It is our job at ALL4 to deliver technical expertise to our clients. When complicated technical decisions need to be made that involve capital spending and regulatory liability, we need to weigh those variables and arrive at a conclusion that maximizes operational flexibility and minimizes the compliance burden of the facility. In the air quality arena, the ability to make those decisions typically comes with time and a great deal of experience. We ask ourselves every day: how do we ensure that this knowledge and decision-making capacity is transitioned from our Senior Consultants to others as efficiently as possible? At your companies, where entire environmental programs are being managed, the question is equally important. We are hearing this question from our clients and believe that we can apply our internal legacy planning approach to help facilitate the same process externally. Here is the problem: Most of our client environmental groups have a select few people with substantial “institutional” knowledge. How can we parse manageable portions of this knowledge and mentor others to ensure that it is not lost? We have outlined a Legacy Planning process that we believe will be a good start.
Scope Step 1 – Legacy Knowledge Transfer Road Map
ALL4 Senior Consultants will meet with your environmental team to prepare a summary of “Legacy Knowledge” categories and processes that are the most critical to document and transition. Our initial categories to kick off this process are summarized as follows:
- Procedural Knowledge: We have management systems that document the processes and protocols used to comply with Title V permit conditions (i.e., reporting, recordkeeping, etc.). This category evaluates gaps in this documentation and asks the question: will new people preparing those reports and information be able to prepare them efficiently and effectively?
- Institutional Knowledge: What is the range of typical emissions for each process unit at your facility? What makes each piece of equipment unique operationally in ways that impacts emissions versus industry averages? Why was one control option selected over another control option? Why was one process option selected over a less polluting option? This knowledge can be important but is very difficult to capture effectively.
- Regulatory Knowledge: Which regulations impact your facility? What are the compliance options and why were they selected? What regulations will impact our capital cost and compliance flexibility moving forward? These questions would fit into the category of regulatory knowledge.
- Historic Project Knowledge: Decisions are made when new projects are permitted that often need to be addressed during future projects. Such permitting decisions, coupled with project history, are critical to document for reference in the future.
- State Agency Knowledge: State agencies and specific permit writers and compliance inspectors apply their own interpretations to our operating permits and projects. Understanding interpretations that have been applied in the past, and how they might change in the future, would be addressed under this category.
- Compliance Knowledge: Annual compliance certifications by the responsible company official represent an extremely important document that can impart liability to the certifying official. How is the compliance status with regard to each applicable air quality requirement at the facility determined? Does documentation exist for each point of compliance? If so, where does it reside and how are the data interpreted? Understanding the underlying bases, assumptions, and their origins associated with the compliance certification is of paramount importance.
A specific list of Legacy Knowledge items would be identified under each of these categories to serve as a road map during future projects and compliance related activities, as applicable.
Scope Step 2 – Incorporating Legacy Planning into the Everyday Activities
How do we take on the daunting task of documenting and transitioning a wide range of Legacy Knowledge? The answer: we don’t do it all at once! ALL4 works with our clients on a variety of reporting, permitting, and compliance issues that span the categories described above. Our plan for each project is as follows:
- Each project scope will include a Legacy Planning scope item. The purpose of the Legacy Planning scope item will be to assess where and how Legacy Knowledge documents should be prepared as an outfall of the project. A couple of examples:
- An annual emissions reporting project might include the preparation of a standalone summary table that includes emissions factors, references for the source, and a deep dive on the logic behind each emissions factor decisions and its likelihood to change in the future. This will provide context for future preparers that may be lacking now.
- Air permitting projects often include a number of regulatory, emissions, and engineering scope decisions that are documented throughout emails and other project documents. The preparation of a Legacy Knowledge document concisely describing these decisions will save a tremendous amount of time when revisiting the project or making permit revisions in the future.
- Compliance certifications rely on vast facility records and data. Is there a “catalog” that identifies the origins, locations, bases, and record location for each of such information? Can the compliance certification process be expanded to reflect such information?
- The Legacy Planning scope item will be reviewed with the project team at the conclusion of the project and added to as appropriate.
We will start by adding these to scopes as an optional task, with the intent that Legacy planning, or at least a discussion of it, occurs during every project.
Scope Step 3 – Routine Presentation and Road Map Check Ins
We hold annual planning discussions with many of our clients. The Legacy Documents prepared during project work will now be a part of the planning discussion. We will:
- Present the Legacy Document observations to the environmental team.
- Evaluate the Legacy information that has been prepared during the routine course of our project work.
- Compare the Legacy information prepared to date to the original road map outlined during Scope Step 1.
- Assess the need for Legacy planning beyond normal projects (i.e., specific training) over the course of the next year to address gaps in the original road map.
Over a period of several years, the process will continue to fill in Legacy Knowledge gaps. The goal is to fill these gaps efficiently since they are part of routine project work. We will be able to evaluate the ongoing effectiveness of the Legacy Planning process and, with intentional effort, set the stage for the future efficiency and compliance knowledge of your environmental team.
What to Expect from ALL4
- 1. Your contacts at ALL4 to discuss this legacy planning process and what it could mean for your facility or company.
- 2. Legacy Planning discussions during the preparation of proposals. ALL4 will work with your team during projects to extract and capture key findings as reference for future environmental team members. At a minimum, we want to prompt a discussion and a thoughtful process around how best to take the learning from each project and carry it forward.
We are looking forward to starting a Legacy Planning process in 2019 and laying the foundation for knowledge for years to come!