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Four State / EPA Region 7 State Implementation Plan (SIP) Kaizen Event Report Out

Performance Excellence Continuous Improvement. Four State / EPA Region 7 State Implementation Plan (SIP) Kaizen Event Report Out. By: SIP Zero January 4-8, 2010. Iowa Dept. of Natural Resources Jim McGraw Kansas Dept. of Health & the Environment Linda Vandevord (State Team Leader)

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Four State / EPA Region 7 State Implementation Plan (SIP) Kaizen Event Report Out

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  1. Performance Excellence Continuous Improvement Four State / EPA Region 7 State Implementation Plan (SIP) Kaizen Event Report Out By: SIP Zero January 4-8, 2010

  2. Iowa Dept. of Natural Resources Jim McGraw Kansas Dept. of Health & the Environment Linda Vandevord (State Team Leader) Rick Brunetti Miles Stotts Tom Gross Missouri Dept. of Natural Resources Karl Fett Jeff Bennett Wayne Graf Nebraska Dept. of Environmental Quality Bev Kellison Shelley Schneider Mid-America Regional Council Amanda Graor EPA Headquarters Scott Mathias, OAQPS Geoffrey Wilcox, OGC EPA Region 7 Becky Weber (Event Sponsor) Ashley Betts (EPA Team Leader) Josh Tapp Bob Patrick Mike Jay Amy Bhesania Dana Skelley EPA – Other Regions Lynorae Benjamin, Region 4 Guy Donaldson, Region 6 Consultant Support Jim Scott, TBM Consulting Jennifer Tice, Ross & Associates Observers: Kim Green-Goldsborough, EPA OPEI Jim Blizzard, Environmental Council of the States Wayne Gieselman, Iowa DNR Brent Jameson, Guidon Performance Solutions Tim Taylor, Guidon Consulting Team Members 2

  3. SIP Zero 3

  4. Key Points Becky • Commitment to Making Timely Decisions • Concurrent and Timely Guidance from HQ • Start Early! • Strong Working Relationships and Early Planning • Communicate-Collaborate-Communicate! • Worksharing Opportunities • Early Complete Draft SIP • On-going Commitment to the Process

  5. ScopeLynorae This event will address the Clean Air Act State Implementation Plan (SIP) process from the time EPA Headquarters promulgates a rule that requires States to prepare or modify a SIP through final EPA approval of the SIP. • Process mapping focused on: • Ozone Attainment Demonstration SIPs 5

  6. GoalsLynorae • 100% of approvable NAAQS attainment demonstration SIP submittals occur within statutory timeframes (baseline is 15-20%). • Concurrent promulgation of EPA standards and issuance of final “implementation guidance.” • 50% reduction from baseline for process time from SIP submittal to final EPA approval. • 100% of SIPs are approved within the statutorily-defined timeframes. • Eliminate a third of the SIP processing backlog each year for the next 3 years, excluding those that are being held up by lawsuits. • SIP submittals are of sufficient quality on first pass to meet statutory requirements, leading to 100% approval of SIPs submitted. 6

  7. Objectives (1 of 2)Jim • Concurrent (or timely) final guidance from EPA in conjunction with rule promulgation (avoid “late hits” and “moving targets”). • Expand opportunities for soliciting State and EPA Regional input into guidance development. • Empower the EPA Regional Office to provide guidance and make decisions in cases where there isn’t clear guidance from EPA HQ. • Strong and productive working relationship and communications between States and EPA; participation occurs in “nuts and bolts.” discussions at early stages; develop a strong partnership relationship. • Recognize and accommodate individual State rulemaking processes, issues, priorities, and problems. • Eliminate “check-box,” “one size fits all” approach (while ensuring legal and scientific defensibility). 7

  8. Objectives (2 of 2)Jim • Accommodate and clarify degree of flexibility States have in SIP development; clarify what you have to do and what would be nice to do; determine how to balance flexibility with clarity of guidance. • Improve continuity of SIP processing staffing and training at EPA Region 7; maintain institutional knowledge. • Ensure SIP process works to protect and improve environmental quality. • Ensure consistent treatment in the SIP process across States and Regions. • Improve timeliness of SIP processing and approval. • Eliminate duplication and redundancy in work. • Identify Clean Air Act/statutory issues and constraints to improvement. • Improve and develop “efficiency tools” (e.g., checklists, templates, Direct Final and Letter Approval). 8

  9. Kaizen Team Process 9

  10. Current ProcessJeff 10

  11. Current Process – DetailJosh 11

  12. BrainstormingGuy • What an ideal process would look like • Identify common themes • How to implement themes

  13. De-selection Guy • Impact/Difficulty matrix developed • Identified ideas that had biggest impact with least amount of difficulty of execution • Mapped matrix into the future state process

  14. Future ProcessMike 14

  15. Future Process- Detail 15

  16. Legal Checks on the New ProcessBob EPA issues guidance and implementation rule at time of NAAQS • State designation recommendation (no more than 1 year) • EPA modification of State recommendation (120 days before final designation) • EPA promulgation of final designation (no more than 2 years) • Process to consult with MPO/DOT/FHWA/FTA/EPA RA on development of MVEBs (30-45 day comment) • Effective date of designation (starts clock for attainment date) • EPA notice of comment on conformity, etc. (as part of nonattainment SIP) • EPA does notice of comment on SIP approval • State submittal of mobile budget • State submits nonattainment SIP– Set by IMP rule or by designation (no more than 3 years from designation) • EPA makes completeness determination on nonattainment SIP (no more than 6 months) • EPA acts on nonattainment SIP (no more than 12 months from completeness) • EPA approves conformity, etc. (as part of nonattainment SIP) 16

  17. ResultsKarl 17

  18. Implementation Priorities Tasks Going Forward Shelley

  19. Resource Needs: EPA HQShelley Identify resource needs or disinvestments to 1) Develop timely guidance for NAAQS designations and implementations. 2) Develop new rules for national control reductions/strategies and a menu of control options. 3) Develop a SIP template to aid in consistent and approvable SIPs. 4) Assist with SIP training. 5) Release timely designation modeling. 6) Technical resource support for RPO/State modeling 7) Time to attend key meetings and address “significant” issues raised by regions. 8) Evaluate funding for RPOs. 19

  20. Resource Needs: Region 7Jim Identify resource needs or disinvestments to do work sharing coordination and concurrent review, specifically: 1) Boundary analysis 2) RPO/State modeling reviews (need modeler) 3) Evaluate national/regional control measures 4) SIP analysis, review, and approvals. Right people, right time, right skill mix. Will require: 1) Promotion potential 2) Additional staff 3) Identify additional disinvestments 4) Minimize rotations 5) Provide training for new staff 6) Consider providing IPA staff

  21. Resource Needs: StatesAmy Identify resource needs or disinvestments to accomplish early work with multiple nonattainment areas. 1) Review and provide for staffing needs (planners, engineers, modelers, etc.) to conduct education/outreach, EI, modeling, and rule development and special assignments/tasks. 2) Establish and complete training. 3) Evaluate equipment needs. 4) Evaluate funding for RPO.

  22. Timely Management DecisionsRick Administrator commit agency to issue timely designation guidance, implementation guidance and updates to federal rules. EPA commit to timely decisions on designation boundaries and consistency on SIP approvals. Specific, high level EPA management commitment to make decisions regarding frontloading EPA work to provide guidance and implementation rules when the final NAAQS is issued, in order for states and EPA staff to meet statutory milestones. Including but not limited to: ** implementation guidance ** designations guidance ** implementation rule ** control options ** federal rule updates ** EPA will pursue accountability for policies regarding timelines for processing SIPs and national guidelines.

  23. Plan for Initial SIP “Road Map” MeetingAmy • Invitees (by nonattainment area): • States • Regional Offices • RPOs • MPOs • Local Agencies • DOTs – each state involved • Facilitators: Regional EPA Offices 23

  24. Agenda Topics for Initial SIP “Road Map” MeetingAmy • Discuss new standard – statutory guidelines and timelines • Discussion of all available resources: staff, money, computers, etc. • Discussion of tasks to be done and by whom: • Communication workgroups, technical workgroups, outreach workgroups • Assignment of “homework” to be accomplished by roadmap meeting • Schedule roadmap meeting 24

  25. SIP Structure – Plan for Developing SIP “Template”Dana • EPA Workgroup w/ input from States (w/ legal) • Project Manager: Bob Patrick/Dana Skelley • Other Members: Geoff Wilcox, Jan (OGC), Mike Jay, Wayne Graf, Miles Stott, Jim McGraw, Bev Kellison, Denise Gerth • Further refinement of initial outline, including more detailed descriptions • Timeframe: Develop within 30 days 25

  26. SIP Structure – Initial OutlineDana • Cover Letter • Clear request for action, including a timeline for parallel process if desired • List of attachments (e.g., attainment demonstration, RACT/RACM, RFP, etc.) • SIP Narrative • Executive summary • Background • Regulatory context • Attainment demonstration [components listed on next slide] • Appendices 26

  27. SIP Structure – Attainment Demonstration ComponentsDana • Met data • Monitoring • Control Strategy • Sum of Modeling • Sum of SIP Emissions Inventory • MVEB • Fed, State, Local Measures • Control Measures • RACT/RACM 27

  28. SIP Structure – AppendicesDana • Detailed emissions inventory info • Planning assumptions & modeling for MVEB • Rules • P.H. notices • P.H. transcript intro statement • CMTS/Responses • Legal authority 28

  29. Federal Register Efficiency Process & Public Comment StrategyLynorae When – After comprehensive draft package submittal Who – EPA Region in coordination w/ State & EPA HQ if necessary What – Only potentially controversial element How – (if controversial) • E.g. include alternatives in proposals? • Limited, conditional, partial approval? • Analyze legal vulnerabilities of approach Collaborative process between EPA and State on response to comments 29

  30. Additional Federal Measures NeededGeoff • Some sectors/source categories identified • Some potential tools identified • Suggest a conference meeting to discuss and identify which warrant further exploration • OGC – Geoff Wilcox • ORC – Bob Patrick • R7 – Cody Brown/Guy Donaldson • Iowa – Jim McGraw • Timeframe: initial meeting 30 days • Nebraska – Brad Reid • Kansas – Rick Brunetti • Missouri - Karl Fett • OAQPS – Peter T’s group 30

  31. Additional Federal Measures – SectorsGeoff • *Industrial Boilers • *Cement/Lime Kilns • *EGUs • IC Engines • Glass Plants • Undone/Underdone mobile (Tier III/nonroad) • CAFOs • Ag/Prescribed burning • Consumer products *NB extra points for multi-pollutant multi-NAAQS 31

  32. Additional Federal Measures – ToolsGeoff • Explore inter-state transport control strategies for other source categories, don’t presume cap & trade instead of command & control emission limits • Review CTGs for improvements • MACT/NSPS/RACT level rules/guidance • Regional Haze (BART determination) • Consumer Products 32

  33. RPO Involvement in SIPsJim Need to determine: 1) What are the staff’s capabilities now? 2) What is the current scope of work and what is desired scope? 3) What are the tasks that states want them to do? 4) Determine resources to do work. 5) Find and secure resources. 6) Based on resources, revisit tasks that we want them to perform.

  34. Possible tasks for the RPOsJim 1) Facilitate communications between states for SIP development and multi-state areas. 2) Build relationship with LADCO and other states as needed. 3) Do EI work. 4) Assemble/compile inventories into a common database. 5) Conduct emissions modeling. 6) Transfer inventory and emissions modeling results to the states. 7) Provide photochemical modeling support to the states. 8) Provide education and outreach for new ozone nonattainment areas (Blue Skyways, etc.). 9) Facilitate SIP training courses for EPA/State/Locals.

  35. Menu of Control MeasuresMiles Developed by EPA to streamline control options decisions and to facilitate State’s measures for meeting reasonably available control measures for NOx, VOC, and PM. Review existing control technologies already in place Document new and innovative control technologies for use in individual nonattainment Voluntary measures to be included in this menu, including how much emissions reduction credits are available. Consider increasing the 3% cap on voluntary reductions to at least 10% For ozone, roll out for states by August 2011

  36. Impact of federal rules on future yearMiles Projection of impact of federal rules on future year emissions inventory. Define emissions reductions expected from “on-the-books” regulation for each nonattainment area. This will include stationary, mobile and area sources. Roll out by August 2011 for ozone.

  37. Roll Out PlanJosh and Shelley Who are the champions? States: Shelley Schneider (NE) Jim McGraw (IA) Rick Brunetti (KS) Jeff Bennett (MO) Regional: Becky Weber, Bob Patrick, and Josh Tapp National: Scott Mathias and Geoff Wilcox Who is the Audience? (State, Regional, National) • Managers • Staff • Elected Officials • RPO • ECOS 37

  38. Roll Out Plan Provide detailed description of what and why to the audience, including: • Process (SIP Lean) • SIP Process (Baseline) • SIP Process Refined • Refined Analyses (Visual)/polished • Scope • Goal • Objectives

  39. Roll Out Plan Inform Audience of Benefits: • Time • Resources • More Expeditiously Protect Public Health • Increased Communications • Increased Partnerships • Certainty for Regulated Community • Less risk for unforeseen delays and litigation (e.g. conformity lapse)

  40. Implementation and Follow-up Actions: Status of: Success Set Backs Adjustment Action Items Tracking System Responsible Parties National Roll-Out? Recommended Actions: 1/8/2010: Report out to State/Federal Sr. Managers Next 30 days: develop and refine presentation for common messages, including: Scope/Goals/Objectives Metrics Process Flow Expected Outcomes Roll Out Plan

  41. 30 days out (conference call) Walk Through Presentation Work group Concurrence Check in on all action items Roll out schedule & champions Evaluate existing resources vs projected needs 60 days out (conference call) Progress on action items Roll out complete 90 days out (face to face meeting) Schedule meeting of SIP Lean Work Group I.D. adjustments Begin to apply to Ozone NAAQS (i.e. implementation Rule, National Rules, etc.) Roll Out Plan

  42. Commitment to Making Timely Decisions Concurrent and Timely Guidance from HQ Start Early! Strong Working Relationships and Early Planning Communicate-Collaborate-Communicate! Worksharing Opportunities Early Complete Draft SIP On-going Commitment to the Process Recap of Key PointsBecky

  43. CommentsJim Scott – Consultant

  44. We welcome your questions and comments! 44

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