BOARD MEETING DATE: March 12, 1999 AGENDA NO. 42A

Norma J. Glover, Board Vice-Chair
Cities Representative, Orange County
Chairwoman, Permit Streamlining Task Force

Ronald O. Loveridge, Board Member
Cities Representative, Riverside County

Background

Chairman Burke established a Permit Streamlining Task Force in February 1998 to bring before the Board concrete recommendations to expedite processing of conventional, Title V and RECLAIM permits. Vice Chair Norma Glover was designated as the Task Force Chairwoman and Board members Ron Loveridge and Jim Silva were also appointed to the Task Force to assist in overseeing the effort. The Task Force also includes representatives from industry, local government, businesses and environmental professionals who represent a cross-section of individuals and groups with expertise in permitting issues. (Attachment 1 provides the complete list of Task Force members' names and affiliations.) An independent facilitator was also used to help focus discussions and assist in development of consensus. The Task Force held its first meeting on April 28, 1998, and has since conducted a total of 13 meetings in the course of ten months.

In addition to actively participating in the Task Force meetings, Executive Officer Dr. Barry Wallerstein also appointed Mohsen Nazemi, a Senior Manager, to serve as the Permit Streamlining Ombudsman to assist in identifying problem areas and implementation of various streamlining initiatives. A contractor was also retained by the AQMD in September 1998 to provide an independent and comprehensive review of AQMD's permit system and to recommend specific steps to streamline permits.

Based on information provided by the contractor along with other ideas from Permit Streamlining Task Force members, industry, permit applicants and staff, the Task Force formulated a set of permit streamlining recommendations. The Permit Streamlining Task Force key recommendations are summarized in Attachment 2. Included as Attachment 3 is the Permit Streamlining Task Force Report and Recommendations (Task Force Report), which provides a more comprehensive look at Task Force efforts and a detailed listing of ideas and discussions leading to their recommendations.

The Permit Streamlining Task Force examined and discussed every major aspect of permitting and related issues to recommend potential enhancements. The scope of permit streamlining study conducted by the Task Force, industry, staff and the independent contractor is unprecedented in detail and breadth in the AQMD's history. The Task Force reviewed and discussed ideas brought before them by the Task Force members, industry, permit applicants, staff, and the contractor. Activities included a review and evaluation of:

The overall process of identifying issues and evaluation of ideas was completed in January 1999. Then, on January 29 and February 5, 1999, the Task Force held two extended meetings to review potential enhancements and develop comprehensive and final permit streamlining recommendations, which are included in the Task Force Report.

The key permit streamlining recommendations are grouped into four distinct areas as follows:

While a summary of key recommendations is included in Attachment 2, Attachment 3 - Permit Streamlining Task Force Report and Recommendations, provides a more detailed listing of all ideas and discussions leading to the recommendations. As part of that the Task Force members also assigned prioritization ranking to each recommendation to indicate the relative impact on streamlining and timeline, level of difficulty and cost to implement each measure.

The Task Force members are in consensus with all of the recommendations. However the environmental community representative member of the Task Force (Tim Carmichael of Coalition for Clean Air) has expressed concerns with some of the recommendations related to rule amendments, Recommendation Nos. A-10, 11, 12 and 14. The Task Force expects that these concerns along with other issues will be addressed as part of implementation of these recommendations within the framework of rule development process.

The Task Force recognizes that implementation of some of the recommendations may be more resource intensive than others, or inherently require more time to implement. AQMD staff has participated in the Task Force meetings and discussions and is in consensus with the Task Force’s recommendations. Staff has developed a preliminary workplan to implement the Task Force’s recommendations. To help staff with proper implementation of the recommendations, the Task Force intends to meet on a quarterly basis to review progress during 1999 and early 2000.

	GROUP A REDUCE STEPS REQUIRED TO ISSUE PERMITS
1	Eliminate prescreening as it currently exists as a separate program. After the minimal necessary preprocessing, send applications directly to respective engineering teams for completeness review and processing.
2	Develop Streamlined Standard Permit packages for frequently permitted equipment (e.g., dry cleaner, printing press) and process these applications with a simplified procedure.
3	Upgrade NSR emissions tracking system to ensure previous emission entries are maintained, to simplify and provide flexibility to determine facility emissions, to simplify processing of applications with no increase in emissions, and to eliminate NSR programmatic bugs (or fixes).
4	Reevaluate Rule 222 registration program for area sources one year after its implementation; and expand/improve the program to cover additional sources if warranted.
5	Establish and implement a clear and simple policy to reject/accept applications without placing any application on hold.
6	Implement the CPP Program Enhancement Work Plan as a pilot program and, if successful, expand key elements to other applications.
7	Allow payment of permit application fees by credit cards.
8	Set up debit account/electronic data interchange (EDI) for qualified applicants to pay for permit application fees electronically.
9	Accept applications for which 85% or more of fees are paid; allow 45 days to pay the remaining fees. Implement initially as a pilot program to assess its impacts.
10	Toxics (Rule 1401) Amendments - Amend Rule 1401 to streamline permitting while maintaining the rule's intent (e.g., exempt natural gas fired equipment). Revisit Rule 219 permit-requirement procedure and thresholds for toxics to streamline the process.
11	NSR (Reg. XIII) Amendments Support Home Rule Working Group in their efforts to address NSR issues such as to: Treat "true" relocations (e.g., loss of lease) not as new facilities so that if there is no net emissions increase, BACT is not triggered. Require LAER only for federal major sources; require local BACT for non-federal major sources.
12	Public Notice (Rule 212) Amendments - Reevaluate Rule 212 public notice requirement when existing facility emissions and risks are not increased, or are redundant to CEQA.
13	Prevention of Significant Deterioration (PSD, Reg. XVII) Amendments - Amend AQMD PSD Regulation by changing the thresholds to make them consistent with EPA's federal PSD regulations.
14	Permit-by-Rule - Develop a rule to regulate a specific equipment category (e.g., gas stations) and then require registration instead of permit.

	GROUP B IMPROVE COMMUNICATION INTERNALLY AND EXTERNALLY
1	Improve and simplify tracking of applications to cover from the time an application is received until the permit leaves the District, including steps when an application is rejected, re-submitted, in transition, in the mail (interoffice or external), etc. Include tracking of documents associated with applications (e.g., source tests, HRA, CEQA).
2	Update and publish standard permitting policies and procedures. This should include the information about some fundamental procedures such as permit unit identification, fee determination, equipment category coding (ECC, or Basic Category [B-Cat]/Control Category [C-Cat]) system, etc.
3	Provide continuing training opportunities on specific permitting-related subjects to better inform and empower permitting staff. Subjects should include all permit-streamlining aspects as well as others such as modeling, risk analysis, and source testing. Also provide training opportunities to applicants/consultants.
4	Redesign permit application forms to be more consistent with data entry, better indicate mandatory/optional fields, explain applicable regulatory requirements, and provide more space and bigger font size. Title V general information should be on a separate form. Also, make application forms available to be submitted on diskette or through the Internet.
5	Update the sections of the 1989 Permit Processing handbook related to frequently permitted equipment and publish the updates for internal and external users.
6	Reconcile Rule 301 fee table and Equipment Category Codes, improve fee table consistency, keep fee table in the database current as soon as new rule is in effect, develop a fee worksheet and completeness checklist for applicants.
7	Develop and maintain a web page for permitting to provide up-to-date application forms and instructions, as well as information on standards, templates, protocols, emission factors, and policies & procedures, etc.
8	Develop equipment specific permit application packages (incl. forms and other relevant information) for frequently permitted equipment and other equipment specific application forms for other equipment categories.
9	Develop and publish a generic permit evaluation guideline with a standard evaluation template.
10	Provide the support system to ensure general permit inquiries regarding information and fees over phone lines and from Permit Service Center are quickly directed to the responsible team and questions answered accurately within a reasonable amount of time. Also, provide an updated directory and make it available to applicants to indicate which team handles what type of permits and to identify staff in each team.

	GROUP C OPTIMIZE PERMIT STRUCTURE AND SYSTEMS
1	Issue future Title V facility permits by compiling the existing equipment-based permit with added standard Title V requirements. Conduct ongoing evaluation of processing time and make adjustments as appropriate consistent with optimizing goals. If warranted, apply the same concept to renewals of existing facility permits (i.e., Title V Group A and RECLAIM permits).
2	Conduct comprehensive review of permitting-related computer systems and programs to improve functionality and coordination to serve AQMD's needs.
3	Develop a simplified and integrated permit program for both Title V and non-Title V sources instead of having two separate systems. The program should be based on the conventional equipment-based permit system to minimize permitting costs and needs for resources. (Enhancements may be made to link controls and subsequent modifications in the database.)
4	Improve consistency and standardization yet provide the needed flexibility in permit description and conditions. As part of that, provide up-to-date templates, adequate training, and consistent review. Avoid using predetermined language and format in detailed equipment description or permit conditions for all cases.
5	Upgrade and maintain the equipment category code (ECC, or B-Cat/C-Cat) system for database and permitting purposes (both Title V and non-Title V). Eliminate duplicative data entry (i.e., device info and SCC on top of ECC); use single ECC system. Update and publish ECC system information to facilitate internal and external users.
6	Revise and improve the permit programs such that the system does not automatically alter permits (mainly facility permits) without permit engineers’ awareness (e.g., situations when a permit is temporarily inactivated for late payment, P/C over 1-year, etc., or when standard conditions are revised).

	GROUP D ENHANCE MANAGEMENT AND ORGANIZATIONAL EFFECTIVENESS
1	Implement a total quality management system (e.g., ISO9000) to continuously measure and improve permitting system performance (permit processing goals related to timelines, accuracy, consistency, user-friendliness, responsiveness, etc.). Make permit streamlining implementation a goal of all staff with a focused coordination staff to ensure implementation.
2	Consolidate all stationary source permitting-related activities with clear delineation of responsibility to promote responsiveness, consistency, and effectiveness.
3	Reevaluate 7/30/180-day management tool used for prioritizing applications to keep applicants better informed and to improve tracking of efficiency/productivity. Develop better methods for accountability and measurement of performance.
4	Conduct a study to fully analyze permit processing time, costs and potential bottlenecks. Results should be benchmarked. Measurable goals should be developed regarding time spent, progress made and number of applications processed.
5	Expand discussion of "Resource Impact" in Board letters for Rule actions to adequately analyze and address impacts of rules on permitting, including processing time/costs, cost recovery, potential delays in issuing permits and staffing needs.
6	Develop and facilitate a corporate philosophy that handles permit applications as project management with permitting engineers assigned early in the process to serve as project managers and are responsible for meeting project requirements in conjunction with permit processing goals.
7	Conduct quarterly Permit Streamlining Task Force meetings to review progress and prepare annual "State of the Permit Processing" reports to Board.

AQMD Board	No. of Meetings Attended
(Chair) Norma Glover - AQMD Board Vice-Chair	12

Ronald Loveridge, AQMD Board Member	10
Jim Silva, AQMD Board Member	7

Other Members
Greg Adams, Sanitation Districts of Los Angeles County	12
Finis Carleton, Carleton Engineers & Consulting	13
Tim Carmichael, Coalition for Clean Air	4
Ann Hempelmann, Sempra Energy	11
Ed Laird/Jerry Kraim¹, Small Business Coalition (combined) 4
Martin Ledwitz², Southern California Edison 4
William Pearce³, Boeing	10
Judy Yorke, Yorke Engineering	10

AQMD Staff Liaison
Dr. Barry Wallerstein, Executive Officer	11
Mohsen Nazemi, P.E., Permitting Ombudsman ¹ Substituted for Ed Laird as of 1/29/99 ² Joined the PSTF as of 9/4/98 ³ Joined the PSTF as of 6/23/98	13

Facilitator
Dr. Cheryl Stecher, Franklin Hill Group

Permit Streamlining Study Contractor
Charles Botsford, AVES