Goal 4: Be Effective, Accountable, and Customer-Oriented

Improve Permitting, Monitoring, and Enforcement

Strategy 4.1 Timely Permits: We will improve the timeliness of permitting decisions.

The Air District is responsible for issuing air quality permits for stationary equipment in the Bay Area. Air quality permits specify how the Air District’s regulations apply to particular equipment, how the equipment can be operated, and what emission limits the equipment must comply with. Many different types of stationary equipment that emit one or more air pollutants require an Air District permit.

The Air District receives over 1,000 new air quality permit applications each year. We also handle about 10,000 permit renewals and manage 78 Major Facility Review Permits (also known as “Title V permits”) for large industrial facilities in the Bay Area. Fees from permits generate significant revenue to support Air District operations related to regulating permitted facilities.

Sometimes we are not able to issue air quality permits within the timeframes outlined in our regulations. Untimely permits can negatively impact businesses, including small businesses, which may have to suspend or delay their operations because they have not received their permit. Delays can also result in lost or late fee collection, inefficient permit reviews, and even increased emissions if installation of pollution controls is delayed. It can also lead to uneven public participation and awareness if the process takes too long.

Under this strategy, we will update our regulations and other policies to ensure efficient and timely permitting processes. We will better track permit applications, address bottlenecks in the permitting process, and improve our internal coordination to ensure permits are processed more quickly. We will establish permit project teams for complex sources and implement updated resource management systems and tools that better match the needs of our permit workload. As outlined in the next two strategies, we will ensure that improved timeliness does not sacrifice transparency, public participation, nor the proper application of permit requirements.

Strategy 4.2 Transparent Permit Process: We will improve our permitting process to be more transparent and accountable to applicants and the public.

When an air quality permit application is submitted to the Air District, we perform a detailed review of the application. The Air District reviews applications for completeness, compliance with regulations, whether the best available pollution control technology is being used, and what emission and health impacts are expected. Depending on the type of permit application and the expected impact, our regulations may require more analysis before we can decide whether to issue the permit and what the permit should contain. We notify the public when an application is submitted, so that people can provide comments.

The timing and status of permit applications is often uncertain. The required analyses can be complex, and the permit application may not initially contain all the information we need to process it. The Air District also conducts outreach to involve members of the public in the permitting process and incorporates public input it receives, which can be time-consuming if there is substantial public interest in a project. Insufficient staffing levels, loss of institutional knowledge due to retirements, and outdated computer systems are also major factors contributing to permitting delays.

The permit process complexity, delays, and uncertainty all contribute to both the permit applicants’ and community members’ frustration and distrust with the process. They feel it is too lengthy and has too little transparency. The technical nature of permit reviews can also make it difficult for the public to understand the outcome of our permit application review.

Under this strategy, we aim to build trust with the community and with permit applicants by providing more information throughout the process, which will promote more meaningful engagement for everyone. We plan to create user-friendly reports and enhance publicly accessible, web-based tools for permit applications, online tracking, and easily accessible information on permitted sources, permit activity, and related air pollution emissions. We will improve how we communicate information about permits and the permitting process to communities and applicants using more understandable, less technical language.

Strategy 4.3 Consistent Permits: We will ensure Air District regulations and associated air quality permits issued are clear, consistent, and enforceable so that air pollution affecting communities is minimized.

Air quality permits are a critical tool in the Air District’s efforts to reduce air pollution from stationary sources. Permits issued by the Air District list all requirements that a business or facility must follow for each piece of equipment covered by the permit to comply with applicable air quality regulations.

For permits we issue, the permit process does not create the air quality requirements that the facility must follow. Requirements are set through our regulations or regulations at the state and federal levels. Our permit process involves analyzing which regulations apply to a given piece of equipment and writing permit conditions that reflect those regulations clearly, so they can be enforced effectively and achieve all the air quality benefits intended by the regulations. The permit should be well understood by the business owner and operator, so they can more easily meet all the regulations that apply to them.

Permits will not effectively implement our regulations if they are not written clearly. If not written clearly, the permit will also not be understood by the public, the facility, or by Air District inspectors checking to see whether the business is complying with the permit conditions. Permits can also be ineffective if the regulation it reflects is not easily understood or needs to be strengthened to adequately protect communities, as described in Strategy 1.2 Stronger Regulations.

Under this strategy, we will improve the outcomes of our permit process by making sure permits are written consistently and clearly and that they protect the public’s health to the greatest extent that our regulations allow. We will review regulations as they are being developed to be sure they will be clear and enforceable when included in a permit. We will review our set of standard permit conditions and our process for translating regulations to permit understood and enforced.

As described in Strategy 2.10 Comply with Civil Rights Laws, we will review how we issue permits to ensure we are following civil rights laws and regulations. We will also explore how to further consider cumulative impacts in our permitting process, as described in Strategy 2.11 Cumulative Impacts. Finally, we will review when to do a broad environmental analysis of a permitting decision under the California Environmental Quality Act, which may provide for additional community engagement and pollution mitigation opportunities.

Strategy 4.4 Improve Air Monitoring: We will update the design and operations of the air quality monitoring network to improve reliability, efficiency, data quality, and accessibility to better meet monitoring objectives and to support efforts to understand local exposure to air pollution.

The Air District maintains a comprehensive air quality monitoring network that includes over 30 monitoring stations across the Bay Area’s nine counties. Our air monitors’ main purpose is to take air pollution measurements to determine regional compliance with national and state air quality standards. We also use air monitoring data to provide air quality forecasts and trends. Air monitoring data informs our strategies to improve air quality and our health research studies. We also do special monitoring projects to gain better knowledge about specific pollutants and local air pollution problems as described in Strategy 1.1 Change Approach to Air Quality and Strategy 2.7 Understand Local Air Pollution.

Operating the air monitoring network is highly complex. The work includes the design of the network, identifying sites to locate monitors, and setting up the monitors. We then collect air pollution data, analyze and manage the data, and maintain and calibrate the monitors. There are also quality assurance, reporting, and state and federal auditing procedures and requirements we must comply with.

The air monitoring network needs some improvements. The demands on the monitoring network have evolved over time, and there are both gaps and redundancies in the network. We also need to update our data systems, as the existing systems have not kept pace with the increasing volume and complexity of data we gather nor with advancements in data science and technology. Upgrades will allow for better access to a wider range of data for internal use and for the public, especially for people who live in areas with high levels of air pollution.

Under this strategy, we will update our air monitoring data systems, prioritizing improvements that can support more efficient data collection, review, reporting, accessibility, and security. We will strengthen quality control systems, including updating quality assurance documentation and standardizing procedures, communication, training, tracking, and project management. We will also evaluate the monitoring network for possible changes and improvements. This update will consider community input. We will especially consider the location of monitors relative to the location of communities overburdened by air pollution. We will use this evaluation to consider changes to the air monitoring network, such as relocating and decommissioning some monitoring sites, and changing which pollutants are measured.

Strategy 4.5 Improve Compliance Investigations: We will increase the efficiency and effectiveness of inspection and investigation resources to improve compliance and increase the impact of our enforcement program.

The Air District reduces air pollution in communities by ensuring that an industrial facility, business, or activity that we regulate complies with the regulations and applicable permits. The Air District performs regular inspections, air monitoring and testing of specific sources to determine compliance. We also conduct inspections based on complaints we receive from the public.

If we find during our inspections that a business or industry may be violating our regulations, we investigate. If the investigation shows the industry or business owner is not meeting its permit requirements or not complying with regulations, the Air District takes enforcement action by issuing notices of violation and following up with legal action as necessary to ensure they get back into compliance. This process takes resources. If we can make the best use of the Air District’s inspection and investigation resources, we will help ensure that all industries and businesses in the Bay Area are minimizing air pollution and complying with the law, especially those located in communities overburdened by air pollution. Further, businesses complying with our regulations benefit from a strong inspection program, which levels the playing field by penalizing competitors not meeting Air District requirements.

While Strategy 1.5 Enhance Violation Investigations and Strategy 1.6 New Enforcement Policy focus on improving our investigations and developing an enforcement policy with communities, this strategy centers on the efficiency and effectiveness of our inspection and compliance processes and practices. Under this strategy, we will undertake efforts to target our inspections and other compliance activities where they are most needed for ensuring compliance with permits and regulations. We will also streamline the process inspectors use to document violations they find, which can reduce the time between finding a violation and starting an enforcement action. We will improve our program of compliance assistance through better information technology tools and access to compliance resources.

Targeting our compliance and enforcement resources where they are most needed will be informed by our efforts in Strategy 2.2 Collect Community Data and Strategy 2.7 Understand Local Air Pollution. With these two strategies, information from people living in areas overburdened by air pollution will help us better understand which sources of pollution are most harming community members. With that information, we will be better able to focus our inspection resources where they will have the greatest impact on compliance, and therefore, the greatest benefits to community air quality and health.

Build Relationships and Enhance Communication

Strategy 4.6 Inspire Action: We will expand our public communication to inspire the public to support efforts to reduce air pollution and to mitigate climate change.

The Air District is widely known by the public for our award-winning Spare the Air program. This program has inspired hundreds of thousands of people to consider how their individual actions can contribute to better air quality. They choose to reduce how much they drive by carpooling, using public transportation, biking, or walking. They avoid using gas-powered lawn and garden equipment or do not burn wood on days when air pollution levels are particularly high. While this campaign has had much success, we would like to do more to inspire individual actions to limit air pollution and to fight climate change.

Under this strategy, we will develop an expanded public information campaign to raise awareness of the actions people can take to reduce pollution. We will also increase our social media presence to expand our youth outreach and engage young people in our mission and work. We will expand our engagement through local media outlets in communities across the region. We will increase our advertising to share ways people can reduce pollution and the health benefits of cleaner air, especially at the local level.

We will also work with our local government partners and Board of Directors to establish an increased presence in all nine Bay Area counties. We will share our efforts to reduce air pollution in communities most harmed by pollution, the health impacts of exposure to pollution, and what local governments and other partners can do to reduce local air pollution, as described in Strategy 4.9 Land Use Impacts.

Strategy 4.7 Customer Service: We will strengthen employees’ organization-wide knowledge and communication skills, and change our organization as needed, so people experience the highest level of service from the Air District.

The public relies on the Air District for critical air quality information. They rightly expect a high level of service and care when reaching out to us for help or information. Helping customers, including community members, small business owners, and industry representatives, resolve issues or receive information in a timely manner creates greater transparency, builds trust, and helps the agency improve its effectiveness.

Air District employees are highly skilled and knowledgeable professionals in their area of expertise and in the work they do. However, many employees may not be aware of what others in the organization are working on, and not all employees have the same level of customer oriented communication skills. Similarly, when contacting the Air District, people may not be aware of who the best resource is for their questions or concerns. To be an organization with a foundation in strong customer service and one that effectively serves our communities requires that all employees have a high level of organization wide knowledge. Such knowledge can ensure we provide the best possible customer service.

Under this strategy, we will strengthen organizational knowledge and communication skills. We will develop an organization-wide curriculum for existing and new employees so everyone can be fluent in all programs at the Air District. We will have employees serve as liaisons to community members who have air quality questions or problems, to ensure community members receive timely, accurate responses. These actions will also help unify all Air District employees to better support customers and communities, furthering our efforts to be One Air District, as described in Strategy 3.3 One Air District Community.

Strategy 4.8 Air Quality Incidents: We will enhance our incident response program in collaboration with government partners.

When a business experiences an air pollution incident, or any non-routine release of air pollution, the surrounding community relies on multiple government agencies to coordinate a response. Government agencies that may respond include the fire department, the local public health department, hazardous materials response units, and specialized pollution control agencies like the Air District. Although Air District employees are not authorized or trained to play a role as first-responders, we work closely and quickly with those on scene to evaluate potential air quality impacts and inform the public about how the incident may affect their health. We also investigate the cause of the incident and whether any air quality regulations may have been violated.

Providing better information to communities during an incident requires us to develop additional capabilities, including information on air pollution and the potential health impacts for community members. Such information can also help us determine the extent and impact of the incident for purposes of any enforcement action we may take. We also need better and more streamlined coordination with other government agencies who respond to the incident, better technology driven incident detection, and proactive community notifications.

In addition, we need to develop better ways to incorporate and act on information from community members as part of our incident response. Communities closest to an incident are often the first ones to become aware of it and to experience the effects.

Under this strategy, we will work with industry, communities, and other local agencies to establish better systems to detect and assess emissions from incidents. We will explore technology solutions that proactively notify communities of incidents including health information.

We will further partner with communities near facilities with recurring incidents to provide enhanced community-led monitoring to more thoroughly and more rapidly understand exposure to air pollution experienced by community members. Ultimately, we will leverage these tools and partnerships to deliver short, understandable, actionable alerts during incidents, and more robust and transparent after-incident resolution and investigations.

Strategy 4.9 Land Use Impacts: We will provide tools for local governments to consider environmental justice, air quality, and climate priorities in local land use plans, policies, projects, and permitting decisions.

By considering air quality and climate impacts at the local level in land use decisions and using techniques to redress environmental injustices and prevent further harm, local land use decision makers can help reduce exposure to air pollution and improve public health.

While air districts are prohibited by law from making local land use decisions, local land use plans, policies and permitting decisions are at the forefront of improving air quality. They shape the built environment and can be instrumental in advancing environmental justice, building community resilience, and elevating local climate priorities. Land use decisions determine where new development projects – sometimes a new source of air pollution – are located and how they are built. For example, zoning regulations that require adequate buffers between where people live, play and work and polluting land uses such as freeways can help protect health. Site development standards and conditions of approval can reduce the impact of new land uses and prevent new polluting land uses from being placed near people who are most sensitive to air pollution.

Under this strategy, we will develop, share, and support the use of technical resources, data, tools, and best practices. Such practices will enable local governments to incorporate air quality, climate and environmental justice analyses and solutions more effectively into local land use planning, policies, and permitting practices. We will provide guidance on how to strategically use land use regulations to address and prevent incompatible land uses, which means separating pollution sources from places people live and frequent, easing environmental burdens, and preventing the concentration of polluting industries near communities. In the guidance, we will highlight innovative land use tools, such as techniques to phase out the highest polluting businesses located near people most sensitive to air pollution, along with how to use zoning overlays, standard conditions of approval, and other permitting approaches.

Be Accountable

Strategy 4.10 Ensure Success: We will ensure we have the resources and capacity to meet both Board and community expectations and honor our commitments, thereby building trust in the Air District’s capacity to succeed.

The Air District’s drive to improve public health often means we take on more than we have the capacity to perform. To ensure we meet community expectations, and do not overpromise, we need to adequately assess our capacity to take on new work, and properly resource existing commitments. We need to be better equipped to minimize unforeseen costs and be able to achieve successful outcomes. We need to enhance our ability to prioritize efforts and ensure that all divisions within the Air District work cohesively towards common goals, and to link these goals with the resources needed for long-term success. Ensuring we have the resources and capacity to take on new efforts, including those identified in the 2024-2029 Strategic Plan, will build trust and accountability both within the Air District and with the communities we serve. The Air District currently lacks a systematic approach to thoroughly scope and plan new initiatives. Without a clear process to evaluate the needed resources and a collaborative process to ensure broad internal and external support, we can struggle to meet projects’ objectives.

Under this strategy, we will put processes in place to ensure the successful launch and implementation of new regulations, policy and program changes, new initiatives, and modifications to the strategic plan. We will develop detailed operational plans and business processes that estimate the required resources and timelines, and that establish clear responsibilities. These plans and processes will involve all relevant Air District divisions and ensure executive commitment and alignment across the organization.

We will continue to make sure we are using best practices across all our operations and initiatives. We will develop and apply standard operating procedures across the organization, from our information technology systems to contracting with suppliers. We will also make sure these systems connect well with one another to easily communicate information internally and with communities.

We will also apply a continuous process improvement model to our operations and procedures to increase efficiency and quality over time. This commitment will improve customer service, our productivity, and our capacity to succeed.

Strategy 4.11 Align Resources: We will be intentional about ensuring the Air District’s resources and annual budgets are well-aligned with organization and community priorities, as identified in the 2024-2029 Strategic Plan.

For any plan to succeed, goals and priorities must be well resourced. Resources include time, personnel, leadership focus, and money. Too often, big plans for change, new ideas, programs, or priorities are not well resourced.

Under this strategy, the Air District will ensure we resource the strategies and commitments in the 2024-2029 Strategic Plan. We will re-orient our annual budget process, including the allocation of funds, to the specific objectives, strategies, and commitments in the plan. We will be intentional in matching our spending to be in alignment with achieving real impact by adopting new approaches to air quality management that focus on understanding and reducing disparities in local air pollution. Spending will also be used to support our efforts in advancing environmental justice, being more cohesive and inclusive, and becoming a more effective, accountable, and customer-oriented organization.

In addition to aligning our resources to our goals and priorities, annual strategic plan progress reports, as described in Strategy 4.12 Report Progress, will be aligned with the development of our annual budget. Each annual budget cycle and the accompanying strategic plan progress report will be an opportunity for the Air District and communities to assess and reaffirm our shared priorities.

Strategy 4.12 Report Progress: We will transparently report on progress in meeting the 2024-2029 Strategic Plan goals and strategies to be accountable for our commitments and meeting expectations.

Developing and adopting an organizational strategic plan is crucial in providing clarity around an organization’s mission, vision, goals, and strategic priorities. The 2024-2029 Strategic Plan is designed to give the Air District the clarity we have long needed on shared goals and priorities. And while the plan is important in setting clear priorities, implementing the plan is even more important. We need to take actions that will reduce unequal exposures to air pollution, build community capacity and partnership, and build a better and cohesive organization.

Under this strategy, and as further described in Chapter 4, we will track our progress in implementing the 2024-2029 Strategic Plan. We will be responsive and accountable to our Board of Directors and communities by doing an annual review of our progress. We will create measurable performance metrics for each strategy and associated actions. During our annual reporting, we will also identify challenges or resources needed to accomplish each strategy.