I wonder about three percentages1. The % of time that the proposals are actually being processed i.e. reading, cross checking references/data etc. Basically stuff that can't and shouldn't be rushed.
2. The % of time that a proposal is waiting on someones desk simply because that person has the luxury 3 Months before it needs a stamp from them
3. To be a fly on the wall of the EPA and see the % of time they are actually working...
Perhaps they are actively maintaining the illusion that the longer they take, the more thorough their process is.
I think based on simple logic, it shouldn't take longer to review a study than it took to produce it, so they're not fooling anyone.