Letter to Stakeholders

Dear XL Stakeholder:

The purpose of this letter is to inform you about our ongoing activities to improve the XL project development process and let you know how you can contribute to this effort.

Launching a national initiative always presents challenges, but especially when the program crosses existing programmatic stovepipes within EPA and requires forging new roles for stakeholders, as Project XL does. Over the past eighteen months, we have worked to improve the program based on the input of stakeholders from industry, the environmental and environmental justice communities, States and EPA. In order to ensure that projects are developed according to the principles important to those stakeholder groups, we developed the "Step-By-Step Guide to the XL Process" (see our Web site at https://www.epa.gov/ProjectXL). This document was presented to representatives of each of the stakeholder groups during a series of meetings last November. The responses of those groups to this document and the process it describes consistently stressed the need to continue our work to reduce transaction costs for all participants.

During the November meetings, industry representatives described their experience with a stakeholder-based process management tool called "Work Process Analysis." We asked them (and they agreed) to help EPA apply Work Process Analysis to the XL process in a concentrated effort to identify ways to reduce the transaction costs while maintaining the quality of the stakeholder and technical review processes.

Work Process Analysis is a three-step process. Each step is kicked off with a meeting of people who use or are affected by the process. The first step is a meeting to accurately map out the process as it is today (sometimes called the "As-Is" step). The second step brings the stakeholders together to brainstorm creative solutions that produce the desired process outcomes ( the "Should-Be" step). In the third step (sometimes called the "To-Be" step), the stakeholders develop suggested solutions into a workable model for implementation.

On April 7, a group of interested parties from industry, government, and public interest groups met as part of Step 1 to help identify opportunities to improve the XL process. This group discussed the existing process (As-is) for developing XL Projects. At the meeting the group utilized the enclosed XL process flowchart as a tool to help identify general issues, concerns, and questions about expectations, roles and responsibilities within the process as well as suggested improvements to the preproposal, proposal, and final project agreement stages of project development. (All comments were recorded and are included in the enclosed meeting summary.) The group ultimately focused on the four areas listed below as those which hold the most promise for significant improvements to the XL process:

1-"Need More Information" loops. This is the part of the process in which someone, primarily EPA, requests more information about the project from the sponsor. Are there places where the sponsor can do more preproposal work to alleviate these more information loops? Can EPA be clearer about what information is required?
2-Coordinate EPA regulatory activities within the agency/coordinate activities with states and other regulators outside EPA. Participants felt that better overall coordination in these areas could materially improve the process.
3-Stakeholder involvement. The meeting participants observed that the XL process does not give very clear guidance on stakeholder participation.
4-Decision-making process. The group felt that the lack of clarity in the EPA decision-making process added delay and uncertainty to the process.

At the Step 2 meeting on May 20, participants brainstormed solutions (how things "Should-Be") in these four areas as well as any other features an ideal "Should-Be" system should contain. The framework for this meeting stressed identification of what works well in XL or other processes that could be applied to XL. In this step we attempted to maximize creativity by encouraging the group to set aside constraints for the moment and focus on ideal solutions. In Step 3, the group will reconcile the idealized solutions with more practical considerations as they move to develop a workable process.

We are distributing all the materials developed during this process to a broad group of XL stakeholders (see enclosed list). It is important to us that you are able to stay informed and to contribute to this process. We are interested in your comments on the materials from the Step 1 meeting. We are also particularly interested in receiving your suggestions for Step 2 -- improvements to the XL process. Any suggestions that you get to us by June 12 will be combined with the results of the May 20 Step 2 meeting as we prepare for Step 3. As you develop your suggestions, please consider presenting them in the following framework: 1) What is working in XL or other processes? 2) What is causing it to work? 3) What other features should be in the process?

The Step 3 meeting has not been scheduled but will probably take place in late June. We will send you a summary of the Step 3 meeting and give you another opportunity to comment. After receipt of any comments, EPA staff will finalize whatever guidance or documents necessary to describe and implement the process improvements and circulate them widely for a final review.

Your input in this process is extremely important as we attempt to create a better process for all parties involved in Project XL. Please provide comments to Reggie Parrish (202) 260-6095. You may mail the comments to USEPA, Attention: Reggie Parrish, 401 M St. SW (1802), Washington, D.C. 20460 or fax comments to (202)260-3125; or E-mail comments to Parrish.Reginald@epamail.epa.gov. If you would like to be included in the Step 3 meeting, please let us know.

Thank you for your continued interest in Project XL. We look forward to hearing your comments or suggestions.

Sincerely,

Lisa Lund
Deputy Associate Administrator
Office of Reinvention

Enclosures

Letter to Stakeholders

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