Streamlining State Geothermal Permitting and Regulatory Processes
Actions States Can Take to Improve Efficiency and Certainty in Geothermal Development
April 2026
This document outlines recommended state-level actions to improve the efficiency, clarity, and predictability of utility-scale geothermal power permitting and regulatory processes. Geothermal development spans land, water, and mineral permitting processes, this document offers strategies applicable across these areas. Drawing on input from developers and regulators who have been on the leading edge of Enhanced Geothermal Systems development, it highlights strategies to reduce delays and uncertainty while accelerating development and maintaining effective oversight.
1. Establish Clear Coordination Across Agencies
States can improve geothermal permitting efficiency by strengthening coordination across agencies. This includes designating a single state point of contact to help guide developers through complex, multi-agency processes and convening regular coordination meetings among key state entities such as water rights, environmental quality, and land management offices. In addition, states should participate in or establish multi-state peer groups that include all relevant agencies to facilitate broader knowledge sharing. These actions are critical because permitting authority is often fragmented, which can lead to delays and inconsistent processes. Improved coordination enhances both efficiency and transparency for developers and regulators alike, and ensures collective regional interests are effectively represented at the state and federal level.
2. Develop “One-Stop-Shop” Permitting Structures
States can improve the efficiency and transparency of geothermal permitting by developing a centralized “one-stop-shop” resource. This includes creating a clear, accessible permitting webpage or portal that outlines application requirements, processes, and expected timelines. States can further streamline reviews by establishing interagency memoranda of understanding (MOUs) to reduce duplication and clarify roles and responsibilities across agencies. Where feasible, implementing joint or concurrent review processes can also help shorten permitting timelines. For example, Utah’s Division of Water Rights coordinates with the Utah Division of Water Quality through an MOU, allowing for more efficient groundwater injection reviews and minimizing redundant steps.
3. Streamline Internal Review Processes
States can streamline geothermal permitting by improving internal review processes to make them more predictable and efficient. This includes setting clear target timelines for permit decisions and standardizing application requirements to reduce the need for revisions and resubmissions. States should also consider developing or expanding joint communication channels with federal permitting agencies, such as monthly meetings, to align processes, develop best practices, and evaluate industry trends. Consistent and timely reviews reduce project risk and increase developer confidence.
4. Clarify Definitions and Regulatory Treatment
States should review and refine how geothermal resources are defined and regulated for clarity. This includes evaluating how geothermal reinjection and water use are classified and, where appropriate, aligning these definitions with regional norms. For example, the treatment of reinjection into the same reservoir may be treated as a non-consumptive or consumptive use and should be clarified. These steps are important because inconsistent definitions across states can significantly affect permitting requirements, timelines, and overall project certainty.
5. Structure Land Leasing to De-Risk Early Geothermal Development
Because land access and permitting processes are often intertwined, structuring state land leasing in phases can help align project development timelines with permitting milestones and reduce early stage bottlenecks. This model allows developers to begin exploration expeditiously and advance to full commercial development once the resource viability is proven. For example, Utah structures its leasing process on state trust lands in three stages: an initial Exploration Agreement based on rental fees, followed by an intermediate arrangement to establish a mineral royalty framework, and ultimately a Renewable Energy Lease Agreement for full commercial operations. This approach provides developers with greater flexibility and lowers barriers to entry while maintaining clear pathways to project maturity.
In addition to these recommendations, we suggest agencies secure sufficient resources to maintain enough staff with relevant expertise to review and action permit applications in a timely manner. States can streamline geothermal permitting and regulatory processes by improving coordination, increasing transparency, and standardizing regulatory approaches. By adopting these practices, states can reduce delays and uncertainty, lower project risk, and accelerate the development of geothermal resources to meet goals for economic investment and clean, firm power deployment.
For more information contact: rachel@s2strategies.org