Meeting Summary

Process Re-engineering Meeting with Stakeholders
April 7, 1998
Washington, D.C.

I. Overall Issues and Concerns

The meeting began with discussions about general impressions, concerns, and questions regarding the process for XL Project Development. Stakeholders were interested in the general mission of the Project XL and how projects are initiated. The following points were raised during this discussion.

1- What are the desired outcomes of the process?

2- Who drives the process?

- Govt. (Fed and State) should develop projects

- Cultural disconnect between XL Vision and project development process

- process ought to be initiated by a joint-partnership between government agencies, environmental groups.

II. Step-by-step review of the process

OR staff displayed flowcharts of the existing process for project development and walked the group through the process step-by-step. Meeting participants identified areas which appear to increase transaction cost and delays, and areas needing clarification. The following issues were raised during this discussion:

Differentiate between preproposal and proposal phase. What are regional roles and expectations in each phase?
Last stages of preproposal may duplicate 1st proposal [HQ] stage
Preproposal stage discourages creativity of a sponsors proposal.
There appears to be duplication in "getting information from project proponent" and "getting feedback from EPA" in both preproposal and proposal phases.
Preproposal lays the groundwork for streamlined analyses and decision-making.
Common work practices should be standardized as tools.
Best practices (successful projects). Does EPA should provide information about successful projects.
What tools are being provide by EPA to sponsors to complete successful project? (e.g. success models to implement)
80% of industry time (transaction costs) is spent in to-do loops (white space) in both preproposal and proposal phase.
Diffuse authority, uniqueness of proposal, EPA discipline
Is there a way to standardize of key players in a process in order to provide certainty and predictability?
Identification of authority. Who are the key decision-makers?
States need to be consulted earlier in the process. Who are the appropriate state folks that should be contacted?
Enforcement Screen- Does EPA and the state eliminate good ideas and sponsors that could potentially improve their compliance?
The role of the Reinvention Action Council (RAC), formerly known as Ombuddies, needs clarification as well as the timing of their involvement in the process (mechanics).
RAC authority. What is it decision-making authority of the RAC?
Is enforcement screen used only to identify good/bad actors?
Is the RAC role to diffuse bottlenecks primarily, or are they brought in early in the process?
Is there or should there be involvement/review by other federal agencies? (e.g. external time and effort could be a labor sink)
In developing FPA, great amount of attention focused upon superior environmental performance, regulatory flexibility, and the stakeholder process.
Is there consistency, continuity, and uniformity in the EPA Review Team.
Is there a concurrent, shadow state process? Does this overlap and/or conflict with the federal review process?
Industry perspective tends to be on " Return on investment".
Can stakeholder be brought in process early in order to address major concerns before final stages?
A significant amount of time is spent on technical aspects w/ regulators:
- SEP; legal mechanism
- idea that EPA wants to test
- stakeholder issues
How to measure SEP? This is not clear and it takes a great amount of time.
Proportionality (balancing) & flex for SEP
Determining stakeholders and their proper role & technical assistance
Is there a process for keeping staff in agreement w/ upper mgmt?
Is there some clear guidance/threshold for identifying stakeholders. What are the rules of engagement?
Technical assistance to sponsors for project development and stakeholder involvement.
Different types of delays can/should be addressed at different stages of the process.
There is general sensitivity that HQ make decisions on or impacts local issues from Washington offices.
There needs to be internal EPA balancing of national policy & local issues.
Stakeholder/sponsor preparation- stakeholders and sponsors need to be prepared to meet & know what they want in a proposal.(e.g. specific outcomes, regulatory flexibility)
Is there individual accountability of time spent on XL FPA Development?
What is the amount of time dedicated to negotiating XL Projects?

III. Bike Rack for Additional Ideas

The purpose of this meeting was to map the process "as-is" and to begin to identify bottlenecks and areas in the process which cause significant delays and transaction costs. As participants identified these issues, they also identified important issues outside of the objective of this meeting which should be considered elsewhere in this effort to improve the project development process. This section is known as the Bike Rack. These issues were recorded and will be applied as related issues surface throughout the process.

Technical assistance. What technical assistance resources are available?
RACI Chart ( roles, accountability, consultation, information)
Day-to-day staff interaction
Joint initiation of projects (i.e. government agencies, stakeholders, sponsors) results in streamlining stakeholder interaction.
In preproposal phase of flowchart "more info " steps need to identify more specifically what sorts of information are needed.
What is the authority & role of EPA as decision-makers? Can EPA representatives on team make decisions?
- Role of stakeholders local & national; who has primacy?
Who has access to preproposal information.
Sponsors fear of citizen suits is a significant concern.
Are there schedules, tracking & measuring systems which quantify the amount of time it takes to get through each phase of the process?
Stakeholder involvement & buy-in. How do you secure this? When is enough?
$ for technical assistance to stakeholders and $ for sponsors to get technical assistance. Where and when in the process are these available and /or encouraged.
"XL not my day job" notion limits the amount of time that people can spend in developing a proposal or FPA.
Staging/ up front work. Is there a way to encourage up-front preparation to resolve issues which slow the process down the road.
Is there a need for full time regional XL coordinators?

IV. Areas of Focus for Second Meeting ("should be")

After the step-by-step evaluation of the process, the group identified general areas that they felt would be the most beneficial to focus our efforts on improving. Typically, they were selected because they were areas that create delays and increase transaction costs. They were organized in four categories that will be focus of the next meeting in which we discuss what "should be." The "should be" discussion will give participants a chance to lay out an ideal process. Real world contraints will be incorporated in the next round.

More information loops. This is the part of the process in which someone, primarily EPA, requests more information about the project from the sponsor. It was highlighted in the meeting as being an unclear process and as posing significant transaction costs. This loop is highlighted in the flow chart in the Preproposal and Proposal stages. Requests for information are also a regular but less structured part of the FPA development process. This discussion will look for ways to improve the quality of information provided while reducing the transaction costs of. For example, 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?
Coordinate EPA regulatory activities within the agency/coordinate activities with states and other regulators outside EPA. The meeting participants felt that there could be better coordination among the many different parts of EPA and State Agencies that review the various phases of an XL project. In particular, the group was interested in examining the ways to improve coordination between EPA and the State Agencies.
Stakeholder involvement. The meeting participants observed that the XL process does not give very clear guidance on stakeholder participation. For example, it is not clear at what point stakeholders should be involved or who the key stakeholders are. The group will discuss how to add clarity to the process.
Decision-making process. The group felt that the lack of clarity in the EPA decision making process added delay and uncertainty to the process. For example, it is not clear who at EPA is ultimately responsible and accountable on project decisions or how to know if a decision is final. This uncertainty hurt the credibility of project XL for sponsors, stakeholders and EPA staff.

Meeting Summary

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