Paying the Price for Expedited IEPA Review

The IEPA now offers an expedited report review option that may be able to cut those statutory review times in half…for a price. If requested, a formal agreement must be entered into and up front fees must be paid at that time. An “Expedited Review” fee of $15,000 is required for each report submittal the RA wishes to have expedited. In addition to that flat fee, the RA must also pay all typical SRP fees plus an amount equal to 1.5x the Agency’s standard review fee for overtime charges for all personnel engaged in the expedited review process. In general, there are usually 2-3 report submittals needed per SRP project in order to receive an NFR letter. Relatively speaking, the expedited review fees can double or triple (at least) the costs of typical SRP projects, and according to SRP personnel involved in developing this option, those fees were set intentionally high in an attempt to discourage widespread use. The expedited review process has no impact on the outcome of the technical report review (i.e. carries no guarantees or greater chances of report approval), only a decrease in the timing of review.

The Illinois EPA (IEPA) has been running a very successful voluntary Site Remediation Program (SRP) since the mid-1990s. The regulations governing the SRP include statutory deadlines for review/evaluation of one or more of the four prescribed reports and since the program is voluntary, it also charges fees for those review/evaluation services. The report review deadlines are 90 days to review two or more reports submitted at the same time or 60 days to review a single report. A basic enrollment fee of $500 is required and typical review and evaluation fees generally range between $5,000 to $15,000 per site. These fees must be paid in full by the Remediation Applicant (RA) in order to receive an NFR letter and maintain its validity.

Pioneer works with the SRP on a regular basis and has obtained over 490 NFR letters under that program which is more than any other firm by a large margin (next closest is 382). Our demonstrated ability and extensive experience limit potential report submittals to the SRP which becomes even more important when expedited reviews are needed. Despite the shutdowns and interruptions in businesses during the global pandemic, last year we were able to maintain our upward trend and actually increased our overall lead in the ranking of total NFR letters from the IEPA (thru both SRP and LUST programs), going from 636 at the end of 2019 to 665 by the end of 2020. The next closest firm has obtained almost 200 fewer NFR letters.

Pioneer Engineering & Environmental Services is proud of its #1 ranking and we look forward to working with you on your next project. If you have any questions or feel we may be able to help you move your project forward, please do not hesitate to contact us.

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