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State Innovation Grants

EPA 2005-2006 State Innovation Grants Competition Pre-Proposals

A Proposal from the Idaho Department of Environmental Quality.

Project Title: A Risk Evaluation Based Approach to Multimedia Permitting
Principal Contact: Andy Micone
Software Development Manager
1410 North Hilton
Boise, ID 83706
Phone: 208.373.0196
Fax: 208.373.0315
E-Mail: Amicone@deq.idaho.gov

[Budget information removed by EPA]

Nationally, agencies issuing permits for discharges of wastewater and stormwater to municipal treatment plant systems find themselves working under increasingly challenging conditions. The current environment of static staffing and funding levels have lead to distribution of regulatory authority for permitting between federal, state, county, and municipal government entities with an increased burden on state agencies to play a coordinating role. Resource constraints allow only cursory triage on incoming permits, creating the possibility that a permit request that should receive additional attention may not receive its due attention in a timely manner. Since permit requests are subject to sharp seasonal spikes in volume, and since agencies with primacy have a limit on the time in which they can respond to permit requests, agencies find their attention drawn away from managing the permitting process and into the reactive mode of hastily approving or denying permits, losing the opportunity yield better environmental outcomes by modifying a permit request. In Idaho, the legislature has recently issued strict guidelines on the time the DEQ has to issue permits and has delegated some permitting authority to municipalities and counties, so these issues become especially critical as these guidelines create the possibility of lost opportunities to reduce pollution. We have a solution, based on our previous EMS experience and evaluation of previous innovation grants, called risk-evaluation based multi-media permitting; an inherently multi-media triage approach that simultaneous prioritizes and parallelizes permitting activities while systemically improving identification of environmental concerns through continuous measurement of positive outcomes. Because it is a general and inherently multi-media approach, the method is applicable to any program’s permitting activity, not just stormwater permitting.

Project Schedule

The initial phase of this project will take ten months with milestones and deliverables at two months intervals as follows:

  1. A paper describing the EMS methodology and how it is implemented.
  2. A spreadsheet implementation and simulation demonstrating the improvements in the permitting process from modeling the first two risk factors.
  3. A web-based reference application that mediates permitting workflow based on the open source package OpenCMS.
  4. A permitting prioritization engine written in Java that will implement the evaluation of the first two risk factors.
  5. A neural networking engine written in Java that will model environmental risk factors by correlating a small set of quantifiable factors already used in stormwater permitting models.

After the initial phase, we will need one summer permitting season to evaluate the results of the project. In any case, all results would be deliverable within two years.

Program Criteria

Idaho’s risk-evaluation based multi-media permitting is an EMS approach based on the knowledge gained from previously funded EPA innovation grants and Idaho’s own EMS experience. It couples an EMS with support tools that help mediate the permitting process, provides measurable positive outcomes, and create continuous improvement based on those outcomes.

Target Environmental Areas

Various environmental policy analysis bodies have called the Clean Water Act a “set of technology forcing regulations,” because of the complexity of the regulations and the difficulty of managing them with traditional approaches. Study of Arizona’s use of support tools for EMS (funded by this grant in 2001) to improve efficiency of stormwater permitting and Idaho’s own use of multimedia GIS information in stormwater permitting both point to how EMS approaches are enhanced through multimedia information to identify environmental risk factors. Leveraging multimedia GIS information has prevented pollution and improved environmental outcomes by providing the necessary information to initiate negotiation with the permit requestors to modify their approach prior to the approval of a permit.

These positive outcomes beg the questions whether the use of multimedia support tools can be broadened from their narrow role of providing evaluation support for specialists to support the entire “Plan-Check-Do-Act” cycle of a traditional EMS. The challenge is to create support tools that quantify and measure outcomes of the EMS and then use those positive outcomes to create continuous improvement. Our risk-based approach achieves positive outcomes by modeling environmental risk factors using traditional models already in use by Idaho DEQ.

We see direct improvement in wastewater, stormwater, point-source and non-point source pollution are possible. Initially, we will focus on the role plant and specification review plays in the stormwater permitting process. The EMS we will develop will feature automatic capture of improvements in environmental outcomes and will improve accountability with defensible outcome measures. To accomplish these goals the EMS will overcome the following three challenges:

  1. The EMS must integrate the “check and act” cycle in a way that permitting activities directly result in the constant improvement of the process. Process improvements can not wait till after “seasonal permitting sprints.”
  2. A specialist’s knowledge of how to leverage multi-media GIS information in permitting must be embodied in an EMS process to the maximum extent possible.
  3. Support tools must be provided to greatly reduce the coordination burdens of the agency in a new regulatory environment of delegated authority so staff can focus on their highest value-add activities.

Expected Outcomes

Difference from Traditional Approaches
Traditional approaches to permitting prioritize permit requests in a first-in first-out manner using specialist knowledge to triage permits on an ad hoc basis. This approach has serious drawbacks because a “person is not a process.” The risk-based approach systematically prioritizes permitting work based on both the risk of meeting permitting deadlines and the environmental risk poised by a project. The most difficult projects that pose the greatest environmental risk, and greatest opportunity for improvement of environmental outcomes, are prioritized first. It also differs from traditional approaches in that it is a learning system, and can dynamically reprioritize work as new outcomes and risks are learned by the system.

Lessons Learned
Lesson’s learned from Arizona’s stormwater permitting GIS system, previously funded under this grant, and Idaho’s own Lower Boise River Effluent Trading EMS lead us to this risk-based approach. The management and accountability needs of a modern EMS supporting the Clean Water Act aren’t easily achievable without supporting information technology tools. With the use of technology, the full “Plan-Do-Check-Act” cycle of an EMS can be evaluated dynamically by a learning system with each permit outcome, supporting and enhancing specialist knowledge and human insight. This is especially critical with the new need for collaboration between delegated authorities in the permitting process.

Quantifiable Improvements in Outcomes
The risk-based approach quantifies, manages, and decreases risk in the following areas:
  1. Time Based Risk – All permits have a regulatory requirement to be evaluated within a certain time period. When it becomes probable that a pending permit request will not be evaluated in the allotted time based on the agency’s average service time, it should be reprioritized upward until it can be evaluated in the allotted time.
  2. Collaborator Risk – Permit requests that have delegated authority should be evaluated against the average service time for the delegated authority in processing permits. When it becomes probable that the delegated authority cannot meet the regulatory time requirements of the permit based on their individual average service times, the permit request should be reprioritized upwards until it can be evaluated in the allotted time or the system should reassign the permit request back to the agency.
  3. Environmental Factor Risk – Multi-media quantifiable GIS information that impacts evaluation in the permitting process will be profiled in cooperation with specialists. This GIS information will then be used as automatic defaults in existing permitting models. Through the use of a learning system to evaluate how these quantifiable factors effect service time on an individual permit, the permit will automatically be reprioritized to a higher or lower priority relative to the other two risk factors.

The system will prioritize the most environmentally sensitive work first and record the environmental outcomes of established evaluation models before and after the evaluation and issuance of the permit. It is based on positive outcomes from this evaluation that the system learns and automatically implements a “check-act” cycle. This dynamic process adjustment method is superior to making process improvements only after “seasonal permitting sprints.”

Improvements in Administrative Efficiency
Improvements in environmental efficiency of the EMS implementation are as follows:
  1. Staff spends most of their time on the most environmentally sensitive permit requests where their knowledge does the most good, in seeking solutions that minimize pollutants. Their activities utilizing the EMS create an automatic knowledge transfer, systematizing their knowledge.
  2. The burden and risk of coordinating with outside parties is greatly reduced, because the system can both mediate and improve the evaluation work of delegated authorities while providing visibility to the requestor of where their permit is in the permitting process.
  3. The “plan-do-check-act” cycle is automatically integrated into the EMS process; metrics are utilized by the EMS to improve itself. These improvements are directly measurable by examining reduced service times, reduced variance, and evaluating the extent to which multimedia permitting knowledge has transferred into the system.
Savings in Costs and Efficiency
The success of the EMS will be measurable by the following factors:
  1. Continuously improved average service times and reduction in variance.
  2. Increase in the number of permits processed.
  3. Increase in the number of negotiated positive environmental outcomes.
  4. Elimination of “backlog sprints” and “emergency evaluations.”
  5. Collaboration with delegated authorities without increase in staffing resources.
  6. Reduced communication with permit requestors due to high visibility.
  7. Reduction in “seasonal bounce” in service times (the system remembers performance factors from the previous season).

Public Involvement
Public involvement will be improved by public and stakeholder visibility into the permitting process through the web or through our CDX node as part of the EPA’s Environmental Network Exchange. The proposed system implicitly improves public involvement in the process by delegating some of the communication burden of the permitting process to an automated system. Since the system profiles the permitting process, any stakeholder could be notified by e-mail as a permit works it way through each step of the permitting process.

Environmental Justice Issues
We believe there are no environmental justice issues in question for this grant. Current regulations outline the timeline for evaluating permits but not the priority they be given.

Accountability

Indicators of Improvement
Beyond the savings in cost and administrative efficiency already outlined above, the system actively profiles “before and after” outcomes of the permitting process based on established models and uses this information to dynamically improve the permitting process. These positive outcomes can be directly reported by the system on an aggregate or case-by-case basis.

Development of Baseline
Because this EMS is implemented as a learning system there is no need to establish an explicit baseline. Improvements over time can be directly reported between any two time periods without the need to establish an arbitrary baseline measurement. The resolution of such a system is very high, information gained from each permit evaluated and issued serves as a baseline for improvement for the next permit.

Commitment for Measuring Objectives
The system automatically measures objectives as part of the EMS process and these results will be available any time to any interested stakeholder either via the web or through Idaho’s CDX node as part of EPA’s Environmental Exchange Network.

Short-Term Benefits
The immediate benefit of the implementation of this grant will be elimination of backlogs, meeting new challenges of collaborating with delegated authorities with no additional resources, and high-visibility for those requesting permits.

Long-Term Benefits
The long-term benefit of this project will be strong, defensible accountability of positive environmental outcomes from permitting activities. Other benefits include the embodiment of specialist knowledge within the EMS itself, opening the possibility of the creation of permitting expert systems by evaluating what the learning system has learned. Others could achieve results similar to what Arizona achieved in lowering their permitting workload by computer evaluation of select permits

Transferring Innovation

Methods of Dissemination
The outcomes will be publicized both via our web site and through Idaho’s CDX node as part of the Environmental Exchange Network. The software support tools created for the EMS will be provided in cross-platform Java source code that should work either in Windows or UNIX based environments. Since the supporting software tools will be built on open source software or by Idaho DEQ, it will be freely shareable between states, tribes, and other outside stakeholders.

Potential for Widespread Use
The system is inherently multimedia. Since it models risk factors and problems common to any permitting process, and evaluates environmental risk factors in a generic manner (by modeling correlations instead of assumptions). It could be applied to any permitting process.

Promoting Organizational Change
In most organizations, the permitting process consists of a schedule of deadlines and a specialist who must work those deadlines. The implementation of the EMS will take organization out of the “person as process” mode of operation and into a true EMS approach to environmental management role as a day to day activity.

Consultation and Mentoring Commitment
The primary researcher for this project is a DEQ employee and will perform the work in house. The primary researcher will be available for consultations with other states wishing to use this approach. The risk-based evaluation approach is closely modeled on the researcher’s previous work on Department of Defense C 3I systems (Command, Control, Communication, and Intelligence) that have successfully been applied to varied enforcement purposes such as national defense, illegal drug interdiction, merchant marine piracy interdiction, and currently homeland security. It has already proven itself as a methodology that can implemented across government organizations for varied compliance purposes.

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