Getting Your Permit on the "Rush" List
One of Ohio EPA's air program's goals is to review and take final actions on all air pollution permits in a timely fashion. We continue to work to improve the permit process in order to achieve this goal. This is especially true when it comes to the processing of air pollution permits to install because permit to install must be obtained prior to any construction of the air pollution source. We recognize that any delays in processing permit to installs has a direct effect on costs the applicant must bear and on the viability of the particular project.
Ohio EPA has taken many steps to improve the permitting process. These steps included such things as allocating more resources to permit writing, updating application forms, updating and expanding guidance, improving internal processing and tracking procedures, and even adding exemptions from permitting requirements for insignificant air pollution sources. One of the more recent steps taken has been an improvement in the tracking of special requests for "rush" processing of permits. "Rush" permits are those that any company has asked for processing that is faster than the then-normal processing time. Historically, Ohio EPA has dealt with these requests on an as-they-came-up basis. As they would come up, we would try to deal with them as best as we could at the time. This historical process did not include any tracking of these requests. Unfortunately, this process limited our ability to plan and organize the work. We would often get lots of requests all at once and we would have a difficult time keeping them organized enough to try to meet permittee's timeliness goals.
In response to this problem, Ohio EPA developed a tracking list called the "rush" list. This list is maintained by the Air Quality Modeling and Planning Section Manager, Mike Hopkins. This list is used internally to track all of the requests we receive for "rush" processing of permits to install. Anyone can get on this list if they call Mike at (614) 644-3611 and provide the following information:
- A date when the company absolutely, positively must know the Agency's decision on a permit application, and
- A description of the adverse consequences that would occur to the company if Ohio EPA could not issue a final decision by the above date.
The adverse consequences can include things like additional construction costs, lost business, lost or delayed jobs, additional interest on loans, etc. We ask that this information be put in the form of an overall dollar per day lost cost.
The information on costs is used to give us a general idea on the significance of the project to the company. We prioritize our work generally by the dates permittees give us. However, because of the large number of permits we are reviewing at any given time (typically 100 or more permit recommendations are under review), because of the large number of requests we get for "rush" processing (typically 10 to 20 are on the rush list at any given time), because of possible delays due to comments from U.S. EPA, the public or permittees, and because we cannot predict what problems we will have with the permit recommendations that require additional work, we cannot guarantee decision dates. However, this process can significantly reduce the time it takes to have a permit reviewed.
The above information can be sent to Mike Hopkins at the following addresses:
Please note that this list tracks the permits once they get to the central office for review. It does not track the permits at the District or Local Air Agency (DO/LAA) office level. Tracking permits at the DO/LAA level is currently the responsibility of each DO/LAA.
Although the above process can significantly hasten the review process, you should not rely on it for deciding when to apply. Instead, you should call your DO/LAA contact for advice on expected processing times.