Illinois

Title of Project
Permitting Process Modernization Conceptual Design

Project Contact Person
Bruce Carlson, Acting Deputy Manager; Division of Information Services; Illinois Environmental Protection Agency; 1021 North Grant Avenue East, P. O. Box 19276; Springfield, IL 62794-9276; Phone: (217) 782-5544; (217) 782-9807; Email: bruce.carlson@epa.state.il.us

Does the project have a significant component related to hazardous waste management and permitting under the Resource Conservation and Recovery Act (RCRA)?

Yes. RCRA permitting will be addressed as an integral part of the multi-media permitting approach covered by this conceptual design.

Is the project being executed in cooperation with or funded by another Federal program; if so, please identify the program?:

No

Will regulatory flexibility (from the Federal government) potentially be needed to implement the project?:

No

Endorsement

This project is endorsed by XXX, Director of the Illinois Environmental Protection Agency.

INTRODUCTION
The Illinois Environmental Protection Agency (Illinois EPA) is preparing to modernize its permitting process as part of its ongoing electronic government initiative, which is intended to provide more efficient permitting operations and more effective exchange of permit related information with the public. In support of this effort, Illinois EPA is requesting funding from a State Innovation Grant to prepare a conceptual design for an information system intended to address the entire permit process from application, evaluation, permit writing, and storing of the data, to the monitoring of permit conditions and integration of that information into the Illinois EPA's new multi-media information system known as the Agency Compliance and Enforcement System (ACES). This project is intended to support and facilitate realization of the expanded vision of environmental protection described in the EPA Innovation Strategy (EPA 100-R-02-002, April 2002). Particularly, the project is intended to generate a systems approach to deal with the entire permitting process in a more holistic manner, as well as to improve public accountability through Web-based receipt of environmental permit applications and dissemination of information on proposed and issued permit content. Key benefits of the project would include the improvement of data quality by capturing data elements related to permitting early on and thereby reducing the errors associated with having to re-enter data manually as permitting or subsequent environmental protection functions proceed. The process re-engineering possibilities to be identified through the conceptual design are intended to consolidate steps in the permitting workflow and result in improved productivity. Timeliness of data availability, both for Illinois EPA staff and the public, would also be improved by this early capture of permitting related data. Permit application information, as well as facility permit conditions and related compliance status, once captured electronically could be shared over the Internet with the public, thus promoting more open e-government access and supplying details relevant to environmental justice considerations. Success of the conceptual design will be gauged by the extent to which the documentation produced provides a comprehensive analysis of existing workflow and details costs effective measures to enhance staff efficiency, improve data quality, and establish standardized data formatting that facilitates prompt Node availability of environmental program data to the Central Data Exchange (CDX). Results of the conceptual design would be made available to interested environmental agencies in other states to assist them in their own assessments of potential permitting process improvements.

WORK PLAN

The conceptual design for the permitting process module will include an analysis of permit application automation options, recommendations for design of a permit writer sub-system, identification of public access requirements for permitting data, plans for design incorporation of data standards, and evaluation of possible links to geographic information system (GIS) applications. An investigation/analysis report, a user requirements and specifications document, detailed component process descriptions, and a cost and schedule estimate will all be produced as part of the conceptual design.

In preparing a conceptual design for a permitting process module, the consultant would be called upon to complete a number of items that would assist in improving data collection, data quality, standardized data formatting, and federal/state data exchange relevant to Illinois EPA's participation in various federal environmental programs. Included among those items are the following:

Perform an analysis of permit application automation options, including, but not limited to, on-line completion of applications via the Internet. Also, prepare a report identifying various automation options that includes, at a minimum, advantages and disadvantages of various options, infrastructure issues, security concerns, ongoing support/maintenance and cost estimates. As part of this analysis, the consultant is to evaluate the Illinois EPA's new system for electronic reporting of discharge monitoring reports (e-DMR system) as a model for the on-line submittal of permit application data. Design and testing of the e-DMR system is currently being completed. A public key infrastructure (PKI) for all Illinois e-government applications has already been established using digital certificates obtained from Entrust, Inc. with the fundamental information technology and procedures for PKI administration being handled by the Illinois Department of Central Management Services pursuant to its PKI certificate policy. Electronic forms for the e-DMR application are based upon an extensible markup language (XML) format and are pre-populated with facility identifying information, permit limitations, and monitoring requirements. The reported monitoring data is imported into an Oracle database and the completed forms are stored in their entirety as binary large objects in this database.
Identify the standard language components that are associated with the Illinois EPA's permits. This would include regulations, statutory provisions, permit conditions, permit templates and any other standard text that is associated with the permitting process. These components will be incorporated into the existing Standard Language Library of ACES for use by other ACES components. Among the multiple functions of ACES will be the tracking of facility compliance status from the field inspection stage through final resolution of each identified violation. Implementation of ACES includes the use of a facility tie-file module that will assign a single identifier to a facility, known as the IEPA ID, and thereby allow for integration of multi-media data regarding the facility.
Develop a conceptual design for a permit writer sub-system. The permit writer would assist the permit analyst in the preparation of a permit. In general, the desire is to have a system that will step the permit analyst through the permit and, based on the information contained in the permit application, present the permit analyst with appropriate standard permit conditions that can be selected. Non-standard permit conditions could be added where appropriate. All of the conditions included in the permit would then be integrated into ACES so that they are available to the field inspectors to use during inspections and for any other compliance and enforcement evaluations and subsequent actions. For NPDES permits, new data requirements for new NPDES programs (dealing with biosolids, confined animal feeding operations, sanitary sewer overflows, combined sewer overflows, and storm water) would be included in the coverage of the module conceptual design. Review the USEPA permit writer pilot programs (i.e., the Integrated Compliance Information System (ICIS), the Permit Application Software System (PASS), and other appropriate permitting systems. Prepare a report summarizing these systems and their applicability to this task.
Through interviews with Agency staff and members of the public or interest groups identify the public access requirements for permitting data.
Evaluate possible links between the permitting module data and current and planned GIS applications.
Produce an investigative/analysis report containing all collected analysis data and recommendations.
Produce an Illinois EPA approved user requirements and specifications document for inclusion into a future request for proposals.
Produce process descriptions for all major components pertaining to the permitting module and identify any Illinois EPA business processes that may require modifications.
Produce a cost and schedule estimate for the design, development and implementation of the permitting module.

PROJECT SCHEDULE AND TIMEFRAME
Conduct of the described conceptual design project will involve publication of a request for proposals (RFP), followed by receipt and evaluation of project proposals from qualified consultants. Award of contract to the selected consultant is anticipated to take place about three months after the RFP publication. Work under the contract is estimated to take nine months to complete.

FULFILLMENT OF PROGRAM CRITERIA REQUIREMENTS

1) Target Priority Environmental Issues
This conceptual design for modernizing Illinois EPA's permitting process targets improvements for multiple environmental issues described in the EPA Innovation Strategy. Those issues include improvements in water quality and smog reduction through advances in the timely collection of permit application information for NPDES, CAAPP, RCRA and other federal permitting programs, improved quality and efficiency of permit preparation, and integration of permit limitation provisions with monitoring data to promptly identify and rectify violations. Additionally, the holistic review of the permitting process encompassed by the conceptual design is intended to produce improved environmental information for use by both environmental managers in developing improved environmental protection strategies and the public and private sector in reviewing and assessing environmental quality data.

2) Likely Improvement in Results from Project Implementation.

a) How does the proposed tool or approach differ from the current methods (i.e., "uniqueness")?
Current methods used throughout the Illinois EPA for the permitting process rely almost exclusively on manual means. Permit applications are received in paper form through regular U.S. mail and permit writers manually draft permit content. Some formatting and storage of standard permit conditions for re-use is accomplished through off-the-shelf word processing programs, but no custom permit writing software is in use. It is envisioned that the conceptual design will lead to advances in accepting permit applications electronically via the Web, automating much of the permit writing process with custom software development, and sharing permit information both within the Agency and with the public.

b) How does the project build on "lessons learned" from prior experience (not limited to the proposing State's own experience)?
The project will build on lessons learned by examining feasibility of applying the infrastructure of Illinois EPA's new Web-based electronic reporting system for discharge monitoring reports to use for receiving electronic permit applications. The project will also examine how existing USEPA pilot programs for permit writing might be adapted for used by Illinois EPA.

c) What are the quantifiable improvements in environmental outcomes expected to result from implementation of this innovation?
Expected quantifiable improvements in environmental outcomes would include expedited issuance of permits, reductions in permit preparation errors, and prompt availability of permit data for use in compliance monitoring.

d) What are the measurable improvements in administrative efficiency and program operational costs that may result from this program?
Administrative efficiency improvements and program operational costs reductions are expected to result from expedited receipt of permit applications, improved data accuracy through elimination of duplicate data entry, expedited permit preparation and processing, and enhanced ability to disseminate permit and compliance related data to the public.

e) What are the quantifiable costs and efficiency improvements for the permit holders/regulated entities resulting from implementation of this innovation?
Permit holders and regulated entities are anticipated to benefit from efficiencies in preparing and submitting permit applications via the Web, as well as receiving accurate issued permits in an expedited manner.

3). Measuring Improvement and Accountability.

a). What are the goals for environmental improvement?
The basic goals for environmental improvement from this project center around achieving reductions in pollutant quantities and toxicities through issuance of accurate, up-to-date permits and making permit related data promptly available for use in compliance monitoring.

b). What are the indicators that will be used to show environmental improvement? (Goal and objective measures should be both qualitative and quantitative and should assess the project's measurable benefits.)
Measurement of improvements will include the effectiveness of permit modernization in reducing the time needed to issue permits and decreasing the backlog of unissued permits. Additionally, compliance statistics will be tracked for the conditions included in permits issued under the modernized permitting system.

c). How and when will the baseline measurements be developed?
Baseline measurements on permit preparation time and permitting backlog are collected currently and will continue to be maintained. Compliance data will be tracked therough ACES, initially with regard to statutory and regulatory provision compliance, but also with regard to permit compliance once permit condition data can be included in ACES.

d). What is the plan, timeline, and commitment for measuring and evaluating how well the project meets its goals and objectives?
An assessment of the documentation and recommendations produced by the conceptual design will be made by the Illinois EPA within three months of the project's completion. The Illinois EPA's conceptual design assessment will include a plan and estimated schedule for proceeding with appropriate development and implementation measures.

e). What are the expected short-term (within one to three years) results to be obtained through this innovation and how will they be measured?
Success of the conceptual design will be gauged by the extent to which the documentation produced provides a comprehensive analysis of existing workflow and details costs effective measures to enhance staff efficiency, improve data quality, and establish standardized data formatting that facilitates prompt Node availability of environmental program data to the Central Data Exchange (CDX). The previously described Agency assessment will be used to gauge the outcome of the conceptual design.

f). What are the expected long-term results to be obtained through this innovation, how will they be measured, and what is the time span for those results?
Long-term results of the project will involve the development and implementation of measures identified through the conceptual design process. Those measures may be completed on a phased-in basis, depending on their complexity and estimated costs. However, development and implementation of core measures selected from the conceptual design are estimated to take about one year to complete following Agency assessment.

4). Transferring Innovation.

a). What methods will be used to document the outcomes and methods of this innovation and make the information available to other jurisdictions?
The content of the conceptual design will be made available for other jurisdictions to review. One means to be used for sharing this information would be the WISER internet site maintained by the Environmental Council of the States (ECOS).

b). What is the specific potential for widespread application or use of the tool/approach as a model for "next generation" environmental protection?
Many environmental agencies are at a similar stage of manual operation in their permitting processes. It is believed that advances in permit writing, electronic permit application submittal, and Web-based reporting will be useful as a model for other state environmental agencies.

c). How will the application of this innovation be used to promote organizational system change, or develop a culture of innovative environmental problem-solving as a "way of doing business" within the State or more broadly?
The permitting data collection effort, and related integration of such data with compliance information, will assist in providing environmental managers with the means to develop better outcome based performance measures. The environmental quality improvements associated with innovative use of incentive related permit conditions can be gauged and quantified through establishment of systems to capture and analyze permit application, permit content, and sample analysis information.

d). What commitments can the proposing State make to provide consultation and mentoring to other States wishing to adopt similar innovations?
Illinois EPA would make consultation and mentoring service available to other states in the form of documentation related to the conceptual design project, as well as direct contact with Illinois EPA's project management and technical support team for discussions upon request.

[Budgetary Information Withheld by U.S. EPA]

Illinois

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