Jumping The Permit Compliance Hurdle

How could water utilities better plan for permit compliance? For any entity conducting business – whether it is providing a public service or selling a good – predictability is a key to long-term survival. You might not be able to control input cost changes, shifts in demand, or adverse events, but the better you can foresee and prepare for them, the more you will be empowered to ensure your sustainability.

As Goes Permit Compliance, So Goes Predictability and Sustainability

The sustainability of water utilities hinges on regulatory and permit compliance at the local, state and federal levels. If they cannot get permits, they cannot get off the ground to begin with. But maintaining compliance is the 800-pound gorilla. If permits are violated, utilities can often keep handling wastewater and providing drinking water, as these services are public health-critical, but violations are unsustainably costly on many fronts:

• Fines can be huge and compound on a daily basis as long as violations are outstanding. Violations can also mean lengthy and expensive legal proceedings involving other government entities, interest groups, and citizens
• More and more, they are the canaries in the coal mine giving the first notice of failed – sometimes catastrophically so – infrastructure
• Since water utilities are monopolies and users cannot turn to other providers, the loss of public trust that violations engender can be profound, lasting decades and creating ripple effects up to the highest levels of an organization or government.

Treating Permit Compliance as a Product

All too often, water utilities see permit compliance as a hurdle they must jump to fulfill their mission: providing clean water efficiently and at a reasonable cost. In the worst-case scenario of breach of public trust, where permit compliance is seen as a hurdle, going around it is a possibility – unless and until caught. The Flint, Michigan water supply crisis happened in large part because the Flint Water Treatment Plant maintained permit despite officials knowing it could not provide safe, clean drinking water.

While clearly Flint Water did not plan for permit compliance as a primary product, too few water utilities do either. What if they did? Would planning a product that everyone depends on start to seem much more positive and predictable than jumping a hurdle or avoiding a punishment? Would it help managers and decision-makers feel more like empowered, responsible adults than guilty children?

For drinking water, wastewater and stormwater, permit compliance is a matter of keeping within standards for a wide range of contaminants (such as metals and harmful bacteria) and indicators of health (such as temperature and pH) – that is, maintaining acceptable quality. So many factors go into that – exogenous ones such as weather events and endogenous ones like infrastructure status. And with climate change, ageing assets and emerging technologies, more new and unexpected factors come into play every day, making planning more challenging than ever. So how can utilities plan for compliance as an end product? All signs point to data as a keystone.

Collecting the Right Data at the Right Time

It is no secret: water supply, wastewater, and stormwater utilities all know what their output is supposed to look like: clean water, which equals compliance. To get there, they need to know what is entering the system and when, what tools they need to use to create compliance, and what their measures of success are indicating – all questions that must be answered by gathering data that passes QA muster. Technology such as new types of sensors and even drones are making possible the collection of critical data in the field that just a few years ago would have been unimaginable, greatly leveraging the ability to gather data about what is coming into the system – typically the greatest challenge to compliance. The right data quality and quantity optimizes data-driven decision-making – which only makes sense to achieve a result (regulatory compliance) that is characterized by data measures.

Making Data More Powerful By Expanding Its Accessibility

A single utility may have dozens of different systems where compliance-critical data is kept, each with protocols and nomenclature known only to staff in specific organization units with highly specialized expertise. It is as if staff working towards the same goals just down the hall from each other were operating on different planets, and the message that only a certain few people – rather than everyone working together – are responsible for compliance.

Achieving consistent compliance rather than reacting to violations requires connecting dots and detecting patterns with a clear “line of sight” across all the organization’s data. But using multiple data storage applications stymies this line of sight, making it much more difficult to spot, investigate and respond to potential problems before they lead to violations.

Decisions are Easier and Better When They are Data-Backed

There is probably no water utility manager out there who never struggled over making a big decision when helpful or critical data was simply not available. Some of the most difficult ones are decisions around money – how much should be planned for future infrastructure, what level and what type of efficiencies should be targeted, how should rates be set? Though the connection may seem indirect, these funding decisions are the foundation to maintaining predictability and steady future compliance – and they are frequently finalized by government legislative bodies with no water utility expertise and a long list of other priorities. Rich data, with its significance put into sharp focus through sound and appropriate analytical tools, gives water utilities the best chance at decisions and their aftermath that will help realize predictability, and permit compliance, for the long-term.

Do you want to improve Environmental Permit Management in your organization? Talk to us and ask for a demo: our team of experts spend time with your team to better understand how you currently manage permit compliance and identify optimization priorities.