NDEE Air Permitting Section Tackles Backlog of Operating Permit Renewal Applications
The results of their process improvement efforts have been impressive – the number of applications that needed to be processed at the end of the year has declined by two-thirds from the end of 2015 to the end of 2019. And, during that time, the permit application process was made simpler for applicants.
This graph shows air quality permitting applications before and after taking steps to reduce its backlog of OP renewal applications.
In 2016, the unit began the year with 118 OP applications. Permit writers processed 53 of those applications, but received 45 more. That means it ended the year with 110 applications that needed to be processed.
Christensen said at that point, the backlog was affected by staff turnover and changes the agency made in how it addressed source-wide limits. Once the source-wide limit implementation was determined and turnover slowed down, the OP team gained both stability and experience.
“Quite honestly, we made some pretty good hires,” he said.
Once that happened, Christensen said the OP team knew they wanted to tackle the backlog.
OP Application Changes
While the OP team has taken several steps to reduce wait times, its most recent change addressed information required for an application renewal. When sources were previously re-applying for their operating permits, they had to fill out numerous forms on existing equipment, even if it hadn't been modified.
Now the OP team uses previous permits as the basis for an application, and the source only has to submit information on changes made at its facility. Christensen said in addition to saving the applicant time, this change has also saved time for the air permitting team.
“They don't have to review all these forms and find if any changes have been made or spend time to verify if the form has been filled out correctly,” Christensen said.
Nebraska Municipal Power Pool is one permittee that has gone through the previous and current permit renewal processes. NMPP serves nearly 200 municipalities in a variety of energy and management areas, according to its website.
Tim Cerveny, NMPP's manager of resources and transmission, said the new process allowed the organization to be more thorough in its review because it wasn't spending time entering data that hadn't changed. He said the new application process took less than half the time to complete.
“The new process was much simpler and took a fraction of the time,” Cerveny said.
With NDEE's faster turnaround time issuing permits, Cerveny said NMPP was able to apply changes required by the permit sooner.
“Reduction of project backlog is always helpful in our effort to optimize workflow and be responsive to our communities,” Cerveny said.
Past changes to the permit renewal process include reducing the size of the OP fact sheet and creating a general operating permit for incinerators with an online application process.
The fact sheet, also called a statement of basis, is provided to permitted sources. It gives them background for the purpose of their permit and includes information on the factual and legal basis for the operating permit.
According to Air Permitting Section Supervisor Gary Buttermore, the current incinerator general air operating permit is good until November 2022. It allows eligible sources to apply for coverage under the general permit, rather than apply for their own individual permit. The GP process is faster and gives the OP team more time to address the backlog.
Results of Efforts
With these changes, the OP Unit began 2019 with 47 pending applications. It received 44 more as the year went on, and processed a total of 53. It ended 2019 with 38 applications to process. As of February 2020, the OP Unit has received three applications and completed six. Almost all of its backlogged applications have been assigned; the exceptions being two permits that are awaiting construction permitting actions.
This is the first year the OP Unit has operated without a backlog since 1995. Removing this backlog is important because over the course of 2021 to 2023, the OP Unit expects to see more than 30 permit renewal applications each year. It is predicted that the impact of the unit's improvement efforts will save more than 10,000 hours of staff time over the next several years.
The unit's goal is to reissue an operating permit within 18 months of receiving a complete application. However, Buttermore said with the renewal schedule (operating permits have a 5-year term), the unit may not see the full impact of these changes for at least another year.
Source: Nebraska Department of Environment & Energy (NDEE) AIR NEWS UPDATES – May 7, 2020