Is CITAP the Right Approach for Your Energy Project?

The energy landscape is changing rapidly—and with it comes a growing need for efficient and reliable transmission infrastructure. To address this need, the Department of Energy (DOE) has launched the Coordinated Interagency Transmission Authorizations and Permits (CITAP) Program, another tool in the toolbox for getting critical interstate transmission projects constructed.

CITAP, which came into effect on May 31, 2024, aims to accelerate the permitting process for major transmission projects by establishing a two-year binding schedule for federal agencies to issue authorizations and permits. This program leverages the DOE’s authority under the Federal Power Act to help shepherd transmission projects through a streamlined, coordinated review process.

The energy and regulatory experts at Environmental Science Associates (ESA) have been watching this program’s implementation and prepared this overview for readers, like you, who might be curious about CITAP and its applications.

What Projects Could CITAP Apply To?

This program applies to high-voltage transmission projects (230 kilovolt or above) that are deemed “regionally or nationally significant” and that meet the following criteria:

• The project must transmit electric energy for wholesale sales across state lines.
• The project needs one or more federal authorizations that require an Environmental Impact Statement (EIS).
• The project does not require authorization under Section 8(p) of the Outer Continental Shelf Lands Act.
• The project does not require a construction or modification permit from the Federal Energy Regulatory Commission.
• The project is not wholly located within the Electric Reliability Council of Texas interconnection.

CITAP is not limited to federal agencies. The program encourages the voluntary participation of state and local agencies, further fostering collaboration and streamlining the permitting process.

How Does It Work?

CITAP uses an Integrated Interagency Pre-Application (IIP) Process to bring stakeholders together early and ensure a smoother permitting path. This process includes three important meetings:

1. Initiation meeting: The developer submits a project summary and public participation plan to the CITAP portal.
2. Review meeting: Federal agencies review the project and identify potential issues.
3. Closeout meeting: The parties agree on the project scope and timeline.

Following the IIP Process, the DOE initiates the environmental review process within 90 days, publishing a Notice of Intent. This triggers a two-year timeline for the development of a single environmental review document.

CITAP’s Environmental Review Process

CITAP includes the National Environmental Policy Act (NEPA) process, with the DOE leading the coordination of NEPA review. While the DOE facilitates the process, the decision-making authority remains with the agency responsible for the permit or authorization. One potential benefit this program offers is that it culminates in a single EIS that incorporates all relevant environmental reviews, streamlining the process and reducing the potential for delays. See the schedule below from the DOE to show how the phases of review and approvals can occur concurrently, potentially reducing the schedule of the overall project.

Is CITAP the Right Approach for My Project?

ESA tracks updates to CITAP and helps clients determine whether it’s the best process for their energy project. If you have questions, please reach out to Meredith Parkin, JD, PMP, NEPA and Permitting Specialist, or Sharon Niemczyk, Energy Market Leader.