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Federal Permit Review and Processing: Geothermal development is also subject to timelines in the review and processing stages in federal permitting. Federal and state permitting office staff have a range of experience and varied processes. At the federal level, field offices in areas that already have geothermal projects often have federal leasing and permitting staff who are familiar with geothermal development, but staff in areas without geothermal projects can lack the experience necessary to process new geothermal applications. Delays can also occur in locations with experienced staff when geothermal experts are unavailable due to competing priorities or other reasons. Multiple Environmental Reviews and the National Environmental Policy Act: The length and number of environmental reviews for a single geothermal project can impact geothermal deployment (Young et al. 2014). Geothermal projects on federally managed land57 may be subject to an environmental review process under NEPA as many as six times—from agency land-use planning through construction of a power plant and associated transmission infrastructure (Figure 2-19) (Young et al. 2014). Data from the exploration and resource-confirmation phases of a geothermal project determine whether and how to proceed with developing the project. Under existing processes, each phase in the geothermal development process may require a subsequent NEPA review. As shown in Figure 2-19, geothermal resource management may require a separate NEPA review at the land-use planning (1) and leasing (2) phases before federal agencies consider lands for leasing, followed by another NEPA review for exploration (3) and resource confirmation (4), a NEPA review for development of a wellfield (5), and an Environmental Impact Statement for the power plant and transmission lines (6). Some geothermal developers have attempted to conduct NEPA reviews that evaluate these multiple project phases in one step, but such approaches have had limited success (Young et al. 2019).58 Pre-Project 7– to 10–Year Project Development Time Frame Agency Land Use Planning EA Pre-Leasing Exploration CX Wellfield Development EA EA Exploration Drilling EA Power Plant and Transmission EIS 1 2 3 4 5 6 Land Available for Leasing Lease Sale, Casual Use Activities Water Sampling, 2-m Probe Survey Exploration Activities: MT, Seismic Surveys, TGHs Drill Multiple Production and Injection Wells Construct Power Plant Facilities, Transmission Lines Drill Exploratory Wells Figure 2-19. Example timeline of a geothermal project on federal lands, illustrating that a single location could trigger National Environmental Policy Act analysis six separate times Source: Young et al. 2014 Figure Note: EA = Environmental Assessment, EIA = Environmental Impact Statement, CX = categorical exclusion, MT = magnetotelluric, and TGH = temperature-gradient hole. 57 The BLM serves as the lead agency for most geothermal projects on leased federal land and has the authority to approve most operations on leased federal lands (e.g., exploration, drilling, power plant, and transmission line construction). 58 Combined NEPA reviews are more time-intensive and increase upfront risks and costs for a developer. Combined NEPA reviews that are based on incomplete or inadequate resource information (pre-confirmation drilling) require the proposal and inclusion of a wide array of potential sites and development permutations as part of the NEPA review. These potential sites are required in order for a developer to secure back-up development locations to adequately reduce the upfront risks. In addition to the increased risks and costs for a developer, these requirements generate more work for the corresponding federal agencies conducting the NEPA review, because agencies need to evaluate longer documents and multiple sites—many of which will ultimately not be used for development. 44 Chapter 2 | What is Geothermal Energy? Location Activities NEPA Analyses Chapter 2PDF Image | What is Geothermal Energy
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