.epa.gov/lean/admin.htm and EGOS' Lean
Government Website at http://www.ecos.org/section/proiects/?id=2292.
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LEAN IN AIR PERMITTING GUIDE
A Supplement to the Lean in Government
Starter Kit
Contents
Introduction: 1
What Really Happens During an
Air Permitting Lean Event: 5
Applying the Starter Kit to an Air
Permitting Lean Event: 9
Improvements Identified in Lean Air
Permitting Events: 14
Successful Lean Implementation and
Follow-Up: 21
Further Information and
Contacts: 23
Introduction
A number of state environmental agencies have
achieved significant gains from air permitting Lean
events. Lean is a process improvement approach and
set of methods that seek to eliminate non-valued added
activities or waste. This Lean and Air Permitting Guide
highlights those achievements and assists state agencies
in planning and implementing successful air permitting
Lean events. This guide also builds on and
complements the information presented in two
administrative Lean products developed by EPA and
the Environmental Council of States (ECOS):
Working Smart for Environmental Protection:
Improving State Agency Processes with Lean
and Six Sigma, which introduces the use of Lean methods for state agency processes and
describes the benefits gained by state agencies that have held Lean events.
Lean in Government Starter Kit: A Practical Guide to Implementing Successful Lean
Initiatives at Environmental Agencies, which provides detailed information and tools for
planning and implementing a Lean event.
This guide should be used in conjunction with the Lean in Government Starter Kit (Starter Kit),
which presents step-by-step instructions for implementing a Lean event.
This Lean in Air Permitting Guide was developed based on air permitting Lean events held at the
Delaware Department of Natural Resources and Environmental Control, Idaho Department of
Environmental Quality, Illinois Environmental Protection Agency, Indiana Department of
Environmental Management, Iowa Department of Natural Resources, Michigan Department of
Environmental Quality, Minnesota Pollution Control Agency, Nebraska Department of
Environmental Quality, and Virginia Department of Environmental Quality. The ideas and best
practices in this document were primarily drawn from the written outputs and presentations
developed by these agencies after completion of their Lean events. Representatives from six of
the agencies listed above, as well as EPA staff, reviewed this guide to provide additional depth
and insights into the characterization of air permitting Lean events.
Lean in Air Permitting Guide: A Supplement to the Lean in Government Starter Kit
Pagel
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Overview of Lean Air Permitting Successes
This Lean in Air Permitting Guide focuses specifically on Lean events conducted on air
permitting processes. Air permitting processes tend to be top candidates for state environmental
agency Lean events because they are areas in which agencies often experience "pain," in the
form of backlogs, permit approval time, staff turnover, and customer complaints. This guide
provides those interested in conducting a Lean air permitting event with an idea of what occurs
during an event and examples of typical inefficiencies and improvements addressed during Lean
air permitting events.
Applying Lean methods to air permitting processes has created tremendous benefits for state
agencies and significant improvements in those agencies' air permitting programs. Agencies that
have held Lean events report a variety of improvements to their air permitting processes,
including:
Decreases to or elimination of permit backlogs
Significantly decreased air permit development timeframes
Fewer or shorter instances when the permit development clock is stopped
Improved relationships with other regulators, the regulated community, and the public
Improved quality of air permit applications
Fewer distractions for permit engineers, allowing more time to be spent on permit
development
Improved coordination between permit engineers and air permit program managers
The table below quantifies several of these success stories.
Example Air Permitting Lean Event Successes
Delaware Department of Natural Resources and Environmental Control reduced their
natural minor source air permit backlog from 199 to 59 permits in three months and to 25
permits in one year. They also reduced rework by 45 percent and decreased the timeframe
in which minor source air permits are issued.^
Idaho Department of Environmental Quality reduced the number of hand-offs in their air
construction permitting process from 71 to 2 and decreased the permitting cycle time from
325 hours to 116 hours.
In this guide, the term "permit development clock" is used to describe the "value-added" time when the air permit is under
active development (being worked on). "Stopping the permit development clock" refers to those periods when the permit
development is put on hold (e.g., when a permit engineer is waiting for additional information from an applicant).
t Please note that the DNREC backlog included permits waiting to be issued and permit applications that had been abandoned or
withdrawn by applicants.
Lean in Air Permitting Guide: A Supplement to the Lean in Government Starter Kit Page 2
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Iowa Department of Natural Resources reduced the average time to issue standard air
quality construction permits from 62 days to 6 days and eliminated 70 percent of the
permitting process steps, moving from 23 to 7 steps.
Nebraska Department of Environmental Quality decreased their air construction permit
backlog by 55 percent and experienced a 50 percent reduction in the permit review
timeframe.
Overall, one of the key accomplishments of air permitting Lean events has been to decrease the
length of time it takes to process and issue a permit or permit modification, as summarized in the
table below.
Example Improvements in Permitting Timeframes Resulting from Lean Events
State
Agency
Idaho Department of
Environmental Quality
Indiana Department of
Environmental
Management
Iowa Department of
Natural Resources
Iowa Department of
Natural Resources
Michigan Department
of Environmental
Quality
Michigan Department
of Environmental
Quality
Permitting
Process
Permit to construct
Title V permit
modifications
Standard air quality
construction permits
Air quality complex
permits
Major air
construction permits
Minor air
construction permits
Permitting Timeframe
Before Lean Event
(in days)
270
164
62
214
422
143
Permitting Timeframe Total
After Lean Event Decrease
(in days) (in days)
97 173
144 20
6 56
180 34
98 324
50 93
As you begin planning your Lean event, remember that successful events require a considerable
amount of planning, support from all levels of agency management, and follow-up work after the
event to sustain continuous improvement. The Starter Kit and this Lean in Air Permitting Guide
provide detailed information on how to plan, implement, and follow-up to a successful air
permitting Lean event.
Organization of this Lean in Air Permitting Guide
Lean in Air Permitting Guide: A Supplement to the Lean in Government Starter Kit
PageS
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The first section of this guide, "What Really Happens during an Air Permitting Lean Event?"
provides a description of how Lean events typically unfold in an air permitting context, drawing
from previous state agency events. The second section, "Applying the Starter Kit to an Air
Permitting Lean Event," supplements the instructions in the Starter Kit by providing ideas and
best practices specific to air permitting Lean events. The third section, "Improvements Identified
in Lean Air Permitting Events," gives examples of air permitting process inefficiencies (and non-
value-added activities) identified in past Lean events and the solutions devised to improve key
permitting process steps. The fourth section, "Successful Lean Implementation and Follow-Up",
provides best practices on sustaining Lean activity in air permitting Lean events. The final
section presents website links to key Lean resources and provides contact information for Lean
in air permitting experts.
Lean in Air Permitting Guide: A Supplement to the Lean in Government Starter Kit Page 4
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Section 1: What Really Happens During an Air
Permitting Lean Event?
The Starter Kit describes a variety of Lean event methods including "kaizen" and "value stream
mapping." However, past experience has shown that state agencies often use a hybrid of two or
more of these Lean methods for their air permitting events. Your Lean facilitator specializes in
one or more Lean method or uses customized hybrid methods for their Lean events. For that
reason, it will be important to work with your facilitator to identify the best method to suit your
needs.
Lean air permitting events typically consist of 3-5 day event including a variety of team
activities: training on Lean methods; mapping the current air permitting process; discussing
inefficiencies in the current process; identifying improvements to address the inefficiencies; and
mapping or defining a new, improved air permitting process. In addition, successful events
require careful scoping and planning in advance, and concerted attention to post-event follow-up.
The following table provides two example agendas for five day Lean events, which is the typical
length of an agency's first Lean event.
Example Five Day Lean Event Agendas
Dayl
Training Day
Training on Lean
methods; begin
mapping and
measuring time to
complete current
work processes
Dayl
Training Day
Training on Lean
methods
Dayl
Discovery Day
Continue
measuring and
analyzing current
work process
Day 2
Current State
Draw a map of
the current air
permitting
process and
identify problems
Day 3
Do Day
Create and map
anew,
improved
process
Day 3
Future State
Map the shared
vision of the
permitting
process
Day 4
Do, Re-Do,
Document Day
Implement
improvements,
evaluate effectiveness,
and modify
improvements if
necessary
Day 4
Planning
achieve the new
process and create
an implementation
plan
Day 5
Celebration
Day
Present results to
agency managers
and staff and
DayS
Celebration
Day
Present results to
agency managers
and staff and
celebrate
Creating maps of the current and improved air permitting processes is a key part of air permitting
Lean events. The following photographs illustrate the outcome of the process mapping stages of
the Indiana Department of Environmental Management's (IDEM) Lean event focusing on the
agency's title V permit modification process.
Lean in Air Permitting Guide: A Supplement to the Lean in Government Starter Kit
Page5
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IDEM "Current State" Process Map
IDEM "Future State" Process Map
Mapping is a group process that often necessitates a large room, as even the simplest air
permitting processes can be lengthy when broken into individual steps. The draft version of the
value stream map is often done on a whiteboard or on butcher paper tacked on a wall during the
event, as shown in the photographs above. These large initial maps may not always be the most
practical reference tools, so after the air permitting Lean event concludes agencies often develop
Lean in Air Permitting Guide: A Supplement to the Lean in Government Starter Kit
Page6
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electronic versions of their process maps. In some cases, however, it can be useful to keep a
hand-prepared map up on the wall in a conference room or hallway to remind team members of
the new process design and what the team accomplished. The following diagrams show
Delaware Department of Natural Resources and Environmental Control's (Delaware DNREC)
electronic process maps that were developed after their air quality construction permitting Lean
event concluded. Please note that the diagrams are not meant to be legible, rather they are mean
to be illustrative of the air permitting process before and after a Lean event. More detailed
versions of the maps can be found by following the links below.
Delaware DNREC "Current State" Process Map
Delaware DNREC "Future State" Process Map
Example Magnified Section of
Delaware DNREC Process Maps
Min
Max
Avg
Lean in Air Permitting Guide: A Supplement to
Assigned to Engineer
I - 3
Dover/New Castle
% Complete £
Accurate
Processing
Time
Production
Lead Time
Production
Lead Time
Production
Lead Time
Batch
100
1-2
0.2
Mins
Days
Davs
Davs
Time;
Day
Assignment based upon
County and workload
Page/
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Lean methods are based on the concept of continuous improvement, and most agencies hold
follow-up events to their initial air permitting Lean event to encourage follow through and
further improvements. Many agencies hold short follow-up events that occur at regular intervals
(e.g., 30 and 60 days) to assess the efficiencies gained through use of the new air permitting
process and to identify further enhancements to the process. These events tend to last one day or
less. Additionally, some agencies hold longer follow-up events that focus on a specific aspect of
the permitting process that was labeled inefficient during the initial event. For example, a 1-3
day follow-up event could focus on updating an air permit application form.
Lean in Air Permitting Guide: A Supplement to the Lean in Government Starter Kit Page 8
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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 processsuch as minor source
construction permittingas 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.
Starter Kit Link
Chapter 2: How to Select a
Lean Project
Air Permitting Programs Targeted
State Agency
Delaware Department of Natural Resources and
Environmental Control
Idaho Department of Environmental Quality
Illinois Environmental Protection Agency
Indiana Department of Environmental Management
Iowa Department of Natural Resources
Michigan Department of Environmental Quality
Minnesota Pollution Control Agency
Nebraska Department of Environmental Quality
Virginia Department of Environmental Quality
During Past Air Permitting Lean Events
Air Permitting Programs
Minor source air construction permitting
Synthetic minor air construction permitting
Air quality permit issuing process (permit to construct)
Minor source air construction permitting
Title V permit modification process
Air quality complex permitting;
Air quality new source construction permits
Air construction permitting (permit to install
application review process)
Air construction permitting
Air construction permitting
State minor new source construction permits;
Major New Source Review permits;
Title V permits
Lean in Air Permitting Guide: A Supplement to the Lean in Government Starter Kit
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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:
Starter Kit Link
Chapter 3: Scope of the
Event
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:
Starter Kit Link
Chapter 3: Set Clear
Boundaries for Your Event
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.
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Example Boundary Conditions for a Lean Air Permitting Event1
In 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)
Out of Scope
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
Starter Kit Link
Chapter 3: Identify
Performance Metrics and
Pre-Work Needed
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)
* Example "In Scope, Out of Scope" list based on a presentation of the Delaware DNREC.
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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
Starter Kit Link
Chapter 3: Select
Participants and Determine
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
Lean in Air Permitting Guide: A Supplement to the Lean in Government Starter Kit Page 12
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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:
Starter Kit Link
Chapter 3: Collect Needed
Data and Information
Examples of past air permits and/or permit applications to assist in reviewing the permit
process§
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.
§ Please note that the examination of past permits and applications is recommended for the purposes of examining the process.
The confidential permit applicant information should not be included or be made available during the Lean event.
Lean in Air Permitting Guide: A Supplement to the Lean in Government Starter Kit
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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
Permit application
development and
submission
Development and
internal review of the
draft permit
Public comment
period and/or other
external reviews, and
development of the
final permit
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" encompasses all activities that
lead up to the emission source sending an air
permit application to the permitting agency.
Perm it application
development and submission
Available information, tools, and
resources
Process for applying for an air permit
Air permit application forms
final pennK
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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.
Lean in Air Permitting Guide: A Supplement to the Lean in Government Starter Kit Page 15
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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 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,
Permit application
development and
submission
Development and internal
review of the draft permit
Communication with the source and
public
Permit engineer processes and tools
Managing the permit development
process
Review and signature processes
Public comment
period and/or other
external reviews, and
d evel o pment of the
final permit
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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.
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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.
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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
Perm it application
development and
submission
Development and
internal reviewofthe
Public comment
period and/or other external
reviews, and development of
the final permit
EPA review process
"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
Source review process
Public comment process
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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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Section 4: Successful Lean Implementation and
Follow-up
Starter Kit Link
While significant progress is typically made in designing and
implementing air permitting process improvements during a Lean
event, successful implementation hinges on effective follow-up.
Agencies have found that several key actions can ensure that
improvements and results are sustained into the future: Chapter 4: Sustaining Lean
Improvements
Documentation and training on the new process: People
need to know what the new air permitting process is.
Agencies have posted the new value stream map or process map so that all can see it;
some agencies make a fresh, clean version using a process mapping software program so
it can be easily posted and distributed. Staff must be trained on the new process,
particularly those who did not participate in the Lean event. There may also be a need to
update or write new office procedures.
Follow-up meetings: Since it is often not feasible to fully implement the new process
during the Lean event, there is typically a list of follow-up actions. Agencies usually
conduct 30, 60, and 90-day follow up meetings to review the status of action items, to
hold team members accountable for completing them, and to review how the new process
is doing and make adjustments as appropriate. Some agencies also find it useful to
conduct 6-month and 1-year follow-up meetings to ensure that the new air permitting
process is performing well and to identify steps to prevent "backsliding".
Management support: It is very important for air permitting program managers, and
their superiors, to clearly communicate their support for the new air permitting process.
All employees must understand that management is fully behind the new process and that
"doing things the old way" will not be tolerated. At the same time, management can let
staff know that communication is encouragedif things are not working well in some
aspects of the new process, the team can discuss adjustments and improvements.
Keeping with the spirit and philosophy of Lean, some agencies view their initial Lean air
permitting events as the starting point for fostering a broader continuous improvement culture.
For many processes, organizations will conduct a kaizen improvement event on the same process
every few years, with mini-events and follow-up meetings held in between to assess performance
and to identify and make incremental improvements. Holding a kaizen event is not just a one-
shot improvement effort. Instead, it is the beginning of a process to engage employees in
continuous process improvement, where the team continues to adjust the air permitting process
to get better results"to make it good for all."
As you can see Lean events have been successful in quickly identifying and implementing a
broad range of solutions to improve air permitting processes. While the Lean journey takes hard
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work and perseverance, the power of harnessing the hearts and minds of employees for achieving
excellence can be transformative, leading to satisfied constituents, empowered and engaged
employees, passionate leaders, and improved air permitting processes. We encourage you to take
time to learn more about opportunities to apply Lean to air permitting and share your own
experiences.
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Section 5: Further Information and Contacts
This guide presents a snapshot of Lean air permitting experience, and is intended to be a living
document. If you would like to share your experiences and ideas in future versions of this guide,
please contact Jamie Burnett at EPA's Office of Policy, Economics and Innovation. Other
contacts and Lean in air permitting resources are also listed below.
Jamie Burnett
EPA Office of Policy, Economics, and Innovation
National Center for Environmental Innovation
Burnett.j amie@epa. gov
EPA's Lean website:
http://www.epa.gov/lean/
Lee Garrigan
Environmental Council of the States
lgarrigan@sso.org
Environmental Council of the States (ECOS) Lean website:
http://www.ecos.org/section/proiects/?id=2292
Administrative Lean Products
Working Smart for Environmental Protection: Improving State Agency Processes with
Lean and Six Sigma: http://www.epa.gov/lean/toolkit/LeanGovtPrimer.pdf
Lean in Government Starter Kit: A Practical Guide to Implementing Successful Lean
Initiatives at Environmental Agencies: http://www.epa.gov/lean/starterkit/
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United States Environmental Protection Agency
www.epa.gov/lean
September 2008
EPA-100-K-08-005
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