In this step we look at priorities. Setting priorities is necessary in case we do not have enough resources and first in, first out is not an option for different kind of reasons.
Permitting Departments are responsible for a range of tasks which directly or indirectly relate to permitting. Available staff do not always provide for the operation of a first in first out application completion method. Where a first in first out method is not feasible a prioritisation model is required.
The aim of a prioritisation model is to identify the factors which influence the prioritisation of permit applications. These factors can then be used to rank permit applications received and those due to be received within the upcoming year.
The figure below is an example of a working set of prioritisation factors for permit applications. This model can be used as a starting point, however, due to variations across IMPEL Member countries these factors should be tailored to ensure relevance.
In random order:
a) Environmental Outcome: In some cases installations may be negatively impacting the environment due to e.g. historic contamination or current emissions. Inspection authorities bodies may wish to regulate activities at an installation that may be causing issues locally or perhaps the installation needs to be closed in a regulated manner.
b) Green or significant Investments: There may be a requirement nationally for a particular economic sector or emerging industry type to be given a priority where investments have been made in order to get these industries operational.
c) Statutory deadline/infringement risk: Applications may need to be prioritised where they have links to statutory deadlines (e.g. implementation of Commission Implementing Decisions relating to BAT conclusions), known infringements, any complaints being made to the Commission, petitions from the European Parliament, queries from MEPS or reports being submitted to the Commission which point to infringements of Community environmental law. Applications should be prioritised to ensure the risk of infringement is reduced.
d) Client and third party demand: Regulatory bodies may have a history of on-going communication with various clients and third parties. As a means of optimising stakeholder focus specific applications may need to be prioritised.
e) Revenue: It may be the case that applications which have higher fees are a priority depending on the financial climate of the regulatory body.
f) Policy drivers: Overall organisation policies require consideration in addition to local enforcement and permitting policies. National policies should also be considered e.g. circular economy, climate, greenhouse gases and national emission ceilings.
g) Age of the Application: If for any reason a permit application has not been progressed for an extended period of time it may need to be prioritised in order to ensure the information within the application remains relevant. Abandonment procedures may need to be progressed in some instances.
h) Enforcement Priority Sites: the Permitting Department should formalise a means of communication with the Permit Enforcement Department. This should ensure that enforcement staff relay their priorities with regard to specific installations and the justification for their prioritisation requirement.
Once the prioritisation model has been decided and agreed by management it can used to assess the current staffing level versus the permit applications which have been submitted and applications due to be submitted in the following year. This will enable permitting managers to allocate permit applications to permit writers with a justified priority ranking as part of the annual working plan for permitting.
It is important to note that this approach requires a certain degree of flexibility as factors which influence prioritisation of permit applications may change over the course of the year.