Sometimes I really wonder if I am a clairvoyant. The topic for this month’s webinar series was decided upon months ago. I knew the TCEQ Autumn Environmental Conference (Air Permitting Workshop) was going to be the week before the webinars were to happen, but there was no conference agenda out until a few week ago.
I figured I would start winding down the year with an overview of the dispersion modeling review process. There may be a question or two from goings on at the Workshop from the week before but I was guessing, most likely, nothing of substance would come up.
TCEQ had other ideas. The Workshop was the stage for TCEQ to introduce and roll out, what it considers, process streamlining tools. The agency rolled out a collection of spreadsheet templates for compiling and submitting much of the information for an air quality permit application, including dispersion modeling.
Though TCEQ did hit on the right concepts (standardization and automation), the implementation of these process changes has a few issues.
Where’s The Back End?
Having been involved in the Air Permits Allowable Database (APAD) development, the proposed workbooks do not take advantage of some of the constructs in APAD that are part of the review business process, namely operating scenarios and emission source groupings. These constructs were always a part of the process and were formalized during the business case analysis.
Without a connection to the operating scenarios and source groupings that are already in APAD, and no plan to import these data into APAD after being received, there is a sizable risk of creating inconsistent and inaccessible permitting data.
Proposed Workflow Changes
One proposal from TCEQ that caused the biggest stir at the Workshop, was really nothing new; submit dispersion modeling with the permit application, at least for minor source permits.
Putting on my former regulator hat on, this proposal makes perfect sense. The sooner the data are in the process, the sooner it will get through the review process. Deficiencies will be found, they always are, and sometimes a portion of the modeling will have to be re-done. That is nothing new. Getting it started sooner will assist in expediting the review.
Putting my consultant hat on, it is very useful to the applicant to know whether the modeling will pass before the application is submitted. Dispersion modeling is a planning tool and should be used early in the process, way before application submittal. I realize modeling is rarely included when an air quality permit application is submitted, but doing so really is a more efficient process.
NaviKnow Offers a Solution
Making a criticism without a proposed solution to the situation is not helpful, at all. We, here at NaviKnow, are keenly aware of the issues involved with making, not just the dispersion modeling review process more efficient, but the air quality permit application review process more efficient, too.
We have a blue print for a solution. We are working on it. We do not believe in the “build it and they will come” business model, though. We are looking for forward-looking companies that are interested in working with our team to solve the permit review problem then put the solution into action.
Give us a call. Send us an email. Let’s sit down and work this out.
If you found this article informative, there is more helpful and actionable information for you. Go to http://learn.naviknow.com to see a list of past webinar mini-courses. Every Wednesday (Webinar Wednesday), NaviKnow is offering FREE webinar mini-courses on topics related to air quality dispersion modeling and air quality permitting. If you want to be on our email list, drop me a line at firstname.lastname@example.org.
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