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Guam EPA outlines pilot allowing DOD contractors to perform initial design reviews to speed permits
Summary
Guam EPA described a pilot with NAFAC Marianas and DOD contractors that would let third-party professional engineers use Guam EPA checklists for preliminary design review when permit timelines exceed 30 days; Guam EPA retains final approval and staff emphasized phased checks and case-by-case safeguards.
At the March 20 board meeting, Guam EPA staff described a pilot discussed with NAFAC Marianas and Department of Defense partners that would allow DOD-affiliated professional engineers to perform a preliminary design review using Guam EPA’s permit checklist when internal reviews exceed 30 days.
The agency described the process as a time-saving mechanism: after 30 days applicants could request that two third-party professional engineers conduct a design review using Guam EPA’s checklist; Guam EPA would still conduct final approvals. "Ultimately, Guam EPA is the final approver on that," an agency representative said.
Board members expressed caution about potential conflicts of interest when contractor-employed engineers review work they are affiliated with. One board member warned that engineers employed by contractors could face pressure from employers and said the arrangement must not allow self-dealing. Agency staff responded that the pilot is intended as a phased, case-by-case approach rather than blanket self-certification and that final permit authority remains with Guam EPA.
Staff described practical safeguards: use of the agency’s standardized checklist, staged design reviews at 60% and 100% completion, and a requirement that Guam EPA sign off on any permit. The pilot was presented as a temporary mechanism to help when DOD projects cause review backlogs, with an internal review to determine whether the approach should continue pending hiring of a chief engineer and other staff additions.
Board members asked for clarity on oversight, the limits of self-certification, and whether the pilot would be temporary until a licensed Guam EPA professional engineer is hired. Agency staff said the pilot is designed to speed reviews but will include agency checks at multiple milestones and that final approval authority will not be delegated away from Guam EPA.
