Lean Government
EPA Region 7 and Four States
Clean Air Act State Implementation Plan (SIP)
Kaizen Event Case Study
Summary
EPA and the four States of Region 7—Iowa, Kansas, Missouri, and Nebraska—conducted a Lean kaizen event in January 2010 to cut
waste and improve the speed and effectiveness of the Clean Air Act State Implementation Plan (SIP) process in the region. Every State is
required to develop an implementation plan for meeting the Clean Air Act requirements; when national rules, state rules, and/or
National Ambient Air Quality Standard (NAAQS) attainment status changes, States must submit revised SIPs to EPA for review and
approval. EPA's review involves the EPA regional office along with the EPA headquarters Office of Air and Radiation (OAR), Office of Air
Quality Planning and Standards (OAQPS), and Office of General Counsel (OGC). Prior to the event, it took as much as an estimated 7.4
years to complete the SIP process in Region 7, from the time EPA promulgates a rule through the SIP development, review, and final
approval.1 With the new process that the kaizen event team developed, the Region 7 SIP process could take significantly less time—as
little as 3.2 years (56% less).
This Lean SIP process improvement event sought to address recommendations in the National Academy of Sciences' 2004 report to
Congress on "Air Quality Management in the United States" by enhancing the effectiveness and efficiency of the SIP process. It was also
responsive to EPA's Clean Air Act Advisory Committee (CAAAC) Air Quality Management Task Force's Recommendations.
During the kaizen event, participants developed a detailed process map of the existing SIP process, brainstormed new approaches, and
developed a process map and plan for a new process that could significantly reduce processing timelines, eliminate redundant or
unnecessary work, and improve collaboration. Process improvements were identified for three phases of the SIP process: (1)
designations—the process of designating nonattainment areas after EPA issues a new NAAQS, (2) the State's SIP development process
and EPA's review process, and (3) the public comment and final approval process. Since the event, the kaizen event team has organized
into workgroups to implement the action items from the event and other follow-up activities needed to enact the new SIP process.
1 7.4 years is a "worst case" estimate of the time needed to complete the current process, not including litigation.
Results
Participants in the SIP kaizen event designed a new, streamlined SIP process representing a desired future state and identified a series
of process improvement actions to work towards the new process. Once fully implemented, the new SIP process is anticipated to
yield the following results:
• Reduced total processing time for the SIP process from 7.4 to 3.2 years (56% reduction).
• Reduced the best case delay time from 4.7 to 1.1 years (77% reduction) and the worst case delay time from 8 to 1.3 years
(84% reduction).
• Decreased process steps from 165 to 134 (19% reduction).
• Cut the number of decisions from 14 to 8 (43% reduction).
• Freed staff time to address the Region 7 SIP backlog and avoid creating a future backlog.
The actual results of implementing the new process could vary widely depending on a number of issues, many of which are outside
the control of the states and the EPA regional office. Although it may take a while for EPA and the Region 7 States to fully implement
the new SIP process and thus achieve the full benefits of the new process, the agencies that participated in the kaizen event are ac-
tively working together on implementation priorities. They have also already benefited from the increased understanding and im-
proved communications and collaboration fostered in the event.
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Scope of the Lean Project
Project Scope: Clean Air Act SIP process from the time EPA promulgates a rule that requires States to prepare or modify a SIP through
the final EPA approval of the SIP
Goals
The goals of the event included:
• 100% of approvable NAAQS attainment demonstration SIP submittals occur within statutory timeframes.
• SIPs are of sufficient quality to be approvable on the first pass.
• Reduce processing time by 50 percent.
• Eliminate a third of the SIP processing backlog each year for the next 3 years, excluding SIPs that are being held up by lawsuits.
Process Changes and Improvements
During this kaizen event, participants developed and analyzed "current" and "future" maps of the SIP process, focusing on SIPs that
relate to demonstrating attainment of national ambient air quality standards for ozone. Along with these process maps, participants
came up with the following key improvement actions to achieve the future SIP process.
• Provide early guidance to States on designations and designation boundaries to improve the quality of State submittals and
allow States avoid rework in their boundary recommendation efforts, which lead to the development of SIPs for the designated
nonattainment areas.
o Ideally EPA should strive to issue implementation rule and related guidance with NAAQS promulgation. (If complete
guidance cannot be issued, EPA could identify key elements that States need to move forward and provide that
information in a memorandum. This information could include technical requirements such as modeling and inventory
development guidance changes, any large or key changes to existing implementation guidance, and/or new emission
control requirements.)
o A joint meeting with EPA headquarters, Region 7, and the affected State(s) may be needed to reach agreement on the
designation boundaries for each area.
• Develop a designation and SIP-development "road map" for each geographic area that allows for EPA, States, and regional
planning organizations (RPOs) to coordinate on a plan for efficiently conducting the work, including work sharing, concurrent
review, and improved collaboration. Establishing clear roles and responsibilities as well as a schedule for the SIP development
and review process will help to decrease processing time and delays, eliminate unnecessary process steps, and improve the
outcomes of the process.
o This process relies on early planning, strong working relationships, and a commitment to making timely decisions and
following through on them.
• Through the road map approach, EPA and the Region 7 States plan to shift from sequential to concurrent steps at many points
in the process to save time, while ensuring the same level of environmental protection.
o In the new process, States will include legal and enforceability reviews as part of their internal rule development process,
as some States do already.
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Explore options to engage RPOs for technical work for air issues affecting multiple states. As regional resources, RPOs could
potentially contribute to overall efficiency improvements in the SIP process by conducting regional analyses that multiple states
could use in their SIPs as well as potentially through work sharing agreements with States.
o The RPO in the Midwest—the Central Regional Air Planning Association (CENRAP), which is affiliated with the Central States
Air Resource Agencies (CENSARA)—is one of five RPOs in the country. These RPOs have varying degrees of resources and
expertise.
Develop standard tools and templates to assist States with SIP development and to speed EPA's SIP review process. Products
included the following:
o A SIP template for SIP submittals, focusing initially on ozone attainment demonstration SIPs
o A menu of control options that are acceptable to include in SIPs (This will be developed by 2011 for ozone.)
Provide guidance on national measures (rules and tools) that could improve the SIP process. Quantifying emissions reductions
expected in future year emissions inventories in SIPs for "on the books" federal regulations will assist States in efficiently com-
pleting their SIP submittals. The kaizen team also decided to explore any feasible actions related to federal rules and measures
that could positively affect the efficiency of SIP process.
Develop a strategy for the public comment and federal register process that maximizes efficiency while retaining transparency
and environmental protection.
Figure 1: Changes to the Four State/EPA Region 7 State Implementation
Plan (SIP) Process
Old SIP Process (approximately7.4 years)
Nonattainment Area
Designation Phase
SIP Development
Phase
EPA Review, Public Comment,
& Final Approval Phase
New SIP Process (potentially 3.2 years)
o As part of the collaborative proc-
ess, States, working with RPOs,
will draft and share the whole SIP
package (all pieces of a SIP sub-
mittal) with EPA early, prior to
public meetings.
o States and EPA will address all
issues and comments at early
draft stage so that the final docu-
ment is "ready to go" at submit-
tal. (This is predicated on timely
promulgation of an implementa-
tion rule and/or adequate guid-
ance to inform the development
of the SIP.)
o The public comment strategy will
include options for efficient proc-
esses (such as a direct final rule
process that uses one instead of
two stages of public comment
when adverse comments are not
expected or an EPA/State parallel process).
• Eliminate unnecessary documentation such as federal technical support documents as part of Federal Register package, the
completeness letter, and other items.
^r Designation ^
L Phase A
Early guidance
Concurrent
monitoring review
Develop road map
(including worksha re)
Early boundary
• agreementwith
j HQ/Region/State
(unofficial)
rsiP Development ^J
& EPA Review Phase ^k
RPO involvement
Guidance on national measures,
menu of controls, SIP template
States share "complete" draft SIPs
EPA HQ/Regions early
involvement
i :
Public Comment & ^J
. Final Approval Phase ^m
Final SI P100%approvable
Public comment strategy
Concurrent public process
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Transferability
Figure 2: Current Process Map
Many of the process improvement strategies
used in the Region 7 SIP Lean event are
approaches that are relevant nationally or
could be adapted to other Regions or States;
however, other strategies are not directly
transferable since they depend on the specific
processes and relationships involving Region 7,
Iowa, Kansas, Missouri, and Nebraska. Region-
specific elements include work sharing, use of
RPOs, the specific collaborative approach
between the States and Region, and the
willingness of all parties to work together on
SIPs early in the process. Transferable
elements of the Region 7 SIP Lean approach
include:
• Early guidance/implementation rules
from EPA
• SIP template
• Menu of control options
• Quantification of emissions reductions
needed for future year emissions
inventories
• Creative strategies for processing
public comments
• Reduced EPA documentation
• SIP Training
• Timely management decisions
Figure 3: Future Process Map
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Implementation
Since the event, the SIP kaizen event team has organized into seven implementation workgroups covering the major follow-up areas
from the event as well as conducted a series of presentations and follow-up meetings. The team has held 30-day and 60-day follow-up
meetings by conference call and met in person for a 90-day follow-up meeting in April 2010. The workgroups involve participants from
the event as well as additional staff from EPA headquarters, regional offices, States, and the Mid-America Regional Council (the
metropolitan planning organization for the greater Kansas City area). The roadmap workgroup is working to identify and pilot test at
least one SIP per State to run through the new process. Other workgroups are developing tools and products, such as a menu of control
options and a SIP template; clarifying roles and procedures to improve efficiencies; and planning for additional communications and
rollout.
At the 90-day meeting, the kaizen event team identified the next set of action items and milestones for implementation of the new SIP
process as well as the tools, products, and procedures to support it. Roadmaps for four pilot SIPs (one per State) will be initiated
immediately following the 90-day meeting. These roadmaps will provide a benchmark by which progress toward the SIP Lean goals can
be measured and evaluated overtime.
For More
Information:
Contact People:
EPA Region 7
• Ashley Betts, EPA Region 7, State Coordinator and Kaizen Event Team Leader,
(913) 551-7336, betts.ashley@epa.gov
• Josh Tapp, EPA Region 7, Air Planning and Development Branch Chief, (913) 551-760,
tapp.joshua@epa.gov
• Becky Weber, EPA Region 7, Air and Waste Management Division Director,
(913) 551-7487, weber.rebecca@epa.gov
States
• Iowa Department of Natural Resources: Jim McGraw, Environmental Program Supervisor, Air
Quality Bureau, (515) 242-5167, jim.mcgraw@dnr.iowa.gov
• Kansas Department of Health and Environment: Miles Stotts, Environmental Scientist, Bureau of
Air, (785) 296-1615, MStotts@kdheks.gov
• Missouri Department of Natural Resources: Jeff Bennett, Environmental Engineer, Air Pollution
Control Program, (573) 751-8406, jeff.bennett@dnr.mo.gov
• Nebraska Department of Environmental Quality: Beverly Kellison, Air Quality Program Planning
and Development Supervisor, (402) 471-2189, bev.kellison@nebraska.gov
EPA Lean Government Initiative
• Jamie Burnett, EPA OPEI, (202) 566-2305, burnett.jamie@epa.gov
• Kimberly Green-Goldsborough, EPA OPEI, (202) 566-2355, green-
goldsborough.kimberly@epa.gov
http://www.epa.gov/lean/leangovernment
United States
Environmental Protection
Agency
Office of Policy,
Economics and Innovation
(1807T)
July 2010
EPA-100-F-10-022
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