Lean Government
Region 3 Clean Water Act Section 404
Aquatic Resources Regulatory Permit Review
Lean Event Case Study
Summary
The Aquatic Resources Regulatory Permit Review program manager and
team leader identified the §404 Aquatic Resources Regulatory Permit
Review program as a process that needed standardized work to help
improve the quality and efficiency of EPA review comments. Under Section
404 of the Clean Water Act, EPA reviews and comments on permit
applications for development and infrastructure projects that will involve
the discharge of dredging or fill materials into U.S. waters. This Lean event,
held in January 2014, covered EPA's review of §404 permits for the U.S.
Army Corps of Engineers (COE). It sought to standardize and improve the
quality of the permit review process, identify feedback opportunities, and
clarify management expectations. The changes identified will improve the
quality of the reviews and allow Region 3 to review permits in a timelier
manner.
Figure 1: Mountain top mining is just one example
of a project requiring a CWA §404 permit
The team reduced the scope to just one branch of the permit review process and held a 3.5-day value stream mapping Lean event.
Since the event, the team has held meetings and office hours to improve communication between management and staff, and has
begun developing team operating procedures.
Results
The improvements in the new process are expected to reduce lead time in permit review by 72 percent. The new process will also
create new opportunities for staff learning and feedback.
Metric
Lead time (low end)
Process steps
Handoffs
Value added process steps
Non-value added steps
Processing time (low end)
Rolled process quality
Old Process
183 hours
37
17
10 (27%)
10 (27%)
25 hours
7%
New Process
100 hours
24
14
12 (48%)
3 (12%)
7 hours
TBD
Percent Change
vU45%
vU35%
vH8%
1^21%
vH5%
vU72%
TBD
*Results are anticipated based on the new process design
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Scope of the Lean Project
Project Scope: Region 3's Aquatic Resources Regulatory Team's reviews of §404 permit applications from receipt of notification
from the COE through sending final EPA comment. Since the review process has multiple branches of varying complexity, the scope was
further limited to the most common branch that covers Individual Permits.
Goals:
The event sought to improve the efficiency of the permit review process through the following goals:
1. Clarify the process and program expectations.
2. Map the existing and future §404 permit application review process and program expectations.
3. Identify mechanisms, including staff-management feedback, to improve the quality of EPA comments by focusing on the
technical aspects of the review and preparation of consistent and clear comments.
4. Identify significant issues/projects early in the application review period.
5. Identify development and/or training needs and opportunities to improve the quality of the reviews.
6. Identify feedback opportunities within the permit review process.
7. Develop a process within 30 days after completion of Team Operating Procedures (TOP) to determine efficacy and success of
procedures.
Process Changes and Improvements
Participants in the Lean event mapped the current §404 permit review
process, analyzed the process to identify waste, brainstormed solutions
and opportunities for improvement, and streamlined the process to
create a new, desired future state process for Individual Permits.
Lessons learned could be applied to other branches of the §404 permit
review process.
The event team identified the following process changes:
• Enhance communication and feedback in the permit review
process with the addition of management office hours and weekly
meetings to ensure permit application notification and
assignments are 'in sync' between the staff and management
• Create opportunities for collaboration and improve the quality of
Process Step Reductions
Old Process
New Process
IValue-Added ProcesSteps Non-Value Added ProcessSteps SOttierProcessSteps
Figure 2: Process Step Reductions
comments through a peer review option for comment letters and a shared library of completed letters.
Establish one channel for reviewers to receive notice of public comment on §404 permits using the COE Public Notice email
distribution list.
Reduce the number of handoffs in the process.
Develop team operating procedures to standardize the steps in the new process.
Figure 3: The Lean event team in action.
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Implementation
As of August 2014, the team has implemented
the following process improvements:
• Streamlined receipt by registering all
review staff for the COE's Public Notice
e-mail distribution list.
• Scheduled meetings and management
office hours for the permit review team.
• Standardized cursory review of permits.
• Standardized staff roles and
responsibilities for entering data into
DARTER (Data on Aquatics Resources
Tracking for Effective Regulation), which
tracks permits reviewed by EPA.
In addition to these process changes, internal
workgroups developed preliminary drafts of
team operating procedures, and will use team
meetings to report on progress and solicit
feedback. At the time of this case study, the
team had held a 120-day check-in meeting.
Implementation of the process changes is in place and the process continues to be evaluated for future improvements.
Figure 4: The process future state (stars
indicate primary areas of improvement).
Team lead
to ORC fo
revisi
er sends
review/
ary
Event Reflections
• The Lean team found facilitation essential to identifying waste and reaching a streamlined future value stream map.
• The group was motivated for improvement and learned about the process and each other.
• Preliminary mapping work enabled a smoother Lean event and identified future areas for improvement.
• Team members began the event with different levels of enthusiasm for process improvement. While some team members were
reluctant, most saw that giving a "fresh look" at the process through a kaizen event was a bold step to be proud of.
The goal of improving the efficiency of the permit review process was met by:
• Clarifying the process for team.
• Improving the efficiency of the review process, giving more time for the technical review.
• Identifying feedback opportunities within the permit review process.
For More
Information:
Lean Event Contacts:
David Byro, Facilitator, (215) 814-5563, byro.david@epa.gov
Barbara Rudnick, Team Leader, (215) 814-3322, Rudnick.barbara@epa.gov
EPA Lean Government Initiative:
Kimberly Green-Goldsborough, EPA Office of Policy, (202) 566-2355
green-goldsborough.kimberly@epa.gov
http://www.epa.gov/lean/government/
United States
Environmental Protection
Agency
Office of Policy
(1807T)
December 2014
EPA-100F14002
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