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Project Title and Location
ADEQ Online Permitting System - Phase II (Smart NOI Plus)
Phoenix, AZ

Applicant State Agency
Arizona Department of Environmental Quality (ADEQ)

Primary Project Contact
Wayne Hood; Water Quality Division; Arizona Department of Environmental Quality, 1110 West Washington Street; Phoenix, Arizona 85007, Phone: (602) 771-4427, Fax: (602) 771-4428, Email: hood.wayne@ev.state.az.us

Project Contact
The project contains significant components related to water quality permitting under the Clean Water Act, and hazardous waste management and permitting under the Resource Conservation and Recovery Act.

This project is not being executed in cooperation with or funded by another Federal program.

No regulatory flexibility on the part of the Federal government will be needed to implement the project.

The ADEQ Director, XXX, endorses this project proposal for submission to the National Center for Environmental Innovation (NCEI), U.S. EPA, for consideration for funding under the 2003-2004 competition for the State Innovation Grant Program..Proposed Budget Summary

. Pre-Proposal Project Narrative

This project significantly expands ADEQ’s innovative Smart NOI Phase I project, which successfully developed and implemented a “smart” user interface for stormwater construction Notices of Intent, under the Arizona Pollutant Discharge and Elimination System (AZPDES). The Smart NOI project was accomplished in part by funding from the 2002 NCEI State Innovation Grant, by matching State funds, and also by substantial local funding from the Arizona @ Your Service Web Portal (under terms pursuant to State Contract AD000129). As demonstrated in Smart NOI, automated and convenient general permit processing improves overall compliance efforts and data tracking, resulting in better environmental protection. Specifically, Phase II of ADEQ’s Online Permitting System (Smart NOI Plus) will substantially enhance the Phase I system by increasing the number of permitting modules of the system and advanced features such as electronic signature, electronic forms (e-forms), and online fee payment. The goals of this project are to use the innovative approaches developed in the Phase I project to broaden the Smart NOI system which will increase accuracy and efficiency for additional permits and compliance processes. ADEQ will measure success of the project by comparing key effectiveness criteria against current conditions. The outcome of this innovative approach is expected to advance ADEQ’s ongoing efforts to expand online services to citizens and businesses, effectively promoting a culture of innovative environmental problem-solving within the State.

Project Description
The components of the Smart NOI Plus project include: 1) Smart NOI Construction Stormwater Online — enhancements to the Smart NOI module to include e-forms that allow for constituents to input required information rather than using the currently-built question and answer approach; 2) De Minimus General Permits Online — addition of a permitting module to provide forms and assistance for instant approval of the Arizona NPDES (AZPDES) De Minimus discharges (General Permit AZG2003-002) to waters of the U.S. in Arizona; 3) Drywells Registration Online — addition of a drywells registration module, for the instant registration of drywells that receive stormwater to protect the state groundwater resources; 4) Pollution Prevention P2 Plans Online — addition of a module for electronic submission and verification of Pollution Prevention (P2) plans and annual progress reports, and, 5) EMS Online — a module that provides a technical assistance framework to facilitate the development of Environmental Management Systems (EMS) from P2 plans.

Advanced features include: (a) Electronic signatures — very few State agencies have attempted to adopt electronic signature standards without final federal regulations (e.g. CROMMER rule) in place. The challenge has been to ensure admissibility and persuasiveness of the electronic data as evidence of authentication, report integrity, and non-repudiation. The project will develop e-signature requirements and protocols. Digital signature options will likely increase online permitting transactions. (b) Electronic forms (e-forms) — e-forms allow online users from the regulated community to enter required permit information directly onto an electronic form that provides a structured range of options and expert assistance towards the completion of these forms. We have learned that this approach will be more convenient and faster for the experienced online user than the question-and-answer forms approach developed in the Phase I Smart NOI project. E-forms will be used to enhance the understanding of required information and provide this expert assistance to the regulated community. In some instances, the forms shall be complemented with case studies and guidance to help the user in the permitting process. (c) Online fee payment — only a few State agencies have adopted a viable online fee payment alternative to receiving direct checks and cash from the regulated community. This feature will be incorporated as an option when fees are required. (d) Enhanced Geographic Information System (GIS) applications — GIS is a well-established technology for improving environmental management processes, and its applicability to permitting was aptly demonstrated previously in Smart NOI Phase I. Further GIS capabilities and enhancements will be made to further harness this technology to automate decision-making for permitting and reporting requirements.

The new system will be designed to help businesses learn about requirements and how they can protect the local environment cost-effectively, by placing important reference documents and application instructions at the user’s fingertips. The system will also augment an innovative GIS processing tool and smart forms to help businesses avoid common mistakes that may incur costly delays. A key advantage to this system is that all data captured online is transmitted in specified formats for downloading into an appropriate agency database system without the need for additional manual data entry by agency staff.

Project Schedule and Time Frame
The project tasks include preparation of a detailed project plan, requirements analysis and design, coding and equipment configurations, web module testing and deployment. The project will begin July 1, 2004, with all project tasks concluding on September 30, 2006.

Project Milestones

Develop Detailed Project Plan
Prepare Requirements Analysis, Design Documents and System Prototype
Complete Programming and Configure Equipment
Complete System Testing
Move System to Production
Complete Final System Documentation and Adjustments

Program Criteria Requirements

1. Target Priority Environmental Issues
The success of the existing Smart NOI application has demonstrated the extraordinary benefits of combining a GIS-based decision-making matrix tool with online permit applications to the regulated community and ADEQ. Several measures of effectiveness have been evaluated for the Smart NOI system through comparison with standard practices of processing permits. The results are summarized in the following table.

Customer Notified of Permit Status
5 to 7 Days
Ease of Use and Convenience
Medium (physical forms)
High (online help)
Data Quality/Validity
Significant Data Entry
Electronic Data Loads
Total Processing Times
5 to 7 Days (signed through mail)
2 to 3 Days
Number of Permits Authorized
25+ per day (actual average)
100s + per day (potential)

Similar results are expected for the other project modules described below. Data will be collected and evaluated following the project to confirm how this alternative to traditional permitting will provide measurably better results than the current program.

Project Application Modules

Smart NOI Construction Stormwater Online
This system which involves enhancing the current Smart NOI construction stormwater permitting system, will include the development of e-forms option; the option of using a digital signature to process an NOI or NOT without having to print out a form, sign it and mail it to ADEQ; an option to pay any fees required online; and general improvements to the GIS mapping tool (e.g., improved road network and other GIS data) to allow more flexibility in its availability and use by customers to obtain accurate latitude and longitude data for site and facility locations.

De Minimus General Permits Online
This module will authorize an instant permit for the discharge of low levels of pollutants from a number of discharging activities that are either of relatively small volumes or are discharged over a short period of time (generally less than 30 days). These discharges contain pollutants which can be reduced to levels below the applicable surface water standards through the use of low level treatment technologies and/or Best Management Practices (BMPs).

Drywells Registrations Online
This module will authorize an instant registration of a drywell including an option to pay fees online. Drywells are bored, drilled, or driven shafts or holes whose depth are greater than its width and are designed and constructed specifically for the disposal of stormwater. Registrations are essential to protection of aquifers in Arizona. Regulation is necessary to ensure that drywells only receive storm-water runoff or discharges that are exempted by state laws. Significant quantities of these registrations are processed annually by ADEQ involving hundreds of companies and organizations.

Pollution Prevention (P2) Plans Online
ADEQ processes reviews and approves approximately 300 pollution prevention (P2) plans and annual reports each year. All facilities meeting certain threshold requirements established by the Arizona Legislature are required to have a P2 plan. In addition, several companies voluntarily file P2 plans to demonstrate efforts and compliance with pollution prevention goals. The 2003 EPA National Pollution Prevention Roundtable national report on P2 activities documented 117 billion pounds of pollutants reduced nationwide in P2 programs. Arizona’s share, which was about 0.54% (.911 billion pounds), is significant given that Arizona facilities only produced 0.13% of hazardous waste generated over that period. ADEQ therefore plays a significant role in the national P2 movement, and is one of only two states (North Carolina being the other) able to measure its progress and accountability in P2 since 1992 (from A. Soesilio, B. Quinn, Journal of Environmental Management, October/November, 2003). The information in P2 plans is used by ADEQ to create a comprehensive database that is used for tracking and planning purposes. All this work is done through facilities submitting P2 plans in paper format accompanied by an often extensive discussion and redrafting period to finalize the plans. Electronic filing of P2 plans will speedup the review process, reduce the turnaround time for approval, allow ADEQ to provide specific guidance and case studies tailored to specific components of a P2 plan, and facilitate the future encouragement of facilities to develop environmental management systems from these P2 plans.

Environmental Management Systems (EMS) Online
Environmental Management Systems are generally viewed as a logical upward sequence and progression of State and Federal P2 plans. ADEQ management desires to move in this direction. This has recently been reaffirmed in statements made by the Director. “ADEQ is seeking in the near future to work with EPA Region 9 and stakeholders to consider an Arizona Performance Track... similar to the National Environmental Performance Track (EPA) which is a voluntary partnership between business and regulators that recognizes and rewards private and public facilities that demonstrate environmental leadership and performance beyond current requirements... The National program, which started in June 2000, is based on the premise that government should complement existing programs with new tools and strategies that not only protect people and the environment but also capture opportunities for reducing cost and spurring technological innovation... The program provides various incentives to encourage businesses to adopt EMS and reduce emissions and waste streams.” (from S. Owens, Journal of Environmental Management, October/November, 2003). Phase II of ADEQ’s online permitting system will provide guidance at specific areas of company submitted online P2 plans, aimed at encouraging migrating of those plans to EMS. This will involve developing smart forms, GIS-based decision matrices, optional digital signature components, and an expert knowledge base for assistance in moving P2 plans to EMS.

2. Likely Improvement in Results from Project Implementation
How does the proposed tool or approach differ from current methods?
The traditional business process for processing NOIs, registrations and permits relies primarily on mail services and few staff to process the forms and accommodate timely customer assistance. Providing additional online permitting services with “smart” features and digital signatures to help constituents completely process the applications allow staff to be more efficient and productive. Potentially hundreds of general permits and registrations could be automatically processed monthly giving staff the chance to focus more on substantive permitting issues, and compliance providing better overall environmental protection.
How does the project build on lessons learned?
Techniques and technology utilized in Smart NOI Phase I will be expanded and improved in Phase II. Phase I used advanced GIS technology to help determine whether permits can be waived or granted or whether further review is required. For stormwater NOIs it is especially important to identify proposed projects located near habitat of endangered species, unique (pristine) waters, or impaired waters so appropriate measures can be applied to ensure adequate protection. This technology also makes it easy for applicants to identify the precise latitude and longitude of a facility or project site using pan and zoom functionality of an online detailed map.
What are the quantifiable improvements in environmental outcomes expected to result from the innovations?
The innovations to be applied, such as migrating these permitting processes to the Internet and the use of GIS to assist in permitting, will continue to allow for easier compliance for the regulated community and the public; encourage the voluntary filing of permits by entities not regulated by the State; allow for a wider scrutiny and review of permits and projects; help reduce human errors; and provide for instant approval of qualified permits that meet program requirements. Better, faster permits promotes greater compliance, which leads to a cleaner, safer environment.
What are the measurable improvements in administrative efficiency and program operational costs?
Data captured online will increase accuracy of permit filings data in ADEQ databases due to automated data loading and less manual data entry by staff. Also, automated and convenient general permit processing will result in better overall compliance, improving agency performance and productivity in proactively protecting the environment. There will be potential savings in staff hours, and in mailing, printing, and other costs associated with a paper-based process.
What are the quantifiable costs and efficiency improvements for the permit holders/regulated entities from innovations?
The Phase II online permitting system will allow for a quicker and easier compliance process for the regulated community, and will significantly improve agency services including rapid responses to constituents on several permit program regulations. Online NOIs and automated decision-making features will save the regulated community considerable costs reducing their need for additional staff to handle existing and new program requirements.

3. Measuring Improvement and Accountability
What are the goals for environmental improvement?
The goals include: to ensure general permits issued better reflect actual on-the-ground activities; more timely determination of permit compliance; and the ability to pursue better enforcement of regulations, resulting in better overall protection of the environment as compared to conventional approaches. The outcomes of the proposed innovations will reduce constituent and agency labor demands for routine processing of NOIs, permits and registrations, increase accuracy of results and more timely notifications of applicants, and improve agency management and availability of data for tracking and analysis crucial to environmental protection.
What are the indicators that will be used to show environmental improvement?
Critical indicators of success in environmental protection for the innovations proposed will focus on the numbers of online permit transactions completed, and the efficiency of the automated system through response times to applicants on the status of permit applications submitted.
How and when will the baseline measurements be developed?
Measurements for this project will be included in the project workplan for FY05. Tracking and evaluating progress will occur upon project completion.
What is the plan, timeline, and commitment for measuring and evaluating how well the project meets its goals and objectives?
The Agency currently includes e-government performance measures, tracking the types of permits available online. This is a strategic plan priority for ADEQ.
What are the expected short-term (1 to 3 years) results to be obtained through this innovation and how will they be measured?
After the system is deployed for two years, 90 percent of users of the online system will be notified within a week of the status of permit applications.
What are the expected long-term (3+ years) results to be obtained through this innovation, how will they be measured?
After the system is deployed for five years, at least 50 percent of all permit types included in this project will be received and processed using the online system versus traditional manual methods.

4. Transferring Innovation
Through use of “smart” permitting systems, relatively simple or routine applications can be processed automatically and accurately. Additionally, the development of digital signature standards for ADEQ will significantly advance the department’s overall e-government efforts, effectively positioning the agency to expand online services to citizens and businesses. Typically, the regulated community’s routinely “buried” in forms and paperwork when doing business with environmental agencies. This project envisions a new, streamlined way to conduct business — a plus for both government and its customers in the next generation. All automated processes developed in this project will be documented, and system and technical information will be made available to other agencies through ASIWPCA’s States Helping States project and the ASIWPCA annual meeting. In 2003, the Smart NOI Phase I project was showcased at the ASIWPCA annual meeting in Montana and received much positive feedback.

[Budgetary Information Withheld by U.S. EPA]

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