Florida’s Electronic Permitting Tools Cindy Phillips, P.E. Division of Air Resource Management Florida Department of Environmental Protection

Florida’s Tools  Organizational Structure DEP’s Division Headquarters in Tallahassee Six DEP District Offices Eight County Local Governments Six Counties have Permitting Authority

Florida’s Tools  Organizational Responsibilities Tallahassee Headquarters office issues specific permit types (electric utilities, waste-to-energy, and PSD), sets policy and writes rules Tallahassee Headquarters office issues specific permit types (electric utilities, waste-to-energy, and PSD), sets policy and writes rules District Offices issue permits and perform compliance & enforcement duties District Offices issue permits and perform compliance & enforcement duties Local program offices have SOA with Tallahassee to perform Permitting and compliance & enforcement duties Local program offices have SOA with Tallahassee to perform Permitting and compliance & enforcement duties  Each is separate entity working together to achieve FDEP goals

Florida’s Tools  Electronic Permit Application forms 1 st attempt – ELSA and EARS st attempt – ELSA and EARS ELSA and EARS used a MS Access database w/a Visual Basic interface.ELSA and EARS used a MS Access database w/a Visual Basic interface. ELSAELSA Allowed applicants to fill out the data (menu driven or by clicking “next page”) and then submit data on diskette w/hard copy signature pages Allowed applicants to fill out the data (menu driven or by clicking “next page”) and then submit data on diskette w/hard copy signature pages Could attach supplemental documents Could attach supplemental documents Could ask the department for a database file to pre-fill application Could ask the department for a database file to pre-fill application EARS – received submitted disks by mailEARS – received submitted disks by mail Data uploaded to EARS and reviewed in an application similar to ELSA Data uploaded to EARS and reviewed in an application similar to ELSA Data would be uploaded after review and permit issuance to ARMS Facility Inventory Data would be uploaded after review and permit issuance to ARMS Facility Inventory

Florida’s Tools  ELSA and EARS lessons learned: ELSA ELSA An attempt was made to try to make the printed forms look like the Hard Copy forms.An attempt was made to try to make the printed forms look like the Hard Copy forms. Made printing difficult Made printing difficult Different printers = different quality of results Different printers = different quality of results Consultants were primary users of the product and had particular needs.Consultants were primary users of the product and had particular needs. Portability Portability Quality Quality Desktop application meant installation issuesDesktop application meant installation issues Different desktop configurations for users Different desktop configurations for users Distribution of new application Distribution of new application

Florida’s Tools  EARS Lessons Learned Development and design did not include much input by Permit Application Reviewers/ Engineers Development and design did not include much input by Permit Application Reviewers/ Engineers Not all data collected in application forms went into writing a permit Not all data collected in application forms went into writing a permit Uploads had to be performed in the HQ office Uploads had to be performed in the HQ office Application forms changed after 2 years and 2 applications had to be enhanced to accommodate the changes Application forms changed after 2 years and 2 applications had to be enhanced to accommodate the changes

Florida’s Tools  Transition to EPSAP – 1999 to present Developed a team of IT professionals and Permit Engineers Developed a team of IT professionals and Permit Engineers Took “lessons learned” and our wish list and developed the EPSAP product Took “lessons learned” and our wish list and developed the EPSAP product Tested with Industry Consultants, Permit Application Reviewers Tested with Industry Consultants, Permit Application Reviewers Incorporated better flexibility to address rule changes Incorporated better flexibility to address rule changes Document content and attachments “hashed” Document content and attachments “hashed” Copy of record maintained Copy of record maintained

Florida’s Tools EPSAP EPSAP Non-Title V Source ApplicationNon-Title V Source Application Handles minor source operating/construction applications Handles minor source operating/construction applications Long Form ApplicationLong Form Application Handles Title V and Synthetic Minor facilities’ Operating and Construction Applications Handles Title V and Synthetic Minor facilities’ Operating and Construction Applications Both require electronic signature to submit (username+password+PIN)Both require electronic signature to submit (username+password+PIN) PE submittal also requires submittal of signed, sealed authentication document per Florida Board of Professional EngineersPE submittal also requires submittal of signed, sealed authentication document per Florida Board of Professional Engineers

Florida’s Tools  3 modules of EPSAP Applicant Module Applicant Module Modeled after hard copy application formsModeled after hard copy application forms Non Title V Source Application Non Title V Source Application Long Form Application Long Form Application Permit Application Review Module Permit Application Review Module Engineer goes to EPSAP to view application dataEngineer goes to EPSAP to view application data May review online or printMay review online or print Data entry tool from issued permitData entry tool from issued permit Inventory Review Module Inventory Review Module QA of Data from specially trained Inventory SpecialistQA of Data from specially trained Inventory Specialist Upload to ARMS DatabaseUpload to ARMS Database

Florida’s Tools  Advantages Ease of completion of application forms Ease of completion of application forms Electronic submittal of Air Permit Application Electronic submittal of Air Permit Application Copy of record available for signatories Copy of record available for signatories Review process flexibility (review online or print) Review process flexibility (review online or print) Data goes through pre-upload QA process Data goes through pre-upload QA process

Florida’s Tools  How does it work? Step 1 – Register Create user account Password will be mailed to address in account Registration includes security question.

Florida’s Tools  EPSAP PIN Request Form Step 2 – for signatories only! Print and sign PIN request form Prefills form with account information Mail to DEP – DARM Help Desk PIN will be ed to account on user account

Florida’s Tools  Prepare Application Prefill application with existing facility data or create application data from scratch for new facilities Multiple users may be assigned to work on an application Each hard copy application may have different signature requirements The signatories are assigned through the “Application Menu”

Florida’s Tools  Adding a Signatory – Responsible Official (Title V) or Authorized Representative Add RO or AR by associating the user account This imports the user account information in to be part of the application content

Florida’s Tools  Adding a signatory – Professional Engineer Adding a Professional Engineer also imports this user’s account information to become part of the application content. These signatories will be required to submit electronically using their Username, password and PIN combination.

Florida’s Tools  Uploading Attachments Attachments may be uploaded and submitted electronically or sent in hard copy if Confidential Business Information or if electronic versions are not available.

Florida’s Tools  Submitting The application may be submitted by the signatories. EPSAP performs a sufficiency edit to ensure no inadvertent omissions of content.

Florida’s Tools  Authentication for PE The Florida Board of Professional Engineers enacted specific requirements for PEs who sign/seal documents. In EPSAP we require PEs to sign/seal an authentication document that contains the hash values of the application contents.

Florida’s Tools  PE Submittal The PE must read the certification statements and warnings and then enter username, password and PIN to submit. Once this occurs the application content cannot be edited.

Florida’s Tools  RO / AR Submittal After the PE signs (if required) the Responsible Official or Authorized Representative must sign electronically to submit to the permitting authority.

Florida’s Tools  EPSAP Submittal Complete The application is submitted and an HTML version of the application available for the signatories to keep. An is sent to the signatories confirming their submittal. Another is sent to the permitting office.

Florida’s Tools  EPSAP Engineer Review Submitted Applications reviewed through the Permit Application Review module. A copy of the application is kept intact, while a “Engineer” copy can be edited. This info is uploaded to the legacy database - ARMS

Florida’s Tools  Challenges Changing the culture Changing the culture Review of applications onlineReview of applications online Responsible Officials/Authorized Representative using Electronic Signature ProcessResponsible Officials/Authorized Representative using Electronic Signature Process Getting constructive criticism from usersGetting constructive criticism from users Changing the process Changing the process Implementing rule changesImplementing rule changes Addressing CROMERRAddressing CROMERR

Florida’s Tools  Overcoming the challenges Training Training Netmeeting Training for off-site locationsNetmeeting Training for off-site locations Workshops for automated productsWorkshops for automated products Help LineHelp Line Listening to our users Listening to our users Asking for suggestions during trainingAsking for suggestions during training Answering help calls as soon as possibleAnswering help calls as soon as possible Addressing required changes Addressing required changes Keeping users in mindKeeping users in mind Making development flexible to allow for changesMaking development flexible to allow for changes

Florida’s Tools  EPSAP Submittals to Date EPSAP Application Submittals EPSAP Application Submittals (to date) 70 Total643

Florida’s Tools  ARMS Permitting Module: Tracks all Permit Requests received in each permitting office. Tracks all Permit Requests received in each permitting office. Tracks events that occur, such as “Completeness Review”, “Requests for Additional Information,” and the “Agency Action” Tracks events that occur, such as “Completeness Review”, “Requests for Additional Information,” and the “Agency Action” Tracks the date of issuance and expiration Tracks the date of issuance and expiration Provides reports to managers and permit processors to indicate when an event is close to its due date Provides reports to managers and permit processors to indicate when an event is close to its due date Tracks the Application Time Clock Tracks the Application Time Clock Permitting data across the department is reported in the same database, so reports can be pulled across programs. Permitting data across the department is reported in the same database, so reports can be pulled across programs.

Florida’s Tools  ARMS Permitting Application For Permit Tracking For Permit Tracking Permit Number Events Scheduling screen tracks processing timelines PA is used throughout DEP to allow query of permitting actions across divisions

Florida’s Tools  Permitting Reports available Pending Permitting Projects – searches against projects in process Pending Permitting Projects – searches against projects in process Upcoming, Overdue, And Completed – one report that searches projects that are about to Expire, have already expired, and completed (i.e. by issued date) Upcoming, Overdue, And Completed – one report that searches projects that are about to Expire, have already expired, and completed (i.e. by issued date) Title V Timeliness – queries Title V projects and categorizes them by time to issue time frames. Title V Timeliness – queries Title V projects and categorizes them by time to issue time frames. Ad Hoc Reports – query PA data and build a custom report Ad Hoc Reports – query PA data and build a custom report

Florida’s Tools  Air Document Search Allows HQ, DEP District and Local Programs to post zipped permit documents Allows HQ, DEP District and Local Programs to post zipped permit documents Original MS Word/Excel versions available internallyOriginal MS Word/Excel versions available internally The converted, PDF versions available to the public via the internetThe converted, PDF versions available to the public via the internet Links the documents with the appropriate permit project record in ARMS PA Links the documents with the appropriate permit project record in ARMS PA Mechanism for EPA to get copies of Title V Permits Mechanism for EPA to get copies of Title V Permits Also allows the search of HQ permit files scanned in Tallahassee Also allows the search of HQ permit files scanned in Tallahassee

Florida’s Tools  Air Permit Document Search Permit Documents available on the World Wide Web! Permit Documents available on the World Wide Web! Search for desired documents by Permit Number, Facility ID, Location, SIC, etc. Results page allows download of Zipped file to obtain permit documents! Show Supporting Documents allows download of other documents such as legal correspondence and the application

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Florida’s Tools  Contact Cindy Phillips Cindy Phillips 850/ / Elizabeth Walker Elizabeth Walker 850/ / / /