Electric transmission is essential for maintaining grid reliability while meeting growing electricity demand, connecting new generation and storage to the grid, and relieving congestion to improve energy affordability. In March, Clean Air Task Force (CATF) and the Niskanen Center released a report assessing the impacts of federal permitting on new transmission lines added to the U.S. bulk power system from 2010 to 2020. We looked at the proportion of projects required to have an environmental impact statement (EIS) in compliance with the National Environmental Policy Act (NEPA), compared to transmission projects in general, and the characteristic differences between lines, including line length, geography, and permitting timelines. Compared to transmission line projects in general, we found that federal environmental reviews are more likely to be required for long-distance transmission lines that interconnect new generation and increase reliability. We also found that while projects requiring an EIS make up a relatively small fraction of all new projects added from 2010 to 2020 (3.5%), they account for nearly a quarter of all line miles (26%).
To move clean electricity from where it is produced to where it is needed, the United States needs to not only triple its transmission capacity but also significantly increase its interstate and interregional transmission capacity. Based on our findings, more interstate and longer lines mean that a greater proportion of projects will undergo a federal permitting process in the future, underscoring the need to improve transmission permitting and enable a clean, affordable, and reliable grid.
Since our report’s publication, the federal government has taken action to reduce planning and cost barriers for new projects, standardize and consolidate federal permitting processes, and expedite transmission corridors of national importance. One of these actions, the Coordinated Interagency Transmission Authorizations and Permits (CITAP) program under the U.S. Department of Energy (DOE), could result in significant time savings for permitting key projects.
What does CITAP do?
Launched in April 2024, the CITAP program implements DOE’s authority as the lead agency for federal permitting and authorizations of qualified electric transmission projects. This program streamlines qualifying federal permitting processes by requiring agencies to work together on standardized pre-application processes, setting a two-year standard schedule for conducting federal reviews, and centralizing documents in an administrative database accessible to applicants via an online portal. Qualifying projects include high-voltage transmission lines (defined as 230 kV or above) or other regionally or nationally significant transmission lines, at the discretion of DOE’s Grid Deployment Office, used in interstate or international commerce.
How could CITAP have impacted timelines for projects in our dataset?
Curious about the potential impact of CITAP, we conducted a hypothetical analysis using our existing EIS dataset. Our dataset contains 33 electric transmission lines that either had an EIS in progress or completed an EIS in the 2010-2020 period. EIS reviews across all electric transmission projects in our database took an average of 4.3 years, with a median of 3.7 years. Assuming all went well with the implementation and execution of the projects in our database, the CITAP program’s goal of two-year EIS review processes would more than halve the average time projects spent undergoing federal reviews.
We found that at least 15 projects would have been eligible for CITAP outright because they met the voltage requirement and were used for interstate or international commerce. These projects, adhering to the two-year timeline, would have saved a combined 37 years of federal permitting.
Since projects can be included in the program at the discretion of the Director of the Grid Deployment Office, we assumed that DOE could have also accepted the remaining 18 lines into CITAP. This would have saved an additional 29 years across the projects on our list.
In total, we estimate that roughly 66 years of federal permitting time could have been avoided for electric transmission lines if CITAP had existed, been broadly implemented, and successfully executed between 2010 and 2020.
Time savings hinge on successful implementation
These estimates assume successful implementation of CITAP and strict adherence to the two-year timeframe. The estimates do not account for possible extensions to the timeline that could have been granted, whether developers would have chosen to opt into CITAP, or potential delays caused by litigation. Nonetheless, these striking statistics underscore how much time could be saved through an improved permitting process.
Another consideration for project timelines is the time a project spends in the pre-application period before the environmental review begins. Activities during this time are hard to track, not publicly documented, and were not a part of our analysis. It is entirely possible that the time savings earned in the two-year standard schedule may be counterbalanced by a longer and more thorough pre-application process. However, pre-application processes are currently not well-coordinated or standardized, causing confusion among agencies and developers alike. CITAP’s standardized pre-application processes could increase efficiency while building in more meaningful opportunities for community engagement, suggesting that CITAP has the potential to impact timelines and coordination of federal transmission permitting positively.
What’s clear on federal permitting
Although hypothetical, this analysis demonstrates the potential impacts of well-coordinated federal processes and collaboration between federal agencies. Historically, lengthy and unpredictable permitting processes have hindered the timely development of electric transmission infrastructure. Recent efforts to amend federal permitting processes could significantly improve agency coordination, quicken timelines, and add more certainty for developers. As more transmission lines are built, and more require federal permitting, the benefits of shortened timelines and streamlined processes will compound.
CITAP can lead to faster, more predictable permitting processes that could accelerate the development of critical transmission infrastructure, contributing to a cleaner, more reliable, and affordable energy grid. However, its impact will depend on its effective implementation and developers’ willingness to participate. CITAP’s progress should be closely monitored to ensure it is meeting its objectives and delivering the promised improvements to the federal permitting landscape.