The Whole Problem

Americans constantly complain that completing their federal income tax return is too complicated and takes too long. Americans spend, on average, 13 hours to complete their federal tax returns. The 13 hours is broken down this way:
• 6 hours to compile information ( W-2, 1099-INT, 1099-R, 1099-MISC, 1098, 1098-T, K-1, etc.)
• 4 hours to actually fill out the tax forms
• 2 hours to plan your tax strategy
• 1 hour for other (like banging your head against the wall)

If doing your taxes yourself is too much trouble, you can still hire a professional to do it for you. However, you still have to spend the 6 hours getting all of your documentation together.

We hope you all realize that most of the documentation you spend hours trying to find is all reported to the IRS by your employer, banks, mortgage holder, or school. Potentially , the IRS could fill out all the forms for you and send you a letter telling you how much you owe or get back. Why not? That’s not how the system is set up.

When you look at the air quality permitting process, in many respects, it is similar to filling out a tax return, except the air permitting process takes weeks, months, or years (200+ days on average in Texas for the review alone) rather than 13 hours. Why does it take so long? That is how the current system is set up.

Defining the Real Problem

In our article, Stone Knives and Bear Skins, we make the assertion that, in spite of large investments made by regulatory agencies, the time and effort used to issue an air quality permit has remained excessive because the solutions developed were not for the correct problem. The entire focus has been on the regulatory review portion of the process with practically no attention being spent on the application preparation portion of the process. Focusing on only a portion of the process not only doesn’t solve the whole problem, but actually solves very little, if anything, having to do with the root causes of the problem.

The whole air quality permit process is depicted (very simply) below.

Let’s start by breaking down the upstream portion of the process.

Next let’s focus just one aspect that shows the root causes of what bogs down the whole process: the forms necessary to complete the air quality permit application.

The Root Cause: What’s Asked For and Why?

Similar to the federal tax return, the typical air quality permit application asks for a lot of information. It takes time and effort for an applicant to find and compile all the information asked for and time and effort for the regulator to validate all that information. It IS ALL validated, right?

An Example: Where Are You? We Need To Know.

One set of questions that is included in forms for nearly every regulatory agency has to do with where the industrial site seeking the air quality permit is located. The reason for this information is, the regulators would want to know who and where are the entities being regulated. Also, the location is a trigger for many other regulatory requirements. Seems pretty straightforward. But how does the regulator get all the information needed to perform a review?

Though I am using the Texas Commission on Environmental Quality (TCEQ) forms in this example, the TCEQ forms are emblematic of every other regulatory agency forms.

On the TCEQ Form PI-1, the following information is asked for/required:
• Site street address
• Site location latitude and longitude
• City/Town of site
• County of site
• Zip code of site
• Driving instructions to site location
• State Senator and House Representative representing the area of the site location
• EPA Class I areas within 100 km of the site
• Nearby tribal lands
• Nearby federal lands
• Nearest city to the site
• Local air programs
• School district of site location
• Any schools within 3000 feet of the site
• Is the site located in an Air Pollution Watch List (APWL) area
• Is the site located in a nonattainment area
• What are the newspapers are in general circulation where the site is located
• Public place near the site for public viewing of the application

Those are 18 pieces of information that the applicant has to run down. Some of them are easy enough to come up with but others require a bit of time to research just to find the information. Once the information is found, is the data source for this information reliable? What does the agency use to validate the responses on the form? The responses are validated, right?

Just like the IRS, the TCEQ does have access to all the information to validate all 18 responses. Unlike the case with the IRS, all the information to validate the 18 responses is in the public domain.

How many questions really need to be asked of the applicant? One. Where is the site? Just click on a an interactive map with recent imagery as the base map and BINGO, all the answers appear and have come from the most reliable data sources.

Does a tool like this actually exist? Well, of course it does, for the most part. NaviKnow has it.

The Real Solution

Eliminating the need to ask for 17 pieces of information among the thousands requested and required items necessary to complete an air quality application seems insignificant, but it is just a start. As we add more datasets and more tools, more and more redundant and unnecessary questions will fall by the wayside. This type of solution shortens both the application preparation time and the regulatory review time. Isn’t it the best solution to save time and effort for everyone involved in the process? We think so.

The solution we pose is not something we can create and construct in a vacuum. We don’t believe in the “build it and they will come” business model. We will require input into the process and buy-in to the concepts from the regulators and the regulated. If you want to be a part of the solution, contact us to start the dialog.

If you found this article informative, there is more helpful and actionable information for you. Go to 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 about air quality issues at 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.