Lean in Air Permitting Guide

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Introduction, Overview, and Organization

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 (PDF, 55 pp, 758KB, About PDF), 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: Practical Guide to Implementing Successful Lean Initiatives at Environmental Agencies (PDF, 75 pp, 818KB, About PDF), 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.

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[1] 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 box 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.[2]

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.

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	Permitting Process	Permitting Timeframe Before Lean Event (in days)	Permitting Timeframe After Lean Event (in days)	Total Decrease (in days)
Idaho Department of Environmental Quality	Permit to construct	270	97	173
Indiana Department of Environmental Management	Title V permit modifications	164	144	20
Iowa Department of Natural Resources	Standard air quality construction permits	62	6	56
Iowa Department of Natural Resources	Air quality complex permits	214	180	34
Michigan Department of Environmental Quality	Major air construction permits	422	98	324
Michigan Department of Environmental Quality	Minor air construction permits	143	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

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.

[1] 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).

[2] Please note that the DNREC backlog included permits waiting to be issued and permit applications that had been abandoned or withdrawn by applicants.

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