BEST PRACTICES IN PERMITTING
Good For The Economy, Good For The Environment
INTRODUCTION
In 2018, EPA established a goal that by September 30,
2022, all EPA permitting decisions would be made
within six months. EPA's Smart Sectors Program set
about looki ng for examples of when the permitting
process has been efficient, so that the Agency
could learn from such examples. This profile and
accompanying video showcase a successful permitting
process in an effort to help EPA, along with companies,
states, and other regional/federal agencies, learn from
this example.
THE CHALLENGE
When The Boeing Company decided to secure
additional land for future growth in Charleston, SC,
the company identified 468 adjacent acres that met its
needs. Because about 150 of those acres were wetlands,
Boeing worked with the U.S. Army Corps of Engineers,
the South Carolina Department of Health and
Environmental Control, and EPA Region 4 to secure
air, wetlands, and other permits for development.
Leadership at Boeing understood that this complex
permitting could take years, but they hoped to attain
the permits faster to allow for immediate expansion
needs.
THE RESULT
Boeing received the necessary permits to expand
onto 468 acres, including a major air permit and
a wetlands permit, just over six months after the
permit applications were filed. One component of the
company's comprehensive wetlands mitigation plan
involved protecting wetland and upland resources
The Boeing Company 787 assembly facility in Charleston, SC.
that are next to the Francis Marion National Forest.
The wetlands mitigation plan includes restoration
and enhancement of aquatic resource functions and
habitat improvements on nearly 4,000 acres of land
that will eventually be turned over to the USDA Forest
Service and the South Carolina Department of Natural
Resources for public access, including hiking, bird
watching, and other recreational activities.
This wetlands mitigation plan benefits the community,
water quality, wildlife, and threatened and endangered
species. From a regulatory perspective, it also helps
maintain and improve the Cooper River watershed
by fully offsetting adverse impacts to aquatic resource
functions associated with the expansion of the existing
aircraft manufacturing and assembly complex. Finally,
landscape-scale conservation and collaboration are
integral to helping restore the longleaf pine ecosystem.
&EPA
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EPA 230-F-18-002 • JUNE 2018

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LESSONS LEARNED	
•	Plan: Engage early with key stakeholders; take
advantage of pre-application meetings; and
create a permit target schedule.
•	Communicate: Identify needs (requirements,
priorities, uncertainties) and solutions.
•	Be flexible: Be willing to change course when
necessary to overcome barriers.
•	Collaborate: Work together to achieve the best
outcomes.
A streamlined permit process is good for the economy
and good for the environment.
FAST FACTS	
•	South Carolina has reduced the average time it
takes to issue state permits by about 40 percent
since 2007.
Planting longleaf pines as part of the mitigation plan.
•	This 40-percent reduction yields an estimated
economic impact between $72-$103 million
dollars each year for the state and corresponds to
between 619-882 jobs and $35.6~$50.7 million in
new labor income for South Carolinians.
•	Any reduction In timeframes contributes
to measurable economic results, and it may
contribute to faster environmental protection.
•	The wetlands mitigation plan protects almost
4,000 acres of property, helping to expand the
green belt around Charleston.
REPLICATION POTENTIAL	
Volvo and Mercedes-Benz have each followed the
Boeing example with similarly successful outcomes.
USDA's Forest Service has changed the way it
prioritizes lands for future acquisition, partially as a
result of this project. Hie Forest Service has added
mitigation potential into the equation.
The Open Space Institute has worked on three projects
immediately adjacent to the site for other mitigating
parties since the completion of this project - and they
all had similar approaches.
PERSPECTIVES
Plan: Engage early with key stakeholders; take
advantage of pre-application meetings; and
create a permit timetable with a joint schedule.
"We make permitting as clear and predictable as
possible starting with Permit Central, our service
for South Carolina's permit information. We jointly
created a matrix with Boeing that
includes every required permit in the W L
process, indicated when they would
•	Healthy People. Healthy Communities
provide required information, and
when we would target a decision on each permit.
We've been very successful when we set a joint
schedule. We also establish single points of contact
for decision makers in the process and make schedule
adjustments as necessary."
- Shelly Wilson, South Carolina Department of
Health and Environmental Control, Permitting
and Federal Facilities Liaison
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"We like to see wetland mitigation
projects adjacent to existing
protected lands because that helps us Army corps
.	r , .	of Engineers ,
ensure the success ot the restoration.
Tliis is a good example of a watershed approach to
compensatory mitigation."
- Nathaniel Ball, U.S. Army Corps of Engineers
Biologist
"Although SC DHEC and Army Corps of Engineers
issue the actual permits, EPA can provide support
throughout the permitting process. What I would say
to other companies is: call us to request pre-application
meetings. Once you file a permit application, the
process becomes more formal. Everything must be
documented in writing back and forth, and that takes
longer.
We often get permit application packages where
the applicant has not engaged the community,
stakeholders, or the regulatory agencies. Engaging
early in the process makes the permitting process
work much more efficiently. Additionally, you must
view your mitigation cost as part of your overall cost.
Wetlands mitigation projects don't have to be large; it's
more about functional ecological gain than it is about
acreage."
-Kelly Laycock, EPA R4 Wetlands Regulatory Division

Wetlands conservation is important for the economy, water
quality, and fish and wildlife productivity.

Maintaining and improving the Santee Watershed is critical
for the health of the diverse ecosystem in Charleston.
Communicate: Identify needs (requirements,
priorities, uncertainties) and solutions.
"When Boeing started talking about how to enable
long-term growth on this site over time, including an
immediate need for a facility where we could paint the
787s we build here, we realized
well need additional land. We (7$ ZMJ/EJA/IZ
intended to acquire about 468
acres adjacent to this campus for just that, but were
faced with a challenge — about 150 of those acres were
wetlands. So, we started having extensive conversations
internally and externally.
We knew wed need permits from the U.S. Army Corps
of Engineers and the South Carolina Department of
Health and Environmental Control. We knew this
kind of permitting could take years, but we aspired
to get the permits in nine months or less to allow for
immediate expansion needs. Never did we imagine
we'd get the permits in six months."
- Leah Krider, Senior Counsel, The Boeing Company
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"^Nature
Conservancy
"In terms of challenges, the
USDA Forest Service couldn't
do the front-end work of
purchasing land and the actual mitigation itself, and
Hie Nature Conservancy was not the right long-term
owner of the land. I think putting our heads together
and communicating was what ultimately worked."
-	Mark Robertson, The Nature Conservancy, South
Carolina Chapter Executive Director
Be flexible: Be willing to change course when
necessary to overcome barriers.
"I recall at one point, we wanted to do something with
another organization, and we weren't able to do it. So,
we got together and said, "Okay, well, what CAN we
do?" The thing is: Everyone has a different mission.
Ours is to protect the land. Boeing really wanted to get
this expansion permitted. Everyone wants to save the
woodpeckers. Hie key was finding a project that met
the goals of everyone involved."
-	Robert Perry, Former Director of Environmental
Programs, SC Department of Natural Resources
"The hardest part was negotiating the property
sale with the owners. The
good news is: after the land
is transferred, it will be
protected for the benefit of
all residents under the South Carolina Land Property
Trust Act."
-	David Maybank, III, Lowcountry Land Trust
Board Chair
"This project has changed the way we
prioritize lands for future acquisition as
part of National Forests. We have added
mitigation potential into the equation.
It's important to point out that from a
federal perspective, we worked together to find the
flexibility to do this within our regulations."
-	Peggy Jo Nadler, USDA Forest Service Lands
Program Manager
Collaborate: Work together to achieve the
best outcomes.
LOWCOUNTRY
LRNDTRUST
US Army Corps
of Engineers^
"When a permit applicant proposes
to impact aquatic resources that are
protected under the Clean Water
Act, the applicant is responsible
for evaluating their options and developing a
compensatory mitigation plan. Boeing took this
responsibility seriously and worked with resource
agencies, environmental organizations, and elected
officials to develop a mitigation plan that would
provide a long-term benefit to the community and the
environment.
Different industries have different permitting
hurdles. But, every industry can stand to gain
from streamlining processes. The importance of
collaboration and flexibility cannot be highlighted
enough."
- Travis Hughes, U.S. Army Corps of Engineers
Senior Chief

OPEN SPACE
I NSTITUTE
"OSI has worked on three
projects immediately adjacent
to this site for other mitigating
parties since the completi on of this project - and they
all had similar approaches to how we worked with
Boeing. We've done three or four other mitigation
projects around the state that are variations on the
Boeing theme, so it is definitely a best practice with a
successful and replicable model."
- Nate Berry, Open Space Institute Vice President

The red-cockaded
woodpecker depends on
the mature pine trees for
nesting and foraging.
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