Lean Government
Region 6 Air Greenhouse Gas Permitting Process
Lean Event Case Study
Summary
In 2011, the Environmental Protection Agency (EPA) began accepting permit applications to build or modify facilities that would emit
greenhouse gases (GHG). While many states issue their own permits, the State of Texas initially declined to issue GHG permits,
leaving the task to EPA Region 6. With an abundance of petrochemical and other carbon-based industries on the Gulf Coast, Region 6
faced one of the largest and most ambitious tasks for GHG Permitting of all the EPA Regions. The Region conducted a Lean project in
February 2014 to streamline its GHG permitting process before transferring authority to issue permits to the Texas Commission on
Environmental Quality (TCEQ). On November 10 2014, permitting authority transferred to TCEQ; thus, Region 6 will no longer be
issuing GHG permits to Texas companies once the Region finalizes the remaining permits in process. Despite the pending transfer of
authority over the last year, the improvements to Region 6's permit writing process initiated by the Lean event have allowed
industries in Texas to receive permits faster and begin construction in a timelier manner.
Results
The Region 6 GHG permitting Lean project created a faster permitting process by streamlining three inefficient aspects of the
process:
1. obtaining supplemental information from permit applicants;
2. coordinating with federal, state, and tribal agencies on cross-cutting issues; and
3. responding to public comment.
The improvements identified allowed Region 6 to issue permits faster, and for Texas industries to proceed with development in a
way that both protects the environment and helps grow the Texas economy. The Lean event team did not quantify the time and
efficiency savings from the project.
Scope of the Lean Project
Project Scope:
The Lean project scope encompassed the Region 6 GHG permitting process in receiving and taking action on a GHG permit.
Goals:
• Develop a flow chart of the R6 Air Greenhouse Gas Permitting Process
• Identify roadblocks and solutions to roadblocks
• Identify innovations to improve process efficiency
Process Changes and Improvements
The Lean team mapped the GHG permitting process and identified a number of process changes to reduce lead time and improve
efficiency. In particular, the team identified three main inefficiencies in the permitting process: (1) obtaining supplemental informa-
tion from the applicant, (2) coordinating with federal, state, and tribal entities on cross-cutting issues, and (3) responding to public
comments.
-------
Obtaining supplemental information from the applicant
• Nearly every GHG permit application requires the permit writer to request additional details from the applicant. Prior to the
Lean event, permit reviewers collected this information via random phone calls from applicants. Permit writers now keep a call
log to track these incoming calls so they become part of the permit record and to facilitate an accurate response when inquir-
ies are made about a permit's status.
• Region 6 also developed standard communication materials, such as a form letter to remind applicants to notify the Region if
changes are made to project design, and started emailing applicants a list of missing items to expedite retrieval of omitted
application materials.
Improving coordination with federal, state, and tribal entities on cross-cutting issues
• Region 6 must consult with (and sometimes obtain approval from) other federal and state agencies and tribes, which can intro-
duce delays to the permit decision. To streamline coordination, the Lean event team developed a standard checklist which
identifies and tracks outreach to the federal, state, and tribal entities that might be involved in the review of each permit. Re-
gion 6 also assigned a liaison responsible for overseeing the checklist and coordinating involvement with these external par-
ties.
• To improve coordination and prevent delays, the Region initiated alerts to the state Congressional office ahead of GHG permit
issuance and began coordinating with the Office of External Affairs to flag GHG permits in weekly congressional reports and in
outreach to Congressional Staff.
Responding to public comments more efficiently
• The comments that Region 6 receives on GHG permits are usually lengthy, technical, and specific to each permit. The Lean
team recommended the Region develop responses for similar issues and repeat responses where applicable.
• The team developed a public comment checklist that both the permit writers and the Office of Regional Counsel use to ensure
the Region addresses all public comments.
• Region 6 now encourages permit applicants to hold direct conversations with environmental groups to address concerns prior
to the comment period on a draft permit. These conversations can minimize, and perhaps eliminate, comments avoiding both
the need for a response from Region 6 and the potential to challenge the permit before the Environmental Appeals Board.
EPA Region t AirfireenlHNBe 03? Permitting Process iValue stream Map
Figure 1: A snapshot of the Lean event team's value stream map.
-------
Region 6 also made the following procedural changes that targeted reductions in lead time in the permitting process:
• Initiated concurrent reviews on draft permits in some source categories with EPA Headquarters and the company
applying for a permit prior to proceeding to public notice. Concurrent reviews eliminated an additional week from the
review schedule.
• Developed a ranking of all permits that do not need Headquarters oversight, reducing process steps and overall lead
time.
• Created a standard checklist for the process for permit writers to follow.
• Eliminated national review on draft permits in source categories where Region 6 has approved multiple permits (e.g.,
coal-fired power plants).
• Changed protocol to assign more complex permits to the most experienced permit writers.
• Brought in temporary technical staff support to increase the rate of permit review in advance of transferring
permitting authority to Texas.
Implementation
Region 6 implemented the process changes discussed above. The Region will no longer be issuing GHG permits in Texas once
all permits in its queue have been issued. As of November 2014, GHG permitting authority transferred to TCEQ and Region 6
will continue to be involved with oversight of the GHG permits.
For More
Information:
Lean Event Contacts:
Margaret Osbourne, EPA Region 6, (214) 665-6508, osbourne.margaret@epa.gov
William Rhea, EPA Region 6, (214) 665-6767, rhea.william@epa.gov
Jeff Robinson, EPA Region 6, (215) 665-6435, robinson.jeff@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-100F14007
------- |