Dispersion Modeling Audits: Model Results and Other Issues

On October 9th, 2018, the Texas Commission on Environmental Quality (TCEQ) announced and introduced its plan to expedite air quality permit application reviews at its Autumn Environmental Conference. TCEQ rolled out spreadsheet workbook templates that would take the place of many of the forms required for an air quality permit application. The rationale for the templates is to standardize the information received by the agency so some of the steps in the review process have the ability to be automated. Without standardization, there is no hope for automation.

Though the concept of the templates was well received by those in attendance, the implementation of the process to use the templates raised a lot of questions, particularly how they would be used to speed up the application or modeling reviews. A lot of questions, but not a lot of answers.

The issue of permit application reviews and dispersion modeling reviews taking “too long” is by no means new or limited to only Texas. The situation is similar for all states and local air programs. The biggest issue to me is the problem has never been defined well or even correctly. The first step to solving any problem is to make sure the problem has been well identified. Otherwise, all the effort to solve the wrong problem will be a waste.

Trust Me, I Know What I am Talking About

I find myself in a unique position. I have been providing consulting services to industry for a few years and have worked as a regulator for nearly 20 more years. This doesn’t sound so special so far.

What makes me different is that, while at the TCEQ,  I designed, developed, and implemented processes and tools to standardize and automate the review of dispersion modeling in support of air quality permits as well as the air quality permit applications. The modeling team has developed a training program for new staff to learn how to use these tools and SOPs for not so new staff as a reminder. The tools developed integrate with several of the TCEQ air quality data systems.

After leaving the agency, I made a presentation on what I had learned over the years and how some of the internal processes at TCEQ were being implemented with the tools I developed. The purpose of the presentation was to shed some light on the true scope of the problem and define what the real problem is. Basically, changing a few forms and developing a few macros was not going to solve much and definitely not a solution to shortening permit application review timeframes.

Making the problem statement regarding air quality permit application and dispersion modeling review timeframes, though a good first step, was not enough. So we, NaviKnow, proposed a solution and have developed a few tools to assist on the dispersion modeling side.

Where Do We Go From Here?

The problem of shortening permit application review timeframes, is a big one; too big to be solved by any one entity in a vacuum, but it can be solved in due time. How?

I don’t have all the answers, but let me provide two quotes that I believe lead to the solution. One is:

“If you want to go quickly, go alone. If you want to go far, go together.”

The workbook templates and a few other “solutions” that have been presented over the years, came up quickly, but really didn’t address the real issues. The approach NaviKnow is taking is to have you review the materials we have presented and provide us with your feedback and then develop a partial solution based on the feedback. We don’t have all the answers. If we are missing something or are going down a rabbit hole, let us know. We want to work with you, particularly if you are a regulatory agency.

The other quote that leads to the solution is:

“Done is better than perfect”

Having been in government, there is extreme pressure to get the answer completely right the first time or else you lose public credibility or are wasting public moneys. I believe this mindset sets agencies up for failure and stifles innovation.

With NaviKnow being a private entity, it is vital that we get something into the marketplace quickly. If we fail, we learn from it, make the fixes, and launch again. The NK Tools are by no means perfect; not even close. But having something to help out the situation is better than having nothing at all. The plan for NK Tools 1.0 is already in the works but is contingent on your feedback. Eventually, we will all get to a solution that is workable.


Solving the air quality permit application and dispersion modeling review timeframe problem is going to be complex, however, no one can do it alone. To make any kind of progress towards a solution, read our problem statement, review our proposed solution, use our tools, and then provide us with your honest feedback. We will come up with something and then ask you for more feedback.

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. We also have articles air quality issues at http://naviknow.com/news. If you want to be on our email list, drop me a line at [email protected].

One of the goals of NaviKnow is to create an air quality professional community to share ideas and helpful hints like those covered in this article. So if you found this article helpful, please share with a colleague.


, , ,